(Revised as of October 31, 2023)
WHY DO WE HAVE THIS POLICY?
- What data we process;
- Whom we may share your data with;
- Purpose of data processing;
- How long do we store data;
- How we protect your data;
- How you can manage the data.
WHO ARE WE?
NEXTERS is an international game development company which strives to introduce the joy of core gaming experiences to casual players on mobile and desktop.
If you are not an adult, please click the link to give your legal guardian permission. You might want an adult to help with these because they can sometimes be confusing or contact us at any time by email@example.com or through the in-game support service.
The Controller for the purposes of the GDPR and other applicable data protection or data privacy laws of the EU Member States, as well as other data protection requirements in respect of the Project, is:
NEXTERS GLOBAL LIMITED
107 Faneromenis Avenue
6031, Larnaca, Cyprus
Data processing is carried out by us solely for the purposes defined by this Policy. Please note that you have the right to withdraw consent at any time, in the manner specified by this Policy.
WHY DO WE NEED YOUR DATA AND WHAT IS IT?
Anything that can be used to identify you is your personal data. You might already know that this can include things like your name or your email address. NEXTERS uses different types of personal data for specific reasons. Please view the complete list of processed data.
- Your IP address and unique mobile device identification numbers
(such as your device ID, advertising ID, android Id);
- Broad location data (e.g. countryCode);
- Data for advertising and analytics purposes (gpsAdid, Idfv / Idfa);
- Data about your device (Name, RAM, Resolution, OS, OS version, device language);
- details of orders (transaction currency, amount spent, date, time, vouchers or offers used);
- Data about your account and game progress, we create a specific ID for you when you use the Services. We store your actions inside the Project, including waste of resources, behavioral activity, time entering the game;
- Contact information (such as name or nickname or email or other identification information);
- Data from platforms that the games run on (such as to verify payment);
- Other data you choose to give us.
Use of Your Email Provided During Registration
Verification and Security: Your email may also be used for user verification and protection against malicious activities. This helps ensure the security and authenticity of user accounts, protecting both you and our Project from unauthorized access and fraudulent actions.
Email Communications with Your Consent: We use your email to send informational newsletters, product or service notifications, and other related information if you have consented to such communications during registration or at a later time.
Sharing Email with Partners: We may share your email with our partners, provided that you have given additional consent for such sharing. This may be done for marketing, analytics, or other purposes, about which you will be duly informed and for which you will provide your consent.
Compliance with Legislation: We commit to complying with all applicable data protection and privacy laws when using your email.
You can always manage your preferences regarding email communications and data sharing with partners through our privacy settings. We value your data privacy and consistently adhere to high standards of protection and compliance with your rights.
The main reason we need to use your personal data is to give you access to the Project and create the best experience for using it.
We need this data to track your progress in the game, participate in multiplayer modes, interact with other players, and perform other actions. NEXTERS may collect anonymized data regarding players' behavior in order to better understand how the game is utilized. This includes identifying challenging difficulty levels, popular interface elements, and utilizing this information for the purpose of enhancing our business profitability (utilizing data for advertising and analytics), ensuring safety and security (for analytics, anti-cheat measures, and combating hacks), and for prospective purposes (for business development, analyzing the popularity of various features, etc.). This data helps NEXTERS improve the game and make it more exciting. Advertising networks may use data with your consent to show more relevant ads.
Sometimes we also use your personal data in connection with events you participate in or contests we organize to ensure that if you win, you receive your prize.
We may process your data based on explicit and informed consent, for the purpose of fulfilling the contract between you and NEXTERS, on the basis of our legitimate interests, and for compliance with legal obligations (such as tax reporting or consumer protection laws).
In general, by your Data we mean any information that relates that relates to you and usage of the Services. All information of your activity processed by us for providing access to the Project and (or) Services, is hereinafter referred to as the "Account".
We collect your personal data on the following lawful basis:
- the data necessary to provide you with access to the Project or the provision of our Services on the basis of the Contract;
- the data necessary for marketing or analytical purposes on the basis of our legitimate interests and your consent.
Methods of collecting information (categories of sources used in the collection).
1.1. Data you provide by yourself. We include the following information that you provide to this type of data:
- date of creating an Account;
- your use of social functions and channels for communicating with other people in the Project;
- purchases or financial transactions, such as in-house purchases and (or) received prizes;
- technical and support services.
WARNING! We are not responsible for the relevance, correctness, completeness or quality of the information you provide. When you place the data indicated independently, we proceed from the presumption of your good faith, accept the specified information as relevant, correct, complete and reliable. If you indicate inaccurate and (or) irrelevant information, access to a number of Services may be limited for you, and a technical support and support services regarding the processing of personal data is suspended until the confirmation of your ownership of the specified information. These measures are necessary to ensure the protection of your data.
1.2. Data we collect automatically.
We may collect data related to your use of the Project and your in-game activity, to your use of our services and the nature of this use and to your devices. The collection of such information is necessary for the analysis of possible technical errors in the Project and their timely elimination. The processing of information about your in-game activity is related to the social nature of our Project, the results of your in-game actions are reflected throughout the in-game world and includes the following information:
- Your use of the Services (such as timestamps, clicks, searches, referral/exit pages, and activity and interactions in our game clients, including chat logs);
- Your device information (such as IP addresses, unique device IDs, processing capabilities, manufacturer and model, language and other regional settings, geographic location, and screen resolution and similar settings);
- Your connection to the Services, including details about the network and software you're using (such operating system name and version, ISP, and your preference settings); and
- Identification and elimination of errors or problems (such as loading errors and response times).
1.3. Information collected from external sources. We may receive information about you and your actions from third parties when you connect external accounts; from advertisers or service providers about your contacts and interactions with them.
Please note when you use Project we may display third party advertising and also promote our Services via third parties.
To enable us to show in-game ads we may send your advertising ID, IP-address, as well as other similar information to advertisers and / or ad networks to enable them to find appropriate ads to serve to you.
You can control our use of your advertising ID in your device and account settings. Also, you can limit the display of targeted ads at any time in your account settings. Nexters does not control which specific ads are shown in Project (this is controlled by ad networks) but we do blacklist certain categories of ads.
WHY CAN WE USE YOUR DATA AND WHO DECIDES HOW THEY WILL BE USED?
We can only use your personal data for specific reasons.
When we provide services, we follow the applicable laws that require us to use your personal data to do our job, and sometimes we can do this without asking you first. As we said earlier, the main one is to provide you with a gaming experience. We need to use your personal data to make that happen, and following the applicable laws we can do this without specifically asking you first since this is something you already entitled us to do by showing your interest and starting the game.
In other cases, we need to get your consent or your parents' consent if you're below a certain age. If you or your parents or guardians say no, we will not be able to use your data.
We process your Data only when necessary to provide access to the Project and (or) Services, while taking reasonable security measures to protect your Data from loss, misuse and unauthorized access, disclosure, modification or destruction.
With respect to the users covered by the General Data Protection Regulation (EU) 2016/679 (hereinafter – the “GDPR”), we use the Data collected through the Project and (or) Services for the purposes of our legitimate interests in accordance with Article 6(1)(f) of the GDPR as well as for the purposes stipulated in the Terms of Service and this Policy. E.g., we may use information we collect -
- to provide our Services or information you request as well as to process and complete any transactions;
- to respond to your submissions, questions, comments, requests and complaints as well as to provide customer service;
- to monitor and analyze the Project’s use and trends or to personalize and improve the Project or user experience on our web sites, such as providing ads, Content or features that match their profiles or interests as well as to increase the Project’s functionality and user friendliness;
- to provide gifts and rewards that you may have to win in the Project etc.;
- to send you confirmations, updates, security alerts as well as support and administrative messages;
- to facilitate your use of and our administration and operation of our web sites; and
Data is collected when you provide it within the Project and (or) Service upon your explicit consent while You can always manage your Data. Indirect collection shall be allowed only on anonymous basis.
We do not ask for your consent with this Policy. We shall process the data only in accordance with applicable law, including providing a valid legal basis for such processing, if necessary. For certain categories of data, we may request additional prior consent.
By commencing the use of the Project, you acknowledge and confirm that you have reached the age required to enter into a binding agreement in the country of your residence of domicile. We do not collect data from persons who are obviously under the age of 18 and do not allow such persons to use our Services without the proper consent of a legal representative. If you have not reached the specified age, you are obliged to provide permission from one of your parents or legal guardians in the form and manner required by the local legislation of the country of your residence of domicile.
We recommend that you fully explore what the gameplay involves and how the children may use the Project. To familiarize yourself with what we do to ensure the safety of children, please read the Parent's Guide (hyperlink).
Please consider! If you have not reached the minimum age required to consent to the collection and processing of Data, and you do not have the proper consent of a legal representative, do not send us any information about yourself, including your name, address, phone number, email. If Nexters becomes aware of the use of the Project by users who have not reached the minimum set age, we will definitely ask you for confirmation of the consent of the legal representative. If such consent is not provided, we will terminate access to the Project and delete the data as soon as possible.
CAN WE SHOW YOUR PERSONAL DATA WITH SOMEONE?
Sometimes, we need to share your data to provide you with the service. We're very careful about how we do this, following all the necessary requirements and using the latest technology solutions. Some data we share based on our legitimate interest or for the purpose of fulfilling the contract between you and Nexters. In other cases, we only share data if you give us your permission. You can read more about why and with whom we share data here.
To provide the Services, we may provide the Data to suppliers or agents working on our behalf. We do not sell your personal data to third parties. We may disclose the Data to third parties that provide a service to us, ensuring that they are contractually obligated to keep your personal data confidential and will comply with the GDPR and other relevant data protection laws.
We may share your information with the following types of third parties:
a) technical and customer support providers who assist us in the provision of the Services,
b) third party software providers, including ‘software as a service’ solution providers, where the provider hosts the relevant personal data on behalf of Nexters;
c) analytical services that help us develop and improve the Project;
d) providers that help us generate and collate reviews in relation to our offers and Services;
e) advertising and promotional agencies and those organizations or online platforms selected by us to carry out marketing campaigns on our behalf and to advertise their own products or services that may be of interest to you; and/or
f) professional advisers such as solicitors, accountants, tax advisors, auditors, and insurance brokers;
g) service providers that assist us in providing our services.
We may share your personal data with our affiliates and partners in the EU / EEA and outside the EU / EEA. If the transfer of data outside the EU / EEA is not regulated by an EU Commission sufficiency decision, we base on the legal guarantees set out in Article 46 et al. Seqq. GDPR. This mainly includes EU Commission-approved Standard Contractual Clauses, which we have strengthened with additional security measures such as additional individual risk assessment, additional contractual guarantees, and technical guarantees, including additional encryption or pseudonymization, to enable international transfers with NEXTERS affiliates and partners outside the EU/EEA.
We may share personal data with external providers or service providers or providers whom we engage to perform services or functions on our behalf and in accordance with our instructions.
If these providers are established within the EU, we ensure that they are contractually bound to comply with EU data protection regulations. We also guarantee in our contracts with these organizations that they only process personal data in accordance with our instructions and provide consistent services and protect the integrity and confidentiality of your personal data entrusted to them. We may also disclose personal information to our advisers, consultants, law enforcement and other government agencies (such as tax and social security authorities), police, prosecutors, and courts. All these recipients are themselves responsible for complying with EU data protection regulations.
Some of the suppliers we work with are located outside the European Economic Area. If the EU Commission has not recognized them as providing adequate protection of personal data, we rely on the legal guarantees described above.
The companies specified in the list may access and process your data in accordance with their own privacy policies, being an equivalent Data Controller. We encourage you to review their privacy policies to learn more about how they process data.
Please feel free to contact us for additional information on third country data transfers as well as our safeguards and supplementary security measures.
HOW LONG DO WE KEEP YOUR DATA?
We are allowed to keep your personal data only for as long as we need it. The duration of data processing depends on the type of data. Some data is required for purposes like tax or reporting, fraud prevention, etc. We may also store and process some information without linking it to your personal data (by making it anonymous or aggregating it). For example, we may keep information about in-game events that affect other users.
We process and store Data during the Project period and within thirty (30) days from the confirmation of the request for deletion, except for the non-personal information that is necessary to fulfill the requirements of applicable law and anonymous information. Some data is required for tax reporting and fraud prevention purposes so we keep it for 7 years. The personal information collected shall be destroyed without any delay once the purpose of its use is achieved. We do not control the data published by you or copied by other users, as well as the data published in the chat of the Project (if applicable) or on thematic groups and forums. After deleting your data, your anonymized account can be saved in the Project if it is used in conjunction with other users.
Information contains personal data of users (if applicable), collected or created by providing of technical support to users, is stored during the period of the User Account that has applied for support in order to provide an optimal solution to issues and problems. Information that does not contain personal data can be stored for the entire duration of the Project.
HOW CAN I CONTROL MY DATA?
There are rules to protect your data, and we've set up ways to make it easy and fast for you to get all the data and use your rights.
You can find out what personal data we have about you, or you can ask us to stop using it or delete it. If your data is wrong or incorrect, you can tell us, and we will fix it.
You have all the technical capabilities to determine how the Data shall be used. We are constantly improving the data management methods available to you.
You can form a request within the Project by sending a request in the Help section or Account. You are entitled to obtain information from us on how we handle your personal data, to see copies of all personal data held by us and to request that your personal data is amended, corrected or deleted from our systems. You can also limit, restrict or object to the processing of your data.
For exercising your rights, you can:
- at any time withdraw your consent for Data Processing;
- access to your Data received by us. You are entitled to access the Data about you received by us which means you have the right to request the provision of information about Data storage, access to Data, as well as copies of the stored Data;
- require limitation of Data processing for the time required to verify the reliability of the information provided;
- change the Data. You may discretionary determine the Data, which shall be associated with your Account.
- object to the processing of your Data. If you believe that we have no legitimate reason for processing your Data, please contact us using email: firstname.lastname@example.org. If we fail to satisfy your claim, you have the right to file a complaint with the local supervisory authority.
- delete Data related to the Account.
The procedure for withdrawing consent to the processing and deletion of Data:
PLEASE NOTE that the Data is used by us solely for the purpose of providing you access to the Project and improving the quality of the Services. By deleting of Account Data, you will lose access to the Project and your Data will be permanently deleted.
The order of execution of the request:
1. An initial request that meets the requirements of this Policy can be sent through the contact form in the Project in the section «Support» / «Privacy protection request».
2. Confirmation of the request - carried out by you through the specified and verified email address.
3. Execution of the request – usually carried out within 30 days from the date of confirmation of the request. This period is necessary for organizational and technical measures to fulfill your request and, if necessary, may require more time.
PAY ATTENTION, We reserve the right to refuse to fulfill the request if the ownership of the Data is not confirmed by the User and (or) the request affects the rights and freedoms of others.
If you have lost access to the Project and do not have the technical ability to perform actions to confirm ownership of the Data, you can send a letter to the address:
107 Faneromenis Avenue
6031, Larnaca, Cyprus
Recipient: NEXTERS GLOBAL LIMITED
In the letter you must provide information by which we can uniquely identify you and the ownership of the Account Data.
FULL NAME AND CONTACT DETAILS OF THE AUTHORIZED DATA PROTECTION MANAGER FROM NEXTERS GLOBAL LIMITED:
NEXTERS GLOBAL User Data Protection Manager:
Personal Data Specialist
107 Faneromenis Avenue
6031, Larnaca, Cyprus
If your consent expires or is withdrawn or canceled, we will delete the data processed on the basis of your consent, unless there is any other basis for processing them in order to achieve other data processing objectives outlined in this Policy. Note that as a result of deleting your data associated with the Project, you will no longer have access to the Services.
HOW NEXTERS PROTECTS YOUR DATA?
At NEXTERS, we have multiple teams dedicated to safeguarding your data. First team focuses on data security to protect your data from hackers, and another team oversees data protection to ensure responsible usage of your data by any individuals or parties with access to it. This means they watch over everything to make sure NEXTERS follows all the rules and that your data stays safe.
Ensuring the security of your data and following all the rules is very important to us. Safety is one of the key aspects of the experience we aim to provide when you use our projects.
We provide you with access to international Project and strive to comply with applicable local laws. Please note that our Services are provided "as is" and you should get to know with applicable laws. By continuing your use of the Project, you are warrant that your use of the Project is not contrary to the applicable law and Terms of Service.
NEXTERS GLOBAL LIMITED respects the confidentiality of your data and strives to ensure the highest level of protection. Despite the measures we are taking to protect your information, any measures that we apply will not have any effect if you neglect the data security.
The project implemented reliable means of protection to ensure the security of your data. We do everything possible for your safety when using the Project and are constantly improving our information protection methods. As some means of protecting information from unauthorized access, alteration, disclosure or destruction, we use the following methods:
- data encryption during storage and transmission;
- we carry out two-stage user authentication when requesting an action with the Data;
- we improve the techniques and methods of collecting, storing and processing the Data;
- access to the Data, in encrypted and impersonal form, have only authorized employees, consultants or interested groups of people who need access to this information to perform their duties;
- all persons having access to the Data are briefed on working with data, their knowledge and skills are systematically being checked.
WARNING! The following actions are prohibited by this Policy and the Terms, and may also violate the confidentiality of your data:
- transfer of information about the Account and (or) access rights to third parties. Please note that our official representative will never request access to your Account;
- the use of unauthorized third-party programs, the use of robot programs and (or) programs that change the game process, including assistance in the game process. In addition to the fact that the use of such programs is expressly prohibited by the Terms, they may contain malicious software that could harm the security of your data;
NEXTERS appreciate the help of our users in identifying and addressing potential vulnerabilities, as we take the security of our systems and data extremely seriously. Please report any security vulnerabilities found in our systems or applications to us as soon as possible.
To report a security vulnerability, please send an email to our designated security team at email@example.com.
In your email, please include a detailed description of the vulnerability, including any relevant technical details that may help us understand the nature and severity of the issue. If possible, please also include steps to reproduce the vulnerability, so that we can more easily investigate and remediate the issue. We take all reports of security vulnerabilities seriously, and we will investigate each report promptly and thoroughly.
We may also contact you for additional information or clarification, so please be sure to include your contact information in your email. Thank you for helping us maintain the security of our systems and data. We greatly appreciate your contribution to our security efforts.
If you have any questions or concerns about what we do with your personal data,
please contact us at firstname.lastname@example.org.
We reserve the right to modify this Policy at any time, so please review it on a periodic basis.
This Policy is made in English language. In case of any inconsistency or discrepancies between a non-English translation of this Policy and the English version, the English version shall prevail.
NEXTERS GLOBAL LIMITED