NovaSonic Games PTE Ltd (“NS”) is committed to protecting the privacy rights of its online users (“You” or “Users”). This Privacy and Cookie Policy is designed to inform You about the methods NS employs to collect, store, use, and manage the information You provide when interacting with any of NS’s games or applications (“Services”).

As the data controller, NS operates in compliance with the General Data Protection Regulation (“GDPR”) established by the European Union (“EU”). For any inquiries regarding privacy, please contact our Data Protection Officer at: privacy@novasonicgames.com.

1. Information Collected and Used

The primary objective of NS in collecting your information is to improve and operate our Services and software, enhancing your experience and facilitating seamless navigation and enjoyment of the Services. The types of information we collect depend on the specific Services you use and how you interact with them.

1.1 Personal Information Provided by You

Personal data submitted by you is essential for fulfilling our agreements, verifying identity, completing transactions, enforcing licensing agreements, and responding to your inquiries. We collect personal information when you engage with our Services, including actions such as registering an account, making purchases through the Services, submitting or selling assets, content, or games, requesting technical support, downloading, registering, or installing any software, or posting content via the Services.

The personal data we collect includes:

• Your NS account details;
• Username, email address, country, and password;
• Security questions along with their answers;
• Information provided when you seek assistance, including your name and records of issues encountered;
• Details shared when entering contests or sweepstakes. For winners, we may require a postal address and/or national identification for eligibility verification, prize delivery, and tax purposes.

Please note that purchases of virtual goods available through the Services are managed by third parties, and therefore NS does not have access to your payment or billing information.

1.2 Information Provided by Third Parties

When you register for our products through third-party platforms, you consent to share your account information from those platforms, allowing us to create an NS Account on your behalf. An NS Account is essential for accessing NS products on these platforms. We may receive personal information from these third parties that you have provided, such as your name, email address, online ID, country, etc. However, we do not obtain your credit card number or other financial information.

These third-party platforms include, but are not limited to:

• PlayStation®4 & PlayStation®5
• Nintendo Switch™
• Facebook
• Google Play
• iOS App Store
• Other app/game stores provided by third parties on mobile devices or PCs

1.3 Additional Information Collected While Using Our Services

While you interact with our products, we automatically gather other information, which includes:

• Identifiers for mobile and other hardware or devices
• Browser details, such as your browser type and language preferences
• Entry and exit pages, including login pages and visited pages
• Type of platform used
• Your IP address
• Information regarding the Services you utilize and how you use them
• Device event details, such as crash reports, requested and recommended URLs, and system activity logs
• Error events that occur during your gameplay
• Your purchases of virtual products or other commercial activities
• Progression events to track your advancement or movements within the game
• Resource parameters concerning virtual currencies in games that you earn or spend
• Data about your media, device, hardware, and software, including hardware settings, accessories, and the software and updates you have installed or utilized, as well as the presence of necessary plugins
• Design events that monitor your in-game behavior, which can pertain to various design elements of the game, including but not limited to level or character appearances, bonuses, social interactions, etc.
• Custom fields encompassing any game parameters specified by you

NS may aggregate and/or analyze your in-game data to enhance our Services as a whole. We want to clarify that we will never make decisions based on this analysis that have legal repercussions for you or similarly significant effects. Our sole intention is to improve your user experience and thereby elevate the quality of our Services.

If you wish to stop the collection or processing of your personal data, you can request that we cease these activities at any time. Section 7 outlines the specific indications and measures related to this policy.

2. Information Sharing and Disclosure

NS does not disclose personal information that directly identifies you to unaffiliated third parties unless necessary to provide the products or Services you have requested, where NS has obtained your consent, or in the following cases:

• To comply with legal obligations;
• To enforce applicable Terms of Service, including investigating potential violations;
• To detect, prevent, or address fraud, security issues, or technical problems;
• To protect the rights, property, or safety of NS, users, or the public as required or permitted by law;
• When essential for delivering the Services you require.

If we engage a third party to deliver part of the Services you have requested or to assist in analyzing our Services or the information collected about you (subject to your consent), NS may share your information with that third party, or the third party may collect information from you on our behalf. When third-party agents or service providers receive or collect your personal information, we require them to use it solely for purposes consistent with this policy and under appropriate standards.

Additionally, we may disclose information about you to third parties in connection with corporate restructuring activities, including mergers, amalgamations, or the sale of all or substantially all of our assets. Where required by law, we will seek your consent before proceeding with these actions.

Furthermore, we may encrypt, aggregate, and/or anonymize the information collected from you or through other sources so that it no longer identifies you. Our use and disclosure of aggregated, anonymized, or otherwise non-identifiable information are not restricted by this Privacy and Cookie Policy. We may share this data without limitation for any purpose, including with game developers, advertisers, publishers, business partners, sponsors, and other third parties.

3. Data Security and Retention

NS has implemented appropriate technical and organizational measures to protect your personal information from accidental loss, unauthorized access, misuse, alteration, or disclosure. However, NS cannot guarantee that these security measures are entirely failproof, nor are we liable for any disclosure of your personal information resulting from your own actions, such as publicly sharing information or improper use of our Services.

We will retain your information and data only as long as necessary to fulfill our agreement with you or as legally required, such as for resolving disputes, enforcing our Terms of Service or other user agreements, or complying with legal obligations. In these instances, your personal information will be restricted from further use for any other purposes.

4. Cookies

A cookie is a small data file that NS transfers to your mobile device or computer’s hard drive for record-keeping purposes. It primarily serves to quickly recognize a user’s device and retain details about the user’s visit. Cookies are sent to your device from our server when you access or view content from an NS game. The information stored in a cookie may be linked to your personal information to improve the quality of our Services, provide personalized recommendations based on your interests, and enhance the overall usability of the Services.

You can disable cookies at any time; however, doing so may limit your access to certain features or functionalities of the Services. NS collaborates with third parties that provide analytics and marketing services, and to enhance your experience with our Services, we may allow these third parties to place cookies on your browser to collect information about your usage. Please note that our cookie policy does not govern the use of cookies or similar technologies placed on your devices by non-affiliated third-party advertising technologies, ad servers, or ad networks.

Session cookies are deleted from your device when you close your browser. You can adjust your browser settings to refuse cookies or to notify you before accepting cookies from websites, which can be done via your browser’s options menu.

5. Policy Regarding Minors

NS acknowledges a responsibility to protect personal information collected from young children. Our Services are intended for general audiences, and NS does not knowingly collect any personal data from minors. When users identify themselves as children (i.e., under the age of 16 or below the minimum age as defined by applicable laws in their region), we will seek parental consent for the collection, use, and sharing of their children’s personal information as required by law. The information collected will be protected according to this Privacy and Cookie Policy.

In the event of significant changes to our practices concerning the collection, use, or sharing of children’s personal information, we will notify parents by email to obtain verifiable parental consent for the new purposes of their child’s information.

If you are a parent or guardian and discover that your child has provided us with information without your consent, or if you wish to withdraw consent, review the information collected, or request its deletion, please contact us at privacy@novasonicgames.com. NS recognizes the importance of protecting children’s privacy and encourages parents to monitor their child’s online activities actively.

6. International Transfer

For the purposes outlined in this policy, your information may be transferred or transmitted to countries outside of your jurisdiction for storage and processing. These data transfers are necessary to provide the Services described herein. If your personal data is transferred to a country that does not provide a comparable or adequate level of protection in line with your country’s laws, we will ensure your personal information remains subject to the protections specified in this policy.

We will use standard contractual clauses, binding corporate rules, or other legal mechanisms to implement adequate safeguards, ensuring that your personal data is protected as per this Privacy and Cookie Policy.

7. Deleting Your Information

In accordance with GDPR standards, you are entitled to various rights as a data subject, including the right to:

• Request a digital copy of your personal data, either for yourself or a designated third party.
• Request access to and correction of your personal data.
• Inquire about the ways in which we utilize your personal data.
• Request a restriction on or object to the processing of your personal data.
• Request the deletion of your personal data if NS is not legally obligated to retain it.
• Exercise any other rights permitted by applicable data protection laws.

These rights granted under GDPR are available to you even if you do not reside in the EU while interacting with NS. If you wish to exercise any of these rights, please contact NS at privacy@novasonicgames.com. Please note that if your personal data is erased or transferred to a third party, your account may be deactivated. Your personal data may be collected, processed, and stored at any of our operational facilities. Regardless of where your data is collected, we will implement the necessary safeguards to protect your privacy as outlined in Sections 1 and 8 of this policy. If you do not agree with our practices regarding the collection, processing, storage, and transfer of your personal data, please refrain from providing it when requested and discontinue your use of the Services.

8. Power of Consent

You maintain the right to decide whether to provide us with your personal information and whether this information may be shared. Generally, we only request the personal data necessary to deliver the specific Service you have requested. You may grant consent for our data collection or withdraw it at any time. If you choose to withdraw your consent, please contact us at privacy@novasonicgames.com. However, withdrawing consent will not affect the processing of your data that was collected prior to the withdrawal. In certain circumstances, withdrawing consent or opting not to share your information may limit our ability to provide specific Services.

Contact Us

If you have any concerns or questions regarding this Privacy and Cookie Policy, please reach out to us via email at privacy@novasonicgames.com.