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Slugterra: Slug it Out 2 Privacy Policy

Last Updated: March 11, 2024

Nightmarket Games Inc. respects your privacy rights and this policy sets out to describe how your personal information is collected and processed by Nightmarket Games Inc. (f/k/a Epic Story Interactive Inc., hereinafter “Nightmarket” or "Us" or "We") when you use the Slugterra: Slug it Out 2 mobile app (the “App”).

Nightmarket provides privacy protection for users of the App of all ages, including children as defined by the Children’s Online Privacy Protection Act (“COPPA”) and the General Data Protection Regulation (“GDPR”).

We reserve the right to update this Privacy Policy. Updates to the Privacy Policy will be indicated by revising the date at the beginning of the Privacy Policy. Additional notice will be provided to you depending on the specific change, such as those that require renewed or additional consent.

Collection of Information

We strive to collect only the personal information that we need to provide you with the best possible experience in the App.

Information You Provide to Us

The App will not request from you any personal data as defined by COPPA and GDPR. We do not request any information that may identify you, including where you live or your appearance.

Information We Collect Automatically

We automatically collect the following information when you use the App:

  • Device information: We collect information about your use of the App, including the make and model of your device, its operating system, and the times it has accessed the App.
  • Usage information: We collect information that relates to your use of the App, such as your game progress, your time spent in the game, and your purchases. We also collect your general geographic location at the country level.
  • Log information: We collect information about the moments in the App when it connects to our servers and retrieves content and data required to operate the App. The collected information includes the content or data being requested and the IP address of the device making the request.

Information We Collect from You and Other Sources

Purchases in the App are handled by your respective device platform’s payment gateway. We do not have access to your payment details such as the payment method, the name of the payee, and the payment details (such as credit card numbers or email addresses associated with payment platforms). We are provided with pseudonymized information about your transaction, such as the item(s) you purchased in the App, the date and time of your purchase, your payment currency, the amount of your transaction, your country, and in some cases your state and your postal code.

Upon installing the App on your device and launching it for the first time, your device’s identification will be collected to determine if you installed the App after viewing an advertisement on your device in another mobile application. Your device's identification may be used to serve targeted advertising. Your device's identification will not be used to serve targeted advertising if you are a child under COPPA or GDPR regulations. On certain operating systems you can notify us that you do not want us to serve you targeted advertising using your device's identification.

Usage of Information

We use your personal data only to the extent needed to fulfill your requests in the App and to support the operation of the App.

Device Information

We aggregate your device information to maintain the App and provide a satisfactory experience. For example, we use the aggregate data on device information to determine minimum hardware standards for the App.

Usage Information

We aggregate your usage information to maintain the App and provide a satisfactory experience. For example, we collect and aggregate information on users’ progress in the App in order to determine if any changes need to be made to improve the user experience.

Log Information

We store information about your content and data requests to our servers for log purposes only. This data is pseudonymized and encrypted at rest.

Storage of Information

We store your information for the time needed to operate the App and fulfill your requests through the App. Your personal data is deleted or anonymized when it is no longer needed to operate the App for your usage and in any event no later than three (3) years after your interaction with Nightmarket has ceased.

Sharing of Information

We do not share your personal information with third parties except in the following ways:

  • With third-party vendors, consultants, and other service providers who work for us and need to access your personal information to do that work
  • If appropriate to
    • comply with laws or to respond to lawful requests and legal processes, including, for example, to comply with a court order or subpoena;
    • protect the rights and property of Nightmarket, our agents, our customers, and others, including to enforce our terms, policies, rules, and agreements
    • protect the safety and security of any person; and/or
    • protect the safety and security of Nightmarket's and our partners' Services, websites, and applications.
  • In connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets for use in accordance with applicable law
  • Advertising network companies to correlate your interaction with an advertisement to an action that involves installing or operating a mobile application related to the advertisement.

We do not share your personal information with advertising network companies for the purposes of behavioral ad targeting. All advertising displayed in the App are contextual advertisements that are selected based on demographic data and not based on a personal profile of your online behavior. We use or may use the following advertising network companies:

SuperAwesome

Our game may display contextual advertisements served by SuperAwesome Trading Limited (“SuperAwesome”), a provider of kid-safe advertising services that are designed specifically for the compliance requirements of younger audiences, including those aged under the age of digital consent.

SuperAwesome is certified as COPPA-compliant by the kidSAFE Seal Program, an FTC-Approved COPPA Safe Harbor Program. Please go to www.kidsafeseal.com for more information.

SuperAwesome is a valid licensee, and participating member, of the Entertainment Software Rating Board’s Privacy Certified Program (“ESRB Privacy Certified”). To protect your privacy, SuperAwesome has voluntarily undertaken this privacy initiative, and its services have been reviewed and certified by ESRB Privacy Certified to meet established online information collection, use and disclosure practices. As a licensee of this privacy program, SuperAwesome’s services are subject to frequent audits and other enforcement and accountability mechanisms administered independently by ESRB Privacy Certified.

SuperAwesome also provides advertising services in compliance with the General Data Protection Regulation (EU 1996/679) and the California Consumer Privacy Act (CCPA). Adopting an approach of ‘privacy by design and by default’, SuperAwesome utilises proprietary technologies so that it neither collects, stores nor shares your personal data to provision advertisements or target advertising to you. SuperAwesome acts as a service provider, as defined by the CCPA, and does not use data collected from children under the age of 16 for any purpose other than to provide contextual advertising for our game.

You may contact SuperAwesome directly at privacy@superawesome.com on + 44 (0) 203 668 6677, or by post: Privacy Team, SuperAwesome Trading Limited, 8 Duncannon Street, London, England, WC2N 4JF, United Kingdom.

Security

Nightmarket takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

Your Rights to Your Personal Information

If you are an individual subject to EU law, you have the following rights:

  • A right to be informed of the ways in which we use your information
  • A right to request from Nightmarket access to and rectification or erasure of personal information, and certain rights to data portability
  • A right to object to the processing of your personal information or obtain a restriction of such processing under certain circumstances
  • If the processing of personal data is based on your consent, a right to withdraw consent at any time (without affecting the lawfulness of processing before its withdrawal)

We process and answer your requests without undue delay and in any event within one month of our receipt of the request unless a longer period is required due to the complexity of the request. In this case, our response time can be up to three months in total as permitted by Article 12 of the GDPR.

If you wish to use any of the rights described above, you may contact us at any time by emailing us at support@epicstory.atlassian.net.

Right to rectification and erasure

You have the right to have inaccurate personal data rectified, see Article 16 of the GDPR.

Furthermore, you have the right to have your personal data erased where one of the following grounds applies, see Article 17 of the GDPR:

  • the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed
  • if you have withdrawn your consent and there are no other legal grounds for the processing
  • if you have objected to the processing and there are no overriding legitimate grounds for the processing
  • the personal data have to be erased for compliance with a legal obligation in Union or Member State law
  • the personal data have been unlawfully processed
  • the personal data have been collected in relation to the offer of information society services.

Please note that your right to erasure may be limited if the data are necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims.

Right to restriction

You have the right to obtain restriction of processing in certain circumstances, see Article 18 of the GDPR. If you have the right to restriction, we will only process your data with your consent or for the establishment, exercise or defense of a legal claim or to protect a person or important grounds of public interest.

Right to withdraw consent

If we have asked for your consent to our processing of your data, you have the right to withdraw your consent at any time, see Article 7 of the GDPR. If you withdraw your consent, we will cease processing of the data for which you have withdrawn consent, unless we have a legal obligation to keep some or parts of your data.

Please note that if you withdraw your consent, your user license to use the App will cease automatically. The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal.

Right to data portability

You have the right to receive the personal data you have provided us with which we process in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller if the processing is based on consent or contract performance, see Article 20 of the GDPR.

Contact and complaints

Nightmarket has the following contact information:

Nightmarket Games Inc.
1750-1055 W Georgia St
PO Box 11125
Vancouver, BC
V6E 3P3
Canada

Phone: +1-604-559-5579
E-mail: support@epicstory.atlassian.net

If you wish to make a complaint over the processing of your personal data, you have the right to lodge a complaint to the relevant supervisory authority.