A quick summary:
This document explains:
We’d also like to remind you that our Nordeus User Agreement has more information about how we operate the Nordeus Services.
1.1. Who is Nordeus? We are Nordeus Limited, incorporated and registered in Ireland with company number 526421 having an address at Nordeus Limited, 3rd Floor, Kilmore House, Park Lane, Spencer Dock, Dublin 1, Ireland and its group of companies (“Nordeus”).
1.4. What about children? We recognise we have a special obligation to protect personal information obtained from children. Legally you must be at least 13 years old to use the Nordeus Services as per our User Agreement. We do not and will not knowingly collect personal information from any child under the age of 13 without consent from their parent or guardian. If you are a parent or guardian and are concerned about the transfer of personal information about your child, please contact email@example.com.
2.1. What information might we collect from you? When you sign up for, download, use or play the Nordeus Services then we will collect certain information from you. The information that we collect varies depending on the particular Nordeus Services used, but this information may include:
A. User Accounts and Newsletters. To access certain Nordeus Services (e.g. our games, including Top Eleven and Spellsouls: Duel of Legends, or our forums) you may need to create a user account. Or if you sign up to a newsletter you will be asked to provide us with certain information. This will be displayed to you at the time you start to use the applicable Nordeus Services (e.g. when you sign up for a newsletter) and may include your name, username, age, birthdate, a photo or avatar, email address, country of residence and contact information.
B. Third Party Accounts. In certain circumstances (e.g. joining our forums) you may be able to log into certain Nordeus Services via third party accounts (e.g. Facebook). If you choose to do so, you are asked to share certain information with us (the exact information will depend on the particular third party account displayed to you on the permissions page when you attempt to log in, but may include your name, location, gender, birth date, email address, photo, profile URL and friends list).
C. Technical Details. When you use, play or access the Nordeus Services we or third parties on our behalf may collect technical details about the device you are using, including: internet and/or network connection (including IP address); MAC address, any console device identifier; device memory; your operating system, browser type or other software; and your hardware or other technical details. In addition, we create a unique user ID to track your use of the Nordeus Services. This unique user ID is stored in connection with your information.
D. Your Activities. When you use, play or access the Nordeus Services we or third parties on our behalf may collect details of how you use our services, including: metrics information about when and how you use the services; traffic data; language preferences; in-game purchases; achievements; scores; gameplay statistics; time spent playing; and your geographical location data.
E. Your Communications. If you contact us (e.g. via email or call for customer support) or post in chat sessions, forums or other areas of the Nordeus Services, we may collect and maintain a record of your contact details and the content of your communications.
Some of the information types referred to above may be collected on an aggregated or anonymised (e.g. hashed) basis, or we may use it or share it in an aggregated or anonymised way, for research or analysis into the way our services operate and are used.
2.2. What about the storage of payment details? The processing and storage of payment details is a matter for the relevant platform and the applicable payment method/processor. Nordeus will not receive, process or store any of your payment details. This is because the payment transactions themselves are completed through the relevant platforms (e.g. Apple’s App Store or Google Play) via the user account you have associated with that platform account. If you make in-game purchases within the Nordeus Services, we are notified by the payment processor once a transaction takes place, but we will not receive any of your actual payment details.
All information we hold is stored on our secure servers (which we own or license from appropriate third parties). We use industry standard procedures and security standards to prevent unauthorised access to our servers, however no online service or website can be completely secure, so please protect the account information in your possession as well.
4.1. How might your information be used? We may use the information above in order to (for example):
A. Perform our agreement with you: provide the Nordeus Services to you, including: to carry out our obligations arising from any contracts between you and us; allow you to participate in interactive features of the Nordeus Services when you choose to do so; and provide you with chat functionality and other communication systems.
B. For our legitimate commercial interests: monitor the performance of the Nordeus Services; to ensure that the Nordeus Services are presented in the most effective manner for you and for your device; enforce our User Agreement and other policies; notify you about changes to the Nordeus Services; provide, maintain, protect and improve the Nordeus Services; and to protect Nordeus and Nordeus Services users.
C. Comply with our legal obligations: where we are required to do so by law; and to comply with intellectual property protection obligations we have under applicable laws including the Digital Millennium Copyright Act and the E-Commerce Directive.
D. Based on consent: provide you with marketing information about products or services that you request from us and which we feel may interest you where you have asked us to do so; and send you push notifications on mobile devices where you have agreed to this.
4.2. Will we ever share any of your information with other parties?
A. We will never share your information with third parties for their own marketing purposes without first obtaining your consent.
B. We may engage third party service providers in the course of providing the Nordeus Services to you (e.g. data storage, server hosting, customer and technical support, game analytics, advertising etc) which may require them to access your information on our behalf. We will ensure there are appropriate contractual arrangements in place with any such third party service providers to protect your information. Those third parties may also collect some information directly from you (e.g. IP address, unique identifiers etc) subject to their own privacy policies.
D. We may share your information within the Nordeus company group for the purpose of providing the Nordeus Services.
How long do we retain your data for? As long as necessary for the purpose for which the data was originally collected. As detailed below, depending on where you live you may have certain legal rights to object to our collection and use of your data, but this may mean some or all Nordeus Services become unavailable to you. We also reserve the right to retain your information as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records, and enforce our agreements.
8.2. What are your rights? Depending on where you live, you may have additional privacy rights. For example, in the EU (particularly under the new GDPR) you have the right to access and obtain a copy of your personal data we possess; you may have the legal right to contact us to request that we delete your personal data from our system; and you have the legal right to ask us to rectify/correct your personal data. We will use commercially reasonable efforts to honour your request, but we may decline requests that are unreasonably repetitive, are disproportionate, infringe the privacy of others or as otherwise permitted by law. Please note though that by withdrawing your consent or otherwise objecting to certain processing of your information, certain Nordeus Services may no longer function properly or be completely unavailable to you.
8.3. Under California law, California residents who have an established business relationship with us have the right to request certain information with respect to the types of personal information we have shared with third parties for their direct marketing purposes, and the identities of those third parties, within the immediately preceding calendar year, subject to certain exceptions. All requests for such information must be in writing and sent to: Nordeus Limited, 3rd Floor, Kilmore House, Park Lane, Spencer Dock, Dublin 1, Ireland. This same California law permits us to provide you, in response to your written request, with a cost-free means to choose not to have your information shared rather than providing the above described information. You may exercise that choice by contacting us at the address above.
8.4. Who should you contact if you would like to exercise these rights? If you would like to exercise any of these rights or have any queries regarding them, please contact firstname.lastname@example.org.