Privacy Policy

1. Introduction

This Privacy Policy applies to Northern Lights Entertainment SAS (hereinafter: “NLE“, “we” or “the company”), a company with its operational office based at 84 rue de Grenelle, 75013 Paris, France. This Privacy Policy covers our games, websites and services on which it is placed (hereinafter: “Services“) and details information the company collects, uses and discloses about its users, including you. If you live in the European Union, we inform you that our Services are provided in compliance with the General Data Protection Regulation (“GDPR”).

We collect and use your information internally and may disclose your information to third parties, outside of NLE, in certain situations described in this Privacy Policy.

This Privacy Policy addresses two kinds of information: (1) personal information, and (2) anonymous information. Personal information identifies you and includes, for example, your name, telephone number, address, email address and other information that you provide to us. Anonymous information does not identify you, such as statistical data about how you use the Services, and can be aggregated with other anonymous information about other users.

2. Website

Every time you visit our website (www.nebulae.world), our system automatically collects data and information from your computer system.

The following data is collected and stored in log files:

  • Information about the browser type and version used
  • The user’s operating system
  • The Internet service provider of the user
  • The IP address of the user
  • Date and time of access
  • Websites from which the user’s system reaches our website
  • Websites accessed by the user’s system via our website

The log files contain IP addresses or other personal information. The data is stored in the log files of our system. This data is not stored together with other personal information of the user.

By clicking the “I Agree” button or by using the Services, you are agreeing to be bound by this Privacy Policy.

3. Personal Information

We collect and use personal information to provide and support our Services. We only collect and process personal information with the user’s consent, or in those cases in which the collection and processing of personal information is permitted by law. Most of the information that we collect about you comes directly from you when you play our games, or interact with our websites, advertising or other Services. The main purpose of collecting such information, is to improve our game, website, advertisement targeting and other Services, in accordance with Section 5 of this Privacy Policy.

We collect your personal information in the following circumstances:

  • To register for any of the Services we provide, we may collect your name, email address, state/province and country of residence, zip/postal code, birthdate and gender;
  • When you sign up for the NLE newsletter, we collect your first name and email address;
  • Your interactions with us on our social media channels;
  • If you connect the Services to a social media account, we may collect your name, email address, profile picture, age range, gender and other information you make public on Facebook, in addition to your friend list (unless you affirmatively revoke such collection);
  • We may collect your geolocation data when you use the Services, which we associate with your personal and anonymous information;
  • If you create an account with NLE, or connect the Services to a social media account, such as Facebook, your personal information may be linked to otherwise anonymous information, collected in accordance with this Privacy Policy, such as how you use the Services or items you purchased at online stores associated with NLE Services; and
  • If you contact us for customer service, we may collect your email address, first and last name and, if required, Facebook information for authentication purposes and customer support, and associate this personal information with anonymous information, such as information about your device;
  • Information that you provide us with when you fill in forms, answer questions or complete surveys when using any of our Services, or if you invite your friends to use our games and Services
  • The content of messages sent using our chat, forum and other messaging systems;
  • Information we collect via cookies and other similar technologies, as explained further below;
  • When you make purchases, whether you shop on NLE websites or directly in-game.

Broadly, the information we collect about you relates to the type of device you are using, how you play our games and may include information that you submit when creating an account with us or which you allow us to access when you connect to your social network accounts through our games or Services. We may also collect information from advertising platforms and partners and other third parties such as information about purchases and interests.

In some instances, when you make purchases on or through our website(s), we may collect certain payment information from you on behalf of our payment service providers, but this information is temporarily cached in a way that is unreadable by NLE. We do not collect or retain credit card information. Our payment service providers will provide us with information about your purchases so that we know if a purchase has been successful.

When you purchase items via our mobile apps (such as those you can purchase in the App Store, on Facebook or on Google Play) we do not collect or store any payment information from you.

We may from time to time ask you for your consent to collect other information from you or your device. For instance, we may invite you to allow us to access your contacts to enable us to invite them to play our games with you. If we do this, we will tell you what information we would like to collect, why we need it and what it will be used for.

Please note that while the Services may allow you to visit as a guest and remain anonymous, you may not be able to access all content and features without providing personal information.

When you make purchases, you agree that NLE may share your personal data with third parties, companies, or organisations, which may collect and process your personal data in order to process and execute online credit card transactions, delivery, discounts, and promotional gifts.

To make a purchase on NLE website or in-game store and process your online payment, you may be asked to provide the following information to a payment provider: your first name, your family name, your address, your email address, your country of residence and your banking details, i.e. your credit card number, the name of the credit card owner, the expiration date and the security code.

This information may be stored in NLE premises, or, when relevant, in the third parties’ premises. Such storage is necessary to allow NLE to manage internal accounts, checking, accounting, compliance, and for legal purposes, in accordance with Section 5 of this Privacy Policy.

4. Anonymous Information

We collect anonymous information from you, which may be provided to us by a third party, including but not limited to:

  • Metrics and other types of statistical data, which could be derived from your use of the Services, for example how you interact with the Services;
  • How you access the Services, for example, computer operating system and web browser, type of mobile device and unique device identifier, device settings, SDK version, mobile advertising identifier (Apple IDFA, Google Advertising ID or Android ID), MAC address, IP address, Wi-Fi information, your “click path” through the Services and the web site or advertisement that was linked to or from the Services;
  • Diagnostic information concerning the Services, for example, logs, error reports and events and the type, number, date and page relating to this information; and
  • Apps you have installed and enabled and how you use those applications.

Please note that while your computer or mobile device may allow you to turn off the collection of some of the above information, you may not be able to access all content and features on the Services.

5. Use of Information

We may use your personal and anonymous information internally for the following purposes:

  • To provide the Services to you, such as hosting and displaying information, providing updates, developing, improving or expanding the Services and addressing technical issues;
  • To generate and analyze information about our users so we can better understand them and how they use the Services and draw trends and predictions based on this information;
  • To enable us to provide our games and other Services to you, to ensure that any purchases you make are verified on our servers and activated in the games, and to provide you with player support if you need it;
  • To enable us to optimise our games for you and for the device that you are using, as well as to deliver customised in game events, offers and promotions;
  • To enable us to use the information that we collect on an anonymised or aggregated basis for product development, to analyse the performance of our games, to troubleshoot and to improve and optimise the games to ensure the best player experience for our players as a whole;
  • To serve you advertisements, provided by NLE or third parties, on the Services, as well as for marketing and promotional purposes;
  • To send Service-related push notifications to your device;
  • To establish and maintain your account on the Services and to protect the security of your account;
  • To provide customer support and to resolve customer issues;
  • To inform you of changes to the Services, such as outages, suspensions or other material changes, which could occur through email or a push notification sent to your device; and
  • If you signed up for any NLE newsletter, to contact you by email for NLE news, promotional purposes or market research which you may opt-out of by clicking an opt-out link located in any such email.

6. Information Disclosure

We may disclose your information outside of NLE for the following purposes:

  • We may disclose your information to third parties who provide services on our behalf, as described in this Privacy Policy;
  • For internal NLE purposes, we may disclose your personal and anonymous information to our parent companies, affiliates, subsidiaries and contractors;
  • We disclose your information to law enforcement or other appropriate third parties in connection with criminal investigations, investigation of fraud, infringement of intellectual property rights, other suspected illegal activities or as otherwise may be required by applicable law or, as we deem necessary in our sole discretion, in order to protect the legitimate legal and business interests of NLE; and
  • In the event of, or in preparation for, a change of ownership or control of NLE, a business transition, such as the sale of some or all NLE assets, or the bankruptcy of NLE, we may disclose and/or assign your personal and anonymous information to third parties who will have the right to continue to use such information in the manner set forth in this Privacy Policy.

7. Cookies & Third Party Services

You consent to us using tracking technologies, such as cookies, web beacons and clear gifs, (“Tracking Technologies“) which assist us to analyze the Services’ functionality, analyze technical issues, send useful notifications to user devices, track use of the Services and generate reports and data models that we use to improve the Services.

A cookie is a file that is sent by a service through your browser to your computer, if your browser is enabled to accept cookies, in order to store certain information on your computer and communicate with a service while you are online. Internet browsers will allow you to erase cookies from your computer hard drive, block acceptance of cookies or receive a warning before a cookie is stored. You should refer to your browser instructions or “Help” screen to learn more about how to manage and block cookies. Please note that, if you block cookies, some portions of the Services may not function properly.

The purpose of using technically necessary cookies is to facilitate the use of the services to the users. Some functions of Services cannot be offered without the use of cookies. The purpose of technically not necessary cookies is the improvement of NLE Services.

Cookies are stored on the user’s computer and transmitted to us. Therefore, you as a user have full control over the use of cookies. You can deactivate or restrict the transmission of cookies by changing the settings in your Internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If cookies are deactivated, it may no longer be possible to use all functions of the Services in full.

We use third parties, who we share your information with. These third party services may be embedded into the Services, such as through an Application Programming Interface (API) or Software Development Kit (SDK), or may take the form of Tracking Technologies which enable these third parties to collect information on our behalf and who may collect information from you to assist us with, for example, serving advertisements, fulfilling a purpose you requested of us (for example, billing services), customer support and feedback, analyzing Services functionality and technical issues, sending useful notifications to user devices, tracking use of the Services and generating reports and data models that we use to improve the Services.

Information collected by third parties is governed by the applicable third party privacy policy, which may provide for broader information collection than collected by NLE. These third parties may use your information internally and disclose your information to others and we strongly recommend that you read each third party’s privacy policy carefully before providing your information.

Here is an overview of our third party SDKs, external service providers and Plug-Ins. This list may be updated from time to time.

Facebook (Android / iOS) (https://developers.facebook.com/docs/apis-and-sdks)
Google Play Services (https://developers.google.com/android/guides/overview)
Google Analytics (https://developers.google.com/analytics/devguides/platform/)
Apple Game Center Services (https://developer.apple.com/game-center/)

Unity Analytics (https://unity.com/solutions/analytics)
Unity IAP (https://unity3d.com/unity/features/iap)

8. Advertising & Product Placement

The Services may contain advertisements served by third parties or product placements conceived in partnership between NLE and third parties. These advertisements use Tracking Technologies to collect information about you, for example, demographics, location and device information, in order to serve you appropriate advertisements and to recognize your device each time a third party serves you an advertisement. Based on this information, third parties may be able to resolve your identity across multiple devices, for example, matching your IP address across multiple devices, in order to target advertisements to you based on your online behavior. This information is collected, used and disclosed in accordance with the terms of the applicable third party privacy policy, as described in Article 5 of this Privacy Policy above.

You may be able to opt-out of mobile behavioral advertising by accessing the settings on your Apple or Android device and selecting the appropriate advertisement tracking settings.

9. Service Communication Features

Your account username and profile picture are visible to other users of NLE Services. We recommend you exercise discretion when selecting your username and profile picture and when using the Services. Personal information disclosed by you within our chat or forum areas, instant messaging service, message boards or during use of the Services can be collected by other users and may result in unsolicited messages. We are not responsible for protecting such information that you may disclose to third parties through our Services (for example, sending your telephone number or credit card information to another user through the chat service). To the extent that you create a public profile that may be available to others on our Services, you are solely responsible for its content and accuracy. You may, at any time, delete your account or modify your account information.

10. Accessing or Changing Your Information

You may contact NLE to obtain a copy of any personal information we have collected about you, the production of which may be subject to a fee as permitted by applicable law. In addition, you may contact NLE to correct or delete such information, except to the extent that retention is necessary for our legitimate business purposes, required by applicable law, in the control of a third party or where correction or deletion is not technically feasible.

If you have any questions or would like to access or change your information via email, please contact us at core-team@nebulae.world

11. Information Storage & Retention

While NLE is a French company, the data you provide through the Services is stored and processed by third parties in countries around the world. You authorize NLE and third parties acting on NLE’s behalf to use and process your data in any country of their choosing, which may cause your data, including personal and anonymous information, to be subject to the privacy protections and legal rights that may not be equivalent to those in your country.

Your personal information is retained until you request its deletion pursuant to Article 10 of this Privacy Policy or until NLE no longer requires such information for the purpose for which it was collected.

12. For European Union Data Subjects

For persons in European Union countries, terms such as “personal information” as used herein refer to “personal data” as defined by the Art. 4 para. 1 GDPR. We will not collect any personal data from you unless you provide it under the terms of the Privacy Policy. By using the Services, you agree that we may transfer your personal information outside the European Union in connection with the purposes stated in the Privacy Policy.

12.1.  Legal basis

Art. 6 para. 1 lit. a GDPR serves as the legal basis for obtaining consent of a data subject on the processing of personal information.

Art. 6 para. 1 lit. b GDPR serves as the legal basis for cases, where the processing of personal information is required for the performance of a contract to which the data subject is a party.

Art. 6 para. 1 lit. c GDPR serves as the legal basis for the processing of personal information necessary for NLE’s compliance with existing legal obligations.

Art. 6 para 1 lit. d GDPR serves as the legal basis for the processing of personal information that is necessary for the protection of vital interests of a data subject or of another natural person.

Art. 6 para 1 lit. e GDPR serves as the legal basis for the processing of personal information that is necessary for the performance of a task carried out in the public interest or as an exercise of official authority as may be vested in NLE.

Art. 6 para. 1 lit. f GDPR serves as the legal basis for the processing of personal information that is necessary for the legitimate interests of NLE or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal information, in particular where the data subject is a child.

12.2. Personal data retention

The personal information will be deleted or access will be restricted as soon as the purpose of storage ceases to apply. The data will also be deleted or access will be restricted if a storage period expires, unless there is a need for further storage of the personal information for the conclusion or fulfilment of a contract.

12.3. The nebulae.world website

The purpose of data processing the temporary storage of the IP address by the system is necessary to enable the website to be accessed by the user’s computer. For this reason, the IP address of the user must remain stored for the duration of the session. The data is stored in log files to ensure the functionality of the website. In addition, the data serves us to optimize the website and to ensure the security of our information technology systems. These are our legitimate interests in data processing pursuant to Art. 6 para. 1 lit. f GDPR. An evaluation of the data for marketing purposes does not take place in this context.

The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected.

If the data is stored in log files, this is the case after seven days at the latest. Further storage is possible. In this case, the IP addresses of the users are deleted or alienated, so that the personal information is anonymized. The collection of data for the provision of the website and the storage of data in log files is necessary for the operation of the website. Consequently, there is no possibility of objection on the part of the user.

Our Website makes use of Google Analytics, a Web analysis service of Google Inc. (“Google”). Google Analytics uses so-called “cookies”, text files which are saved on your computer and through which an analysis of website usage is enabled. The information generated by the cookie about your usage of this website is normally transmitted to a Google server in the USA and saved there. In case of activation of the IP anonymisation of this website, your IP address will however first be abbreviated by Google within the member states of the European Union, or other contracting member states of the Treaty of the European Economic Area. Only in exceptional cases shall the full IP address be transmitted to a Google server in the USA, and then be abbreviated there. On our behalf, Google will use this information in order to analyze your use of the website, to compile reports regarding website activities and to render further services to us associated with website and Internet usage. The IP address transmitted by your browser within the scope of Google Analytics will not be combined with other data from Google. You can prevent the storage of cookies by setting your browser appropriately; however it should be noted that in this case it may not be possible to use all functions of this website to their full extent. Furthermore, you can prevent the recording of data generated by the cookie and data related to your usage of the website (incl. your IP address) by Google, as well as the processing of this data by Google, by downloading and installing the browser plug-in available under the following link.

For more information, please visit: http://www.google.com/analytics/privacyoverview.html

12.4. The NLE newsletters

You can subscribe to a free newsletter from NLE. When registering for the newsletter, the personal information namely name and email address, is transmitted to us. No personal information is passed on to third parties. The collection of the user’s email address and name serves the purpose of sending the newsletter.

The personal information will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. The user’s email address will therefore be stored for as long as the subscription to the newsletter is active. The user may cancel the subscription to the newsletter at any time by clicking on the unsubscribe link at the end of each email newsletter.

12.5. Right of access

You have the right to obtain confirmation from NLE; as to whether or not personal data concerning you are being processed, and, where that is the case, access to your personal data and the following information:

  1. The purposes of the processing;
  2. The categories of personal data concerned;
  3. The recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
  4. Where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  5. The existence of the right to request from NLE rectification or erasure of personal data or restriction of processing of personal information or to object to such processing;
  6. The right to lodge a complaint with a supervisory authority;
  7. Where the personal data are not collected from you, any available information as to their source;
  8. The existence of automated decision-making, including profiling, referred to in Art. 22 para. 1 and 4 GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.

You have the right to request information as to whether the personal data concerning you is transferred to a third country or to an international organization. In this context, you may request to be informed of the appropriate guarantees pursuant to Art. 46 GDPR in connection with the transmission.

12.7. Right of rectification

You have the right to obtain from NLE without undue delay the rectification of inaccurate or incomplete personal information. Taking into account the purposes of the processing, you shall have the right to have incomplete personal information completed, including by means of providing a supplementary statement.

NLE shall communicate any rectification or erasure of personal data or restriction of processing carried to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. NLE will inform you about those recipients if you request it.

12.8. Right to be forgotten

You shall have the right to obtain from NLE the erasure of your personal information without undue delay and NLE shall have the obligation to erase personal information without undue delay where one of the following grounds applies:

  1. The personal information is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  2. You withdraw consent on which the processing is based according to Art. 6 para.1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR, and where there is no other legal ground for the processing;
  3. You object to the processing pursuant to Art. 21 para. 1 GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 para 2 GDPR;
  4. The personal information has been unlawfully processed;
  5. The personal information has to be erased for compliance with a legal obligation in the European Union
  6. The personal information has been collected in relation to the offer of information society services referred to in Article 8 para.1.

Where NLE has made the personal information public and is obliged pursuant to the above to erase the personal information, NLE, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

The right to erasure shall not apply to the extent that processing is necessary:

  1. For exercising the right of freedom of expression and information;
  2. For compliance with a legal obligation which requires processing by the European Union or for the performance of a task carried out in the public interest
  3. For the establishment, exercise or defense of legal claims.

12.9. Right to restriction of processing

You shall have the right to obtain from NLE restriction of processing where one of the following applies:

  1. The accuracy of the personal data is contested by yourself, for a period enabling NLE to verify the accuracy of the personal data;
  2. The processing is unlawful and the data subject opposes the erasure of the personal information and requests the restriction of their use instead;
  3. NLE no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
  4. You have objected to processing pursuant to Art. 21 para. 1 pending the verification whether the legitimate grounds of NLE override those of the data subject.

Where processing has been restricted, such personal data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State.

If you have obtained restriction of processing pursuant to the above, you shall be informed by NLE before the restriction of processing is lifted.

12.10. Right to data portability

You have the right to receive the personal information, which you have provided to NLE, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:

  1. The processing is based on consent pursuant to Art. 6 para 1 lit. a or Art. 6 para 1 lit. b or Art. 2 para 2 lit. a GDPR
  2. The processing is carried out by automated means.

The right shall not adversely affect the rights and freedoms of others.

In exercising your right to data portability you shall have the right to have the personal information transmitted directly from one controller to another, where technically feasible.

The exercise of this right shall be without prejudice to the right of erasure. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

12.11. Right to object

You shall have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning him or her which is based on Art. 6 para. 1 lit e) or lit. f). NLE shall no longer process the personal information unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

Where personal information is processed for direct marketing purposes, you shall have the right to object at any time to processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.

Where you object to processing for direct marketing purposes, the personal information shall no longer be processed for such purposes.

At the latest at the time of the first communication with you, the right referred to above shall be explicitly brought to your attention shall be presented clearly and separately from any other information.

In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise the right to object by automated means using technical specifications.

12.12. Automated individual decision-making

You shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or otherwise significantly affects you.

This shall not apply if the decision:

  1. Is necessary for entering into, or performance of, a contract between you and NLE;
  2. Is authorised by European Union law and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or
  3. Is based on your explicit consent.

NLE shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of NLE, to express his or her point of view and to contest the decision.

Decisions shall not be based on special categories of personal data referred to in unless Art. 9 para.2 lit. a) or lit g) GDPR applies and suitable measures to safeguard your rights and freedoms and legitimate interests are in place.

12.13. Right to complain to a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right of appeal to a supervisory authority, in particular in the European Member State where you reside, work or suspect of infringement, if you believe that the processing of personal information concerning you is not in compliance with GDPR. The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and results of the complaint, including the possibility of a judicial remedy under Art. 78 GDPR.

13. Minors

NLE does not use its Services to knowingly solicit information from, or market to, children under the age of 16. In the event that we learn that we have collected personal information from a child below 16 years of age, we will take all reasonable measures to delete such information as quickly as possible.

Please do not play our games or use our Services if you are under the age of 16.

If you are a parent or a legal guardian, please do not leave your children unattended on the Internet and explain them the importance of the proper handling of their data.

14. Security

While NLE takes precautions against possible breaches in the Services, no website, application or Internet transmission is completely secure. For example, NLE employs a security technology known as a secure-socket-layer, or SSL, to protect the transmission of critical account information through the Services. However, NLE cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. Your use of the Services is at your own risk.

NLE urges you to take steps to keep your personal information safe by using a unique, strong password that you do not use on any other website or service, not sharing your login information with anyone, regularly logging out of your account and closing your web browser when you are not in control of your user session.

15. Updates to the Privacy Policy

NLE reserves the right, at its sole discretion, to change, modify, add or remove portions of the Privacy Policy at any time (“Updates“). We agree to notify you of Updates through a Services message and to make them available on our website. You are deemed to have accepted any Update by continuing to use the Services. Unless NLE states otherwise, the Updates are automatically effective 30 days after being posted on our website.

16. Contact Information

If you have any questions or concerns about any of the matters in relation to this Privacy Policy, including to exercise any of your rights, please contact us at core-team@nebulae.world