YOUR PRIVACY RIGHTS
– NEXON PRIVACY POLICY
The purpose of this Privacy Policy is to inform you about our
information privacy practices and your privacy rights. Because the success of our Applications is dependent on building and
maintaining goodwill with our users, we are committed to implementing measures
designed to protect the privacy of those using the Applications (which term
includes any NEXON websites; please see Definitions section for details). This Privacy Policy
describes the types of information we collect; how we collect, use, and
share the information; your choices related to our information practices; and
how we protect your information.
Some terms used herein are defined
in the last paragraph of the Privacy Policy.
Please refer below for definitions. This Privacy Policy is governed by
and incorporated by reference into the Terms available at Terms,
and should be interpreted consistent therewith.
You may be able to access third party services (including through
links, advertisements, or other means), including social networks, such as
Twitter, Facebook, and Google+, from our Applications. When doing so, please understand that those
third parties have their own set of information practices. We strongly recommend that you read their
privacy policies and terms and conditions of use to understand
how they collect, use, and share information.
We are not responsible for the privacy practices or
the content on the websites of third parties.
Table
of Contents
1. Information Practices Concerning
Children
2. Types
Of Information We Collect
3. How
We Collect Information About You
4. How
We Use The Information We Collect
5. Sharing
Of Your Information
6. Your
Choices
7. Security
Of Your Information
8. Changes
To Our Privacy Policy
9. California
Privacy Rights
10. Contact
Us
11. Definitions
1. Information
Practices Concerning Children
It is our policy not to knowingly solicit or permit children under
the age of 13 to provide their Personal Information for any purpose.
We encourage parents and guardians to take an active role in
monitoring their children’s use of the Applications. In the event that we learn that we have
inadvertently collected Personal Information from children under the age of 13,
we will make efforts to promptly delete the information.
For further information on
Personal Information from children, please refer to “YOUR CHILDREN’S PRIVACY
RIGHTS NEXON KIDS PRIVACY POLICY” in the lower part of the page.
2. Types Of Information We Collect
You
consent to us collecting the following information, including both Personal
Information and non-Personal Information:
·
Information We Collect About You. When you use our
Applications, we may collect and store information from you directly. For example, when you register with us, we may
collect certain information from you, including your name, email
address, username, nicknames and passwords, and social networking and
open market usernames and information, including
profile pictures. Once registered, you
may also have the option of completing a user profile.
When you contact us, we also collect certain Personal Information in order
to be able to respond to you.
·
Your Contacts. We offer you the ability to locate, invite,
and play games with your contacts. To do
so, NEXON may request access to your address book or social networking
accounts. We will ask you for your permission before we access and store
your contacts.
·
Your Device Information. When you use our Applications on your mobile
devices, such as a phone or tablet, we may collect information regarding your devices,
including your mobile unique device identifiers and Internet Protocol (IP)
address. We may also collect the name
you have designated for your device, the device type, the name of your mobile
network and mobile provider, and the country from which you connect.
·
Your Location. In order to allow you
to use the location-based matching feature available in some of our
Applications, we may track your location.
·
Technical and Usage Information. When you use
our Applications, we collect technical and usage information such as your browser type,
browser language, referring and exit URLs, platform type, interactions with
other users, and usage statistics with the Applications, such as connection
times and download records. For more information on how we utilize
log files and cookies, please see Section 3, “How We Collect Information about
You.”
·
Download and payment information: We
collect information on what games you download and payments you make to us.
3. How
We Collect Information About You
We may collect information about you, your device, and your usage in
a number of ways:
·
When Provided Directly from You. As mentioned above, we collect information
about you directly from you in certain circumstances, including:
o
Account registration;
o
Contest registration and prize
acceptance;
o
Customer support and/or
technical service requests;
o
Player match up and other
head-to-head online competitions;
o
Registration for games and/or
special game-specific events;
o
Newsletter subscriptions,
referral services, and other marketing surveys and email campaigns;
o
Creation of a personal profile;
o
Product, service and/or
subscription orders;
o
Service requests from third
party service providers made available to you as part of our Applications;
o
Your accessing our products
and/or services on social networks or other third party services; and
o
Otherwise through use of our
Applications and other online services where personal information is required
for use and/or participation.
·
When Communicated or Shared with Other Users. You may also participate in
certain activities on our Applications that give you the opportunity to
voluntarily communicate or share information with other NEXON users,
such as Posting messages on a message board, Posting public comments to user
profiles or games, sending private messages, sending invitations, and Posting
photos. We may monitor, record and store
these communications in order to protect your safety or the safety of other
users, to assist with regulatory or law enforcement efforts, or to protect and
defend NEXON’s rights and property. You
consent to the recording, storage and disclosure of such communications you
send or receive for these purposes.
· Through log files, cookies,
and similar technological means. When you use our Applications, NEXON may
collect information about your use and interaction with those Applications. The bulk of this information is collected and
stored through the use of technological means like cookies, log files, and
analytical measurements and tools.
o
Cookies are small pieces of
instruction stored on your hard drive or device, not on our Applications. Cookies may help you navigate the
Applications as easily as possible, may allow you to customize your user
experience in our Applications, or provide other means of enhancing the
services we can deliver through our Applications.
We may use cookies to deliver content specific to your interests and to
prevent you from reentering your username and password each time you access the
Applications. We collect information
using cookies in order to analyze the usage of our Applications, for authentication
purposes, and to improve and personalize the services we provide to you. Cookies may be delivered to your mobile
device as part of your access to and use of our Applications. You may have the option to reject cookies,
depending on the Application, your mobile device, and other factors, though
rejecting cookies may impair certain functionalities offered from within the
Application.
o
Log files are small files that
typically contain IP addresses. An IP address is a numeric address that may be
assigned to your computer by your Internet Service Provider. In general, we use
log files to monitor traffic on our websites and through our Applications, to
troubleshoot technical problems and authenticate users' entitlements to our
products. In the event of user abuse of
our websites or Applications, however, we use IP addresses or game system IDs
provided by our licensed hardware manufacturers to exercise our right to block
access to our websites or Applications.
If available, IP addresses and game system IDs may be used in order to
enforce our Terms
o
We may also make use of
analytic metrics tools, whether created by
us or by third parties, to collect information when you use our games,
services, and Applications
§ These tools and technologies use server log files, web beacons,
cookies, tracking pixels and other technologies to collect and analyze certain
types of information, including cookies, IP addresses (including for purposes
of determining your approximate geographic location), mobile or other hardware
device ID or other device identifiers, the name of
your mobile network and mobile provider, browser types, browser language, information passed from your
browser (if any), referring and exit pages, and URLs, platform type, click
information, information about your device, peripheral hardware, software
and/or applications installed on your machine and/or device, domain names and
types, landing pages, pages viewed and the order of those pages, advertising
conversion rates, the date and amount of time spent on particular pages, other
Internet and website usage information, game state and the date and time of
activity on our websites or games, information about how your game is used,
including game metrics and statistics, feature usage and purchase history, as
well as unique hardware identifiers such as MAC Address, mobile unique device
ID (if applicable) and other similar information.
§ Use of certain analytic tools may require the transmission and/or
storage of information about you and your activities on services and devices
not controlled by NEXON. For example, use of Google Analytics, a web
analytic service offered by Google Inc. ("Google"), requires that
certain information about your activities be transmitted to and stored on
Google server based in the US. On behalf
of NEXON, Google will use this information in order to
evaluate your usage of this websites and/or Applications (as may be
applicable), to make reports on website activities and/or to provide the
website operator with other services related to this websites. Your IP-address collected by Google Analytics
will not be matched up with other data of Google.
§ Similarly, certain third party analytic tools may allow the
companies offering those tools to collect information on our websites or
through our Applications for their own purposes. In such cases, information collected about
you may be combined with information collected independently from other
websites and/or other online or mobile products and services relating to your
activities across their network of websites as well as online and/or mobile
products and services. Such information
is not subject to this privacy statement, nor is under the control of NEXON.
4. How
We Use The Information We Collect
We may use the information we collect in the following ways:
·
To create your account, which
allows you to play our games and communicate with other NEXON users;
·
To provide you with a
customized or personalized experience;
·
To provide you with technical
support or to respond to your questions or comments;
·
To identify and suggest
connections with other NEXON users or to send invitations on
your behalf to your social networking friends or contacts in your address book;
·
For legal purposes, for example
to enforce our Terms or to prevent fraud or other illegal activities;
·
To provide you with relevant
and targeted or direct advertising from NEXON or third parties;
·
To send you e-mails with useful
updates or promotions about our Applications and other products and services;
·
To send you notifications (SMS,
push, remote, or local) on your mobile device to provide you with useful
information about our Applications and other products and services (to learn
how you can manage the types of notifications you receive, follow the
instructions under Section 6, “Your Choices”).
5. Sharing
Of Your Information
It is our
policy not to share your Personal Information with third parties for
their own use except with
the following parties or in the following
circumstances. With respect to your
non-Personal Information (such as anonymous, aggregated statistical data), we
may share such information with third parties for various purposes, including
for the purpose of explaining our user demographics or improving the quality or
delivery of our services and the marketing materials available through the
Applications. Although we will not share
your Personal Information with third parties for the purpose of enabling third
parties to send marketing materials to you about their products or the products
of others, we may use third party advertisers (including Chartboost, AdMob, and
Cauly) to deliver advertising within the NEXON mobile environment. We may share your non-Personal Information,
including your operating system, country location, and Applications usage
information with these third party advertisers for the purposes of delivering
these advertisements. If you do not want us to share your Personal Information
with the third parties set forth below for particular purposes as described,
please see Section 6 below, Your Choices, or do not provide us any Personal Information or use the
Applications. Usage constitutes consent
to the practices described herein.
·
Third Party Service Providers. We may use third party service
providers, such as payment
gateway companies, platform service companies, and analytics
companies, to help us provide or improve the Applications we offer you. We may share your Personal Information with
these third party service providers so that they may provide their services to us.
·
Social Networking Users. Your profile, which will have your username
and profile picture, may be visible to other
third party social network users.
In addition, your social networking friends may be able to see
information about your uses and interactions with our Applications, for example
your game results, scores, and profile information may be Posted on your
Facebook Wall or on Twitter.
·
Other NEXON Users. Some of your Personal Information (included in your profile and
nicknames) may also be visible to other NEXON users, through the Applications or through related websites. Other NEXON users
(both those who are your social networking friends and those who are not your
social networking friends) may be able to view information about your uses and
interactions, such as your game results, scores, and profile information.
·
Legal Purposes. We may
provide your Personal Information to third parties where we have a good faith
belief that doing so is required by law or to cooperate with regulators or law
enforcement authorities. We may also
provide your Personal Information to third parties in order to protect the
rights or property of a third party or NEXON, including enforcing our
Terms.
·
Health or Safety. We may share
your Personal Information when we have a good faith belief that there is an
emergency that poses a threat to the health or safety of you, another person,
or the public generally.
· Sale or Merger. If NEXON is involved in a major business transition, such as a merger,
acquisition by another company, or sale of its assets, we may transfer your
Personal Information to the successor organization in such transition. If material changes to NEXON’s
privacy practices will occur as a result of the business transition, we will
amend the Privacy Policy and the Personal Information you previously submitted
will continue to be treated pursuant to the last version of the Privacy Policy
you agreed to unless you continue to use the Applications, which usage shall
constitute consent to the new practices.
· Game Events. For some game
related events, we may share information, including your profile and nicknames,
with third parties.
NEXON
provides you with a variety of choices to control the use and sharing of your
information, including your Personal Information.
·
Notifications (SMS, Push, Remote, and Local). You can usually opt out of
receiving notifications by following these steps: (1) Go to Menu; (2) Settings;
(3) Push “off” under “Push Notifications”. When we receive an opt-out
request from you, we may send you a message confirming our receipt of your opt-out
request.
·
Accessing Your Contacts. We offer you the ability to locate, invite,
and play games with your contacts. To do
so, NEXON may need to access your address book or social networking friends
lists. We will ask you for your opt in
permission before we access and store your contacts.
·
Cookies.
You may be able to manually delete HTML cookies and set your browser to
refuse HTML cookies by going into your browser’s settings. Note though that doing so may affect your experience
with our Applications.
·
User Profiles. You can change and update information in your
user profile at any time. The
information your previously provided may continue to be stored, however.
·
Ads. Advertising
associations offer methods (http://www.aboutads.info/choices/ and http://www.networkadvertising.org/choices/)
by which you may be able to opt out of receiving behavioral advertising.
·
Personal
Information. You may at any time indicate that you wish us to stop processing
your Personal Information (if such Personal Information is necessary for you to
have an account, you will no longer be able to use the Game and may no longer
be able to use other aspects of the Service).
7. Security of Your Information
Although we do not represent that we follow any particular,
independent code of best practices, we maintain reasonable physical,
electronic, and procedural safeguards to protect your information. For example, we protect some of your
information by using a
firewall and Secure Socket Layer (SSL) encryption.
While we take reasonable precautions against possible security threats,
there is no such thing as “perfect security” on the Internet, so we cannot
guarantee that unauthorized access, hacking, data loss, or other breaches will
never occur. We strongly recommend that
you take steps to maximize the security of your information, such as not
sharing your login information and logging out of your account after you are
done using our Applications.
We store your information in the United States as well as other
territories. You consent to such storage
and to the transfer of information from one territory to another.
We will take reasonable steps to
require any third parties who you authorize us to share your Personal
Information with to comply with the terms of this Privacy Policy.
8. Changes
to Our Privacy Policy
From time to time, we may make changes to this Privacy Policy. If we amend this Privacy Policy, we will
notify you and other users by Posting a revised version of the Privacy Policy.
Any changes to this Privacy Policy will
take effect upon Posting on the effective date which
is Posted at the bottom of this Privacy Policy. Your continued use of the Applications after
any such changes signifies your acceptance thereof.
In some circumstances, California residents would have the right to
request information from us regarding the manner in which we share your
Personal Information with third parties for their direct marketing
purposes. However, we do not share your
Personal Information with third parties for the purpose of direct
marketing. If you have any questions
regarding our practices, please email us at help_Quest&Collect@nexon.com.
If you have any questions or concerns regarding our Privacy Policy
or our information practices generally, you can e-mail us at help_Quest&Collect@nexon.com. We allow you to access and change or modify your
information as previously provided. You
may do so by accessing and modifying your information through the Applications.
To protect your privacy and security, we will take reasonable steps to verify
your identity before granting access or making changes or modifications.
Unfortunately, we cannot always ensure that such changes or modifications will
be reflected in all iterations of your information as previously stored.
11. Definitions.
“Applications” à Our communications
tools, which may heretofore or hereafter be accessed by users through any
medium or device now known or hereafter devised, including but not limited to communication tools such as websites, software, mobile games and applications. Unless explicitly stated otherwise, any new
tools that alter or improve the current Applications shall be included in the
definition of “Applications.”
“Including” à
“Include,” “Includes,” “Including,” “include,” “includes,” and “including”
herein mean including without limitation.
“Personal Information” à Any information
concerning the personal and material circumstances of an identified or
identifiable individual. This includes information like name, postal address,
e-mail address or telephone number, but also usage date in some cases. Usage
data are data required to use our website, for instance information about
start, end and extent of website use as well as login data.
“Post” à To upload, post, create, make available, send, share, communicate or
transmit.
“Privacy Policy” à
This policy available at Privacy.
“Terms” à The terms and conditions, available at Terms, and the Privacy Policy,
available at Privacy.
Effective Date: 2016.6.02
YOUR CHILDREN’S PRIVACY
RIGHTS
NEXON KIDS PRIVACY POLICY
The purpose of this Privacy Policy is to inform you about our
information privacy practices as they specifically pertain to our Applications
directed towards Kids. Because the success of our
Applications is dependent on building and maintaining goodwill with our users,
we are committed to implementing measures designed to protect the privacy of
those Kids using the Application (which term includes any NEXON websites;
please see Definitions section for details) directed to Kids. This Kids Privacy
Policy describes the types of information we collect, if any;
whether – and if so how – we use and share the information; parental consent;
your choices related to our information practices; and how we protect
your Kids’ information.
This Kids Privacy Policy is incorporated by
reference into the general Nexon Privacy Policy available at Privacy.
Please refer to that policy as a supplement to this policy, which only
contains details specific to information submitted by Kids.
Also, we encourage you to be informed about
privacy laws applicable to Kids.
Information regarding the Children’s Online Privacy Protection Act
(“COPPA”) is available here: COPPA.
Finally, if you have any questions or
concerns regarding our Kids Privacy Policy or our information practices
pertaining to Kids generally, you can contact NEXON, at mail to help_Quest&Collect@nexon.com,
by calling +82-31-8016-7742 or by e-mail at parents@nexon.com.
1. Types of Information We Collect From
Kids
and How It is Used
We do not knowingly collect Personally
Identifiable Information (defined below)
from Kids, with the following exceptions:
We may collect Parental contact
information, including a full name and email address, from a Kid for the sole
sole purpose of contacting their Parents to obtain consent to collect and/or
use additional Personally Identifiable Information. In that event, we would provide notice and
disclosure as to what additional Personally Identifiable Information we would
like to collect and/or use in obtaining parental consent. Our policy regarding obtaining your Parental
consent is described below.
In addition, like most applications, we do
collect some information about Kids’ use that does not necessarily identify the
Kids personally, such as a cookie, an IP address, a processor or device serial
number, or a unique device identifier. However, we collect no other Personally
Identifiable Information and such persistent identifiers are collected solely
for the purpose of providing support for the internal operations of our
Application; e.g., it is used for activities necessary for the Application to
maintain or analyze its functioning; perform network communications;
authenticate users or personalize content; serve contextual advertising or cap
the frequency of advertising; protect the security or integrity of the user or
Application; and ensure legal or regulatory compliance. Moreover, we will not disclose this information
to third parties unless (a) the third parties assist us in providing support
for the internal operations of our Application; (b) we are required to do so by
law; or (c) it is necessary to protect the child’s safety.
Upon obtaining actual knowledge that a Kid
submitted Personally Identifiable Information to Nexon other than as discussed
above, we will delete such information expeditiously, unless retention is
necessary: (a) protect the security or integrity of our Applications; (b) to
respond to judicial process; (c) to take precautions against liability; or (d)
to the extent permitted under other provisions of law, to provide information
to law enforcement agencies or for an investigation on a matter related to
public safety.
Finally, we do not knowingly allow Kids to
make publicly available any Personally Identifiable Information collected
without parental consent.
2. Parental
Consent Policy
If a Kid wishes to use an Application where
we intend to collect Personally Identifiable Information from Kids in addition
to that outlined in Section 1, above, we will obtain advance parental
consent. Parental consent will be
obtained by emailing a Parent to notify the Parent of the Parent’s rights and
request consent for the collection of the information. Unless we receive within two business days a
response to the email confirming that the Parent consents to our collection of
the Kid’s information for our specified purposes, we will not collect the
information. If we receive a response to
the initial email, we will send a follow-up email the next day to confirm
consent.
Although we do not currently share
Personally Identifiable Information regarding Kids with third parties other
than as described above and consistent with law, if we do so in the future, we
will email a Parent to notify the Parent of the Parent’s rights and request
consent for the sharing of the information.
We will ask the Parent to download a consent form and return the
completed form to us by U.S. mail, fax, electronic scan or by calling us and
responding to questions designed to verify provision of Parental consent. If we do not verify Parental consent through
one of these methods, we will delete the information, unless we have already
received consent from the Parent to the collection of the information for
Nexon’s internal use.
Consistent with law, we will not condition
participation in our Applications on the provision of Parental consent for
information sharing or on the provision of certain pieces of Personally
Identifiable Information unless such consent or provision is reasonably
necessary to the performance of the Application.
4. Correcting/Updating
Kids’ Information
Consistent with law, Nexon provides you
with the ability to review, correct and/or delete any Personally Identifiable
Information that your Kid has provided to us. If you have questions about this
Kids’ Privacy Policy or wish to review or correct any information you have
provided to us, you may do so by (a) accessing your user profile, or (b)
contacting NEXON, at mail to help_Quest&Collect@nexon.com,
by calling +82-31-8016-7742 or by e-mail at parents@nexon.com. To protect your
privacy and security, we will take reasonable steps to verify your identity
before granting access or making changes or modifications. Unfortunately, we
cannot always ensure that such changes or modifications will be reflected in
all iterations of your information as previously stored.
5. Kids’ Privacy
Policy Updates
From time to time, we may make changes to
this Kids’ Privacy Policy. If we amend
this Kids’ Privacy Policy, we will notify you and other users by Posting a
revised version of the Kids’ Privacy Policy. Any changes to this Kids’ Privacy Policy will take effect ten days
after the effective date which
is posted at the bottom of this Kids’ Privacy Policy. Your continued use of the
Applications after any such changes signifies your acceptance thereof.
However, we will not deem applicable to you
any future changes made that would constitute a change in the Personally
Identifiable Information that we collect, enable sharing of Kids’ Personally
Identifiable Information or communicating with Kids without acquiring verified
parental consent.
Definitions
“Applications” à Our communications
tools, which may heretofore or hereafter be accessed by users through any
medium or device now known or hereafter devised, including but not limited to communication tools such as websites, software, mobile games and applications. Unless explicitly stated otherwise, any new
tools that alter or improve the current Applications shall be included in the
definition of “Applications.”
“Including” à “Include,”
“Includes,” “Including,” “include,” “includes,” and “including” herein mean
including without limitation.
“Kid” à means a child under the age of 13.
“Parent” à includes a Parent or legal guardian.
“Personally
Identifiable Information” à includes
a full name; home or other physical address, including street name and city or
town; online contact information like an email address or other identifier that
permits someone to contact a person directly — for example, an IM identifier,
VoIP identifier, or video chat identifier; screen name or user name where it
functions as online contact information; telephone number; Social Security
number; a persistent identifier that can be used to recognize a user over time
and across different sites, including a cookie number, an IP address, a
processor or device serial number, or a unique device identifier; a photo,
video, or audio file containing a child’s image or voice; geolocation
information sufficient to identify a street name and city or town; or other
information about the child or parent that is collected from the child and is
combined with one of these identifiers
“Post” à To upload, post,
create, make available, send, share, communicate or transmit.
“Privacy Policy” à This policy available
at Privacy.
“Terms” à The terms and
conditions, available at Terms.