Last modified on [September 11th, 2024]
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, the 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 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 signifies your full comprehension and full agreement to the Terms of Use, End User Agreement, and any other Smartbig’s rules, policies, notices, agreements, and guidelines.
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 for all actions and their consequences within the legal boundaries of our online properties that create conflict/s of interest 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 US federal law, Children’s Online Privacy Protection Act (commonly referred to 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 their 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 is provided by you. You may only visit some parts of our online properties without providing such information to us; however, 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, and 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) with 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 a fee/s. Please note that the permissions for the use of certain features of our online properties that require you to provide us with personally identifiable information are granted to only those who provide us with 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.
(Addition: Google Login Information Collection)
If you use Google Login to access our services, we may collect the following additional personal information directly from your Google account:
· Google Account Name
· Email Address
· Google Unique ID (Google User ID)
· Name of Account Owner
· Date of Birth
The information collected through Google Login is used solely for account authentication, providing access to our services, and enhancing the user experience. We do not use this information for marketing or any other unrelated purposes without your explicit consent.
If you use Facebook Login to access our services, we may collect the following additional personal information directly from your Facebook account:
· Facebook Account Name
· Email Address
· Facebook Unique ID (Facebook User ID)
· Name of Account Owner
· Date of Birth
The information collected through Facebook Login is used solely for account authentication, providing access to our services, and enhancing the user experience. We do not use this information for marketing or any other unrelated purposes without your explicit consent.
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 to 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 functioning 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 the types of technologies, methods, and/or services we use at any given time, you may contact us by using Lounge Service for such requests.
Ⅲ. The Use and Share of the Information We Gathered.
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 include, but are 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 in response to your requests for certain information and/or services. We may also 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. For example, this may include studying your web-browsing patterns and comparing them with those 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 established 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 to successfully process the customer-requested fee-based services and/or products. The use of such information we share with third parties is strictly limited to the connection with the specific services and/or products we cater to our customers. For example, 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 to use your personal information other than in the manners described in this Online Privacy Policy. Therefore, if you conclude that they are misusing your personal information without your permission and in ways not allowed by our Online Privacy Policy, please contact appropriate personnel at their company. For such third parties with whom we have business relationships, you may be required to accept their end-user agreements, privacy policies, and/or any other types of their rules and policies. If you agree to the aforementioned agreements, policies, and/or any other types of rules of third parties, we will not be responsible for 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.Use and/or Share with Law Enforcement and Government Entities for Legal Purposes.
We reserve the right to fully cooperate with all law enforcement authorities and government entities to comply with all applicable laws, rules, and regulations. If we, in our sole and absolute discretion, determine that we must comply with legal requirements, such as but not limited to, lawful subpoenas, warrants, court orders, and/or any other types of legal procedures, we may disclose any and all information we collect from you to law enforcement authorities and/or government entities. Such disclosure of your information may be in the forms of, but not limited to, your online usage patterns, personally identifiable information, and/or any other types of information we collect.
4.Use of Non-Personally Identifiable Information.
We may share aggregated information and/or non-personally identifiable information about you with third parties for purposes such as analyzing how our services are used, diagnosing technical issues, maintaining security, and improving our products and services. Such information cannot be used to identify you personally.
5.Google Login Integration and Use of Google Login Information
When you choose to use Google Login to access our services, we collect basic account information such as your name, email address, and profile picture. This information is used exclusively to authenticate your account and facilitate your access to our services. We do not share your Google account information with third-party services or use it for marketing purposes unless you have expressly consented. We also encourage you to review Google’s privacy policies to understand how your information is managed by Google. You can manage your Google permissions at any time through your Google account settings.
6.Facebook Login Integration and Use of Facebook Login Information.
If you use Facebook Login to access our services, we may collect the following personal information directly from your Facebook account:
· Facebook Account Name
· Email Address
· Facebook Unique ID (Facebook User ID)
The information collected through Facebook Login is used solely for account authentication, providing access to our services, and enhancing the user experience.
We do not use this information for marketing or any other unrelated purposes without your explicit consent. Please review Facebook’s privacy policies to understand how your information is managed by Facebook. You can manage your Facebook permissions at any time through your Facebook account settings.
7.In Case of Promotions, Contest, and/or Sweepstakes.
For any promotions, contests, and/or sweepstakes organized, in part or as a whole, by us and/or hosted on our site, there will be an event-relevant privacy policy in the official rules and/or registration area. Such event-relevant privacy policy will govern that particular promotion, contest, and/or sweepstake only. Such an event-relevant privacy policy may differ from this Online Privacy Policy, so we advise you to read it thoroughly before accepting the terms described in such policy or policies. In most cases, promotions, contests, and/or sweepstakes require participants’ permission for the collection and/or use of participants’ certain personally identifiable information by event organizers; we advise you to make decisions that are appropriate for you.
8.Purchase, Sale, Liquidation, 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 parties. In such cases, the transfer of our collection of personal information may occur as a part of such business transactions unless the law prohibits us otherwise. If we sell or liquidate our business and must transfer such personal information collected by us to third parties with a different Privacy Policy from this Online Privacy Policy, we will require the business purchaser(s) to treat such transferring information in the same manners as described in this Online Privacy Policy.
Ⅳ. Requesting Data Deletion
We are committed to providing you with control over your personal data. If you wish to request the deletion of your personal information collected by our services, please follow the procedures outlined below:
1. Contact Method for All Users, Including Facebook Login Users:
Users, including those who access our services via Facebook login, may request the deletion of their personal data by contacting us through our Lounge Service or via the contact information provided on our website at lounge.netgame.com. In your request, please include:
· Your full name
· The email address associated with your account
· A clear statement specifying that you are requesting the deletion of your personal data
Upon receipt of your request, we will process the data deletion within 30 days. You will receive confirmation once your data has been permanently deleted. Please note that certain information may need to be retained to comply with legal obligations or for legitimate business purposes as permitted by applicable law.
2. Account Termination Menu for Netgame Account Users Only:
Netgame account users can also initiate the deletion process by accessing the "Account Termination" menu on our website. This option is specifically available for users who have created accounts directly with Netgame and is not available for those who log in via Facebook. The deletion process will be completed within 30 days of your request, and a confirmation will be sent once the data has been permanently removed.
3. Processing Time:
All data deletion requests are processed within 30 days. Following completion, you will receive a confirmation that your data has been deleted. Please be aware that while we strive to fulfill your request in a timely manner, there may be instances where certain information must be retained to comply with legal requirements or for legitimate business purposes.
If you have any questions or require further assistance, please contact us through the Netgame Lounge System at lounge.netgame.com.
Ⅴ. Third-Party Sites and Services.
Our online properties may contain links to third-party websites, services, and/or products. You acknowledge and agree that SMARTBIG is not responsible for the privacy practices of such third-party sites, services, and/or products. We encourage you to carefully read the privacy policies of these third parties, as they may differ from our policies.
Ⅵ. Data Security.
We implement reasonable security measures to protect your information from unauthorized access, use, and disclosure. However, you acknowledge and agree that no method of transmission over the Internet or method of electronic storage is 100% secure, and we cannot guarantee the absolute security of your information.
Ⅶ. International Users.
If you are accessing our online properties from outside the United States, your information may be transferred to, stored, and processed in the United States or other countries where our servers are located. By using our services, you consent to such transfer, storage, and processing of your information as described in this Online Privacy Policy.
Ⅷ. Changes to This Online Privacy Policy.
We may update this Online Privacy Policy from time to time to reflect changes in our practices or legal requirements. Any changes will be posted on this page, and we will update the "Last modified" date at the top of this policy. Your continued use of our online properties following the posting of changes signifies your acceptance of such changes.
Ⅸ. Contact Us.
If you have any questions, concerns, or requests regarding this Online Privacy Policy, please contact us through our Lounge Service or via the contact information provided on our website.