Privacy Policy

This policy applies to personal information we hold about our customers, our suppliers and potential suppliers, persons who visit our website and any other person whose personal information we hold.

In this policy, "we", "our" and "our" refer to NEVERLAND ENTERTAINMENT LIMITED

and its affiliated companies. A group of companies dedicated to developing and distributing video games worldwide. This policy addresses our conduct as a "data controller" under data protection legislation: this essentially means that we are responsible for deciding what personal information we collect and how it is used. We also often act as a "data processor", which means that we process personal information on behalf of another entity, such as the publisher of one of our games. When we refer to "personal information", we mean an "individual" who relates to you personally or by which you can be identified. Some information referred to in this policy is not "personal information" within the meaning of data protection legislation, but we may refer to it to help you understand what we do.

Subject to the applicable laws and regulations of the country in which you live, the minimum age for you to access our Services without supervision is 18 years old. We do not knowingly collect personal data from children under that age without the prior consent of a parent or legal representative. If you are a child under the above age, we will seek parental consent before creating an account for you and collecting personal data related to it, and we will make all reasonable efforts to verify that consent has been given by the child's parent or legal representative, Take into account available technology. We encourage parents to instruct their children not to disclose personal data while surfing the Internet.

We are committed to protecting and respecting the personal information of everyone we deal with - it's important to us and we know it's important to you too.

In this policy you will find information about what type of personal information we hold about you, how and why we collect it, how we use it and how we keep it secure. You will also find information about your rights and how to exercise them.

Please read this policy carefully, if you need to contact us about any content here or other content related to your personal information, you can contact us by email: [email protected].

In this policy you will find information about:

1. What information do we collect about you?

What information we hold will depend on our relationship with you. Typically, this may include the following:

Customers/Players We will collect some information about you so that you can play our games, improve or optimize your gaming experience, provide customer service, improve the services we provide, and for marketing purposes (see below for more details). This includes:

● your contact information, such as name and (if you choose to provide) phone number and email address;

● your player username and password;

● Your game profile – including your profile picture and any information needed for the game to function, such as an in-game inventory;

● other data you choose to provide to us, such as data used to identify a lost or lapsed account, such as answers to special questions we may ask you to allow you to unlock or restore a lost or lapsed account;

● Your game user account or character ID – a special ID for NEVERLAND ENTERTAINMENT LIMITED generated for you by our game server;

● Analytics ID – a randomly generated, anonymous identifier used to distinguish the activity of one game account from another in our analytics data;

● Third-party account ID – such as your Facebook, Xbox, Game Center, VK, WeChat, Google, Steam or PSN account, which you can use to log into your game account, utilize your social graph or integrate with third-party features ( such as achievements);

● Usage Data, including information about how you use our website, products and services and your game progress;

● your internet protocol (IP) address and mobile device identifiers (such as your device ID, advertising ID (only if you choose to provide it), MAC address, IMEI);

● data to combat fraud (such as chargeback abuse in games or click fraud in advertising);

● data about your device, such as device name and operating system, browser type and language;

● Marketing and Communications Data, including your preferences for receiving marketing from us and our third parties and your communications preferences, which may be turned off by adjusting the settings on your device at your own discretion and control.

Our suppliers We will collect contact information in order to manage our relationship with you and where applicable we may collect bank account details (to enable payment for services). When you provide services to us, we may collect other information from you in connection with providing those services.

Job Seekers If you apply for a job with us, or send us your resume, we will collect information relevant to the position you have applied for and, if necessary, retain a copy of your resume in order to assess your suitability for a position and us. This will be explained in more detail when you make any application.

2. How we collect information about you

We will collect this information in a variety of ways depending on how we interact with you.

Direct Interactions You may provide us with your identity, contact details or other information by filling out online forms or by corresponding with us by post, telephone, in-game, email or otherwise. This includes personal data provided by you when:

● use our products or services;

● create a game account on one of our games or on our website (if available);

● Interact with our Customer Service or Privacy Office;

● subscribe to our mailing list;

● enter contests, promotions or surveys;

● give us feedback;

● To provide services to us.

automation or interaction


As you interact with our Sites or Games, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data through the use of cookies, pixels, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies. You can refuse us to collect cookies through your personal browser settings. See our Section 4 for more details.

Third Parties ● We may receive Personal Data from third parties. If you link it to a service or provide it to us through your privacy settings. This may include your third party account ID, game profile and user ID, for example from your Facebook, Game Center, VK, WeChat, Google, Xbox, Steam or PSN account, which you can use to log into your game account, Take advantage of your social graph, or integrate with third-party features such as achievements.

● Technical data comes from ad networks and

● Search information providers.

● If you are applying for a position with us, please provide references and other information.

3. How we use your information

We use different information in different ways:

send you communications related to our services and games, answer your inquiries or address your complaints;

To provide and administer our Services, including our games;

To allow you to participate in our website features;

Verify and confirm payments (where relevant for interactions with third-party payment providers);

Account verification and clearing;

direct marketing to let you know about products and services that may be of particular interest to you;

Administer surveys and polls;

administer contests and/or promotions and your registration;

Technical and usage information/analytics to help us develop games that our customers want to play and improve them, and to detect cheating and activities that disrupt players' experiences with our games, security risks, fraud and other illegal activities;

business and website analysis and improvement;

Provide social features as part of our Services;

customize your personal experience;

send you relevant information, such as updates, security alerts and support messages;

On-site and in-app advertising and promotions of goods and services by us and our service providers and trusted third parties;

Website, system administration and account verification;

Leaderboards, Discord and community information, nicknames and club names/club information;

automatically or manually regulate communications between players;

to answer or satisfy legal or regulatory requests; and

To serve you advertisements and engage with you on third-party social networks when you interact with third-party social networking features (we encourage you to review the privacy statements/policies of those social networks so that you can opt-out of such activities).

4. Cookies

Like most online services, we and our partners may use cookies and similar technologies to provide and personalize our services, analyze game usage, target advertisements and prevent fraud. Cookies are small text files stored by your browser on your desktop computer or mobile device. To be clear, a cookie in no way gives us access to your computer or any information about you (other than the data you choose to share it with). You can modify your browser setting to decline cookies if you prefer. In such cases, some aspects of the Service may not function properly.

We and our partners may use tracking technologies such as cookies, beacons, tags and scripts. These technologies are used to analyze trends, administer the site, track user activity on the site, and gather demographic information about our user base as a whole. We may receive reports based on these companies' individual and aggregated use of these technologies.

Users can control the use of cookies at the individual browser level. If you decline cookies, you may still use our site, but your ability to use certain features or areas of our site may be limited.

5. Legal basis for processing

There are a number of different legal bases for processing personal information. Which one applies will depend on how we use your information and for what purpose. In most cases, this situation is:

you have consented to us using your personal information in this way (for example, you have consented to us sending you marketing communications about our products and services); and/or

Our use of your personal information is in our legitimate interests as a business organisation. For example, we may use cookies to track information about how our website is used, to continuously improve its layout based on how you and other users interact with its content, and to provide personalized services to users (for example, by displaying content or communicating with your location-related language), provided that it is always done in an appropriate manner and respects your right to privacy; and/or

Our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you (such as managing your account); and/or

Our use of your personal information is necessary to comply with relevant legal or regulatory obligations.

We generally do not collect or process any "special categories" personal data (including information about your health, religious or political beliefs, ethnic background, sex life and sexual orientation). Where applicable, we will generally obtain your additional specific consent at the time of collecting the information, unless there is a legal requirement or other reason to process that information.

6. Children

Protecting children's privacy is very important to us. Our Site and Games are not intended for children under the age required by your country's data protection regulations or applicable law, and we do not knowingly collect data relating to children. For games that are not directed at children but may appeal to them, we take the extra step of restricting access to the Services based on the player's age.

7. Sharing your information

The personal information you provide to us may be shared with third-party companies, agents, contractors, service providers or our affiliated companies share. This may include:

our business partners and suppliers;

Sub-processors who store or process information on our behalf, in particular data analysis providers and data storage providers. Information shared with such providers is provided in an anonymous format so that the data cannot be linked to any specific individual and is therefore not considered "Personal Data";

our auditors, insurers, lawyers and other professional advisers;

credit counseling agencies;

Law enforcement agencies, other government agencies, or third parties (if required by law);

We plan to merge with or be acquired by another business entity, or we are in a reorganization with that entity.

8. Social functions

Social features are a core component of our games. For example, other players and users may see your profile data, in-game activity and read your posted messages.

Our games and services may include features from our partners, if available, such as social media interaction tools (though not currently, they may also be relevant to in-game advertising in the future). In such cases, these partners (if any) can access your data with your consent and operate in accordance with their own privacy policies. We encourage you to review their privacy policies to learn more about their data processing practices and to opt-out where you feel relevant.

9. International data transfers

9.1 Your personal information we collect above is stored and encrypted on our servers located in the United States.

9.2 Due to the nature of our services, you understand and agree that your personal information may be transferred to affiliates, subcontractors and/or our partners located in third countries/countries outside your country of residence, and by their storage and handling. Because different countries may have different data protection laws than the country in which you live, and they may not provide you with the same level of protection for your personal information as the data protection laws of the country where you live or work, in which case , we will take steps in accordance with the applicable laws and regulations of your country to ensure that adequate safeguards are in place and that your personal information is adequately protected where the data is processed. For example, we will give you special reminders and obtain your prior consent,

10. Your rights

You have a number of rights in relation to your personal data under the applicable data protection laws of your country of residence. We respect and honor these rights and will do everything we can to help you exercise them.

Your rights include but are not limited to:

request access to or obtain a copy of any personal data we hold about you;

correct your personal data if you believe that the information we hold is inaccurate;

Request erasure of your personal information, or object to the processing of your personal information.

Note that these rights are not absolute - in some cases they do not apply to your or our specific use of your data, and there are exceptions (for example, if we have to process the data to comply with our own legal obligations), but if this is the case, we will let you know if you make a request which we believe we cannot comply with.

Any request by you to access or copy your personal data must be in writing and we will endeavor to respond within a reasonable period of time after verifying your identity in accordance with data protection legislation. We will comply with our legal obligations regarding your rights as a data subject.

You understand and agree that, subject to applicable law, we may have the right to charge you an amount based on the complexity of your request to cover our operating expenses.

If the applicable laws and regulations of the country/region where you live or work have other special provisions, we will process your personal data in accordance with the applicable laws.

Our aim is to ensure that the information we hold about you is always accurate. To help us keep your information up to date, you can choose to have full control over the data you share with us, and you can update your information or adjust settings on your device directly under your profile.

You can also contact your local data protection authority if you have an unresolved privacy or data use concern that we have not resolved satisfactorily.

11. Marketing

If you agree to receive notifications for a game, we may use your personal information to send you customized recommendations, offers or auctions about that game. For opting out of personalized in-game offers, you can use the options available in the game settings. You can easily turn off each of the different categories of notifications in the game, or choose not to receive notifications or alerts on your device.

You can opt-out of interest-based advertising on mobile apps (if available) by checking your Android or iOS device's privacy settings and selecting "Limit Ad Tracking" (Apple iOS) or "Opt-out of Interest-Based Advertising" (if available) android).

12. How long do we keep your information?

We will only retain the information we collect about you for as long as necessary for the purposes set out in this notice or to comply with any legal obligations we are subject to. This will involve us regularly reviewing our files to check that the information is accurate, up to date and still required.

In some circumstances, you can ask us to delete your data: see "Your Rights" for more information.

You understand and agree that in order to improve our service quality, sometimes we may need your user data for research or statistical purposes, in this case, we will ensure that your personal information is first desensitized, de-identified, and anonymous Personalized (so that it can no longer be associated with you), we may use this information without further notice to you.

If you opt-out of marketing, we may retain information necessary for us to honor your wish not to be contacted for marketing purposes.

13. Security

We are committed to keeping your information secure. To prevent unauthorized access or disclosure, we have in place appropriate physical, electronic and managerial procedures to safeguard the information we collect. Such measures will be appropriate to the nature and level of risk of the relevant data. If you have been given a password to access any of our services, you should not share that password with anyone else.

14. Links to other websites

Our website may contain links to other websites, including through our social media buttons. While we try to link only to sites that share our own high standards and respect for privacy, we are not responsible for the content, security or privacy practices employed by other sites, and a link does not constitute an endorsement of that site. Once you link to another website from our site, you must abide by that website's terms and conditions, including but not limited to its Internet privacy policy and practices. Please check these policies before submitting any data to these sites.

15. Contact information

Questions, comments and requests regarding this Policy are welcome and should be sent to [email protected]

You also have the right to lodge a complaint with the data protection authority in your country of residence if you have any concerns about our use of your information.

16. Changes to this Policy

Any changes we make to the policy in the future will be posted on this page and, where material and appropriate, notified via an in-game message. We strongly encourage you to check our policy periodically for any updates or changes. Unless otherwise required by applicable law, all changes to the Privacy Policy will be effective upon posting, and your continued use of any Services after the update will be deemed acceptance of the updated Privacy Policy, unless a material change is involved, in which case Next, when you log in to our service again, we may notify you in advance according to applicable laws, and obtain your consent again in the form of a pop-up window.