Last updated: June 9, 2018
This Policy is incorporated into, and is subject to, the Nitroxis Terms of Service. Capitalized terms used but not defined in this Policy have the meaning given to them in the Nitroxis Terms of Service.
“Nitroxis” is the name of the company having legal name registered as “Nitroxis (SMC-PVT) Limited” with the Government of Pakistan, incorporated under the Companies Act, 2017 (XIX of 2017), w.r.o. Securities and Exchange Commission of Pakistan
“Client” means a customer of Nitroxis.
“Client Data“ means personal data, reports, addresses, and other files, folders or documents in electronic form that a User of the Service stores within the Service.
“Personal Data” means any information relating to an identified or identifiable natural person.
“Public Area” means the area of the Site that can be accessed both by Users and Visitors, without needing to log in.
“Restricted Area” means the area of the Site that can be accessed only by Users, and where access requires logging in.
“User” means an employee, agent, or representative of a Client, who primarily uses the restricted areas of the Site for the purpose of accessing the Service in such capacity.
“Visitor” means an individual other than a User, who uses the public area, but has no access to the restricted areas of the Site or Service.
For details about how to contact us, see the “How To Contact Us” section below.
1. WHAT PERSONAL INFORMATION DOES NITROXIS COLLECT?
The personal information we may collect about you through the Services falls into the following general categories:
1.1. Information that you provide voluntarily
Certain parts of our Services may ask you to provide personal information voluntarily. For example, we may ask for certain information in order to register an account with us, to begin playing Games, to subscribe to marketing communications from us and/or to submit enquiries to us, such as:
- your name, email address or other contact details
- any information you submit to our customer service team in the Game or via any communication medium such as (email, phone call, messages, etc)
The personal information that you are asked to provide and the reasons why you are asked to provide it, will be explained to you when we ask you to provide your personal information.
1.2 Information we collect automatically
When you use our Services, we may also collect certain information automatically from you and/or your device which may be considered personal information under applicable data protection laws, such as:
- Your Service communications (e.g. in-game chats and messages with other players)
- Data and analytics about your use of our Services (e.g. heatmap of users activity on our site/app, various analytics, in-game play progress, levels, games played, session length, preferred settings, which in-game adverts you may have viewed, in-game preferences or just game preferences, which friends you connect with, the means by which you were referred to our Services)
- Your IP address and device identifiers such as your Advertising ID, Device ID numbers (for more see our section “Advertising IDs and Device IDs”)
- Your device type and the operating system that you use
- General geographic location (e.g. country or city location) based on your IP address
- GPS location, with your consent
1.2.1 Advertising IDs and Device IDs
“Advertising ID” means the Apple Identifier for Advertisers (“IDFA”) on Apple, and Google Advertising Identity (“GAID”). These are unique identifiers for mobile devices that advertisers use for interest-based advertising. They are consistent across all games and applications and thus allow cross-app tracking. On Apple, you can opt out by choosing the “limit ad tracking” option in the privacy settings. On Google Android, you can opt out by choosing the “Opt out of interest based ads.” Advertising IDs are non-permanent, non-personal identifiers uniquely associated with your device. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognize your device when you use websites and applications.
“Device identifier / information” means device type, device model, device manufacturer, device operating system and language, or other technical data like screen size, processor, or a combination of this data, available from a device for a developer to check the device’s compatibility with a particular application.
Some of this information may be collected using cookies and/or similar technologies (such as “software development kits, or “SDKs”), as explained in the “Cookies and similar tracking technology in websites” section below.
1.3 Information we obtain from third party sources
(a) Information from social media platforms. You may choose to connect to our Services via your social media account. The exact information we receive from you will depend on your social media privacy settings but it will typically include your basic public profile information, such as:
- your username
- profile picture
- age range
- your friends playing the same Game
Typical uses include updating game progress on multiple devices you may own so that you can continue your progress using multiple devices. In addition, we may also show your Facebook friends in the Game and show your public Facebook profile name and picture in Game leaderboards and in your Game profile.
(b) Third party service providers. We may receive personal information about you from third-party sources. We may get your personal information, for example, when you installed our Application and/or Game or when, prior to installation, you click on an advertisement for the Application and/or Game (see “Third Parties” section below for further detail).
(c) Advertising partners. From time to time, we may also receive personal information about you from other third-party sources. For example, if you clicked on an advertisement directing you to one of our Services (such as an ad for one of our Application and/or Games in another publishers’ service e.g. app/mobile), we will be provided with information about which ad network and advertising campaign the install originated from (See also “Advertising” below).
1.4 No special categories of information
We do not request or intend to collect any “special categories of information” such as any information on health, race, religion, political opinions or philosophical beliefs, sexual preferences or orientation. Please, be cautious when sharing this information about yourself (or others) in our forums.
2. HOW WE USE YOUR PERSONAL INFORMATION
We use your personal information for the following purposes:
2.1 To provide and operate our Services:
- To create user accounts/profiles to enable you to user our services
- To provide you with the correct versions of our services (e.g. knowing which language to make our services available to you in)
- To enable you to communicate with other users (including via chat rooms, forums and/or private messages) and leaderboards local to you
- To send you service-related communications including confirmations, technical notices, updates, security alerts, and support/administrative messages
2.2 To improve our Services and keep them secure:
- To respond to your customer support requests (e.g. if you write to us with a complaint)
- To receive error messages about any issues you/your device encounters with our Services to enable us to fix bugs and interoperability issues
- To detect and prevent illegal activities (e.g. hacking or cheating)
- To track application and/or game installs (for purposes of measuring the effectiveness of marketing campaigns).
- To conduct optional user feedback surveys
- To understand you, your preferences and user traffic to enhance your experience and enjoyment using our services
- To conduct research to provide you more better services
2.3 To personalize our Services:
- To remember you next time you visit one of our Services
- Communicate with you about promotions, rewards, upcoming events, and other news about products and services we offer
2.4 For promotional activities (including marketing and advertising)
- To provide you with in-service offers and rewards based on your in-service behaviors
- To serve you with relevant targeted advertisements (necessary to fund our Services)
- To make you offers to purchase in-service items on discount based on your in-service activity and purchase history
- To send you marketing communications and/or newsletters about rewards and promotions if you have subscribed to them
- To comply with our legal obligations
- To exercise, establish or defend our legal rights, or to protect your vital interests or those of any other person
- To prevent and/or detect fraud or fraudulent behavior
3.1 We use advertising to fund our Services which are available for free or you can purchase a license for our service, if you want advert free experience. We show third-party advertising in our Services and also advertise our Services via third parties. We want to provide you with more detail about how we use information for advertising, both in our properties and in third-party properties.
3.2 To enable us to show in-service ads, we may send your advertising ID and IP address to advertisers (or ad networks) to enable them to find appropriate ads to serve to you in our Services and on third-party properties. You can control and limit our use of your advertising ID in your device settings. Nitroxis does not control which specific ads are shown in our services (this is controlled by ad networks) but we do prohibit certain types of ads (such as gambling, profanity, pornographic, etc)
3.3 Advertising IDs are used by ad networks for a number of purposes (please refer to the Privacy Notices of our advertising partners listed herein as “Third Parties“) including, for example, to:
(a) limit the number of times you see the same ad
(b) ensure they are dealing with humans with real devices and not automated “bots”
(c) to serve you with advertisements likely to be relevant to you based on your advertising ID, your engagement with other brands and ads which is recorded using your advertising ID, and to use your general geographic area.
(d) Other brands buy ad placements via an ad network or ad exchange to advertise their products in Our Services. The ad network or ad exchange acts as intermediary between other service providing companies and Nitroxis. In order for an ad network to charge the company purchasing the ad, clicks from the ad and potential installs of other developers’ apps are tracked. Views, clicks and installs from ads are measured using the Advertising ID.
(e) Ad networks track which services you have used to market you similar kind of services.
Your IP address is typically used by advertisers to identify your general geographic location, for example, your country, state and, sometimes, your city).
3.4 Nitroxis also advertises its services on other games and apps by asking ad networks to place ads for audiences that will be interested in them (determined using Advertising IDs).
3.5 Ad networks use Advertising IDs for this and other purposes (please refer to the Privacy Notices of our advertising partners listed as “Third Parties”) including, for example, to:
(a) Measure ad effectiveness (looking at total views, clicks and installs generated by its advertising in other publishers’ games and/or apps);
(b) Inform clients that have not used our services for a while about new content. Nitroxis gives a list of these users in the form of Advertising IDs to an ad network. The ad network then shows these users ads about the new content.
(c) Not display ads for a services a player is already using. Nitroxis may send a list of active clients in the form of Advertising IDs to an ad network. The ad network then excludes these players from seeing the ad.
(d) Market services to a group of potential customers. Nitroxis provides Facebook a list of Advertising IDs to match them with similar type of Facebook users to whom Nitroxis could then market its games. Nitroxis does not have information on how Facebook identifies or creates profiles of similar type of users.
3.6 You can opt out of interest-based advertising on mobile applications and/or games by changing the privacy settings of your device and selecting “limit ad tracking” (Apple iOS) or “opt out of interest-based ads” (Android).
3.7 Our Advertising Partner: We use Appodeal in almost every services for Advertisements Monetization. Appodeal seems to be compliant with GDPR and our customers choose to give consent to collect Advertising IDs and show relevant Ads to them, which we then provide to the Appodeal API by using their SDKs in our services. They work by showing Ads from multiple Ad Networks to us. You can view their Advertising partners privacy policies and opt-out from individual networks from this link
4. COOKIES AND SIMILAR TRACKING TECHNOLOGY IN WEBSITES
Our Services may use “cookies” and other technologies such as pixel tags, local shared objects, hardware-based device identifiers, flash cookies, operating system-based identifiers, clear GIFs and web beacons.
Cookies: A “cookie” is a small file your browsers stores when told to do so by a website. Typically, websites place a number of different cookies on an end-user’s device. Some are “First-party” cookies,’ i.e. from the website itself, and others are “Third-party” cookies, meaning they belong to advertising and analytics entities or social networks. Cookies are personal information. However, Nitroxis’ cookies do not include any other personal information and are typically used to quickly identify your device and to “remember” your device during subsequent visits for purposes of functionality, preferences, and website performance. You can disable cookies on your device or set your device to alert you when cookies are being sent to your device; however, disabling cookies may affect your ability to use the Services.
4.1 Details of Cookies being/ or were being used in our services:
|Service provider||Cookie name||Cookie type||Expiration||Content|
|Nitroxis||has_account||3||1 year||Helps to make clear whether the visitor has an account with Nitroxis|
|Nitroxis||last_visited||3||1 year||Helps to make clear whether the visitor has an account with Nitroxis|
|Google DoubleClick||__ar_v4||2||5 years||Helps with tracking conversion rates for ads|
|Google Analytics||__utma||2||2 years||Helps to identify sessions of visitors|
|Google Analytics||__utmb||2||30 minutes||Helps to identify new visitors to the Site|
|Google Analytics||__utmc||2||session||Helps to identify new visitors to the Site|
|Google Analytics||__utmt||2||10 minutes||Helps to throttle traffic rate for Google servers|
|Google Analytics||__utmz||2||2 years||Helps to identify the traffic source of visitors|
|Google Analytics||_ga||2||2 years||Helps to identify sessions of visitors|
|Google Analytics||_gat||2||10 minutes||Helps to throttle traffic rate for Google servers|
|Segment||ajs_anonymous_id||2||1 year||Helps to identify sessions of visitors|
|Segment||ajs_group_id||2||1 year||Helps to identify registered visitors by group|
|Segment||ajs_user_id||2||1 year||Helps to identify registered visitors|
|Amplitude||amplitude_idnitroxis.com||2||10 years||Helps to identify sessions of visitors|
|FullStory||fs_uid||2||100+ years||Helps to identify sessions of visitors|
|Nitroxis||nitroxis_trafficsource||1||1 year||Helps to identify the traffic source of visitors|
4.2 Types of Cookies
- strictly necessary/essential cookies – These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services you have asked for cannot be provided. These cookies don’t collect information that identifies a visitor.
- performance cookies – These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.
- functionality cookies – These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, a website may be able to provide you with local weather reports or traffic news by storing in a cookie the region in which you are currently located. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
- behavioural targeted advertising cookies – These cookies are used to deliver adverts more relevant to you and your interests They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organization.
5. LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only where (i) we need the personal information to perform a contract with you, (ii) the processing is in our legitimate interests and not superseded by your rights, or (iii) we have your consent to do so.
(a) Under our terms of service, “performance of contract” as a legal basis for processing your information refers to when we make our Services available to you, provide customer support, integrate Services with technology and distribution platforms such as Apple iOS and Google Android, and inform you of service-related changes and service’s progress.
(b) We process your personal data on the basis of our legitimate interests for example when we provide you the Service events, serve interest based advertisements to you (both in-service and on third-party properties), carry out marketing, keep our services secure, for engineering purposes, analyzing the users’ behavior across our services, moderating chat discussion.
(c) We have a “legal obligation” to process your personal data when complying with a legal obligation, such as the preventing a crime or fraud or maintaining tax records.
(d) If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
If you have questions about, or require, further information concerning the legal basis for collecting and using your personal information, please contact us using the contact information provided in the “How To Contact Us” section below.
6. WHO DOES NITROXIS SHARE MY PERSONAL INFORMATION WITH?
We may share your personal information with the following types of recipients:
(a) With companies in our business group, third-party service providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help enhance the security of our Services), or parties that otherwise process personal information for the purposes described in this Privacy Notice or communicated to you when we collect your personal information
(b) With any competent law enforcement body, regulatory authority, government agency, court of law or other third-party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person
(c) With a potential or actual buyer (and its agents and advisers) in connection with any proposed or actual purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information solely for the purposes disclosed in this Privacy Notice
(d) With any other person, with your consent for such disclosure.
7. HOW DOES NITROXIS KEEP MY PERSONAL INFORMATION SECURE?
We use appropriate technical and organizational measures designed to protect the personal information that we collect about you and process. The measures we adopt are designed to provide a level of security appropriate for the degree of risk involved with processing your personal information. Specific measures include encrypting your personal information in transit and at rest.
8. INTERNATIONAL DATA TRANSFERS
Your personal information may be transferred to, and processed in, countries other than the country of which you are a resident. These countries may have data protection laws that are different from the laws of your country.
Specifically, our Services servers are currently located in the UK, and our business group members, third-party service providers and partners operate around the world. This means that when we collect your personal information we may process it in any of these countries. However, we ensure appropriate safeguards are in place so that your personal information will remain protected in accordance with this Privacy Notice. This includes complying with the European Commission’s Standard Contractual Clauses for transfers of personal information among companies in our business group and third-party service providers and partners, which require all members of our business group to protect the personal information they process from the EEA in accordance with European Union data protection law. It also includes the transfer of personal information to third-party service providers and partners that are certified under the EU-US Privacy Shield.
The Standard Contractual Clauses can be provided on request. We have implemented similar appropriate safeguards with our third-party service providers, and partners and further details can be provided upon request.
9. DATA RETENTION
We retain personal information we collect from you where we have an ongoing legitimate business need to do so. For example, to provide you with a Service you have requested, or to comply with applicable legal, tax or accounting requirements. For example, we periodically de-identify unused Game accounts and regularly review and de-identify unnecessary personal information.
We only retain the Personal Data collected from a User for as long as the User’s account is active or otherwise for a limited period of time as long as we need it to fulfill the purposes for which we have initially collected it, unless otherwise required by law. We will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements as follows:
- the contents of automatically marked for closure accounts are deleted within 3 months of the date of closure;
- the contents of requested
Delete accountwill be delete immediately from running application servers, data storage servers and CDN servers/partners other than backup data storage or backup servers
- backups are kept for 3 months;
- billing information is retained for a period of 10 years as of their provision to Nitroxis in accordance with the Pakistan’s accounting and taxation laws
- information on legal transactions between Client and Nitroxis is retained for a period of 10 years as of their provision to Nitroxis in accordance with the general limitation period set for civil claims in the Pakistan’s Government Laws
10. YOUR DATA PROTECTION RIGHTS
You have the following data protection rights:
(a) To access, correct, update or request deletion of your personal information. You may do so in your account settings (via “Terms of Service and Privacy Notice“) or by contacting us using the information in the “How To Contact Us” section below.
(b) To object to the processing of your personal information (which is processed on the grounds of legitimate interests), ask us to restrict processing of your personal information or request portability of your personal information. Again, you may do so by opting out of personalized offers based on in-service behavior, or by contacting us using the information in the “How To Contact Us” section below.
(c) To opt out of marketing communications we send you, at any time.You can exercise this right by clicking on the “unsubscribe/opt out” link in the marketing communications we send you or by contacting us using the information in the “How To Contact Us” section below.
(d) If we are processing your personal information with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted pursuant to lawful processing grounds other than consent. You may do so by contacting us using the details at “How To Contact Us” heading below.
(e) You have the right to file a complaint with a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
We will respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
11. AGE LIMIT
When we collect personal information we do not know the age of our customers. If a customer has a Facebook account and has logged into our service via Facebook, we obtain the age information from the user’s Facebook profile. If we discover we has inadvertently gathered personal information from a minor under 13 years of age, we will take reasonable measures to promptly delete such personal information from our records.
12. UPDATES TO THIS PRIVACY NOTICE
We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, in accordance with the significance of the changes we make.
13. HOW TO CONTACT US
Data controller: M33, Mezannine Floor, Siddiq Trade Center, Main Gulberg, Lahore, PK. Email Address.
You can exercise your right to access personal information, request the deletion of personal information or opt out of personalized offers directly in our Games, Mobile Applications or any other (Service)s
To do so,
Method 1 (quick and recommended)
- open the Settings/Account, and
- tap the “DELETE YOUR DATA”
- (optional: after providing the relevant account information) we start the process to delete your data
Method 2 (need patience and verification of Authenticity)
- you can email us at email@example.com your account information and our support staff will guide/help you through the process to Delete your DATA after verification. This method needs take extra patience and verification so that not any unnecessary data got deleted by accident
This is our preferred contact method, as we can more accurately validate a request received directly from a device and application.
Please note that other third parties (our data partners) may be data controllers of your information. More information regarding the third parties we work can be found in the Third party data controllers and processors section below
14. Third party data controllers and processors
|DATA PARTNERS (DATA CONTROLLERS)|
|Nitroxis DATA PROCESSORS|
|Google Analytics||Analytics for websites|