Privacy Notice

Last Updated: 15 April 2022

Welcome to MARVEL SNAP (the “Game”). The Game is provided, operated and managed by Nuverse (Hong Kong) Limited ("Nuverse") and Second Dinner Studio, Inc ("SecondDinner"). Each of Nuverse and Second Dinner collects and processes your personal data independently. This Privacy Notice explains how Nuverse, whose registered address is at Unit 1003, 10/F., Tower 2, Silvercord, 30 Canton Road, Tsim Sha Tsui, Kowloon, Hong Kong, collects, uses, discloses and otherwise processes your personal data. For information regarding how SecondDinner collects, uses, discloses and otherwise processes your personal data, please refer to SecondDinner Privacy Notice .

You are reading the Privacy Notice , which explains how we collect, use and disclose your personal data when you download the Game from Apple App Store or Google Play, access the Game, and the rights you may have under applicable privacy laws. If you do not agree with this policy, you should not play the Game.

If you have any questions about how we use your personal data, please contact us at legal@marvelsnap.com.

PLEASE READ THIS PRIVACY NOTICE CAREFULLY. This Privacy Notice consists of the summary of the key points in our Privacy Notice, the main body, and a jurisdiction-specific section. The jurisdiction-specific section might include additional information required under your local data protection laws, render certain aspects of the Privacy Notice to be inapplicable, or amend them to ensure compliance with local data protection laws. As such, please be sure you review this Privacy Notice in its entirety.

PRIVACY NOTICE SUMMARY

What data do we collect about you?

We collect and process your data when you create an account and play the Game, including your contact details and other data you provide when you register for an account or play the Game. We also collect data you share with us from third parties (such as Facebook, Apple, Google, etc.) if you choose to log in to the Game via your account with such third party networks, and technical and behavioral data about your use of the Game. We may also collect data about you automatically through your use of the Game.

1.How and for what purpose will we use the data about you?

We use your data to provide the Game to you and to improve, develop and administer it. We may also use your data to, among other things, ensure your safety. We may also use your personal data to serve you targeted advertising and promote the Game and other products and services (in each case, if required under applicable law, where we have your consent).

2.Who else will access and collect your personal data and who do we share your data with?

The third party developer of the Game will have access to your data. Your data may also be collected by and shared with other companies in the same group as the Nuverse, payment providers, and advertising service providers. Where required or permitted by law, we will share your data with law enforcement agencies or regulators and with third parties pursuant to a legally binding court order.

3.Your rights.

In certain circumstances, you have rights in relation to your data such as the right to access and the right to correction. Depending on your jurisdiction, you may have additional rights - please see the jurisdiction-specific section at the end of this Privacy Notice .

4.How long do we keep hold of your data?

We retain your data for as long as it is necessary to provide you with the Game service so that we can fulfill our contractual obligations and rights in relation to the data involved. Where we do not need your data in order to provide the Game to you, we retain it only as long as we have a legitimate business purpose in keeping such data or where we are subject to a legal obligation to retain the data. We will also retain your data if necessary for the establishment, exercise or defense of legal claims.‎

5.How will we notify you of any changes to this Privacy Notice ?

We will generally notify all users of any material changes to this policy through a notice within the Game when you log in. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy. By accessing the Game, you acknowledge that you have read this policy and that you understand your rights in relation to your personal data and how we will collect, use and process it.

******************************************************************************

1.The types of personal data we collect

Unless otherwise stated in this policy, the personal data we collect from you or about you is required so that we can perform our contract with you to provide the Game to you as detailed in our Terms of Service. The provision of certain data is mandatory for the purposes of your access to the Game, and if you do not provide certain types of data, we may not be able to grant you access to the Game, provide certain aspects of the Game or certain functionalities may be lost. However, you have control over certain kinds of personal data that you can choose to share or to withhold from us, and will still be able to access the Game, as detailed in this policy.

We collect and use the following data about you:

Data You Provide to Us, Including Your Profile Data. You give us data when you register an account to play the Game via the application directly or if you choose to register using your social network account details (e.g. Facebook etc.), including your name, username, password, age, language, email address, shipping address, phone number, country, data you disclose in your user profile, character name or nickname, and data you voluntarily elect to provide in order to customize game play, such as gender. We link your data with your activity on our Game across all your devices, using your email or other log-in or device data.

We also collect data in correspondence you send to us.

Behavioral and Use Data.

Gameplay

We collect and process data regarding your use of the Game including login history, purchase history, how you engage with the Game, the preferences you set, the amount of time spent in the Game, your gameplay and activity, your Game progress, your interactions with other players in the Game, and other pieces of data in connection with your various activities within or through the Game or otherwise (including when you capture a screenshot in the Game) that are sent by your device or computer system when you access the Game, which are automatically tracked and recorded by our servers. We also link your subscriber data with your activity on our Game across all your devices using your email address, phone number, or similar data that you have provided. When you capture a screenshot, we will give you the option to share the screenshot through either an SMS, email, messaging app or social media platform.

Surveys

We collect data through surveys, challenges and competitions in which you may participate including gender, likeness, age and preferences. We also infer your preferences, including your interests, gender and age for the purpose of serving personalized advertising (with your consent, if required under applicable law). We will also process your personal data in order to tell you about services and opportunities.

Messages

Where local laws allow us to, we collect and process, which includes scanning and analyzing, data you provide in the context of composing, sending, or receiving direct messages to and from other players, either directly on our websites and apps or to third party social media account and whether by words, audio, video or photos and your communications with us e.g.in the context of customer support including audio messages. That data includes the content of the message and data about when the message has been sent, received and/or read, as well as the participants of the communication.

We do this to prevent and block spam, prevent and detect crime, safeguard children (where this is in the substantial public interest) or to protect the interests of our users and other people.

Please also be aware that messages sent to other players will be accessible by those players and that we are not responsible for how those players use or disclose them.

Message Boards and Chat Rooms

We may also collect additional data you share about yourself such as on the Game's message boards, chat rooms and in the Game, including comments, images, photos, links, stickers and emojis. Any actions you perform with other players are considered public and are solely at your discretion, and therefore you should have no expectation of privacy or confidentiality. You may choose to disclose data about yourself in the course of contributing user generated content to the Game or in its chat rooms, blogs, message boards, user "profiles" for public view, or in similar forums on its sites through mobile services and/or through third party sites or services. You should be aware that any personally identifiable data you submit in the course of these public activities can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages.

Feedback

We, either directly or indirectly through third-party customer service partners, including Helpshift, also collect data and content of messages you provide to us through your feedback such as product reviews you write, or questions and data you provide for customer support. In this case, we may collect and store your contact data that you give them (i.e. your name and email address), your social network or service user ID number. When you contact us, such as for customer support, phone conversations or chat sessions with our representatives may be monitored and recorded.

Data from Third Parties. You may choose to share certain data with us from third parties or through your use of the Game. We have set out further details on the data we receive from third parties below:

Social Networks

If you choose to register to use the Game using your social network account details (e.g. Facebook, etc.), you will provide us or allow your social network to provide us with your username and public profile (including your name, profile picture, gender, networks, user IDs, list of friends, followers and accounts you follow, date of birth, email address, and any other data you have set to public on your account).

Advertising Service Providers

We use the data collected from you and your interaction with the Game to infer your likely interests to provide you with more relevant advertising. We will obtain your consent to do this where required by applicable law. This data tells us about purchases you have made so that we can predict what else might interest you in the future and assess how effective the advertising on our Game is. We collect this data by the use of Cookies and similar technologies in our Game and from similar data received from third parties who advertise through our Game and whose sites you visit.

Technical Data we collect about you. We automatically collect certain data from you when you use the Game. Such data includes your IP address, time zone settings, language, data regarding the device or hardware you are using to access the Game such as the model of your device, mobile device’s unique identifier (UDID) or serial number, cellular information, WiFi network, identifier for vendor (IDFV), source of user (where you use your account on a third party platform to log in), device screen resolution, mobile carrier, network type, device ID, operating system, Android ID, Google Advertising ID as well as other types of data sent by your device when you access the Game. Where you log-in from multiple devices, we will be able to use your profile data to identify your activity across devices.

Location. We use the 'Region' you select in Settings to customize your Game experience. When you play the Game on a mobile device, we will collect data about your location, including your country, zip code, area code and geolocation. In certain jurisdictions, with your permission, we will collect Global Positioning System (GPS) data and mobile device location data based on your SIM card. If you do not wish to share your precise location with us, you can switch off location services via the settings on your mobile device.

Find other users and invite your friends. You can choose whether to find other users of the Game among your contacts in your preferred social networks who have a Game account. The Game supports and often encourages you to interact with other players. If you choose to find other users through your social network contacts, we will collect your public profile data as well as names and profiles of your social contacts. If you play through a social network or register through a social network, your social network friends will see your name, profile photo and descriptions of your Game activity. Similarly, other players, regardless of whether they are your social network friends or not, will be able to see descriptions of your Game activity and view your Game profile, which may include your name or a “game name” and your profile photo. Other players may also be able to send you Game requests or even friend requests. You can also use this function to invite your contacts to join you in playing the Game. We will use the contact data you have for that person, from Facebook friends (or other similar social network) list and give you the option to send them either an SMS, email or third party message (such as WhatsApp, Facebook (including Facebook Messenger), Instagram, Google, Twitter, Kakao or Line) inviting them to play the Game.

Buy virtual items. If you buy virtual items, subscriptions or advantages via in-app purchases, your purchase will be made via your Apple iTunes or Google Play account. When you play the Game or access any of our other services on connected third-party applications or platforms (like Facebook, Apple, Google, etc.), any purchases you make will be processed by that third-party application and subject to that third-party application’s terms of service and Privacy Notice . We do not collect any financial or billing data from you in relation to such a transaction but may receive non-financial data related to your purchase, like your name and approximate physical location, and the items purchased. Please review the relevant app store's terms and notices in respect of the handling of such data. So that we can credit your account with the correct value in virtual items, we keep a record of the virtual assets/items you own, purchases you make, the time at which you make those purchases and the amount spent.

In addition, if you choose to make other payment related transactions, we may collect payment information, including payment card numbers or other third-party payment information (such as PayPal) where required for the purpose of payment.

Other. Nuverse may also receive either non-personal or public data from third parties in connection with market and demographic studies and/or data that Nuverse may use to supplement personal data provided directly by you. Nuverse may ask some third-party service providers to supplement the personal data that you provide to Nuverse for its own marketing and demographic studies, so that Nuverse can consistently improve its services and related advertising to better meet its visitors' needs and preferences. To enrich its understanding of individual customers, Nuverse may tie this data to the data you provide to us.

2.Cookies

We, our vendors and service providers use cookies and other similar technologies (e.g. pixels, web beacons etc.) (collectively, “Cookies”) to enhance your experience using the Game. We will obtain your consent to the use of Cookies where required under applicable law.

a) What is a Cookie?

Cookies are used to collect data, including personal data, from you. Cookies are small files which, when placed on your device, enable the Game to provide certain features and functionality. Web beacons are very small images or small pieces of data embedded in images, also known as “pixel tags” or “clear GIFs,” that can recognize Cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar data from your computer or device.

Cookies are stored on your browser by website or apps that you visit. When you return to that website or app (or visit websites or apps that use the same cookies) these platforms recognize the Cookies and your browsing device.

b) Categories of Cookies

Cookies do many different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience. Cookies can tell us, for example, whether you have visited the Game before or whether you are a new player. They can also help to ensure that adverts you see online are more relevant to you and your interests.

There are different categories of Cookies, including:

Cookies can remain on your computer or mobile device for different periods of time. Some Cookies are 'session cookies', meaning that they exist only while your browser is open and are deleted automatically once you close your browser. Other Cookies are 'permanent cookies', meaning that they survive after your browser is closed. They can be used by the platform to recognize your computer when you open your browser and browse the Internet again.

c) What types of Cookies do we use and how do we use them?

The types of Cookies and similar technologies used by us and our partners in connection with the Game can be classified into one of five categories, namely 'essential Game Cookies', 'functionality Cookies', 'analytics and performance Cookies', 'targeting and advertising Cookies', and 'social media Cookies'. Cookies do a lot of different tasks to ensure you enjoy your use of the Game, for example, they are used to remember your preferences on sites you visit, to help you navigate between pages more efficiently and to make sure the adverts you see on our Game are relevant to you and your interests. We have set out some further information about each category, and the purposes of the Cookies we and third parties set in the following table.

Cookies that are necessary for essential purposes

These Cookies are essential to provide you with the Game and to use some of its features, such as to enable you to log in. Without these Cookies, we would not be able to provide you with a secure log in account. We use Cookies to uniquely identify you. Each time you log in to the Game, a Cookie containing a unique identifier that is tied to your account is placed on your browser. These Cookies allow us to uniquely identify you when you are logged into the Game and to process your online transactions and requests.

Functionality Cookies

Functionality Cookies record information you have entered or choices you have made. These Cookies also enable you to optimize your use of the Game after logging in so that we can personalize our content for you, greet you by name and remember your preference. These Cookies can also be used to remember settings you have applied. These Cookies mean that when you continue to use or come back to the Game, we can enable you to start the Game from where you left off.

Analytics and Performance Cookies

We use analytics/performance Cookies to analyze how you use the Game, including your level in the Game, measure any errors that occur and test different design ideas. The information is used to report and evaluate your activities and patterns as a user of the Game to provide services in accordance with these activities. These Cookies do not collect information that individually identifies you and all information these Cookies collect is aggregated and anonymous. We also use third-party analytics tools to help us measure traffic and usage trends for the Game (with your consent if required under applicable law).

Targeting or Advertising Cookies

Analytics: As you use the Game, you will notice that it features advertising. We allow third party companies, including advertising companies, to place Cookies in the Game to track the performance of our advertisements (with your consent if required under applicable law). As an example, these Cookies remember which users have used the Game. The information provided to third parties does not include personal data but it may be associated with personal data after they receive it.

Marketing: We may also (with your consent, where required under applicable law) contract with third-party advertising networks that collect IP addresses and other information from the Game, from third party websites and apps. Ad networks follow your online activities and collect information through automated means (such as through the use of Cookies, again, with your consent, if required under applicable law). Ad networks use this information, mainly to serve adverts about products and services that are likely to interest you. We may also partner with third parties to provide certain features in the Game or display advertising based on your web browsing activity. We may also use information from one device to help personalize your experience on another device. For advertising purposes, we may collect your Google Ad ID, Android Ad ID or (where applicable) your IDFA (IDFA stake the place of Cookies in mobile advertising delivered to iOS devices).

Social Media Cookies

Third parties whose applications are connected to the Game by you will set their own Cookies in order to customize their applications for you. Because of how Cookies work, we cannot access these Cookies, nor can the third parties access the data in Cookies used by us. If you are logged in to your account with the third party, the third party will be able to link information about you with your actions via Cookies.

  1. How and for what purpose we use your personal data

We may use the data we collect about you in the following ways:

In accordance with, and to perform our contract with you, we may use your data to:

In order to comply with our legal obligations, we may use your data to:

In accordance with our legitimate interests to provide an enjoyable and safe Game experience, we may use your data to:

4.Who else will access your personal data and how will we share your data

Third Party Game Developer

We work with third party game developers, and the third party developer of the Game will have access to your technical data and other data.

Social Networks

If you choose to register to use the Game using your social network account details (e.g. Facebook etc.), you will provide us or allow your social network to provide us with your user name and public profile (including your name, profile picture, gender, networks, user IDs, list of friends, date of birth, email address, and any other data you have set to public on your account).

If you access third-party services, such as Facebook, to log in to the Game, these third-party services may be able to collect data about you, including data about your activity on the Game, and they may notify your connections on the third-party services about your use of the Game in accordance with their privacy policies.

To manage the data Nuverse receives about you from a third-party application, such as Facebook, you will need to follow the instructions for the third-party application for updating your data and changing your privacy settings. You can also manage some aspects of data collection and use by visiting the “settings” page of your mobile device and reviewing the permissions of each application or “app.” Once Nuverse receives your data from a third-party application or your mobile device, that data is stored and used by Nuverse in accordance with this Privacy Notice . You may access and update that data as described herein.

Payment Provider

If you choose to buy virtual items or make other payment related transactions, we will share data with the relevant payment provider to facilitate this transaction. We share a transaction ID to enable us to identify you and credit your account with the correct value in virtual items once you have made the payment.

Advertising Partners

We may share and/or advertisers and third party measurement companies may collect some of your personal data, for example to show how many and which users of the Game have viewed or clicked on an advertisement. We may also share and/or they may collect non-personal and personal data e.g. IDFA, IP address, time zone settings, browser type, language, operating system, network connection type and speed, and data regarding the device or hardware you are using to access the Game such as the model and make of your device. You may refer to the advertisers' privacy policies for more information.

Please note, after clicking on a third party advertisement, you may no longer be on a site hosted by Nuverse or the social network through which you are playing the Game. If you no longer want to receive tailored in-Game advertisements from third parties, you may adjust your privacy settings.

Our third-party analytics providers use this data to help us serve targeted adverts which may be of interest to you (if you have chosen to receive personalized advertising from us and/or our partners). For more data about how our analytics providers collect data from the Game, please see the above section on Cookies.

We may also share your personal data, such as your email, with advertising service providers, or other platforms that promote the Game, and social media platforms such as Facebook in order to advertise and market the Game to you and monitor our advertising and marketing of the Game, including displaying our advertisements to you when you visit other platforms or social media platforms.

Our Corporate Group

We may also share and/or other members, subsidiaries, or affiliates of our corporate group may collect your data to provide the Game including improving and optimizing the Game, preventing illegal use, and supporting users.

Law Enforcement

We may share your data with law enforcement agencies, public authorities or other organizations if legally required or permitted to do so, or based on our legitimate business interests if such use is reasonably necessary to:

Sale or Merger

We will also disclose your data to third parties:

5.International data transfers

For the purpose of performance of our contract with you, the personal data that we collect from you may be transferred to, and stored at, or otherwise accessed from or processed in a destination outside of your jurisdiction of residence (including Singapore and the United States of America) that has laws and regulations that may not guarantee the same level of security and protection of personal data as your jurisdiction. We will take reasonable and necessary steps to ensure that we handle personal data in accordance with this Privacy Notice and provide a standard of protection that it is comparable with the protection under the laws of your jurisdiction, regardless of where your personal data is transferred to or accessed from.

We will separately obtain your consent for international data transfer if this is required under applicable law.

6.Your rights

You may have the following rights under applicable laws:

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.

Depending on your jurisdiction, you may have additional rights. Please see the jurisdiction-specific section at the end of this Privacy Notice .

Please send an e-mail to legal@marvelsnap.com 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.

In addition:

7.The security of your personal data

We take steps to ensure that your data is treated securely and in accordance with this policy. We understand the importance of keeping your personal data safe and private, and we are committed to protecting your personal data from being lost, stolen or misused.

You are also responsible for keeping your personal data safe. Also, you are responsible for keeping your account details (if any) confidential.

We will, from time to time, 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 that we do not accept any responsibility or liability for these policies. Because Nuverse cannot control the activities of third parties, it cannot accept responsibility for any use of your personal data by such third parties, and it cannot guarantee that they will adhere to the same privacy and security practices as Nuverse. Please check these policies before you submit any data to these websites.

8.How long do we keep your personal data

We retain your data for as long as it is necessary to provide you with the service so that we can fulfill our contractual obligations and rights in relation to the data involved. However, there are occasions where we are likely to keep this data for longer in accordance with our legal obligations or where it is necessary for the establishment, exercise or defense of legal claims.

9.Data relating to children

The Game is not directed at children under the age of 13 and we do not knowingly collect or solicit personal data from children under 13. If you believe that we have personal data about or collected from a child under the relevant age, please contact us at legal@marvelsnap.com and we will ensure that it is deleted.

10.Complaints

In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at legal@marvelsnap.com and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to lodge a claim with the relevant data protection authority.

11.Changes

We will generally notify all users of any material changes to this Privacy Notice , through a notice provided via the Game and providing any other notice required by applicable law. We will also update the “Last Updated” date at the top of this Privacy Notice , which reflects the effective date of such Privacy Notice . By accessing the Game, you acknowledge that you have read this Privacy Notice and that you understand your rights in relation to your personal data and how we will collect, use and process it. If you do not agree to the updated Privacy Notice , you must stop accessing or using the Game.

12.Contact

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

Supplemental Terms – Jurisdiction-Specific

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

EUROPEAN JURISDICTIONS

Germany. If you are using the Game in Germany, the following additional terms apply. If any conflict arises between the additional terms below, on the one hand, and the main Privacy Notice or the additional terms for the European Region (as defined below), the following terms shall prevail: 

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

In the Section 6 (How will we notify you of any changes to this Privacy Notice ?) of the Summary, the following sentence shall be deleted:

European Region. If you are using the Game in EEA, UK and Switzerland (the “European Region”), the following additional terms apply. If any conflict arises between the main Privacy Notice and the additional terms, the following terms shall prevail: In Section 2 (Cookies), the following shall be added:

In Section 3 (How and for what purpose we use your personal data), the following shall be added:

You may withdraw your consent at any time and such withdrawal shall not affect the lawfulness of the processing based on consent before its withdrawal.

The following shall be added to Section 5 (International data transfers):

The following shall amend Section 6 (Your rights):

These rights might be limited under applicable national data protection law.

Please send an e-mail to legal@marvelsnap.com 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.

Section 8 (How long do we keep your personal data) is modified to add:

Section 9 (Data relating to children) shall be replaced with the following:

ASIA-PACIFIC JURISDICTIONS

Australia

The following definition shall apply to the Privacy Notice :

The following shall be added to Section 5 (International data transfers):

The following shall replace Section 12 (Contact):

India.

If you are accessing the Game from India, the Game is provided and controlled by Nuverse. Nuverse is our brand for providing and promoting the services. When using these services from India, please accordingly read “Nuverse”, “we” or “us” in this policy to refer to Nuverse.

New Zealand

The following sentence should be added to the end of Section 5 (International data transfers):

Hong Kong

Section 3 (How and for what purpose we use your personal data) is modified to add:

Japan

The following shall be added to Section 5 (International data transfers):

Macau

In Section 1 (The types of personal data we use), the first sentence of the second paragraph is modified to read:

In Section 3 (How and for what purpose we use your personal data), the first sentence is modified to read:

In Section 4 (Who else will access your personal data and how we share your data), the first sentence is modified to read:

Section 5 (International data transfers) shall be modified as follows:

In Section 6 (Your rights), the following sentence: "The right to object to processing your personal data for the purposes of sending you promotional messages" shall be deleted and replaced with the following:

Section 9 (Data relating to children) shall be modified as follows:

South Korea

Section 3 (How and for what purpose we use your personal data) is modified as follows:

Section 4 (Who else will access your personal data and how we share your data) shall be modified as follows:

Service Providers

We provide data and content to service providers who support our business, such as cloud service and data storage providers, and technical support providers who enhance game operations, improve the Game experience, conduct debugging, and provide general support services. Details of the service providers are as follows:

NamePurposeDuration
Googleenable users to log in via Google account and to use Google Play purchaseSo long the user is using the application
Appleenable users to log in via Apple ID account and use Apple iTunes purchaseSo long the user is using the application
Facebookenable users to log in via Facebook account So long the user is using the application

Section 8 (How long do we keep your personal data) shall be replaced with the following:

Procedure and Method for Destruction of Personal Data

In principle, we will promptly destroy your personal data in our possession once we achieve the purpose of collection and use of your personal data.

Your personal data will be destroyed after storage for a certain period pursuant to our internal policy or applicable laws and regulations (please refer to the provisions on retention and use period). Personal data stored in electronic file format will be deleted by using technical means that will not allow data recovery.

Section 9 (Data relating to children) shall be replaced with the following:

Taiwan

Section 5 (International data transfers) shall be modified as follows:

"The personal data that we collect from you may be transferred to, and stored at, or otherwise processed in destination outside of your jurisdiction of residence, including Singapore and the United States."

The following wording shall be added to Section 6 (Your rights):

Singapore

The following shall be added to Section 5 (International data transfers):

Section 6 (Your rights) shall be deleted and replaced as follows:

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 send an e-mail to legal@marvelsnap.com 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.

Malaysia

The following sentence shall be added in the second paragraph of the Privacy Notice before "If you do not agree with this policy, you should not play the Game":

The following shall be added to Section 5 (International data transfers):

The first paragraph of Section 6 (Your rights) before "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" shall be deleted in its entirety and replaced with the following:

Section 12 (Contact) shall be deleted in its entirety and replaced with the following:

Philippines

The following is added to the "Summary":

The following is added to Section 6 (Your rights):

The following shall replace Section 12 (Contact):

Vietnam

Section 3 (How and for what purpose we use your personal data) is modified to add:

Section 4 (Who else will access your personal data and how we share your data), the first sentence is modified to read:

The Law Enforcement in this Section shall be replaced with:

“We may share your data with law enforcement agencies, governmental, public and regulatory authorities or other organizations (whether in Singapore or another jurisdiction) if legally required or permitted to do so under applicable laws, or pursuant to any court order, or based on our legitimate business interests if such use is reasonably necessary to:

• comply with a legal obligation, process or request by any law enforcement agencies, governmental, public and regulatory authorities (whether in Singapore or another jurisdiction) or any court order, subpoena or search warrant (Nuverse is not required to question or contest the validity of any legal process, search warrant, subpoena or other similar governmental request that it may receive);

• enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation thereof;

• detect, prevent or otherwise address security, fraud or technical issues;

• or protect and defend the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging data with other companies and organizations for the purposes of fraud protection, anti-money laundering prevention, “know your client” checks and credit risk reduction).”

Section 5 (International data transfers), the first sentence is modified to read:

Section 6 (Your rights), the following shall be added:

Section 9 (Data relating to children) shall be replaced with the following:

Thailand

If you are using our services in Thailand, 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.

By accessing and/or using the Game, you represent that you are at least 20 years of age and/or legally competent under the applicable laws. If you are below 20 years old and/or not legally competent under the applicable laws:

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 Game; (ii) your compliance with this policy; and (iii) ensuring that any of your participation in the Game 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 immediately cease accessing the Game.

Indonesia

If you are using our services in Indonesia, 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 apply.

By accessing and/or using the Game, 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 under guardianship:

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 Game.

THE AMERICAS

Canada

The following sentence shall be added in the second paragraph of the Privacy Notice before "If you do not agree with this policy, you should not play the Game":

The following shall be added to Section 5 (International data transfers):

The following shall replace Section 12 (Contact):

The following additional provisions apply only to individuals who reside in Canada.‎

CASL Policy.

We are committed to compliance with Canada’s Anti-Spam Legislation (“CASL”). Any electronic ‎‎communication we send to outside parties is protected by a range of business procedures, processes ‎‎and policies to ensure that such communication is done in compliance with CASL. In our electronic ‎‎communications with outside parties, we comply with the rules established by CASL and enforced by ‎‎various Canadian authorities including the Canadian Radio-television and Telecommunications ‎‎Commission. CASL regulates, and our policies generally apply to, each commercial electronic message ‎‎‎(a “CEM”) that we send. A CEM is an electronic message sent to an electronic address that, among its ‎‎purposes, encourages participation in a commercial activity.‎

In addition to adopting and updating this policy, we undertake various transparency initiatives to ‎ensure ‎we comply with CASL, which include:‎

If you receive a CEM from us but believe that you should not have or no longer wish to receive CEMs, ‎we ‎will aim to respect your preferences in a timely manner once you update them through our ‎unsubscribe ‎mechanism. CASL requires us to process unsubscribe requests within 10 business days. If ‎you have any ‎questions or concerns about our unsubscribe options, you may contact us at the address ‎indicated in ‎Section 12 (Contact).‎

USA

Data relating to children

Section 9 (Data relating to children) is modified to add:

Supplemental California Disclosures

In this section, we disclose information about our data processing practices as required by the California Consumer Privacy Act of 2018 (“CCPA”). These disclosures are addressed only to residents of the State of California. These disclosures do not reflect our collection, use or disclosure of California residents’ personal information where an exception under the CCPA applies.

For the purpose of these supplemental disclosures, personal data as used in the Privacy Notice , shall have the same meaning as “personal information” under the CCPA.

A. Right to Know about Personal Information Collected, Disclosed or Sold

You have the right to request that we disclose what personal information we collect, use, disclose and sell about you specifically (“right to know”). To submit a request to exercise the right to know, please submit an email request to legal@marvelsnap.com and include “California Request to Know” in the subject line. Please specify in your request the details you would like to know, including any specific pieces of personal information you would like to access.

We will ask that you provide certain information to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. We will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.

B. Our Personal Information Handling Practices over the Past 12 Months

We have set out below categories of personal information we have collected about California residents in the preceding 12 months. For each category of personal information we have collected, we have included the reference to the enumerated category or categories of personal information in California Civil Code § 1798.140(o)(1) that most closely describe such personal information.

Category of personal information Corresponding reference to category of personal information under CCPA definition of personal information (Cal. Civ. Code § 1798.140(o)(1))
Name (A) Name
Gender (B) Information that relates to a particular individual
User ID (A) Unique personal identifier
Age (B) Information that relates to a particular individual
Language (B) Information that relates to a particular individual
Email address (A) Email address
Telephone number (B) Telephone number
Information you disclose in your user profile, information you voluntarily elect to provide in order to customize gameplay, information you share on message boards and via in-game communications, and information on your social network account you choose to share with us (B) Information that relates to a particular individual
Profile photograph or video (H) Audio, visual, or similar information.
Purchase history(D) Commercial information
Payment information (B) Credit card number, debit card number, or any other financial information
Login history and information about how you engage and interact with the Game and other players (F) Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement
Preferences (K) Inferences reflecting the individual’s preferences and characteristics.
IP address (A) Internet protocol address
Location (G) Geolocation data
Information about your device, browser and network, including your mobile carrier, time zone settings, device model, network type, device ID, operating system, installed packages and running apps or processes, file names and types, Android ID, and Google Advertising ID (F) Internet or other electronic network activity information
Feedback and survey responses (D) Commercial information, including histories and tendencies

We collect such information from you or your device. If you choose to provide us with information through your social network account, we also collect information about you from the provider of that social network. We may also collect information about your interests, preferences and characteristics from advertising networks and publicly available sources for the purposes of targeting advertising at you. We use your personal information for the purposes set forth in Section 3 of the Privacy Notice above.

In the past 12 months, we disclosed the above categories of personal information to our affiliated and unaffiliated service providers for the purposes listed in our Privacy Notice . If you direct us to share your personal information with other specified third parties, we may disclose information about you with these third parties for the purposes described in your directions. We may also disclose personal information to the recipients described in Section 4 of the Privacy Notice above.

[We do not sell, and in the preceding 12 months did not sell, California residents’ personal information.]

Or

[We may share and/or advertisers and third party measurement companies may collect some of your personal information to help improve your ads experience in the Game or on third party platforms. This sharing of data may constitute a sale under the CCPA. To opt out of the sale of your personal information, visit the Game's settings menu. ]

C. Right to Request Deletion of Personal Information

You have a right to request the deletion of personal information that we collect or maintain about you. To submit a request to delete personal information, please submit an email request to legal@marvelsnap.com and include “California Request to Delete” in the subject line. Please specify in your request the personal information about you that you would like to have deleted, which can be all of your personal information as required by the CCPA.

We will ask that you provide certain information to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. Once confirmed, we will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.

D. Right to Non-Discrimination for the Exercise of CCPA Rights

You may not be discriminated against because you exercise any of your rights under the CCPA in violation of California Civil Code § 1798.125.

E. Right to Information about Direct Marketing Disclosures

Once a calendar year, you may be entitled to obtain information about personal information that we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information, as well as the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year. To request a notice, please submit your request to legal@marvelsnap.com.

Uruguay

In Section 1 (The types of personal data we use), the paragraph under Surveys in “Behavioral and Use Data”, the following sentence will be added:

Section 2 (How and for what purpose will we use the data about you?) of the "Summary" should be amended as follows:

Under Section 6 (Your rights), the first paragraph is supplemented with the following additional rights:

Section 9 (Data relating to children) is amended as follows:

Colombia

The introduction shall be amended as follows:

The following definitions shall be taken into account for Colombia:

1.Data Base: Organized set of personal data that is processed.

2.Personal Data: Any information linked or that can be associated to one or more determined or determinable persons.

3.Data Subject: all the individuals whose Personal Data is processed.

4.Sensitive Personal Data: Personal data that may affect Data Subjects privacy or give rise to discrimination, such as personal data associated with racial or ethnic origin, political orientation, religious or philosophical beliefs, membership of trade unions, social organizations, human rights or that promote the interests of any political party or that guarantee the rights and guarantees of opposition political parties, as well as data concerning health, sex life, and biometric data.

5.Consent: Prior, express and informed authorization granted by the Data Subject to carryout the processing of personal data.

6.Applicable Law: Law 1581 of 2012, Decree 1377 of 2013, Law 1266 of 2008 and other regulations that modify, add or repeal them.

7.Transfer: The transfer of data takes place when the Data Controller in charge of the processing of personal data, located in Colombia, sends the information or personal data to a recipient, who in turn is also a Data Controller for the processing of personal data and is inside or outside the country.

8.Transmission: Processing of personal data that implies the communication of the same within or outside the territory of the Republic of Colombia when the purpose is to carry out processing by a Data Processor on behalf of the Data Controller.

9.Processing: Any operation or set of operations on personal data, such as collection, storage, use, transmission, transfer or deletion.

10.Children or adolescent: person under the age of 18.

11.Data Access Request: “Consults” or “Requests” as mentioned in the Applicable Law.”

The following shall be added to Section 1 (The types of personal data we use):

The following shall be added to Section 2 (Cookies):

The first paragraph of Section 6 (Your rights) shall be supplemented with the following rights under the Colombian Data Privacy Regime:

The following shall be added to Section 9 (Data relating to children):

The following shall be added to Section 10 (Complaints):

Section 11 (Changes) shall be amended as follows:

Argentina

The following sentence should be added to Section 1 (The types of personal data we use):

The following paragraphs should be inserted under Section 6 (Your rights):

The following sentence should be added to Section 8 (How long do we keep your personal data):

Brazil

In Section 6 (How will we notify you of any changes to this Privacy Notice ) of the "Summary, the following sentence shall be deleted:

The following shall be added to Section 3 (How and for what purpose we use your personal data):

In Section 6 (Your rights), the first paragraph is supplemented with the following additional rights:

Section 9 (Data relating to children) is amended as follows:

In Section 11 (Changes), the following sentence shall be deleted:

Section 12 (Contact) is amended as follows:

Mexico

If you are using our services in Mexico, 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. If you are under age 18, you may only use the Game with the consent of your parent or legal guardian. Please be sure your parent or legal guardian has reviewed, discussed and agreed to these Terms, with you.

MIDDLE EAST JURISDICTIONS

Bahrain

The following shall amend the first paragraph of Section 6 (Your Rights):

Section 9 (Information relating to children) shall be replaced with the following:

Israel

In Section 1 (The types of personal data we use), the first paragraph (before the words "We collect and use…") shall be amended in its entirely, as follows:

In Section 1 (The types of personal data we use), under the section Data You Provide to Us, Including Your Profile Data, the following sentence shall be added after the first paragraph:

In Section 3 (How and for what purpose we use your data), the following shall be added:

In Section 5 (International data transfers), after the sentence "The personal data that we collect from you may be transferred to, and stored at, or otherwise processed in a destination outside of your jurisdiction of residence", the following shall be added:

In Section 6 (Your Rights), the first paragraph (before the words “Before we can respond to a request to exercise one or more of the rights listed above …”) shall be amended as follows:

Section 9 (Data relating to children) shall be replaced with the following:

In Section 11 (How will we notify you of any changes to this Privacy Notice ) of the "Summary", the sentence "…you acknowledge that you have read this policy and that you understand your rights in relation to your personal data and how we will collect, use and process it", shall be deleted, and replaced in its entirely with the following:

Qatar

The following shall replace the first paragraph of Section 6 (Your Rights):

1.Have us notify you of the processing of your personal data and the purposes for which such processing is conducted and to notify you of any disclosure of inaccurate personal data, subject in each case to any restriction which arises in the relevant circumstances under the applicable law;

2.Obtain a copy of your personal data held by us upon payment of the service fee;

3.Withdraw your consent to the processing of your personal data subject to any overriding requirement of applicable law and provided that such withdrawal shall not affect the lawfulness of the processing based on consent before its withdrawal;

4.Object to the processing of your personal data if that is found to be unnecessary to achieve the purposes for which it was collected or if it is in excess of the requirements, discriminatory, unfair or against the law;

5.Request the deletion or erasure of your personal data in cases 3 and 4 referred to above or upon the achieving of the purpose for which it was processed or if there is no reason for us to keep it; and

6.Request the correction of your personal data, subject to you providing us with reasonable evidence as to the validity of your request.

Section 9 (Data relating to children) shall be replaced with the following:

Section 10 (Complaints) shall be replaced as follows:

Turkey

Data Controller Representative. You may contact our data controller representative in Turkey by email or mail to handle questions and complaints in connection with the processing of your personal data if you are in Turkey.

legal@marvelsnap.com

Section 2 (Cookies) shall include the following:

Section 3 (How and for what purpose we use your data) shall include the following:

You may withdraw your consent at any time and such withdrawal shall not affect the lawfulness of the processing based on consent before its withdrawal.

References in this policy to the 'performance of contract' as a legal basis refers to the legal basis under Article 5(2)(c) of the Turkish Data Protection Law, where the processing of your personal data is necessary for and directly related to the establishment and/or performance of our contract with you.

References in this policy to 'our legal obligations' or 'legal requirements' as a legal basis refers to the legal basis under Article 5(2)(ç) of the Turkish Data Protection Law, where the processing of your personal data is mandatory for compliance with our legal obligations under applicable laws; and/or Article 5(2)(a) of the Turkish Data Protection Law, where the processing is expressly laid down in laws.

References in this policy to our 'legitimate interests' or 'legitimate business purposes' as a legal basis refers to the legal basis under Article 5(2)(f) of the Turkish Data Protection Law, where the processing of your personal data is mandatory for our legitimate interests, provided that it does not violate your fundamental rights and freedoms.

References in this policy to 'the establishment, exercise or defense of legal claims' refers to the legal basis under Article 5(2)(e) of the Turkish Data Protection Law, where the processing of your personal data is mandatory for the establishment, exercise or defense of a legal claim.”

Section 6 (Your rights) shall be amended as follows:

Please send an e-mail to legal@marvelsnap.com if you would like to exercise any of your rights. 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.

We will respond to your request 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 us, then you may be charged over the tariff fee determined by the Turkish Personal Data Protection Board. ”

Section 9 (Data relating to children) shall be replaced with the following:

United Arab Emirates

Under heading “Targeting or Advertising Cookies” in Section 2 (Cookies), amend the paragraphs as follows:

Under heading “Analytics and Performance Cookies” in Section 2 (Cookies), amend the last sentence of the paragraph as follows:

In Section 3 (How and for what purpose will we use the data about you?) of the “Summary”, the last sentence shall be amended as follows:

Egypt

If you are using our services in Egypt, 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.

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 Privacy Notice and Terms of Use and agree to the use by your child of the Services and registration for an account.

South Africa

If you are using our services in South Africa, 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.

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 Privacy Notice and Terms of Use and agree to the use by your child of the Services and registration for an account.