Privacy Policy

Nuromedia GmbH Privacy and Cookie Policy for End Users

The privacy and security of your personal data is of high importance to Nuromedia GmbH (“nuromedia”). The following privacy and security policy outlines what personal data nuromedia collects and how it is used, when you use downloadable, online as well as mobile services and products offered by nuromedia or visit any live events organized by or in connection with nuromedia.

1. Contact Us

If you would like to contact us to exercise your rights or in case you have any questions or suggestions about this information, please contact us via: info@nuromedia.com.

The controller of the personal data processed under this policy is Nuromedia GmbH, Schaafenstraße 25, 50676 Cologne, Germany.

2. Data collected by Nuromedia

Depending on which products are used and how they are used, the data we collect from you can vary.

a) Data directly given to us by you

Data that is directly provided by you to us includes:

• Security questions and their answers
• Payment information such as your card number and the billing address
• Your Nuromedia account information, which can include username, telephone number, email address, date of birth, password and country
• Details provided by you in surveys related to our products that you answer
• Data provided when requesting assistance from us such as your telephone number, email address, records of the problems you encountered and your name

Taking part in online multiplayer games will lead to your gameplay, statistics and in-game profile being visible to all. Participating in competitive game modes may lead to us recording your controller inputs and gameplay. The resulting footage could be replayed to other players at any live event involving nuromedia including your game statistics and in-game profile. Please be aware that your privacy settings should be based on your preferences. The information that you disclose when resorting to the use of social applications (e.g. chat) could become publicly available. Moreover, it could be collected, copied, read or used in another form by other users.

b) Additional data collected during the use of our products

Other information is collected automatically by Nuromedia when you use our products, which includes:

• Type of platform
• Referring and exit pages, which incorporates landing pages and pages viewed
• IP address
• Information on device events such as crash reports, referral and request URL’s and details on your system activity (e.g. error reports while playing the game)
• Information on your browser such as browser language and type
• Hardware or device identifiers
• Information on which Nuromedia products you use and your use of them
• Details about your software, device and hardware including Nuromedia software and updates installed and used by you, and the presence of plug ins required, as well as your hardware settings and components

In some cases we might collect and store data on your device locally, resorting to mechanisms such as application data caches, browser web storage (incl. HTML 5) and cookies.

c) Data provided to us by third parties

1. Wii / Wii U: By signing up to use our products on a Nintendo Wii or Wii U console, you agree that your Nintendo user account data may be provided to nuromedia by Nintendo in order for us to establish a nuromedia account for you. Some of our products will require you to use a nuromedia account if you play online. We receive information such as your email address, your country, date of birth, your Nintendo Network ID, language, friend list and your Mii information from Nintendo. However, we do not receive financial information such as your credit card number.
2. Nintendo Switch™:By signing up to use our products on a Nintendo Switch™ console, you agree that your Nintendo user account data may be provided to nuromedia by Nintendo in order for us to establish a nuromedia account for you. To play our products online you will need a nuromedia account. We receive information such as your email address, your country, date of birth, your nickname, language and your friend list from Nintendo. However, we do not receive financial information such as your credit card number.
3. PlayStation®3 & PlayStation®4 Computer Entertainment Systems: By signing up to use our products on a PlayStation®3 or PlayStation®4 computer entertainment system, you agree that your Sony Entertainment Network account data will be provided to nuromedia in order for us to establish a nuromedia account for you. Some of our products will require you to use a nuromedia account if you play online. We receive information such as your email address, your country, your name, language, state or province, date of birth and Online ID from Sony. However, we do not receive financial information such as your credit card number.
4. Xbox Live:By signing up to use our products on Microsoft’s Xbox Live Service, you agree that your Microsoft user account data may be provided to nuromedia by Microsoft in order for us to establish a nuromedia account for you. Some of our products will require you to use a nuromedia account if you play online. We receive information such as your email address, your country, age, language, state or province and Gamertag from Microsoft. However, we do not receive financial information such as your credit card number.
5. Mobile platforms: We receive data about you from the app stores and other mobile platform providers, if you purchase or use our applications on your tablet and/or mobile device. This data, for example, contains the information that you made a purchase, your device ID and/or your username, but it does not contain any financial or otherwise sensitive information. Also, some of our mobile platforms might provide us with data that you authorized them to provide. Further, our mobile products might ask for more personal information from you, such as your contact list or precise location and push notification tokens. This information will only be collected if you explicitly agree to our request.
6. Facebook Connect:We also offer you the option of easier registration for our games and services through Facebook. You can use your existing Facebook user account for this purpose. By clicking the “Log in with Facebook” link, you can use this registration method via our online portal. To do this, you need to already have a Facebook account or have access to Facebook.
   If you would like to register for one of our services using your Facebook account, the first step in the registration process will immediately redirect you to Facebook. Facebook will then ask you to log in or to register. Under no circumstances will we receive your personal access data (user name and password).
   In a second step, you will connect your Facebook profile with the service for which you would like to register. At this point, you will be told what data from your Facebook profile will be transmitted to us. This information is usually your “public information” on Facebook and information which you have made available to the public or authorized for the application in question. Information of this type generally includes your name, profile picture and cover photo, your gender, your networks, your username (Facebook URL), and your user ID number (Facebook ID). We will also use the email address you have saved with Facebook in order to contact you outside of Facebook. You can see an overview of information in your profile that is available to the public via the General Account Settings menu of your Facebook profile (https://www.facebook.com/settings?tab=applications).
   The legal basis for data collection and storage is your consent, within the meaning of Art. 6 paragraph 1 sentence 1 letter a GDPR. If you would like to remove the connection between Facebook Connect and our service, please log in to Facebook and make the required changes to your profile. We will then no longer have the right to use information from your Facebook profile.
7. Other third parties: We may use data from third parties, for example, to better identify your approximate location via your IP address in order to customise some of our offerings to your location, or for tax purposes, and for the purpose of preventing abuse and/or fraud. Further, third parties such as may provide us with data, in case you use these services in connection with our products. When other players decide to share their contact list with nuromedia, we may also receive data about you. In addition, we may also receive data from third parties to supplement the data we received from you. Data from these companies is used to optimise the advertising delivered to you in order to ensure that it is of relevance to you. An overview of these third parties can be found on privacyappendix.nuromedia.com.

d) Legal grounds for data processing

We resort to a number of legal grounds to process data about you, if you are a resident belonging to the European Union. For instance, we will process data concerning you, where you agreed to us doing so (Art. 6(1)(a) of EU General Data Protection Regulation [GDPR]), where we have a legal obligation to do so (Art. 6(1)(c) GDPR), where the processing is necessary to fulfill the requirements of a contract with you (Art. 6(1)(b) GDPR) and where we have a justified interest to do so (Art. 6(1)(f)). For instance, we resort to our justified interest in serving targeted marketing and on the necessity resulting from our contract to process data if you create a nuromedia account. If you want to receive additional information on the legal grounds on which we resort to in order to process your data for different purposes, please contact us.

3. Methods of collecting data used by Nuromedia

We collect data from you when you provide the latter directly, e.g. when you fill out an online form. Additionally, we and third parties working with us, also apply some technologies outlined below to gather data in order to offer you an excellent service experience. The different methods how we collect data, directly or indirectly, are explained in the following.

a) Job Application

You can apply for a job with us through our website in the “career” section. To this end, we collect personal contact data from you, which specifically includes your name, your CV, your cover letter and other content provided by you.

Your personal application data will only be collected, stored, processed and used for purposes in connection with your interest in current or future employment with us and the actual processing of your application. Your online application will only be processed and handled by the relevant contact people in our company. All employees entrusted with data processing are obliged to maintain the confidentiality of your data.

The legal basis for this data collection is Section 26 BDSG 2018.

b) Cookies

Cookies can be described as small text files, which are stored on your internet browser. Nuromedia applies cookies and similar technologies to better understand what web pages, ads or features you view and which games you play. We use this information to improve your user experience, e.g. by keeping track of your purchases and measure the efficiency of our advertising, thereby trying to prevent that you are confronted with the same ads repeatedly. You can set your browser instructions to notify you in case cookies are sent, disable cookies or introduce limitations to the type of cookies that you permit. In order to gain a better understanding of how to manage your cookie preferences, we recommend you to refer to guidance by the web browser you use. Furthermore, we resort to other technologies for similar purposes as a cookie. We apply, amongst other tools, tracking pixels or clear GIFs to collect data concerning your use of nuromedia’s products and your response to our emails. Moreover, we resort to Internet log files to gain a better understanding of the traffic on our products, identify and prevent fraud, enforce our User Agreement and solve technical problems. Further, we also use device fingerprints, “flash cookies”, Silverlight Application Storage and HTML 5 cookies. By changing your preferences in the Macromedia Website Privacy Settings Panel at www.macromedia.com/support/documentation/en/flashplayer/help/, you can delete flash cookies or stop them from being placed. As of now, we do not respond to Do Not Track (DNT) signals but we might do so if a DNT standard is established. In the meantime, you can disable certain types of tracking such as tailored advertising by adjusting your cookie settings.

c) Use of Analytical Technologies

Nuromedia uses its own game servers and internal and third party analytical tools to collect data about how you use your computer or device, our product and about the health of our products. For example, nuromedia may store and collect information from your device or computer when you use its products. This data consists of technical and related information regarding your computer or device and the respective operating system (e.g. IP address and device ID), gameplay and usage statistics, data on your feature usage, system interactions and peripheral hardware. Playing a game offline will lead to the data being stored on your device, whereat it will be transmitted to nuromedia once your device has an Internet connection again. If you take part in online services, nuromedia may also collect, store, use, publicly display and transmit your statistical data and/or persona concerning your game play (e.g. accomplishments, scores and rankings), or identify content created and shared by you with other players. Further, third party analytical tools used by our products may combine information collected in the scope of nuromedia’s services with data they have independently collected over time from different sources. These companies mostly collect and use data in accordance to their own privacy and security policies. A list of third party analytical companies operating in our products and how to evade the extent applicable can be found at privacyappendix.nuromedia.com.

d) Technologies used for Ads

Some of our products resort to ad serving technologies which employ clear GIFs, tracking pixels, cookies, web beacons and other similar technologies such as identifiers to propose offers to you. These technologies can connect or synchronize behavior across devices, different websites and mobile apps in some cases. Further, the ads can also be customized to meet your interests, e.g. you may be offered a game we think you would like or if you have shown interest in a certain game, you may be shown advertisements for that game or similar products on nuromedia or third party sites. Through other in-game advertising technologies, advertising can temporarily be uploaded to your web browser, game or mobile device and later substituted while you are online. These technologies collect and use data in order for us to show suitable ads to you and track results as well as measure effectiveness. Apart from identifiers, there is information including:

• domain type, size of the advertisement and IP address
• advertisement served and the location of the ad
• advertisement response
• length of time an ad was visible

Third party advertising companies may combine data they have independently collected across different websites over time with the information collected while delivering an ad to you via our products. These companies mostly collect and use data resorting to their own privacy and security policies. A list of ad companies operating their own networks on our online and/or mobile products and/or services and on our sites and how to evade them to the extent applicable can be found at privacyappendix.nuromedia.com. In order to gain more insight concerning some of these ad networks’ methods, or to evade third party targeted advertising, you can visit www.networkadvertising.org, www.aboutads.info/choices, youradchoices.ca, or www.youronlinechoices.eu. Evading these ads does not mean that you will not see any ads; it just means that they will not be tailored to your preferences anymore.

e) Fraud and Anti-Cheat Prevention Technologies

Nuromedia aims to provide a fair and safe gaming experience to all of our players. In order to prevent fraud and for security and authentication purposes, we or third parties may apply cookies and similar technologies or collect information regarding your device or machine to create a machine “fingerprint” or “hash” of your machine components, when you log in to one of our products, make purchases or create a nuromedia account. Further, we also may apply anti-cheat technology in our products such as automated abuse and anti-fraud algorithms. In case you believe that your access to our products and/or services was blocked without justification, please contact nuromedia at info@nuromedia.com.

4. Storage Location of Your Information

Personal data we collect may be stored and processed for the purposes outlined in this policy in Germany or any other country in which nuromedia, its subsidiaries or third party agents operate. Third parties are certified under the Privacy Shield Agreement and thus guarantee compliance with European data protection legislation (https://www.privacyshield.gov). By using our products, you acknowledge that your personal data may be transmitted to recipients in the United States and other countries that may not have the same level of privacy protection in place as it is the case for the laws in your country of residence or citizenship.

5. Usage of your data

We use your non-personal and personal data, both individually and combined together in the following ways:

To enhance and personalize your gaming experience and operate our business including to:

• Provide you with personalized recommendations for Nuromedia products and/or features
• Help you find your friends and tell your friends about a Nuromedia product
• Measure the health of our services
• Provide software updates
• Help keep our services fair and safe, investigate and help curb fraud and illegal behavior, to enforce our agreements and policies, resolve disputes and comply with the law
• Authenticate or activate your games and save stats and game progress
• Facilitate your gameplay on multiple devices when available
• Facilitate sharing on social networks
• Populate leaderboards online and enable online matchmaking
• Develop, operate and improve our games and services
• Provide replays to other players and you using spectator modes
• Identify, fix and troubleshoot service errors and bugs
• Deliver dynamic content and adhere to your preferences
• Set up loyalty programs
• Set up and maintain accounts you register for
• Provide game experiences that may be to your liking
• Serve and measure the effectiveness of advertising

To provide you support, including to:

• Survey your opinions through surveys or questionnaires
• Manage and send you important information and confirmations about your account, purchases, products, warranties and subscriptions
• Respond to your specific questions or requests and communicate with you
• Help identify and troubleshoot problems related to your account or games

To personalize our communications with you, including to:

• Customize advertising for you and deliver targeted marketing, promotional offers and service updates
• Make recommendations to you
• Provide information and/or offers related to games you might like

We keep the data we collect for as long as necessary to provide our services and products and we keep the information beyond this period if necessary for operational, legal or other legitimate reasons.

6. Protection of Personal Information

The security of players’ information is of great importance to Nuromedia and we resort to different actions to protect their data. However, no security measure is completely perfect. Consequently, we cannot vouch for the security of your information and thus do not assume any responsibility for unauthorized access or use to your information under our control.

7. Data Shared with Third Parties

We do not share any personal data that directly identifies you (e.g. postal address, e-mail, your name) with third parties for their own us without your consent. Exceptions are if we determine that disclosure is reasonably necessary to enforce our rights, operations or property or there is a requirement by law or to protect our players or third parties. We may share anonymous or aggregated information or other information, which cannot be used to directly identify you, with third parties, for example, your game stats on leaderboards, your persona or to show trends about the usage of our products.

To collect and process personal information on our behalf for different reasons, such as facilitating credit card processing, sending emails or conducting market surveys, we employ third parties in and outside of your country of residence (including outside of the European Union). In case third party agents or service providers collect or receive personal data, we require them to use the information exclusively on our behalf and for purposes consistent with this policy. Further, we do not knowingly disclose personal data concerning children under 18 years of age to independent third parties, even with a consent. Nevertheless, in case of a divestiture merger, sale, bankruptcy or reorganisation, we might transmit all information we collect to the respective third party, while obtaining your consent to do so, if required by law. Moreover, we do not control information sent from your browser to third parties such as analytics companies and advertising networks that receive data in the course of your normal Internet usage. When third party social tools or technologies are part of our products, the responsible third parties may collect data when you use our products. For instance, the Facebook “Like” button.

8. Services of Third Parties

Our products and websites may contain services of third parties or advertising such as links to third party websites or the Facebook Like button. You will leave the nuromedia website and go to the site you selected, if you click on one of those links, including advertisement. In case you use a third party service or go to a third party website, you should be aware of that service’s or site’s privacy policy.

9. Privacy of Children

It is of utmost importance to Nuromedia to protect children’s privacy online. By children we mean individuals under the age of 13 or the minimum age in the respective territory if that age is older than 13. Many nuromedia mobile or online services and products are designed for general audiences and do not knowingly collect any personal data from children. When users identify themselves as being children, we will: (1) collect certain information for limited purposes only, (2) block or restrict the child from accessing relevant services such as chat functionality, (3) not provide a path for them to input personal information; and/or (4) obtain consent from their parents for the use of their children’s personal data, all according to applicable law. Using our mobile applications your child will be able to receive in-app notifications, which do not collect any personal data.

Please be aware that if you give consent for your child to use Nuromedia’s mobile or online services and products, this may include general audience communication services such as instant messaging, online groups and email, where your child will be able to communicate with and disclose personal information to other users of all ages. If as a parent you wish to revoke a previously provided consent, review information collected from your child or have this information deleted, contact the appropriate Privacy Policy Administrator at nuromedia GmbH, Schaafenstraße 25, 50676 Cologne, Germany or via info@nuromedia.com.

Collected information is processed and stored in a manner consistent with this Privacy and Cookie Policy. We will notify parents by in-game notice or by email to receive verifiable consent from them, if we make changes to how we collect, use or share their child’s personal data. Nevertheless, we encourage parents to talk with their children about disclosing personal information online and communicating with strangers.

Under no circumstances do we condition a child’s participation in activities such as contests on its disclosure of more personal data than is necessary to take part in the activities. We may not grant children the permission to participate at all on certain sites regardless of consent.

10. User Choices and Control

We provide you with meaningful choices concerning important uses and collection of information. For instance, you can decide to opt in or out of nuromedia marketing emails, choose whether your information is shared with selected partners of nuromedia and update your preferences and account information. If you choose to opt out any time after you have given your consent, contact the appropriate Privacy Policy Administrator at nuromedia GmbH, Schaafenstraße 25, 50676 Cologne, Germany or via info@nuromedia.com.

Most of your preferences can be reviewed and modified using your Nuromedia account settings. In those cases where we need a consent to collect and use data concerning you, this consent can be withdrawn any time by you. You can delete personal data associated with your nuromedia account or deactivate your nuromedia account. By doing so, you will lose access to nuromedia services or games associated with your account. Be aware that nuromedia may keep data needed to enforce our user agreements, comply with legal and technical requirements, resolve disputes, protect our legal rights and comply with constraints related to security, operation and integrity of our products. In any other case, we will keep your personal data for as long as reasonably necessary to create and improve our products, run our business, provide you services and comply with the law.

You can access the personal data we hold about you. Please contact help.nuromedia.com to request access. In order to verify your identity, we may ask for certain personal information before we process any request. Under local law you may have additional rights such as the right to restrict or object to processing of information and the right to request portability or erasure of personal data. You can exercise these rights by contacting help.nuromedia.com, where applicable.

If you want to block certain online tracking such as cookies, you may modify your browser settings.

11. Changes to our Policy

Please review this policy frequently since we may change this policy from time to time. In case applicable data protection laws require us to notify you in an enhanced matter or request your consent to any such changes, we will do so. To see when this policy was last updated, please refer to the “last updated” date displayed at the top of this policy.

12. Contact a Data Protection Authority

Please contact us, if you are concerned with the way we collect and use data. If you prefer, you also are entitled to contact your local Data Protection Authority . The contact details for these Authorities in the EU can be found at ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.