Nuverse Privacy Notice

Last Updated: September 5, 2023

Effective Date (U.S): September 5,2023

Effective Date (Non-U.S.): October 5, 2023

Click here to view our prior privacy policy.

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This Privacy Notice applies to Nuverse services (the “Services”), which include Nuverse games, apps, software, websites, and related services accessed via any platform or device that link to this Privacy Notice. Our games are provided and controlled by Nuverse (Hong Kong) Limited, whose registered address is at Unit 1003, 10/F., Tower 2, Silvercord, 30 Canton Road, Tsim Sha Tsui, Kowloon, Hong Kong (“Nuverse”, “we”, “us” or “our”).

The Marvel Snap game is provided, operated and managed by Nuverse (Hong Kong) Limited ("Nuverse") and Second Dinner Studio, Inc ("SecondDinner"). Nuverse and Second Dinner collect and process your personal data independently. This Privacy Notice explains how Nuverse collects, uses, discloses and otherwise processes the personal information of users and other individuals in connection with our Services. For information regarding how SecondDinner collects, uses, shares, and otherwise processes your personal data, please refer to SecondDinner Privacy Notice.

We are committed to protecting and respecting your privacy. This Privacy Notice explains how we collect, use, share, and otherwise process the personal information of users and other individuals in connection with our Services.

Information We Collect

We may collect and use the following information from and about you, such as:

Information You Provide

· When you register an account: Your name (e.g., first and last), e-mail address, phone number, password, and other account registration information.

· When logging in, signing up, or linking to our Services via third party accounts such as Facebook, Apple, or Google: Your name, e-mail address, profile picture, other identifiers, and other public information. We may also collect information about your social connections on those services, with your permission.

· When using our Services: Information about how you use the Services. This may include, for example, your game-specific information, such as login history, preferences, and game progress, as well as other activities like your participation in rewards programs. Some of this information may be collected as aggregated analytical data.

· When completing transactions: Your purchase and transaction history, your virtual assets, and other financial information that you provide. If you make purchases via your Apple or Google account, your purchases will be processed by that third party and are subject to their terms of service and privacy policy.

· Your location: Your approximate location, including location information based on your SIM card and/or IP address. With your permission and depending on the jurisdiction from which you access our Services, we may also collect precise location data (such as GPS).

· When choosing to enter surveys, challenges, and competitions: Information such as name, address, e-mail address, phone number, social media handles, gender, likeness, interests, age, preferences, and other specific information you choose to share with us.

· When sending messages on the Services: Messages you compose, send, or receive through the Services’ messaging functionalities, including voice messages. This information may include the content of the message and information about the message, such as when it was sent, received, or read, and message participants. Please be aware that messages you choose to send to other users of the Services will be accessible by those users and that we are not responsible for the manner in which those users use or share the messages.

· When contacting us: For example, messages and other identifying information you send to us through your feedback, such as product reviews you write or requests you provide for customer support.

Automatically Collected Information

We automatically collect certain information from you when you use the Services, like your device or app usage data when you access the Services, such as through SDKs or APIs. This information may include, for example, technical information about your system, network, or device (e.g., your operating system, device model, system language, and device resolution), information about your usage of the services (e.g., items you purchase on the Services), and information about your experience on the Services to infer your interests. We also automatically collect certain information from you when you use the Services through cookies and other similar technologies (e.g., web beacons, flash cookies, etc.) (“Cookies”). We and our service providers and business partners may use these technologies, for example, to measure and analyze how you use the Services, including which pages you view most often and how you interact with content, enhance your experience using the Services, facilitate payments on the Services, improve or promote the Services, and measure the effectiveness of advertisements and other content. We will obtain your consent to our use of cookies where required by law.

Information from Other Sources

We may receive information about you from other sources, including through service providers, business partners, or other third parties. For example, our third-party partners may use technologies such as software development kits (SDKs) or APIs to gather information about your activities on our Services and other sites. This may include, for example, log-in records, purchase history, and information about how your app is working. Please see <How We Share Your Information> for more details on our collaborations with our partners, including advertising and analytics partners.

Some of the information that we collect is required for certain features to work, for example, we collect third party account information (e.g., from Facebook) to allow you to log in using a third party service. Some of the above personal information may be collected whenever you are using the Services, irrespective of your account login or registration status.

How We Use Your Information

As explained below, we use the information we collect about you to improve, support and administer the Services, to allow you to use its functionalities, and to fulfill and enforce our applicable Terms of Service. We may also use your information to, among other things, show you suggestions, promote the Services, and customize your experience.

We generally use the information we collect from and about you:

· To enable us to deliver the Services, including initiating your gaming experience based on your geography and other information.

· To enable us to deliver a fast and convenient logging-in experience.

· To enable us to deliver you a more personalized gaming experience.

· To help you connect to the other gamers in the Nuverse community.

· To perform customer support.

· To verify your identity.

· To promote the safety, security, and stability of the Services, such as by preventing and detecting fraud, including by scanning, analyzing, and reviewing messages.

· To enable us to review, improve, promote and develop our Services to better serve you and the Nuverse community, including by performing analytics.

· To deliver personalized advertising when you visit other platforms that promote our Services, and to measure and understand the effectiveness of that advertising.

· To communicate with you, such as to inform you of updates.

· To provide you with promotional communications, including emails about new products, features, enhancements, special offers, upgrade opportunities, contests, and events of interest.

· To comply with our legal obligations.

· Consistent with your permissions, to provide you with location-based services, to help you match with other users.

How We Share Your Information

We are committed to maintaining your trust. We want you to understand when and with whom we may share the Information We Collect. We may share the Information We Collect:

· With Service Providers and Business Partners. We may share the categories of personal information listed above with service providers and business partners to help us perform business operations and for business purposes, such as payment processors to complete your transactions or third-party services to streamline your log-in experience. For example, if you choose to log in to the Service using another service (e.g.,Facebook) we may share certain information with that service, such as records of your log-ins or if you choose to make a purchase through the Services, we may share certain information with the relevant payment provider such as transaction ID. Our service providers may only have access to your personal information for purposes of performing their functions for us and are not permitted to disclose or use your data for any purpose other than providing services to us, unless such sharing is otherwise permitted by applicable laws.

· Within Our Corporate Group. As a global company, the Services are supported by certain entities within our corporate group. We may share all of the Information We Collect with a member, parent, subsidiary, or other affiliate of our corporate group as necessary to provide important functions, such as storage, content delivery, and security. Please see <European Economic Area (EEA), Switzerland, and UK> for additional detail.

· With Third Party Game Developers. We work with third party game developers and may share your technical data and other data with such third party game developers to, for example, facilitate the provision of the Services.

· With Advertising and Analytics Partners. Depending on the jurisdiction from which you access our Services, we may share information collected through your use of our Services with our advertising or analytics partners. These partners help us promote the Services through advertising displayed on other platforms, some of which, in some jurisdictions, may be based on your activity across other sites and services. These partners may also help us and our partners measure the effectiveness of our advertising campaigns.

· In Connection with a Sale, Merger, or Other Business Transfer. We may share your information with third parties in connection with a corporate transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control, acquisition of all or a portion of our business, or in the unlikely event of bankruptcy, or other similar business arrangement in which the Information We Collect may be among the transferred assets, as permitted by applicable law.

· For Legal Reasons. We may disclose any of the Information We Collect to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims, or government inquiries, and to protect and defend the rights, interests, safety, and security of the Services, our affiliates, users, or the public. We may also share any of the Information We Collect to enforce any terms applicable to the Services, to exercise or defend any legal claims, and comply with any applicable law.

· With Your Consent. Depending on where you live, we may share personal information with the proper authorization or to provide the Services you have requested or authorized.

We will occasionally include links to and from the websites of our partner networks, advertisers, and affiliates. If you follow a link to any of these websites, please note that these websites have their own Privacy Policies and please check these policies before submitting any information to these sites.

Data Security

We use reasonable measures to help protect information from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. You should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100 percent secure. Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information. Therefore, be sure to consult the security measures adopted by third parties in their respective privacy policies.

Data Retention

We retain information for as long as necessary to provide the Services and for the other purposes set out in this Privacy Notice. We also retain information when necessary to comply with contractual and legal obligations, when we have a legitimate business interest to do so (such as improving and developing the Services, and enhancing its safety, security and stability), and for the exercise or defense of legal claims.

The retention periods will be different depending on different criteria, such as the type of information and the purposes for which we use the information. For example, when we process your information to provide you with the Services, we keep this information for as long as you have an account.

In some cases, we may aggregate or anonymize your personal information and use it in a way that is designed to be unable to identify you, for research or other purposes, to the extent allowed by applicable law.

Your Rights and Choices

Depending on where you live, you may have certain rights with respect to your personal information, such as a right to know how we collect and use your personal information. You may also have a right to access, change, oppose, request a copy of your authorization, file complaints before the competent authorities, withdraw your consent, or limit our collection and use of your personal information as well as to request that we delete it, and potentially others. In certain circumstances, you can also ask us to provide additional information about our collection and use of your personal information. Please note that your exercise of certain rights may impact your ability to use some or all of Nuverse's features and functionalities.

If you previously chose to share precise location information, you can prevent your device from sharing precise location information (e.g.,GPS location information) with the Services at any time through your device’s operating system settings or by contacting us by email as described in the “Contact Us” section.

If you have registered for an account, you may also be able to access, review, and update certain personal information that you provided to us by logging into your account and using available features and functionalities.

You may also be able to control the information we collect about you through your device browser settings to refuse or disable Cookies. Because each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types of Cookies. In addition, your choice to disable Cookies is specific to the particular browser or device that you are using when you disable Cookies, so you may need to separately disable Cookies for each type of browser or device. If you choose to refuse, disable, or delete Cookies, some of the functionality of the Services may no longer be available to you.

You may also opt out of marketing or advertising emails by using the “unsubscribe” link or mechanism noted in marketing or advertising emails.

Please contact us by using the contact information provided in the “Contact Us” section if you would like to exercise any of your rights. We will respond to your request consistent with applicable law and subject to proper verification.

Information Relating to Minors

The Services are not directed at children under the age of 13. The minimum age to use the Services may differ depending on the country or region you are in. If you believe that we have collected personal information from a minor under the minimum age, please contact us through the methods listed in the “Contact Us” section.

International Data Transfers

The personal information we collect from you may be stored on servers located outside of the country where you live. We store the information we collect in secure servers located in the United States and Singapore. Where we transfer any personal information out of the country where you live, including for one or more of the purposes as set out in this Policy, we will do so in accordance with the requirements of applicable data protection laws.

Privacy Notice Updates

We may update this Privacy Notice from time to time. When we update the Privacy Notice, we will notify you of any material changes to this policy by updating the “Last Updated” date at the top of the new Privacy Notice, posting the new Privacy Notice, or providing any other notice required by applicable law. We recommend that you review the Privacy Notice from time to time to stay informed of our privacy practices.

Contact Us

Questions, comments and requests regarding this Privacy Notice should be addressed to legal@marvelsnap.com.

SUPPLEMENTAL TERMS JURISDICTION-SPECIFIC

If you are using the Services in the following jurisdictions, the respective jurisdiction-specific terms below will apply. In the event of a conflict between the provisions of the Supplemental Privacy Notice –Jurisdiction-Specific section of this Privacy Notice that are relevant to your jurisdiction from which you access or use the Services, and the rest of this Privacy Notice, the relevant jurisdictions’ Supplemental Privacy Notice – Jurisdiction-Specific provisions will supersede and control.

European Economic Area (EEA), Switzerland, and UK

If you are using the Services in the EEA, Switzerland, or the UK (the “European Region”), the following additional terms apply:

Legal bases for processing

We use your personal data only as permitted by law. Our legal bases for processing the <Information We Collect> about you are described in the table below.

International data transfers

If you normally reside in the European Region, the personal information that we collect about you may be further transferred to, and stored at, a destination outside of the European Region (for instance, to our service providers and partners). For example, we may store the information that we collect in secure servers located in the United States and Singapore.

When we transfer your information outside of the European Region, we ensure it benefits from an adequate level of data protection by relying on:

· Adequacy decisions. These are decisions from the European Commission under Article 45 GDPR (or equivalent decisions under other laws) where they recognise that a country offers an adequate level of data protection. We transfer your information as described in What Information We Collect to some countries with adequacy decisions; or

· Standard contractual clauses. The European Commission has approved contractual clauses under Article 46 of the GDPR that allows companies in the EEA to transfer data outside the EEA. These (and their approved equivalent for the UK and Switzerland) are called standard contractual clauses. We rely on standard contractual clauses to transfer information as described in What Information We Collect to certain entities in our Corporate Group and third parties in countries without an adequacy decision.

For a copy of these adequacy decisions or standard contractual clauses, please contact us by using the contact information for your region provided in the “Contact Us” section.

Your rights

You have the following rights:

· The right to request free of charge (i) confirmation of whether we process your personal information and (ii) access to a copy of the personal information retained;

· The right to request proper rectification or erasure of your personal information;

· Where processing of your personal information is either based on your consent or necessary for the performance of a contract with you and processing is carried out by automated means, the right to receive the personal information concerning you in a structured, commonly used and machine-readable format or to have your personal data transmitted directly to another company, where technically feasible (data portability);

· Where the processing of your personal information is based on your consent, the right to withdraw your consent at any time (withdrawal will not impact the lawfulness of data processing activities that have taken place before such withdrawal);

· The right not to be subject to any automatic individual decisions, including profiling, which produces legal effects on you or similarly significantly affects you unless we have your consent, this is authorised by Union or Member State law or this is necessary for the performance of a contract;

· The right to object to processing if we are processing your personal information on the basis of our legitimate interest unless we can demonstrate compelling legitimate grounds which may override your right. If you object to such processing, we ask you to state the grounds of your objection in order for us to examine the processing of your personal information and to balance our legitimate interest in processing and your objection to this processing;

· The right to request the restriction of the processing of your information where (a) you are challenging the accuracy of the information, (b) the information has been unlawfully processed, but you are opposing the deletion of that information, (c) where you need the information to be retained for the pursuit or defence of a legal claim, or (d) you have objected to processing and you are awaiting the outcome of that objection request.

· The right to object to processing your personal information for direct marketing purposes; and

· The right to lodge complaints before your local supervisory authority in your Member State.

Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.

Please use the contact information for your region provided in the “Contact Us” section if you would like to exercise any of your rights

Representatives

If you are based in the United Kingdom, our designated GDPR representative is:

Cosmo Technology Private Limited

2 Temple Back East

Temple Quay

Bristol

United Kingdom

BS1 6EG

If you are based in the EEA or Switzerland, our designated GDPR representative is:

Mikros Information Technology Ireland Limited

Mespil Business Centre

Mespil House

Sussex Road

Dublin 4

Ireland

Cookies

We will, unless exempt, obtain your consent to the use of cookies. For more information about cookies, please visit our Cookies Policy.

United States

If you are using our Services in the United States, the following additional terms apply:

Your Rights and Choices

Depending on where you live, you may be entitled to certain rights with respect to your personal information, subject to certain exceptions, as described below:

· Right to Know. You may have the right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which it is collected, the business or commercial purposes for collecting, selling, or sharing it, and the categories of third parties to whom we disclose it.

· Access and Data Portability. Subject to certain exceptions, you may have the right to request a copy of the personal information that we collected about you.

· Deletion. You may have the right to request that we delete information that we collected from or about you, subject to certain exceptions.

· Correct Inaccurate Information. You may have the right to request that we correct inaccuracies in the personal information we maintain about you.

You may also have other choices regarding the use and disclosure of your personal data. For example, you may be able to manage third-party advertising preferences for some of the third parties we work with to serve advertising across the Internet by using the choices available at https://www.networkadvertising.org/managing/opt_out.asp and https://www.aboutads.info/choices.

You may exercise the rights above rights by contacting us via the methods listed in the “Contact Us” section above. You may be entitled, in accordance with applicable law, to submit a request through an authorized agent. To designate an authorized agent to exercise choices on your behalf, please provide evidence that you have given such agent power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf.

We will respond to your request consistent with applicable law and subject to proper verification. We will verify your request by asking you to send it from the email address associated with your account or to provide information necessary to verify your account.

You may appeal any decision we have made about your request by replying to the communication you receive from us communicating our decision. We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on the Services may change or no longer be available to you.

California Residents

Categories of Personal Information About You We Collect, Use, and Disclose

Throughout this Privacy Notice, we discuss in detail the specific pieces of personal information we collect from and about the users of our Services. During the 12 months leading up to the effective date of this Policy, we collected all of the types of personal information described in the “Information We Collect” and “How We Use Your Information” sections of this Policy. Depending upon the types of services you use, the categories of personal information we collect are: identifiers (such as name, address, phone number, email address, IP address, social media handles, and passwords); demographic information (such as gender and age); commercial information (such as your purchase and transaction history or your virtual assets); other financial data that you provide; internet or other network or device activity (such as technical device information and a record of your use of Services); geolocation information, including precise location (e.g., GPS) with your permission; information from third-party accounts that you may use when logging in, signing up, or linking to our Services, such as your name, profile picture, other public information, and information about your social connections with your permission; user-generated content; messages you send on the Services, including when you contact us; inferences we make from other data; and other information that identifies or can be reasonably associated with you.

We collect the above categories of information from you, our service providers, our business partners, social network services, and other parties. We use these categories of information, for example, to enable us to deliver the Services; to communicate with you; to enable us to review, improve, promote and develop our Services to better serve you and the Nuverse community, including by performing analytics; to enable us to deliver you a more personalized gaming experience; to promote the Services, including by advertising on other platforms, where applicable; to promote the safety, and security, and stability of the Services, including by scanning, analyzing, and reviewing messages; to protect the rights of the Services; for legal compliance; and for other purposes, with your consent. For more detail regarding the purposes for which we use information, please see the “How We Use Your Information” section.

Depending on the circumstances, we may share any of the above categories of information we collect with: our corporate group; service providers; business partners; other parties, including government entities, when required by law or to protect our users and services; third party integration services pursuant to that service and your settings; and with your consent or in connection with a corporate transaction. In addition, we may share commercial information and financial data, including your payment information, with payment processors. See the “How We Use Your Information“ and “How We Share Your Information” sections for more information.

Other California Rights

· If you are a California resident, you can request that we disclose the categories of personal information we have shared with third parties for the third parties’ direct marketing purposes. Requests may be submitted via the methods listed in the “Contact Us” section above.

· Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and/or across different websites. Our products do not support Do Not Track requests at this time.

· You may also have the right to opt out of the sale and sharing of your personal information for purposes of serving you advertisements based on your activity across other sites and services (“cross-context behavioral advertising”). Although Nuverse does not sell your personal information for money, Nuverse does collect and disclose your personal information collected on some Nuverse websites to third parties for cross-context behavioral advertising purposes, such as on the website for Marvel SNAP. You may opt out of the disclosure of your personal information for these advertising purposes by navigating to the “Your Privacy Choices” link at the footer of applicable sites, such as on the Marvel SNAP website, to exercise these rights.

o You may also exercise your right to opt-out by enabling the Global Privacy Control (“GPC”), which is a browser-based opt-out preference signal that enables you to communicate your privacy preferences to the websites you visit. For more information about the GPC, please visit their website here. If we recognize that you have enabled the GPC on your browser, our policy is to opt you out of the disclosure of your personal information for cross-context behavioral advertising purposes for the browser on which you have GPC enabled. Please note that because the Global Privacy Control is a browser-based mechanism, your opt-out preference will apply only to the browser from which you enabled the signal.

Although some of the information we collect may be considered sensitive personal information, we only process such information in order to provide the Services and within other exemptions under applicable law, such as when we process your sensitive personal information in order to perform the services or provide the goods you request from us.

Australia

Certain entities in our corporate group, located outside of Australia, are given limited remote access to your information so that they can provide certain functions, as described in the section on "How we share your information."

Brazil

If you are using the Services in Brazil, you acknowledge that you have read, understood, and agreed with the practices described in this Privacy Notice, so the following additional terms apply. Your continued access to or use of the Services after the date of the updated Privacy Notice constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Services. If any conflict arises between the main Privacy Notice and the additional terms, the following terms shall prevail:

Exercise of data protection rights. Brazilian law provides certain rights to individuals with regard to their personal data. Thus, we seek to ensure transparency and access controls in order to allow users to benefit from the mentioned rights.

We will respond and/or fulfill your requests for the exercise of your rights below, according to the applicable law and when applicable, to the Brazilian General Data Protection Law - LGPD:

· confirmation of whether your data are being processed;

· access to your data;

· correction of incomplete, inaccurate or outdated data;

· anonymization, blocking or erasure of data;

· portability of personal data to a third party;

· object to the processing of personal data;

· information of public and private entities with which we shared data;

· information about the possibility to refuse providing personal data and the respective consequences, when applicable;

· withdrawal of your consent.

· request a review of decisions made solely based on automated processing of personal data affecting your interests, including decisions made to define your personal, professional, consumer or credit profile, or aspects of your personality.

We encourage you to contact us if you are not satisfied with how we have responded to any of your rights requests. You also have the right to lodge a complaint with the Brazilian Data Protection Authority (ANPD).

Verifying your identity: For your safety and to allow us to make sure that we do not disclose any of your personal data to unauthorized third parties, in order to verify your identity and guarantee the adequate exercise of your rights, we may request specific information and/or documents from you before we can properly respond to a request received concerning your data. All data and documents received from you in the process of responding to your requests will be used for the strict purposes of analyzing your request, authenticating your identity, and finally responding to your request.

Limitations to your rights: In certain situations, we may have legitimate reasons not to comply with some of your requests. For instance, we may choose not to disclose certain information to you when it could adversely impact our business whenever there is a risk of violation to our trade secrets or intellectual property rights. In addition, we may refrain from complying with a request for erasure when the maintenance of your data is required for complying with legal or regulatory obligations or when such maintenance is required to protect our rights and interests in case a dispute arises. Whenever this is the case and we are unable to comply with a request you make, we will let you know the reasons why we cannot fulfill your request.

Retention of Data: We generally retain your personal information for as long as it is necessary to serve the purpose(s) for which such information was collected, for no longer than is required or permitted by law, or our records retention policy, reasonably necessary for internal reporting and reconciliation purposes, or to provide you with feedback or information you might request.

If there is a legitimate interest justifying the storage, the possibility of opt-out will be offered when applicable, such as in cases involving marketing communications.

Contact: In case of doubt about your privacy, your rights or how to exercise them, please contact us by using the contact information provided in the “Contact Us” section.

DPO. If you wish to contact the Data Protection Officer, please contact us at: dpobrasil@bytedance.com

Access Logs. We keep your application access logs, under confidentiality, in a controlled and safe environment, for at least 6 months, in order to comply with legal obligations.

Language. The Policy may have been prepared in the English language and in the Portuguese language. If you are a user located in Brazil, you shall refer to the Portuguese version, which shall prevail.

Information related to younger users. By accessing the Services, you represent that you are over 13 years old.

International Transfers. International data transfers are necessary for us to provide our services. We will always rely on one of the international data transfer mechanisms under applicable data protection laws and regulations.

Canada

If you are using the Services in Canada, the following additional terms apply.

Your Rights. Subject to limited exceptions under applicable law, you have the right to access, update, rectify and correct inaccuracies in your personal information in our custody and control and to withdraw your consent to our collection, use and disclosure of your personal information. To exercise these rights, you may contact us using the contact information set out below. We may require certain personal information for the purpose of verifying the identity of the individual making the request.

Your Choices. You can unsubscribe from our marketing emails at any time by clicking the “unsubscribe” link included at the bottom of each email we send. You can also adjust your preferences regarding certain types of personalized advertising by using the Ads tools in Settings.

Transfer Outside Your Jurisdiction. We and our service providers (including members, subsidiaries, or affiliates of our corporate group) may access, store and otherwise process personal information outside of Canada (and, for residents of Quebec, outside of Quebec), including in the United States and Singapore, and other foreign jurisdictions where we or our service providers are located. For information about the manner in which we or our service providers (including service providers outside Canada) process personal data, please contact us using the contact information set out below.

Contact. If you are a resident of Canada, you can contact our Privacy Office using the contact information provided in the “Contact Us” section.

Egypt

If you are using the Services in Egypt, the following additional terms apply. Your continued access to or use of the Services after the date of the updated Privacy Notice constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Services.

You declare that you are over the age of 18. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the age of 13 and that you have read and acknowledged the Nuverse Privacy Notice and Terms of Use and agree to the use by your child of the Services and registration for an account.

India

If you are using the Services in India, the following additional terms apply. Your continued access to or use of the Services after the date of the updated Privacy Notice constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Services.

Grievance Officer For India. In accordance with Information Technology Act 2000 and rules framed thereunder, a Grievance Officer has been appointed and a complaint or other issue faced by a user of our platform or other issue faced may be submitted through the email provided in the “Contact Us” section.

The complaint should provide: (i) username of the relevant account holder (ii) specific content that is of concern and (iii) reason(s) for the request.

Indonesia

If you are using the Services in Indonesia, the following additional terms apply. Your continued access to or use of the Services after the date of the updated Privacy Notice constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Services. If any conflict arises between the main Privacy Notice and the additional terms, the following terms shall prevail:

Age, Parental and Guardian Consent. By accessing and/or using the Services, you represent that you are at least 21 years of age, or married, or not under guardianship. If you are below 21 years old and you are not married, or you are under guardianship:

· you must obtain approval from your parent(s) or legal guardian(s) to access or use the Services; and

· your parent(s) or legal guardian(s) are responsible for: (i) all your actions in connection with your access to and use of the Services; (ii) your compliance with this Privacy Notice; and (iii) ensuring that any of your participation in the Services will not, in any event, result in any violation of applicable laws and regulations relating to child protections.

· If you do not have consent from your parent(s) or legal guardian(s) and your parent(s) or guardian(s) is not willing to open the account under their name, you must cease accessing the Services.

Your Choices. You may withdraw your consent to Nuverse's disclosure of personal data to third parties. Upon your request, we will cease to display, publish, transmit, disseminate, and/or open the access to your personal data to third parties. Please note that by withdrawing your consent to the disclosure and/or collection of your personal data, we may not be able to fulfill your requests and you may not be able to use some of the Nuverse features and functionality.

You may request that Nuverse (i) disclose the history of personal data that we have collected; and/or (ii) erase and dispose of your personal data that we have collected on our server. Please note that by requesting that we erase or dispose of your personal data, you may not be able to use some of Nuverse features and functionality.

To exercise any of your rights, contact us by using the contact information provided in the “Contact Us” section.

Notification. In the event of any breach of personal data, we will notify you and provide you with information regarding such breach of personal data.

Data Retention. We retain your information for as long as it is necessary to provide you with the Services. Where we do not need your information in order to provide the Services to you, we retain it only for so long as we have a legitimate business purpose in keeping such data. However, there are occasions where we are likely to keep this data for five (5) years (or longer if required) in accordance with our legal obligations or where it is necessary for the establishment, exercise or defence of legal claims.

After you have terminated your use of our Services and the five (5) years retention period has lapsed, we store your information in an aggregated and anonymised format. Non-personally identifiable information may be retained indefinitely for analytics.

Language. This Privacy Notice has been prepared in the English language and Indonesian language. In the event of any inconsistency or different interpretation between the English text and Indonesian text, the English text shall prevail and the relevant Indonesian text shall be deemed to be automatically amended to conform with and to make the relevant Indonesian text consistent with the relevant English text. You acknowledge and agree that (i) you have read this Privacy Notice and understands the content of this Privacy Notice; (ii) you enter into this Privacy Notice freely and without duress, and (iii) you will not use the provisions under Law of the Republic of Indonesia No. 24 of 2009 on Flag, Language, State Emblem and National Anthem or any of its implementing regulations to invalidate this Privacy Notice.

Israel

If you are using the Services in Israel, the following additional terms apply. Your continued access to or use of the Services after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Services.

You declare that you are over the age of 18. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the age of 13 and that you have read and acknowledged this Privacy Notice and Terms of Use and agree to the use by your child of the Services and registration for an account.

Argentina

If you are using the Services in Argentina, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this Policy, the following terms shall prevail.

Your rights and options. According to Law No. 25,326, Regulatory Decree No. 1558/2001 and the provisions and/or binding resolutions issued by the Agency for Access to Public Information ("AAIP"), you have the following rights with respect to your personal data: access, rectification and deletion regarding data protection. If you have questions about your privacy, your rights, or how to exercise them, please contact us using the information in the "Contact Us" section. If you have any questions about the processing of your personal data, we would like to clarify them.

We encourage you to contact us if you are not satisfied with how we have responded to any of your rights requests. You also have the right to lodge a complaint with the AAIP. You can contact AAIP through the site:https://www.argentina.gob.ar/aaip/datospersonales/derechos.

Mexico

If you use our services in Mexico, the following additional terms apply. In the event of a conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall prevail.

Data Controller. Nuverse (Hong Kong) Limited, whose registered address is at Unit 1003, 10/F., Tower 2, Silvercord, 30 Canton Road, Tsim Sha Tsui, Kowloon, Hong Kong.

How we use your personal data. Almost all of the purposes of the processing data indicated above in the main section of this Privacy Notice are necessary purposes. However, the following are secondary purposes:

· To provide you with personalized advertising and surveys.

The above purposes are not necessary to provide the Services, but allow us to provide you with a better experience. We offer you the ability to make choices about how we use and disclose your personal data. You may be able to limit the secondary purposes of personalized advertising by using the tools available to you in the Settings that allow you to limit certain features.

We use both human and automated means to process your data.

How we share your personal data. We may share your personal data with a third party for purposes other than processing on our behalf. We will obtain your consent to such disclosure as required by applicable laws.

By providing us with your personal data and using our Services, you agree to transfers that require your consent. You can always revoke your consent and exercise your rights as outlined below.

Language. The Policy may have been prepared in the English language and in the Spanish language. If you are a user located in Mexico, you shall refer to the Spanish version, which shall prevail.

Your Rights. You have the following rights with respect to your personal data: access, rectification, cancellation, objection, consent withdrawal, limitation of use and disclosure of your data. You may exercise your rights by sending your request to the contact information listed in the "Contact Us" section. To learn about the applicable requirements and the procedure for exercising your rights, please contact us at the contact information listed in the "Contact Us" section. If you are under 18 years of age, you may exercise your rights through a parent or guardian. Requests to exercise for your rights will be resolved as soon as possible according to the applicable data protection law and the nature of your request.

Information relating to minors. You may review more information on parental consent in the Terms of Service.

Philippines

If you are using the Services in the Philippines, the following additional terms apply pursuant to the relevant laws, rules and regulations and issuances by the Philippines National Privacy Commission (“NPC”) on data privacy. Your continued access to or use of the Services after the date of the updated Privacy Notice constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Services.

Your Rights. To the extent that the relevant laws, rules and regulations on data privacy recognize your rights and freedoms as data subjects, you shall have the right to information, object, access, rectification, erasure or blocking, lodge complaints before the NPC, damages and data portability. Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.

Russia

If you are using our services in Russia, the following additional terms apply. Your continued access to or use of the Services after the date of the updated Privacy Notice constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Services.

What are legal grounds for data processing. When we process your personal data, we rely on your consent, performance of a contract, our legitimate interest and obligations to process personal data, when required by law.

By signing up and using the Services, you consent to the processing of personal data in accordance with this Privacy Notice.

Where we store your personal data. Your personal data may be transferred from Russia to the United States or Singapore and stored in that location, outside of the country where you live.

South Africa

If you are using the Services in South Africa, the following additional terms apply. Your continued access to or use of the Services after the date of the updated Privacy Notice constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Services.

You declare that you are over the age of 18. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the age of 13 and that you have read and acknowledged the Nuverse Privacy Notice and Terms of Use and agree to the use by your child of the Services and registration for an account.

South Korea

If you are using the Services in Korea, the following additional terms apply. Your continued access to or use of the Services after the date of the updated Privacy Notice constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Services. In the event of any conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall prevail.

· Data retention. We destroy personal information whose purpose of collection as consented to by you have been achieved, or whose periods of and use to which you consented to or which were provided in this Privacy Notice have expired; provided, however, we will continue to store your personal information for the following statutorily-prescribed periods, where applicable, including but not limited to:

Act on Consumer Protection in Electronic Commerce

· Records on your cancellation of an order, your payment on a purchased item, and our supply of a good/service: 5 years

· Records on the handling of consumer complaints or disputes: 3 years

· Records on advertisements and labels: 6 months

Protection of Communications Secrets Act

· Records on your visits to our website: 3 months

· Destruction of Personal Information. We destroy your personal data in a manner that renders it unrestorable by the relevant department.

· Data rights. You have the right to access personal information we hold about you, to rectify any personal information held about you that is inaccurate, to request the deletion of personal information held about you, and the right to request the suspension of the processing of your personal information. You can exercise your rights by contacting us by using the contact information provided in the “Contact Us” section.

· Data Security. We work hard to protect Nuverse and our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. To this end, we have in place technical, managerial and physical safeguards, including internal policy for data protection, limiting the access to personal information on a need-to-know basis and controlling access to the facilities where personal information is processed.

· Information Relating to Children. The Services are not directed at children under the age of 14.

· Entrustment and/or Overseas Transfer of Personal Information. We entrust your data to our affiliates, cloud storage providers, IT service providers, and data centers, some of whom are located abroad (See the Korean language Privacy Notice), subject to your consents or notifications to you, if applicable. The entities receiving and processing your data are committed to using and storing personal information in compliance with domestic and international regulations and to taking all available physical and technical measures to protect personal information. You may opt-out of such transfer so long as the transfer is not necessary to provide you with the Services, by contacting us by using the contact information provided in the “Contact Us” section.

Türkiye

If you are using our services in Türkiye, the following additional terms apply. Your continued access to or use of the Services after the date of the updated Privacy Notice constitutes your acceptance of the updated policy. In the event of any conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall prevail.

Legal bases for processing your personal data. Nuverse relies on the following legal bases while processing your personal data in accordance with Article 5 of the Law No. 6698 on Protection of Personal Data:

· processing is explicitly laid down or dictated by laws

· processing of your personal data is necessary provided that it is directly related to the conclusion or fulfillment of the contract between us

· processing is mandatory for us to be able to comply with our legal obligations

· the relevant data is made available to the public by yourself

· processing is mandatory for the establishment, exercise or protection of a right

· processing is mandatory for our legitimate interests, provided that it does not violate your fundamental rights and freedoms

· your explicit consent (Please note that we rely on this legal basis only when we require your consent for the processing and we do not rely on this legal basis if and when we rely on one of the other legal grounds above)

Your rights. According to Article 11 of the Data Protection Law, you have the following rights with respect to your personal data:

· the right to learn whether we process your personal data,

· the right to request information with regard to such processing, if we process your personal data,

· the right to learn the purposes of the processing and whether they are used for such purpose or not;

· the right to know the third parties within or outside the country, to whom we transfer your personal data,

· the right to request correction of incomplete or inaccurate personal data,

· the right to request deletion or destruction of your personal data under the conditions set forth in Article 7 of the Data Protection Law,

· the right to request that we notify the third parties, to whom we transferred your personal data, about the correction, deletion and/or destruction of your personal data per your request within the scope of the foregoing two items,

· the right to object to the negative results about you that are due to the analysis of your personal data processed solely by automated means,

· the right to claim indemnification for damages incurred due to illegal processing of your personal data.

You may exercise your rights listed above by contacting us by using the contact information provided in the “Contact Us” section.

The requests found in your application will be resolved as soon as possible according to the nature of your request and within thirty days at the latest free of charge. However, if your request incurs additional cost to our company, then you may be charged over the tariff fee determined by the Turkish Personal Data Protection Board.

United Arab Emirates

If you are using our services in the UAE, the following additional terms apply. Your continued access to or use of the Services after the date of the updated Privacy Notice constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Services. If any conflict arises between the main Privacy Notice and the additional terms, the following terms shall prevail:

How we share your personal data

In addition to the main text of this policy, by using the Services in the UAE you agree to the terms of this Privacy Notice and consent to our sharing of your personal data in line with the main text of this Privacy Notice.

Governing law and dispute resolution

By using our Services in the UAE, this Privacy Notice will be governed by and interpreted in accordance with the laws of the UAE. In the event of a dispute arising between the parties in connection with this Privacy Notice:

· where the dispute relates to a claim for a sum within the limits specified by the DIFC Small Claims Tribunal from time to time, then the dispute shall be referred by either party to the said Tribunal; and

· for all other disputes, the parties shall seek settlement of that dispute by mediation in accordance with the Mediation Rules of the DIFC-LCIA Arbitration Centre, which Rules are deemed to be incorporated by reference to this clause. If the dispute is not settled by mediation within 30 days of the commencement of the mediation, or such further period as the parties shall agree in writing, the dispute shall be referred to and finally resolved by arbitration under the Arbitration Rules of the DIFC-LCIA Arbitration Centre, which Rules are deemed to be incorporated by reference to this clause. The language to be used in the mediation and in the arbitration, shall be English. In any arbitration commenced pursuant to this clause the number of arbitrators shall be one and the arbitration shall be conducted in Dubai.

Vietnam

If you are using our services in Vietnam, the following additional terms apply. Your continued access to or use of the Services after the date of the updated Privacy Notice constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Services. If any conflict arises between the main Privacy Notice and the additional terms, the following terms shall prevail:

Age, Parental and Guardian Consent. By accessing and/or using these Services, you represent that you are at least 16 years of age or not under guardianship. If you are below 16 years old or under guardianship:

· you must obtain approval from your parent(s) or legal guardian(s); and

· your parent(s) or legal guardian(s) are responsible for: (i) all your actions in connection with your access to and use of the Services; (ii) your compliance with this Privacy Notice; and (iii) ensuring that any of your participation in the Services will not, in any event, result in any violation of applicable laws and regulations relating to child protections.

If you do not have consent from your parent(s) or legal guardian(s) and your parent(s) or legal guardian(s) is not willing to open the account under their name, you must cease accessing the Services.

Language. This policy has been prepared in the English language and Vietnamese. In the event of any inconsistency or different interpretation between the English text and Vietnamese text, the English text shall prevail and the relevant Vietnamese text shall be deemed to be automatically amended to conform with and to make the relevant Vietnamese text consistent with the relevant English text.