Naruto Online
Privacy Policy
Last Updated: June 10, 2026
Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.
Here is a summary of the information contained in this privacy policy (“Privacy Policy”). This summary is to help you navigate the Privacy Policy and it is not a substitute for reading everything! You can use the hyperlinks below to jump directly to particular sections.
What information do we need to provide the Game?
If you register an account to use Naruto Online (“Game”) then we will need some information from you to set this up. If you choose to set up your profile using a social media account, we also collect information, including contact details, gender and birth date, from that social media account. If you choose, you can provide certain other information to personalise the gaming experience and enable Game features. If you need to get in touch with us then we will also retain some information so that we can get back in touch with you and address any concerns.
What information do we collect about you?
We collect information when you set up your account for the Game. If you choose to set up your Game profile using a social media account, we will collect your information from that social media account such as your Facebook ID and your Mars user ID in order to set up your account.
How will we use your information?
We use your information to provide the many functions and services that comprise the Game. We also use your information for account verification, security purposes and to support and improve the Game. We do not share your information with any third parties, except where we need to in order to provide the Game (e.g., use local cloud providers or to back up your data; use our affiliates around the world to help us to deliver the Game) or we are instructed to by a court, authority or compelled by law.
Who do we share your information with?
We use some third parties for support services, such as game servers and support ticketing. When we use a third party, we only do this to process or store your information for the purposes described in this Privacy Policy. We also have affiliates around the world who help us deliver the Game and we may be required by a court or legal obligation to disclose certain information in some circumstances.
Where do we process your information?
Our servers are located in Germany, Singapore, United States and the Netherlands. Your information can be accessed from outside of where you live by our support, engineering and other teams around the world, including the People’s Republic of China (for this purpose excludes Hong Kong SAR, Macau SAR and Taiwan) (“PRC”).
How long do we keep hold of your information?
We generally retain your information for the Game for the period during which you maintain an account, after which time your data is deleted (as further described in this Privacy Policy), unless otherwise required by applicable laws. We delete certain information earlier at your request, and in accordance with local law.
How can I exercise my rights over my information?
Depending on where you are, you may have certain rights with respect to your information, such as rights of access, to receive a copy of your information, to delete your data or restrict or object to our processing of, your data.
How to get in touch with us
If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, please contact us as set out in Section 10 (Contact).
How will we notify you of changes?
If there are any significant changes to this Privacy Policy, we will notify you within the Game.
Contact Information
Joint Data Controllers: Mars Era (HK) Limited | Email: gdpr@mars.games
Proxima Beta Pte. Limited | Contact: as set out in Section 10 (Contact)
EU Representative:
For Mars Era (HK) Limited: IMI Entertainment GmbH | Email: gdpr@mars.games
For Proxima Beta Pte. Limited: Proxima Beta Europe B.V. | Contact: as set out in Section 10 (Contact)
Turkey Representative:
For Proxima Beta Pte. Limited: Özdağıstanli Ekici Avukatlık Ortaklığı. Email: turkeydatarep_proximabeta@iptech-legal.com
INTRODUCTION
Welcome to Naruto Online!
This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with the Game, and sets out your choices and rights in relation to that information. Please read it carefully - it is important for you to understand how we collect and use your information, and how you can control it.
Please note that this Privacy Policy only applies to the Game. If you use any other products or services please refer to the privacy policy for that particular product or service.
When you contract to use the Game, you accept our rules and policies regarding your personal information and you expressly consent to us collecting, processing, using and storing your personal information, as described in this Privacy Policy.
If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop using the Game. By using the Game you are acknowledging how we process your personal information as described in this Privacy Policy.
Mars Era (HK) Limited (“Mars”) is a company registered in Hong Kong with its office located at
Room 07 on 7th Floor New East Sun Industrial Building No.18 Shing Yip Street Kwun Tong Kowloon Hong Kong. Mars can be contacted at gdpr@mars.games. The representative of Mars in the EU for the purpose of EU data protection laws is IMI Entertainment GmbH, a company registered in Austria. Their registered address is Wiedner Hauptstrasse 51/2/15, A-1040, Vienna, Austria and can be contacted at gdpr@mars.games. Mars’ data protection officer can be contacted at gdpr@mars.games.
Proxima Beta Pte. Limited (“Proxima Beta”) is a company registered in Singapore with its office located at 79 Robinson Road, #07-01, Singapore (068897). The representative of Proxima Beta in the EU for the purpose of EU data protection laws is Proxima Beta Europe B.V., a company registered in the Netherlands. Their registered address is Buitenveldertselaan 1-5, 1082 VA, Amsterdam, the Netherlands and can be contacted as set out in Section 10 (Contact). Proxima Beta’s data protection officer can be contacted as set out in Section 10 (Contact).
For the purpose of data protection laws, Mars and Proxima Beta (collectively, “we”, “us” or “our”) are (except where otherwise stated in this Privacy Policy) joint data controllers. This means we jointly determine the means and purposes of processing personal data collected in connection with the operation of the Game.
If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, you should at first instance contact Mars at: gdpr@mars.games. You can reach us using our online form here to submit Data Subject Rights requests and any questions or concerns related to data privacy. This form also allows you to contact our Data Protection Officer regarding your privacy-related inquiries.
1. The Types of Personal Information We Use
This section describes the different types of personal information we collect and how we collect it. The following is a high level summary of the types of personal information we use:
· Information you give us. You give us information about you:
o when you register for the Game (including, if you log in via social media, your Facebook ID and your Mars user ID in order to set up your profile); and
o when you set up your profile for the Game (including information you voluntarily elect to provide in order to populate your profile).
· Information we collect about you. We automatically collect certain data from you when you use the Game, including your IP address and device information (such as browser type and version information), information regarding your use of the Game, such as date and time stamps of actions, and transaction records if you make in-Game payments. We also collect and store your data each time you interact with us, for example, when you use in-app support to communicate with us.
· Information you generate and display in the course of using the Game. You may provide or generate information when you communicate with other users in the Game (e.g., chat log data, chat content).
2. Cookies
We use cookies and other similar technologies (“Cookies”) to enhance your experience using the Game. Cookies are small files which, when placed on your device, enable us to provide certain features and functionalities.
For more information about our Cookies Policy, click here.
3. Children
Children must not use the Game for any purpose, except where their parent or guardian has provided lawful consent (to the extent this option is available in your jurisdiction). By children, we mean users under the age of 18 years old; or in the case of a jurisdiction where the minimum age for processing personal information differs, such different the minimum age. For users located in certain jurisdictions, we have listed the relevant minimum age in the table below. You should in any case refer to the laws in the relevant jurisdiction to ensure you or the user (as applicable) are above the relevant minimum age.
Jurisdiction in which the user is located | Minimum age of the user |
Algeria | 19 |
Australia | 18 |
Bangladesh | 18 |
Brazil | 18 |
Cambodia | 18 |
Chinese Taipei | 20 |
Egypt | 18 |
European Economic Area | 16 |
Hong Kong | 18 |
Indonesia | 21 |
Japan | 18 |
Kingdom of Saudi Arabia | 18 |
Kuwait | 21 |
Macau | 18 |
Malaysia | 18 |
Mexico | 18 |
Morocco | 18 |
Myanmar | 18 |
Philippines | 18 |
Qatar | 18 |
Serbia | 15 |
Singapore | 13 |
South Africa | 18 |
Sri Lanka | 18 |
Switzerland | 14 |
Tunisia | 18 |
Turkey | 18 |
United Arab Emirates | 21 |
United Kingdom | 13 |
United States | 13 |
Vietnam | 16 |
Other than as provided above, we do not knowingly collect personal information from children under these ages for any purpose. If you believe that we have personal information of a child under these ages without lawful consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us at gdpr@mars.games or as set out in Section 10 (Contact).
4. How We Process Your Personal Information
This section provides more detail on the types of personal information we collect from you, and why. For users who live in the United Kingdom, the European Economic Area, Switzerland, or Turkey (“Relevant Jurisdiction”), it also identifies the legal basis under which we process your data.
Personal Information | Use | Legal Basis for Processing (where applicable) |
Information you provide to us (either directly or through a third party) | ||
Log-in information: · Mars user ID · Facebook ID (if using Facebook login)
| We use this information to: · create your account for the Game in accordance with your request; and · store your Game data (including level and progress) with your profile. | Necessary to perform our contract with you to provide the Game. |
Region Location (manually selected by you) | We use this information to determine your statutory rights under applicable data protection laws. | Necessary to perform our contract with you to provide the Game. |
Game Data – Open ID, game play statistics (Level, Properties, Score/s) | We use this information to provide you with feedback and information about your gameplay and progress. | Necessary to perform our contract with you to provide the Game. |
Chat Data (Open ID, chat content (text, emoticons), time stamp) – users are able to enter free text and emoticons using the chat function. | We facilitate the posting of your communications with other users. | Necessary to perform our contract with you to provide the Game where you seek to use chat services. |
Device Information (Browser type and version information) | We use this information: · to improve our services, including the functionality of the Game; · for security and verification purposes; · identify and address bugs and assess game function for optimisation; and · for game analytics purposes. | It is in our legitimate interest to ensure the security of our services, manage registrations and improve our services. |
Log Data (IP address, purchasing actions, game results (e.g., win or lose), in-game performance) | We use this information: · to maintain a record of log-in and actions of your account; and · for security and verification purposes. | Necessary to perform our contract with you to provide the Game and retain your record of progress. |
Transaction Records: payment data (Open ID, Order ID, currency, payment amount in chosen currency, game coin, time, IP address, source channel ID, device type) | We use this information to maintain a record of your transaction history. | Necessary to perform our contract with you to provide the Game, information about your in-game purchase history and to restore purchases of in-game items. |
Customer Support Ticket ID & User Communications with Support (User ID, ticket description, certain Log Data if necessary) | We use this information to: · improve our services; · provide troubleshooting, such as addressing and remediating technical issues and bugs. | Necessary to perform our contract with you to provide and support the Game. |
5. How We Store and Share Your Personal Information
Pursuant to our contract with you to provide you, we may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy. We have servers for the Game in:
· Germany;
· Singapore;
· United States; and
· Netherlands.
The services applicable to your use of the Game will depend on your location. We also have support, engineering and other teams who may support the Game, including the PRC.
Only where necessary will we share your personal information with third parties. Situations where this occur are:
· Third parties that provide services in support of the Game including: providers of cloud services that process information identified in this Privacy Policy on their servers for the purpose of providing the Game; and AWS, located in Japan, for the purpose of processing payments. All third party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Game (i.e., for the purpose(s) described above).
· Companies within our corporate group who process your personal information solely for the purpose of providing the Game to you. All such group companies may only use your personal information in accordance with this Privacy Policy.
· Regulators, jurisdictional authorities and law enforcement agencies. There are circumstances in which we may be legally required to disclose information about you, such as to comply with legal obligations or processes. In complying with the terms of valid legal processes, such as a subpoena, or search warrant, unfortunately we may not be able to seek your consent to or notify you in advance of such disclosure.
· Third parties to ensure safety, security, or compliance with laws. We may disclose your information to:
§ enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
§ detect, prevent or otherwise address security, fraud or technical issues; or
§ protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (such as exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
· A third party that acquires all or substantially all of us or our business. We may also disclose your information to a third party if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.
6. The Security of Your Personal Information
We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted through the Game or otherwise via the Internet; any transmission is at your own risk.
7. Data Retention
We do not keep your data for longer than is necessary to fulfil the relevant purpose described above unless we are required or permitted to do so under law. If we retain your information beyond the retention periods set out below, for example to comply with applicable laws, we will store it separately from other types of personal information.
For further details on how long we keep your data, please refer to the time periods set out below.
Personal Information | Retention Policy |
Log-in information Region Location (manually selected by you) Game Play Statistics (Level, Properties, Score/s) | Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then for 30 days. |
Chat Data | We do not store this information. Your data is transferred through our game servers transiently to facilitate exchange of chat data between players. |
Device Information | Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then for 30 days. |
Log Data | Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then for 30 days. |
Transaction Records | Stored for 1 year from transaction date. Upon receiving a request for account deletion, such data will be deleted within 30 days unless such data must be retained in order to comply with our legal obligations. |
Customer Support Ticket ID & User Communications with Support | Stored for 30 days from your operation log. Upon receiving a request for account deletion, such data will be deleted within 30 days. |
8. Your Rights
Some jurisdictions’ laws grant specific rights to users of the Game.
Please refer to the Supplemental Jurisdiction-Specific Terms, or the applicable laws in your jurisdiction, for an overview of specific rights that apply to persons subject to data protection laws in the listed jurisdictions and how these can be exercised.
You may have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). To exercise any of your rights, please contact us at gdpr@mars.games.
Access
You may have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your Game account. If you believe we hold any other personal information about you, please contact us at gdpr@mars.games.
Portability
You may have the right to receive a copy of certain personal information we process about you. For example, in certain jurisdictions, this can comprise personal information we process on the basis of your consent or our contract with you (e.g., game play statistics), as described in the section “How We Use Your Personal Information”. We will provide further information to you about transferring this data if you make such a request.
Correction
You may have the right to correct personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your Game account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at gdpr@mars.games.
Erasure
You may be able to delete your account, or remove certain personal information, by logging into your Game account. If there is any other personal information you believe we process that you would like us to erase, please contact us at gdpr@mars.games.
We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Game and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.
Restriction of Processing to Storage Only
You may have a right to require that we stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or for another’s protection). Where we agree to stop processing the personal information, we will take steps to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.
Objection
You may have the right to object to our processing of your personal information. If you wish to do so, please contact us at gdpr@mars.games, and we will consider your request.
Consent Withdrawal
To the extent provided by applicable laws and regulations, you may withdraw consent you previously provided to us for certain processing activities by contacting us at gdpr@mars.games. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service. Please note that the right to withdraw consent is only available if the legal basis for processing information is consent.
9. Announcements
We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend Game access for maintenance, or security, privacy or administrative-related communications). These are essential system and service-related announcements and you are not about to opt-out of these notifications, which are not promotional in nature.
10. Contact
Please get in touch with us if you have any questions. You can contact Mars in the first instance at: gdpr@mars.games.
You can reach us using our online form here to submit Data Subject Rights requests and any questions or concerns related to data privacy. This form also allows you to contact our Data Protection Officer regarding your privacy-related inquiries.
If you are an agent or official of a regulatory authority and have a specific data and privacy regulatory inquiry, please use our Data and Privacy Regulatory Inquiry here.
Mailing address: International Privacy & Data Protection Centre
79 Robinson Road, #07-01, Singapore 068897
We will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the country in which you live or work where you think we have infringed data protection laws.
11. Changes
If we make any changes to this Privacy Policy, we will post the updated Privacy Policyhere and notify you in accordance with relevant legal requirements.
12. Language
Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version of this Privacy Policy, the English version shall prevail.
SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC
Some jurisdictions’ laws contain additional terms for users of the [Service], which are set out in this section. If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our Privacy Policy above.
Algeria
By using the Game, you give your consent to the collection, storage, treatment and use of your personal information, and transfer of your personal information to third parties or our affiliates to help us deliver the Game, in each case location in the jurisdictions specified in Section 5 (How We Store and Share Your Personal Information).
Australia
We take reasonable steps to ensure that third party recipients of your personal information located outside Australia handle your personal information in a manner that is consistent with Australian privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients. You have the right to access personal information we hold about you, how we use it, and who we share it with. You have the right to correct any of your personal information we hold that is inaccurate.
If you are under the age of 18, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Game.
Where practicable, we will give you the option of not identifying yourself or using a pseudonym when registering an account on or using the Game. You acknowledge that if you do not provide us with your personal information, we may be unable to provide you with access to certain features or sections of the Game, including social media integration and in-Game purchases.
If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the Australian Information Commissioner (Telephone: +61 1300 363 992 or email: enquiries@oaic.gov.au).
Bangladesh
By acknowledging the Privacy Policy, you expressly state that you authorise us to collect, use, store, and process your personal data, including disclosing to third parties, to the extent provided by the Privacy Policy. You also consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to the jurisdictions specified in Section 5 (How We Store and Share Your Personal Information).
Brazil
This Brazil Addendum supplements the Privacy Policy by providing information regarding the processing of Personal Data governed by the Brazilian General Data Protection Law (Law No. 13,709/18 – “LGPD”) and measures we adopt in relation to Services that are available to individuals under 18 years old pursuant to the Brazilian Digital Child and Adolescent Statute (Law No. 15,211/2025 – “ECA Digital”) and the Brazilian Video Games Regulatory Framework (Law No. 14,852/2024).
In the event of any inconsistencies related to the processing of Personal Data subject to the LGPD, this Brazil Addendum shall prevail over the Privacy Policy (available in Portuguese by selecting the language at the top right corner).
For purposes of this section, “Personal Data” or simply “Data” means any information relating to an identified or identifiable natural person governed by the LGPD.
Collection and Disclosure of Personal Information
We may collect and process the following categories of Personal Data from users who are under 18 years old, as well as from their parents or legal guardians, as applicable and as required under applicable Brazilian law, including the LGPD, ECA Digital and the Video Games Regulatory Framework:
· Identification, contact, age, and family relationship data, such as name, date of birth, user ID, email address, phone number, age-related information, and information used to establish the relationship between the minor and a parent or legal guardian.
· Parental or legal guardian consent and transaction-related data, such as contact details, payment information, records of consent for the processing of the minor’s Personal Data, and information required to authorize and process purchases or other commercial transactions involving minors, where permitted by law.
We may collect the Personal Data described above directly from the minor and/or from the parent or legal guardian and may process the Personal Data for the following purposes:
· To verify the age of users and confirm whether an individual accessing the Services is a minor.
· To contact parents or legal guardians and obtain valid consent for the processing of a minor’s Personal Data, where required.
· To enable, authorize, and process purchases and commercial transactions involving children, in compliance with applicable Brazilian law.
· To comply with legal and regulatory obligations in Brazil.
Personal Data collected for these purposes is used exclusively for the purposes described above.
For additional information about what each type of Personal Data is used for, what categories of Personal Data that we collect, legal basis for processing and our retention practices, see Sections 4, 5 and 7, respectively, of the Privacy Policy.
Rights under the LGPD
Pursuant to the LGPD, you have the right to:
· Obtain confirmation of the processing of your Personal Data. Upon request, we will inform you whether or not we process your Personal Data.
· Access your Personal Data. Upon request, you may receive a report containing the Personal Data relating to you that is processed by us.
· Correct incomplete, inaccurate, or outdated Personal Data. If you believe your Personal Data is incorrect, you may request correction by specifying what needs to be changed and why. We may request supporting documentation to carry out the correction.
· Request anonymization, blocking, or deletion of unnecessary, excessive, or unlawfully processed Personal Data. If you believe your Personal Data is being processed unnecessarily, excessively, or in violation of the LGPD, you may request that such Personal Data be anonymized, blocked, or deleted.
· Request the portability of your Personal Data to another service or product provider, subject to our trade and industrial secrets and following regulation by the Brazilian National Data Protection Agency (“ANPD”). As the data subject, you may request the transfer of your Personal Data to another provider, in accordance with ANPD regulations, provided that trade and industrial secrets are respected.
· Request deletion of Personal Data processed based on your consent, except where retention is permitted by law. Where your Personal Data is processed based on consent, you may request its deletion. However, the LGPD permits retention for compliance with legal or regulatory obligations; research by a research entity, where possible with anonymization; transfer to third parties; or exclusive use by the controller, provided the data is anonymized.
· Obtain information about entities with whom we share your Personal Data. You may request information regarding the entities with whom your Personal Data is shared.
· Obtain information about the possibility of refusing consent and the consequences thereof. When consent is used as the legal basis for processing, you have the right to be informed of the possibility of refusing consent and the consequences of such refusal.
· Revoke your consent to the processing of your Personal Data. Where processing is based on consent, you may revoke it at any time. Upon revocation, any processing carried out based on consent will be discontinued.
· Object to processing that violates the LGPD. If you believe your Personal Data is being processed in violation of the LGPD, you may object to such processing. Your request will be carefully reviewed and, if upheld, the non-compliant processing will be discontinued.
· Request review of decisions made solely on the basis of automated processing of your Personal Data. If decisions affecting you are made exclusively through automated processing, you may request a review of such decisions.
· Submit petitions regarding your Personal Data to the ANPD. If you deem it necessary, you may submit a petition to the ANPD regarding the processing of your Personal Data.
How to Exercise your Rights
If, for any reason, you need to contact us regarding matters involving your Personal Data, including to exercise your rights, please contact us as set out in the Section 10 (Contact) of the Privacy Portal.
Before responding to any request to exercise the rights listed above, we may request additional information to verify your identity.
Legal Bases for Processing
We ensure that the Processing of Personal Data subject to the LGPD is carried out based on one of the legal bases set forth in Articles 7 or 11 of the LGPD, as applicable.
Minors Personal Data and Safety Measures
We always strive to process the Personal Data of children and adolescents in their best interests, in accordance with the LGPD and ECA Digital.
By default, our Services apply privacy and data protection settings for children and adolescents, that are designed to safeguard Personal Data while considering the individual’s autonomy, evolving capacities, and progressive development, and are implemented with the best interests of the child or adolescent in mind.
We also ensure that clear, accessible, and age-appropriate information regarding the processing of Personal Data is made available to children and adolescents, as well as to their parents or legal guardians, respectively, in our Children’s Privacy Policy and in the Information for Parents and Guardians. Such information is provided in a manner intended to support informed decision-making and to facilitate the meaningful exercise of rights under applicable data protection and child protection laws.
We also adopt technical and organizational security measures designed to protect children and adolescents whenever accessing and using our Services, as required by the LGPD and ECA Digital, including, for instance, through privacy-by-default settings, access controls, data minimization practices, and age-appropriate safeguards.
International Transfers of Personal Data
When Personal Data subject to the LGPD is transferred outside Brazil, we will adopt appropriate measures to ensure an adequate level of protection in accordance with the LGPD and ANPD regulations, including entering into appropriate data transfer agreements with third parties and adopting the standard contractual clauses approved by the ANPD (“BR SCCs”), where required.
Contact Us
If you have questions or concerns regarding this Privacy Policy, please contact us as set out in the Section 10 (Contact) section.
United States
For purposes of this section, “personal information” and “sensitive personal information” have the meanings given in any applicable U.S. privacy or data protection law (“US State Laws”), and respectively include the terms “personal data” and “sensitive data” and any other analogous terms used in US State Laws.
Collection and Disclosure of Personal Information
Over the past 12 months, we have collected and disclosed for a business purpose the following categories of personal information, including sensitive personal information (denoted by *), from or about you or your device:
· Identifiers, such as your user ID, nickname, profile information, social media account ID and information, IP address, device ID and information, and email address. This information is collected directly from you and your device, from social media platforms if you choose to provide such information, and if applicable, the data subject request requestor on your behalf.
· Characteristics of protected classifications under California or federal law such as age. This information is collected directly from you in the context of being our consumer.
· Internet or other electronic network activity information, such as your information regarding your use of the Services, including log-in and clickstream data and other device information as described in the Privacy Policy. This information is collected directly from you and your device.
· Device information. This information is collected directly from you and your device.
· Social connections, such as names of your friends if you choose to log-in using a social media service and friend interaction information. This information is collected from social media platforms if you choose to sign in using a social media account.
· Game-related data, such as gameplay data and in-game interactions. This information is collected automatically when you use the Services.
· Commercial information about any transactions and refund requests related to the Services. This information is collected directly from you and your device and the relevant app store or the third party where you made the purchase.
· Geolocation information such as your region location when you set up your profile or use region-specific features on the Services. This information is collected directly from you.
· Audio and visual information such as your social media profile picture, and photos, videos and audio content shared in the Services. This information is collected directly from you and from social media platforms if you choose to sign up using a social media account.
· Account log-in information, including the username and password used to access your account for the Services.*
· Communication data, including contents of your communications with customer support*. This information is collected directly from you.
We collect and disclose your personal information, including sensitive personal information, for the purposes listed in Section 1 of the Privacy Policy.
We disclose each of the categories of personal information that we collect as described in Sections 4 of the Privacy Policy
By using our Services, you may make certain personal information publicly available to other users of our Services, including, for example, your name, nickname, profile information, and game-related data.
In the past 12 months, we have not sold or shared personal information of California residents within the meaning of “sold” and “share” in the California Privacy Rights Act of 2020. And we have no knowledge of any sale or sharing of personal information of users under 16 years of age.
In addition, we do not use or disclose sensitive personal information for purposes other than to perform the services reasonably expected by an average consumer who requests those services or as otherwise permitted by US State Laws.
For children under the age of 13, we may collect certain persistent identifiers such as IP addresses prior to obtaining parent or guardian consent, for the purpose of triggering age verification and consent procedures. Any collected persistent identifiers will not be used or disclosed for any other purposes without parent or guardian consent, and will be deleted if parent or guardian consent is not obtained.
Retention of Your Personal Information
The retention period varies among the different categories of data collected. For detailed information about the retention period for any specific category of data, see the table in Section 7 of the Privacy Policy.
Rights under US State Laws:
Depending on where you live, you may have some or all of the rights listed below in relation to information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.
· Right to Access/Know. Request we confirm whether we process information about you and give you access to that information. You may also request to receive that information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another business without impediment. If you are a California resident, you may request the following information about our collection, use and disclosure of your information:
§ the categories of personal information about you that we collected;
§ the categories of sources from which the personal information was collected;
§ the business or commercial purposes for collecting personal information about you;
§ the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and
§ the specific pieces of personal information we collected about you;
· Request to Delete. Request we delete personal information we collected about you;
· Request to Correct. Request we correct inaccurate personal information that we maintain about you;
· Right to Opt out of Targeted Advertising or Profiling. Request to opt-out of the processing of your information for the purposes of targeted advertising or the profiling of your information in furtherance of decisions that produce legal or similarly significant effects; and
· Right to Non-Discrimination. Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the US State Laws.
How to Exercise Your Rights
First, you may wish to log into your account and manage your data from there. Depending on where you live, you may also exercise your rights, if any, regarding other data by contacting us as specified in in Section 10 (Contact). We may take steps to verify your identity before complying with your request to protect your privacy and security, and may decline your request if we are unable to verify your identity. To verify your identity, we may need the following information from you: your first name, last name, address, phone number, date of birth and email address.
Depending on where you live, you may exercise these rights yourself or you may also designate an authorized agent to make these requests on your behalf. In order for us to process the request, you must provide the authorized agent with signed written permission. We reserve the request to require the agent to verify their own identity and to confirm directly with you that you have provided the authorized agent permission to submit the request.
In addition, where applicable, we will provide you with more information about our appeal process. When you submit a request or launch an appeal, we will limit our collection of your information to only what is necessary to securely fulfil your request or process your appeal. We will not require you or your authorized agent to pay a fee for the verification of your request or appeal.
Parents or guardians for children under the age of 13 can review or request deletion of their children’s personal information, or refuse to permit further collection or use of their children’s personal information, by contacting us as specified in in Section 10 (Contact).
Questions
If you have questions or concerns regarding this Privacy Policy, please contact us as set out in Section 10 (Contact).
Canada
If you are located in Canada and wish to obtain written information about our policies and practices with respect to our service providers located outside Canada, you may contact us as specified in Section 10 (Contact). Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any purpose other than as provided in this Privacy Policy.
Egypt
By clicking “accept” or by proceeding with the sign up process, you acknowledge that you have read, understood, and consented to this Privacy Policy. You are acknowledging your consent to the processing, storage, and cross-border transfer for your personal data. The cross border transfer may occur to any country in which we have databases or affiliates, in particular the jurisdictions specified in Section 5 (How We Store and Share Your Personal Information).
If you are a new user, you have seven days to inform us of any objection you may have to the terms of this Privacy Policy.
As an Egyptian data subject, you have certain rights under the Egyptian Personal Data Protection Law.
France
Instructions for the processing of your personal data after your death. You have the right to provide us with general or specific instructions for the retention, deletion, and communication of your personal data after your death. The specific instructions are only valid for the processing activities mentioned therein and the processing of these instructions is subject to your specific consent. You may amend or revoke your instructions at any time.
You may designate a person responsible for the implementation of your instructions. This person will be informed of your instructions in the event of your death, and be entitled to request their implementation from us. In the absence of designation or, unless otherwise provided for, in the event of the death of the designated person, their heirs will have the right to be informed of your instructions and to request their implementation from us.
When you wish to make such instructions, please contact us as set out in Section 10 (Contact).
Hong Kong
As a Hong Kong data subject you have legal rights in relation to the personal information we hold about you (to the extent permitted under applicable laws and regulations). You are entitled to make a subject access request to receive a copy of the data we process about you, a data correction request as well as a right to reject to the use of your personal data for direct marketing purposes. A fee may be chargeable by us for complying with a data access request.
Indonesia
By accepting and consenting to this Privacy Policy, you agree that we may collect, use and share your personal information in accordance with this Privacy Policy, as revised from time to time. If you do not agree to this Privacy Policy, you must not access or use our services and we have the right to not provide you with access to our services.
If you are under the age of 21, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Game.
In the event we fail to maintain the confidentiality of your personal information in the Game, we will notify you through the contact information provided by you or via the Game, to the extent required by local laws and regulations.
You are responsible for making sure that any personal details which you provide to us are accurate and current. In order to confirm the accuracy of the information, we may also verify the information provided to us, at any time. You hereby represent that you have secured all necessary consent(s) before providing us with any other person’s personal information (for example, for referral promotions), in which case we will always assume that you have already obtained prior consent, and as such, you will be responsible for any claims whatsoever from any party arising as a result of the absence of such consent(s).
Japan
If you are under the age of 18, you must obtain your parent’s or legal guardian’s consent to register an account on and use the Game.
By clicking “accept”, you consent to the transfer of your personal information to third parties (if any), which may include the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to the jurisdictions specified in Section 5 (How We Store and Share Your Personal Information).
The categories of personal information specified in to the jurisdictions specified in Section 5 (How We Store and Share Your Personal Information) may include "special care-required personal information" (i.e., sensitive information as detailed under applicable law), and you consent to the collection of such information.
You may request us to notify you about the purposes of use of, to disclose, to make any correction to, to discontinue the use or provision of, and/or to delete any and all of your personal information which is stored by us, to the extent provided by the Act on the Protection of Personal Information of Japan. When you wish to make such requests, please contact us as set out in Section 10 (Contact).
Kingdom of Saudi Arabia
You consent to the collection, use, disclosure, export and storage of your Personal Information as described in this Privacy Policy.
Kuwait
By accepting this Privacy Policy, you expressly state that you authorise us to collect, use, store, and process your personal data and to disclose this data to third parties whether inside or outside of Kuwait, in line with the provisions of this Privacy Policy.
Malaysia
In the event you are agreeing to this Privacy Policy in order for a minor to access and use the Game, you hereby consent to the provision of personal information of the minor to be processed in accordance with this Privacy Policy and you personally accept and agree to be bound by the terms in this Privacy Policy. Further, you hereby agree to take responsibility for the actions of such minor, and that minor’s compliance with this Privacy Policy.
Right of access: You have the right to request access to and obtain a copy of your personal information that we have collected and is being processed by or on behalf of us. We reserve the right to impose a fee for providing access to your personal information in the amounts as permitted under law. When handling a data access request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data access request.
Right of correction: You may request for the correction of your personal information. When handling a data correction request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data correction request.
Right to limit processing of your personal information: You may request to limit the processing of your personal information by using the contact details provided above. However this may affect our provision of the Game to you.
To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.
· Our data protection officer, responsible for the management and safety of your personal information
Mars Era (HK ) Limited
§ Telephone: +86 13311129160
Proxima Beta Pte. Limited
§ Contact: as set out in Section 10 (Contact)
Mexico
Some of the purposes of processing specified in Section 4 (How We Process Your Personal Information) are voluntary, which may include to show you personalised recommendations or advertising.
In general, we do not require your consent to carry out the transfers detailed Section 5 (How We Store and Share Your Personal Information). In any case, by using the Game and providing us with your personal data, you agree to the data transfers detailed therein that require your consent.
To understand more about and exercise your rights to “Access”, “Correction”, “Erasure”, “Objection”, “Restriction of Processing to Storage Only “, which includes the limitation to the use and disclosure of your personal data, as well as the applicable means, procedures and requirements to exercise any of your rights, please contact us as specified in Section 10 (Contact).
Morocco
We collect information for purposes strictly necessary for the proper use of the Game. By accepting this Privacy Policy, you explicitly accept that your personal data may be subject to processing by the Game.
Kindly note:
· the identity of the joint Data Controllers are Mars Era(HK) Limited and Proxima Beta Pte. Limited, email: gdpr@mars.games or contact: as set out in Section 10 (Contact).
· the purposes of the processing for which the data are intended are set out in Section 4 (How We Process Your Personal Information).
· recipients or categories of recipients are set out in detailed Section 5 (How We Store and Share Your Personal Information).
· whether the answer to the questions is compulsory or optional, as well as the possible consequences of a lack of answer: please refer to Section 4 (How We Process Your Personal Information) and Section 8 (Your Rights).
New Zealand
We take reasonable steps to ensure that third party recipients of your personal information located outside New Zealand handle your personal information in a manner that is consistent with New Zealand privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients.
You have the right to access personal information we hold about you, how we use it, and who we share it with. You have the right to request the correction of any of your personal information we hold that is inaccurate.
If you are under the age of 16, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Game.
If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the New Zealand Privacy Commissioner (www.privacy.org.nz).
While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, you acknowledge and agree that we cannot control the actions of third party recipients and so cannot guarantee that they will comply with those privacy laws.
Philippines
You are entitled to the following rights:
· Right to be informed. You may in certain circumstances have the right to be informed whether personal data pertaining to you is being, or has been processed, including the existence of automated decision-making and profiling.
· Right to object. You may in certain circumstances have the right to object to the processing of your personal information, including processing for direct marketing, automated processing or profiling.
· Right to access. You may in certain circumstances have the right to seek reasonable access to, upon request, your personal information.
· Right to rectification. You may in certain circumstances have the right to dispute an inaccuracy or error in your personal information and have us correct it, unless the request is vexatious or otherwise unreasonable.
· Right to erasure or blocking. You may in certain circumstances have the right to suspend, withdraw or seek the blocking, removal or destruction of your personal information.
By consenting to this Privacy Policy, you consent to us:
· collecting and processing your personal information as described in Section 4 (How We Process Your Personal Information);
· sharing your personal information with third parties, companies within our corporate group, and a third party that acquires substantially all or substantially all of us or our business, as described in this Privacy Policy and for the purposes stated herein; and
· transferring or storing your personal information in destinations outside the Philippines as described in Section 5 (How We Store and Share Your Personal Information).
Qatar
If you are using the Game in Qatar, you consent (for the purposes of Law No. 13 of 2016 on the Protection of Personal Data as may amended from time to time) to the processing of your information in accordance with this Privacy Policy.
Serbia
Our designated local representative in Serbia is Karanovic & Partners for the purposes of compliance with the Law on Personal Data Protection, and can be contacted at local.representative@karanovicpartners.com. Please include the word “Serbia” in the subject line of your email.
· Name: Karanovic & Partners o.a.d. Beograd
· Address: Resavska 23, Belgrade, 11000, Serbia
· Telephone Number: +381 11 3094 200
· E-mail: local.representative@karanovicpartners.com
Singapore
By clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, the locations specified in Section 5 (How We Store and Share Your Personal Information).
You have the right to access your personal information, how we use it, and who we share it with. You have the right to correct any of your personal information that is inaccurate.
Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted as set out in Section 10 (Contact).
South Africa
You have the right to lodge a complaint with the Information Regulator (South Africa) by emailing it on inforeg@justice.gov.za. The Information Regulator (South Africa)’s physical address is 33 Hoofd Street Forum III, 3rd Floor Braampark, Braamfontein, Johannesburg, South Africa.
Turkey
You have legal rights, which are set forth in Article 11 of the DPL, in relation to the personal information data we hold about you. As a Turkish data subject, you may have the right to apply to the data controller and (to the extent permitted under applicable laws and regulations):
· learn whether or not your personal data has been processed;
· request information about processing if your personal data has been processed;
· learn the purpose of processing of your personal data and whether they have been used accordingly;
· know the third parties in the country or abroad to whom personal data has been transferred;
· request rectification in the event personal data is incomplete or inaccurate and to demand the operations in this regard be reported to third parties your personal data has been transferred to;
· request deletion or destruction of personal data within the framework of the conditions set forth under Article 7 of the DPL and to demand the operations in this regard be reported to third parties your personal data has been transferred to;
· object the occurrence of any consequence that is to your detriment by means of analysis of personal data solely through automated systems; and
· demand compensation for the damages that you have suffered as a result of unlawful processing of your personal data.
United Arab Emirates
You consent to the collection, use, disclosure, transfer, export (to the extent permitted by applicable laws), sharing and storage of your personal information, as described in the Privacy Policy.
We may voluntarily report a cyber-security incident where it constitutes a crime under UAE law (e.g. under the UAE Cybercrime Law). The incident can be reported to the relevant authorities for the purpose of investigations. Please note that voluntary reporting of a cyber-security incident can also be made to the UAE Computer Emergency Response Team (“CERT”). CERT is a security awareness organisation that provides a process for logging incidents and advising on known cyber security threats in the UAE.
Vietnam
By accepting this Privacy Policy, you expressly agree and authorise us to collect, use, store, and process your personal information, including, lawfully disclosing and transferring it to third parties, as described in this Privacy Policy.
Where we permit any third parties to collect and use your personal information, we shall take reasonable measures to ensure that the third parties do not further disclose the personal information.
You have the right to access, correct, and erase the personal information we hold about you. You also have the right to withdraw your earlier provided consent to collect, store, process, use and disclose your personal information and to request us to stop providing your personal information to a third party.
Virginia
This section applies to Virginia residents covered by the Virginia Consumer Data Protection Act (“VCDPA”). For purposes of this section, “personal data” and “sensitive personal data” have the meanings given in the VCDPA and do not include information excluded from the VCDPA’s scope.
If you are a Virginia resident and the law does not recognize an exception that applies to you or your personal data, you have the right to:
· request that we disclose to you the personal data that we collect, use, or disclose, and information about our data practices.
· request we delete personal data we collected from you, unless the law recognises an exception;
· request we correct inaccurate personal data that we maintain about you;
· be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the law
We do not collect sensitive personal data about you. We also do not process personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.
How to Exercise Your Rights
First, you may wish to log into your account and manage your data from there. If you are a Virginia resident to whom the VCDPA applies, you may also exercise your rights, if any, regarding other data by contacting us as specified in Section 10 (Contact).
How to Appeal Decision on Your Request
If you would like to appeal a decision on your request to exercise any right you have under the VCDPA, you may contact us as set out in Section 10 (Contact).