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Privacy policy

Last modified on [December 1st 2023]

Ⅰ. Smartbig USA Inc. (DBA:Netgame.com) – Online Privacy Policy

Smartbig USA Inc. and its subsidiaries and affiliated companies (collectively, hereafter, `SMARTBIG`, `we`, `us`, the `companies`) highly respect the privacy rights of our online properties’ visitors, users, and customers (collectively, hereafter, `you`). Our online properties include, but are not limited to, website (the `site`) and all website related services and products that are, in part or as a whole, owned and provided by us to you. The following privacy policy informs you on how we engage in all activities correlated to, including but not limited to, collecting, storing, handling, and using your personally identifiable information you provide us and non-personally identifiable information we collect. We take your privacy issues very seriously; hence, we do not release any of your personally identifiable information without your permission. Prior to using any of our online properties, you must thoroughly read and fully comprehend our Online Privacy Policy and signify your full agreement to the Online Privacy Policy. Furthermore, your use of our online properties signify your full comprehension and full agreement to the Terms of Use, End User Agreement, and any other Smartbig’s rules, polices, notices, agreements and guideline.

Ⅱ. Types of Information We Gather from You.

1.Children

We take minors’ online privacy issues very seriously. You are a minor if you are under the age of eighteen (18) or under the legal age to form a legally binding contract in your jurisdiction. If you are a minor, you must have your parent/s and/or legal guardian/s to thoroughly review and fully agree to our Online Privacy Policy and any other aforementioned rules of SMARTBIG. The parent/s and/or legal guardian/s must agree to take full responsibility of all actions and its consequences within the legal boundaries of our online properties that creates conflict/s of interests of SMARTBIG by the minor/s under their custodianship/s. Such responsibilities mean, but are not limited to, that you agree to indemnify us for any types of monetary and non-monetary, tangible and intangible damage/s done by minor/s in your custodianship in the form/s of monetary and non-monetary, tangible and intangible compensations. We ask all parents and/or legal guardians of every minor to take an active and serious role in all minors’ online experiences at all times. If you are a parent or a legal guardian of any minor(s), please inform and educate them not to disclose any personally identifiable information such as, but not limited to, real name and any types of contact information. To comply with a US federal law, Children’s Online Privacy Protection Act (commonly referred as COPPA), we do not knowingly collect, store, handle, and/or use personally identifiable information from children. Children are defined herein as minors under the age of thirteen (13). If we learn that we have unknowingly and/or advertently gathered personally identifiable information from any child, we will immediately terminate such information and any account/s linked to such information from our database and/or records and take appropriate actions and attempt to notify parent/s and/or legal guardian/s of such child. Please note that SMARTBIG does not have absolute control over the actions taken by you, which means that any types of personally identifiable and/or other information disclosed, intentionally or unintentionally, by you in the public domain and its consequences are solely your responsibilities. We are responsible only for our actions and its consequences, as far as this Online Privacy Policy is concerned. There are two channels through which we collect information about you; one, information you provide us, and two, information we collect through technologies, methods, and/or services.

2.Information you provide Us.

Personally identifiable information we collect are provided by you. You may only visit some parts of our online properties without providing such information to us; however, in order for you to use certain features of our online properties, such as playing our online game properties and getting involved in community forums on our site, you are required to provide us with certain personally identifiable information. These include, but are not limited to, your actively used email address, gender, phone number, home address, date of birth. Furthermore, you are required to provide us or third party payment service provider/s (e.g., PayPal or equivalent service provider/s) additional information such as, but not limited to, credit card related information, if you choose to purchase any types of services and/or products we provide for fee/s. Please note, the permissions for the use of certain features of our online properties that require you to provide us personally identifiable information are granted to only those who provide us honest, correct, and up-to-date information. Falsifying any information is against our Online Privacy Policy. Such fraudulent act/s done by you may result in legal actions against you if such legal actions are deemed necessary.

3.Information We collect Through Technologies, methods; and/or Services.

Through available and legal technologies, methods, and/or services, we may collect and store information about your computer hardware/s, software/s, system specification/s, Internet IP address/s, your online activities (not limited to your use of our online properties) and patterns of such activities, and more. The primary purpose of such information collection is to ensure the quality of our online properties to better serve our customers and improve the ways we do our businesses. Better serving our customers and optimizing the ways we do our businesses is the key for our success and viability. Therefore, your use of certain features of our online properties requires you to accept/allow, for example but not limited to, Cookies and/or Web Beacons. You may choose not to accept/allow such information tracking technologies, methods, and/or services performed by us, such as cookies blocking through your web browser setting changes; however, this may result in some features of our online properties not to function properly. From time to time, we may change and/or test-out various technologies, methods, and/or services that are available at our discretion. For any questions about specifics, details, and up-to-date information about types of technologies, methods, and/or services we use at any given time, you may contact us by using Lounge Service for such request.

Ⅲ. The Use and Share of the Information We Gathered.

In essence, all information we gather about you, whether personally identifiable or not, are used to support your use of our online properties and to fulfill our legitimate business objectives.

1.SMARTBIG’s Internal Use for Business Purposes.

Business purposes are all activities performed by us to fulfill our legitimate business objectives and/or to serve the needs of our customers. Such activities by SMARTBIG may be in the forms of, but not limited to, sending you business, administrative, informative and/or reminder emails about some existing and/or new features added to our online properties and/or about, in response to, your request/s for certain information and/or service/s and/or your use of paid and/or not-paid services and products we offer our customers. In addition to the use of your information in the manners as described above, we may use any combination of your personally identifiable information and various other types of information we gather about you and/or others through information collecting technologies, methods, and/or services to optimize our business to better serve the needs of our customers to serve our business objectives. For example, this may include studying your web-browsing patterns and comparing that of others we learned through information collecting technologies and third-party services, then modifying and enhancing our online properties to better suit the general web-browsing patterns of our customers.

2.Use and/or Share with Third Parties for Business Purposes.

In connection with fee based services and/or products of our online properties, we have set up business relationships with third parties. In such relationships, we share, in part or as a whole, personal information records of our customers with third parties in order to successfully process the customer requested fee based services and/or product/s. The use of such information we share with such third parties are strictly to be used ONLY for the connection with the specific services and/or products we cater to our customers; for example, such shared information cannot be used by third parties for direct or indirect advertisements and/or marketing campaigns carried out by such parties. We do not grant them any permission of using your personal information other than to be used in manners described in this Online Privacy Policy. Therefore, if you reach to a reasonable conclusion that they are misusing your personal information without your permission, and in manners not allowed by our Online Privacy Policy, we ask you and contact appropriate personnel at their company. Please note, for such third parties that we have business relationships with, you may be required to accept their end user agreement, privacy policy, and/or any other types of their rules and policies. If you agree to aforementioned agreement/s, policy/s, and/or any other types of rules of the third party/s, we will not be responsible for the collecting, storing, handling, and/or using your personal information you provide them and/or personal information they gather through any types of information collecting technologies, methods, and/or services they employ.

3.In Case of Promotions, Contest and/or Sweepstakes.

For any promotions, contests and/or sweepstakes which will be organized, in-part or as a whole, by us and/or hosted on our site, there will be such event relevant privacy policy in the official rules and/or registration area. Such even relevant privacy policy will govern that particular promotion, contest, and/or sweepstake only. Such event relevant privacy policy may differ from this Online Privacy Policy, so we advise you to read it thoroughly prior to accepting terms described in such policy or policies. In most cases, promotions, contest and/or sweepstakes require participants’ permissions for the collection and/or the use of participants’ certain personally identifiable information by event organizer/s; we advise you to make decision that is appropriate for you.

4.Purchase, Sale, Liquidate and/or Merge of Business.

We may purchase, sell, liquidate, and/or merge one or more businesses from time to time within internal business units/parties and/or to/with/from external third party/s. In such cases, transfer of our collection of personal information may occur as a part of such business transaction/s, unless the law prohibits us otherwise. If we sell or liquidate our business/s and must transfer such personal information collected by us to third party/s with different Privacy Policy from this Online Privacy Policy, we will require the business/s purchaser/s to treat such transferring information in the same manners as described in this Online Privacy Policy.

5.Disclosure, Use, and/or Share of Your Information for Non-Business Purpose.

We may purchase, sell, liquidate, and/or merge one or more businesses from time to time within internal business units/parties and/or to/with/from external third party/s. In such cases, transfer of our collection of personal information may occur as a part of such business transaction/s, unless the law prohibits us otherwise. If we sell or liquidate our business/s and must transfer such personal information collected by us to third party/s with different Privacy Policy from this Online Privacy Policy, we will require the business/s purchaser/s to treat such transferring information in the same manners as described in this Online Privacy Policy.

Ⅳ. Links to Third Parties.

Our online properties may contain links to other websites and/or services operated by third-parties. In some cases, these links may lead you to web properties that may partially or wholly operated and/or owned by us. In any cases, such linked web properties may have privacy policy differs from this Online Privacy Policy. In any cases, it is your responsibility to check the privacy policy of each web site you are visiting and/or linked-to, prior to engaging in any kinds of activities within such web properties.

Ⅴ. Notice of Privacy Policy Amendment/s.

We reserve our rights to amend any portion/s of this Online Privacy Policy at any time for any reasons. When we amend any parts of this Online Privacy Policy, we will notify you by sending an e-mail notice and post such notice in, but not limited to, forums and/or any other, what we view as, appropriate places within our online properties. When such changes to our Online Privacy Policy are made, the new Online Privacy Policy will be effective, beginning, on 31st days from the day of any type/s of aforementioned and other types of notice we choose to utilize. Please note, although we will try to send you email notice, your email host company may view our mails as spam and/or junk emails; therefore, our email may not reach you in time. We advise you to view this Online Privacy Policy section at least once a month to be on the safe and sure side. Also, as soon as any of the personal information you provide us change, please update your profile with us, so that we can continuously ensure and provide you with the most up-to-date services and products available for our customers.

Ⅵ. Change/s to Your Personal Information.

You can access and make changes to any parts of the personal information you provide us from ‘My Account’ section of our online properties. Please note, to use some features of ‘My Account’ section, we ask you questions about personal information that you initially provided us in order to match your responses for identity verification. Please make a note of information you provide us initially and each time you update your profile, thereafter, for your record and keep it in the safe place/s. We will not be giving out any parts of your personal information in our database, even if it indeed is you to ensure the security and safety of your information.

Ⅶ. Your Online Privacy Rights.

Please note, you have control over the personally identifiable information you submit to us. At any time, for any reasons, you may choose to terminate your account with us from ‘My Account’ section; in which case, we will remove your personal information from our database.

1.Opting-Out.

You can choose to opt-out from certain service and/or product features we provide you in ‘My Account’ section of our website. For example, we may send out marketing emails to our customers. If we do so, you will be able to opt-out from such practice by declining to such services in ‘My Account’ section on our website. When you opt-out from any types of service and/or product features, you will not be receiving any features in the similar nature, until you re-allow us to offer such features to you.

2. Your California Privacy Rights.

Beginning January 1, 2005, California Civil Code Section 1798.83 permits customers of SMARTBIG and California residents to request information regarding the company`s disclosure of personal information to third parties for purposes of direct marketing. You may contact us by using Lounge Service for such request.

Ⅷ. Privacy related Inquiries.

If you have any questions, issues, and/or comments relating to our Online Privacy Policy and/or your personal information, you may contact us by using Lounge Service.