Privacy Policy

Posted: 20^th of June 2024

Effective as of 20^th of June 2024

At Next Genium FZCO, a company incorporated in IFZA, UAE with license number 37310 (hereinafter Next Genium), we respect your privacy and want to give you the best possible experience to ensure that you enjoy our Website and games. Your privacy and the security of your Personal Data are, and will always be, enormously important to us. So, we want to transparently explain how and why we collect, store, share and use your Personal Data – as well as outlining the controls and choices you have in respect of Personal Data we hold about you.

Capitalised terms used in this Privacy Policy have the meanings given to them in the Definitions section below. Unless specifically defined, any capitalized terms used throughout this Privacy Policy (but not defined herein) shall have the same meaning attributed to it in User Agreement.

Please read this Privacy Policy carefully before using the Website or submitting any information to us. By accessing the Website, you acknowledge that you have read, understood, and agreed to this Privacy Policy, as amended from time to time. We may, from time to time, amend this Privacy Policy or parts of it in accordance with clause 1.2 below. If you do not agree to any part of this Privacy Policy, you must immediately cease accessing our Website or using any of our games.

Definitions:

• “comply with a legal or regulatory obligation” means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject to;
• “Data” means personal and non-personal User’s data that is submitted, generated, featured and displayed through the Website, collected from the use of the Website or the games and stored on Next Genium’s servers.
• “legitimate interest” means the interest of our business in conducting and managing our Website or games to enable us to give you the best and most secure experience. We consider and balance any potential impact on you and your rights before we process your Personal Data for our legitimate interests;
• “Personal Data” means any information that specifically identifies an individual (such as a name, address, photo, telephone number, mobile number, e-mail address, birthday, office location, professional and personal interests, company name, title, department, spoken languages) or information about that individual that is directly linked to personally identifiable information;
• “Website” means our website, available at https://next-genium.com/;
• “Privacy Policy” means all of the privacy policies, practices and notices contained or referenced in this document (as amended from time to time) and all other Next Genium rules and policies in relation to our data practices that may be published from time to time on the Website;
• “User”, “you” and “your” collectively mean the person that has visited or is using the Website and/or the games.
• “Next Genium”, “we”, “our” and “us” means Next Genium FZCO, a company incorporated in IFZA, UAE with license number 37310.

1. Important Information

1.1. Purpose of This Privacy Policy:

This Privacy Policy aims to give residents of UAE information on how Next Genium collects and processes their Personal Data through use of the Website, including any Data you may provide through the Website when you visit the Website, use any our games and/or sign up to any Next Genium newsletter or waitlist.

This Privacy Policy applies to your use of our Website and/or games and all information we collect through our Games. By accessing and using the Website, you (i) agree irrevocably and without condition to this Privacy Policy, (ii) consent to your Personal Data being collected, processed, used and shared in accordance with this Privacy Policy, and (iii) agree that we may provide notices to you electronically on the terms and conditions set forth in this Privacy Policy.

It is important that you read this Privacy Policy together with any fair processing notice we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your Personal Data. This Privacy Policy supplements the other notices and is not intended to override them.

1.2. Changes to the Privacy Policy

You agree that Next Genium may amend this Privacy Policy from time to time, and in Next Genium’s sole discretion. Next Genium is not obliged to give prior notice of any amendments to this Privacy Policy, but will provide advance notice of such amendments, where possible.

Next Genium will publish any amendment or change to this Privacy Policy or any part of it on the Website and will specify the date on which such amendment becomes effective. Your continued use of the Website and/or any games after the stated effective date constitutes your acceptance of the relevant revised policy, amendment or change.

You agree and undertake to review our Privacy Policy each time you visit our Website and/or prior to each use of our games. If you do not agree to our Privacy Policy, as updated from time to time, you undertake to cease using our Website and/or games immediately.

1.3. Your Duty to Inform Us of Any Changes in Your Personal Data

Please note that it is crucial to the performance of our Website or games and correct working of the Website that the Personal Data we hold about you is accurate and current. Please keep us informed and updated if your Personal Data changes during your relationship with us. You may review and update your Personal Data by contacting us at support@next-genium.com.

1.4. Third-Party Links

Our Website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third-parties to collect or share Data about you. We do not control these third-party websites, plug-ins and applications, whether or not they operate on top of the Website or on an external website, and are not responsible for their privacy statements. When you engage such third-party website, plug-in or application, whether or not you have left our Website, we encourage you to read the privacy policy of each website, plug-in or application you visit or engage with. Data and payment API providers and the Payment Gateway Provider that we may work with from time to time have their own privacy policies and we are not responsible for any of their actions or omissions, including their information protection practices.

2. The Data We Collect About You

2.1. Depending on which of our games you use and how you interact with our Website, we collect different kinds of information from or about you. We may collect, use, store, share, transfer or otherwise process different kinds of Personal Data about you which we have grouped together as follows:

• 2.1.1. Identity Data includes first name, last name.
• 2.1.2. Contact Data includes physical address, email address, and mobile number. By giving us your phone number through Website you agree to receive the calls and SMS from employees of Next Genium only regarding your specific request.
• 2.1.3. Technical Data includes internet protocol (IP) address, your login data, browser type and version, model of your mobile phones and computers and their device identification number, operating system, hardware version, device settings and other technology identification on the devices used to access our Website, file and software names and types, time zone setting, device locations such as through GPS, Bluetooth or Wi-Fi signals, browser plug-in types and versions, connection information such as the name of your mobile operator or ISP, or language setting.
• 2.1.4. Usage Data includes information about how you use our Website, games, products and how you use your devices to access our Website, including the pages you visit and searches you make.
• 2.1.5. Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
• 2.1.6. Contacts Data includes information that we collect from your contacts when you grant us access to your phonebook contacts. This includes your contacts’ names and phone numbers.
• 2.1.7. Other Personal Data includes:

• any other data uploaded onto our Website by you;
• communications with us via social media platforms, email, electronic messages and other electronic and non-electronic communications;
• third-party partner information related to how you use our third-party partners, such as your reviews of our partners or other service providers;
• your networks and connections made available to us, depending on the permissions you have granted, from your mobile and desktop devices’ address book contacts, and other social media such as Facebook, Instagram and Twitter.

2.2. We also collect, use and share aggregated Data such as statistical or demographic Data for any purpose. Aggregated Data may be derived from your Personal Data but is not considered Personal Data as this Data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of Users accessing a specific Website feature.

2.3. We are dedicated to providing safe and secure access to the Website and games. Therefore, before permitting you to use the games, we may require additional information from you which we can use to verify your identity or other information or to manage risk and compliance throughout our relationship.

2.4. We may also collect additional information from or about you in other ways. For example, we may collect information related to your contact with our customer support team or store results when you respond to a survey or provide us with your feedback.

2.5. We do not collect any Personal Data about racial or ethnic origin, communal origin, political affiliations or opinions, religious or philosophical beliefs, trade-union membership, health, sex life or genetic data. Please note however that in order to verify your identity, maintain the security features of the games and comply with the applicable laws and regulations, we may need to process your face biometric data.

2.6. Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that Personal Data when requested, we may not be able to provide you with certain features of our Website or games. In this case, we may have to cancel your access to such features of the Website or games. We will notify you if this is the case at any time.

3. How Is Your Personal Data Collected?

We use different methods to collect Personal Data from and about you through the following categories of sources:

• When you communicate with us in writing, by telephone, fax, email or through the Website or other forms of electronic communication or when you submit information to us or allow us to access information;
• From publicly available sources or from third-parties, most commonly where we need to conduct background checks about you. This may include third-party verification services;
• Your devices and how you interact with our games. You may give us your Personal Data by filling in forms on the Website. This includes Personal Data you provide when you:
  • enter data for using any Next Genium websites;
  • purchase or play our games;
  • subscribe to our publications;
  • sign up for any waitlist or otherwise give us your contact information;
  • enter a competition, promotion or survey;
  • correspond with us (online or offline including via email addresses and phone numbers), if you contact us;
  • give us feedback and/or review our games.
• Automated technologies. As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies;
• From our group companies or affiliates based on your consent to transfer such data to us;
• Technical Data from the following parties:
  • analytics providers such as Google;
  • advertising networks/agencies;
  • search information providers.

4. How Do We Share Your Information?

• 4.1. Information Shared with Everyone in The Community: We do not share your data in public media.
• 4.2. Information Shared with Other Next Genium Users: We do not share your data with other users.
• 4.3. Information Shared with our Affiliates and Group Companies: We may share your Personal Data with our affiliates and group companies to improve our games.
• 4.4. Information Shared with our Service Providers: We may share your Personal Data with:
  • Third party service providers that assist us in providing our games to you (for example, different game stores);
  • Our professional advisers where it is necessary for us to obtain their advice or assistance, including lawyers, accountants, IT or public relations advisers;
  • Service providers that help us run our marketing and advertising campaigns, contests, special offers, or other events or activities;
  • Other third parties with your consent or at your direction to do so, including if you authorize an account connection with a third-party account or platform.
• 4.5. Business Transfer: In the event that Next Genium is involved in a merger, acquisition, reorganization, sale of assets or bankruptcy, your information may be transferred as part of that transaction. The promises in this Privacy Policy will apply to your information as transferred to the new owner or entity.
• 4.6. Protection of Next Genium and Others: We may release Personal Data when we believe that disclosure is reasonably necessary (i) to comply with any applicable law, regulation, legal process or governmental request; (ii) to exercise or defend our legal rights; (iii) to enforce other applicable agreements or policies; (iv) to protect our or our customers’ or the public rights or property, or the security or integrity of our games from harm, fraud, or potentially prohibited or illegal activities or otherwise; or (v) for an investigation of suspected or actual illegal activity.
• 4.7. Aggregated and Anonymized Information: We may share aggregated and anonymized information that does not specifically identify you or any User of our games with service providers or other third parties.

5. How We Use Your Personal Data

We may collect, use and share your Personal Data for the following reasons:

• 5.1. Performance of our obligations: We process your Personal Data because it is necessary for the Performance of our obligations. In this respect, we use your Personal Data for the following:
  • To determine whether our games are available in your country;
  • To answer any questions you may have;
  • To deal with any complaints you may have;
  • To send you surveys and collect any feedback you may have or to send you information we think you may find useful or which you have requested from us about our games. For avoidance of doubt, you agree that we may communicate with you in a number of ways for the purpose of collecting your feedback, including through the Website, by email, telephone, or through other digital channels. Please contact us at support@next-genium.com if you wish to withdraw your consent to receive communications from us seeking feedback;
  • To develop new products and games (such as machine learning based tools) to better serve you;
  • To track and analyze usage in connection with your use of our games; and
  • To issue reports/analytics on a no name basis for business and marketing purposes.
• 5.2. Legitimate interests: We also process your Personal Data because it is necessary for our legitimate interests, or sometimes where it is necessary for the legitimate interests of another person. In this respect, we use your Personal Data for:
  • The administration and management of our business, including recovering any money you may owe to us;
  • Seeking advice on our rights and obligations, such as where we require legal advice;
  • Contacting you to resolve disputes;
  • Investigating, detecting, preventing, recovering from, or reporting fraud, misrepresentations, security breaches or incidents, other potentially prohibited, malicious, or illegal activities;
  • Protecting your, our, or our other Users’ rights or property, or the security or integrity of our games; and
  • Verifying or maintaining the quality and safety of our games.
• 5.3. Legal obligations: We also process your Personal Data for our compliance with legal obligations which we are under. In this respect, we will use your Personal Data for the following:
  • Meeting our compliance and regulatory obligations, enforcing any applicable laws, regulations, legal requirements, and industry standards (such as compliance with anti-money laundering laws) and responding to lawful requests for information from the government or in relation to any legal process; and
  • As required by tax authorities or any competent court or legal authority.
• 5.4. Marketing: We may send you marketing about the games we provide which may be of interest to you, as well as other information in the form of alerts, newsletters and invitations to the events or functions which we believe might be of interest to you or in order to update you with information (such as legal or commercial news) which we believe may be relevant to you. We may communicate this to you in a number of ways including through the Website, telephone, SMS, email, post or other digital channels. You have the right to withdraw/unsubscribe your consent to marketing emails/newsletters at any time by contacting us at support@next-genium.com.
• 5.5. Promotional offers from us: We may use your Identity Data, Contact Data, Technical Data, Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which games and offers may be relevant for you. You may receive promotional marketing communications from us if you have requested information from us or used our games and, in each case, you have not opted out of receiving that promotional marketing communication.
• 5.6. Other reasons: For any other reason for which you provide us with your Personal Data and express consent to its processing.

6. Cookies

6.1. Our website uses web technologies such as cookies to distinguish you from other users of our site. This helps us to provide you with a good experience when you use our Website. We use the following cookies:

• 6.1.1. Strictly necessary cookies: These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website.
• 6.1.2. Analytical/performance cookies: They allow us to recognise and count the number of Users and to see how Users move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that Users are easily finding what they are looking for.
• 6.1.3. Functionality cookies: These are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by your name and remember your preferences (for example, your choice of language or region).
• 6.1.4. Targeting cookies: These cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

6.2. While we set some of these automated technologies ourselves, some of them are set by third parties who provide services to us. For example, we may use other companies’ web analytics services such as Google Analytics, which use automated technologies to help us evaluate how our Users use our Website.

6.3. You can set your browser to refuse all or some browser cookies or to alert you when our Website sets or accesses cookies. If you use a mobile device, you can manage how your device and browser share certain device data by changing the privacy and security settings on your mobile device. If you disable or refuse cookies, please note that some parts of our Website may become inaccessible or not function properly.

7. Change of Purpose

We will only use your Personal Data for the purposes for which we collected it in accordance with this Privacy Policy or any applicable agreement between us and You, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. We will start processing such data only after obtaining your express consent to do so. Please note that we may process your Personal Data without your knowledge or consent, in compliance with this Privacy Policy, where this is required or permitted by law.

8. Data Security

Your data security is important to us, and we take reasonable steps to ensure that your Personal Data is treated securely and to prevent unauthorised access, collection, use, disclosure, or similar risks.

We have put in place appropriate security measures to limit the possibility of your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

Although we aim to create a safe and secure environment, we cannot guarantee absolute security of the transmission or storage of your information. To the extent permitted by applicable law, we expressly exclude any liability arising from any unauthorised access to your Personal Data.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. Your Choices

9.1. You May Withdraw Your Consent

If you wish to stop processing of any of your Personal Data you may send us notification about your intent at support@next-genium.com. We will delete such information about you as soon as practicable possible. Provided however, that withdraw of consent to processing of certain data may make it is impossible for you to use any of our games for which such data is crucial. Withdrawing of your consent does not impact on processing of personal data that we shall process in accordance with regulatory obligations.

9.2. You May Ask to Access to Your Data

As a data subject you have the right to obtain from us free information about your personal data processed at any time and a copy of this information. Furthermore, you will have access to the following information: the purposes of the processing; the categories of personal data concerned; where possible, the envisaged period for which the personal data will be processed, or, if not possible, the criteria used to determine that period; the existence of the right to request from us rectification or erasure of personal data, or restriction of processing of personal data concerning you, or to object to such processing; the existence of the right to lodge a complaint with a supervisory authority; where the personal data are not collected directly from you, any available information as to their source; and the existence of automated decision-making, including profiling, and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for you.

9.3. You May Change Your Personal Information

Depending on the type of the information, you may access, review, change, or correct such information by making a request to us by contacting us at support@next-genium.com. We may require additional information to verify your identity before granting access or otherwise changing or correcting your information.

9.4. You May Cease Our Collection of Location Information

In order to provide certain features of the Website or games, we may need to access to your location information, including precise geolocation information collected from your device. If you do not consent to collection of this information, such certain features may not function properly and you may not be able to use them. You can stop our collection of location information at any time via the settings on the Website. If you do so, some of such features may cease to function.

10. Data Transfers

The Personal Data we collect from you may be transferred to, and stored at, a destination outside the UAE as it may be processed by our affiliates and group companies, or by our service providers when they are located outside of the UAE.

Where required for certain matters, we may use service providers located outside the UAE and transfer Personal Data to such service providers (for example, fraud prevention, anti-money laundering, know your client or know your business checks, payment processing, client verification services or technology services).

Depending on the circumstances we may also need to transfer Personal Data to other kinds of third parties, for example regulators, government authorities, law enforcement authorities (such as police) as necessary.

11. Data Retention

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, we may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

12. Information from Children

Although the majority of our services and games are intended for adults, We recognize the importance of protecting the privacy of children who may access our Website and games. We strive to ensure that children who access our Website and games receive age-appropriate experiences by employing data minimization, privacy by design, and default practices. We consider the best interests of children when determining the age-appropriate experience they receive and take into account the developmental maturity of children of different ages. When children reach the age of majority in their country or territory, they may receive the adult experience.

When players identify themselves as being children under the minimum age of digital consent guidelines set by the law of individual countries or territories, we will:

• obtain consent from parents for the use of their children’s personal information, when required by applicable law;
• disable features in certain games that could allow a child to share information that directly identifies them, unless a parent has provided relevant consent to us or the third-party platform on which their child is playing;
• collect and use certain information for limited purposes only. For example, we may send notifications, which do not rely on collecting personal information. Also, persistent device identifiers like IP address or advertising device identifier may be collected to support our internal operations, such as:
  • Delivering the games;
  • Maintaining or analyzing the functionality of the games;
  • Serving contextual ads or frequency capping;
  • Protecting the security or integrity of the user of Website; or
  • Legal or regulatory compliance;
• not condition a child’s participation in an activity (such as gaming contests) on the disclosure of more personal information than is reasonably necessary to participate in the activity. With certain game-related activities, we may not permit children to participate at all, even if we have consent; and
• offer parental controls and choices. If you are a parent or guardian and wish to revoke your previously provided consent, review information collected from your child or have that information deleted, please contact us via the options in How to Contact Us. If we become aware that a child has provided us with personal information without parental consent, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account and/or revert them to the age-appropriate experience, as applicable.

If we make material changes to how we collect, use, share or otherwise process your child’s personal information, we will notify parents as required by applicable law.

We encourage you to talk with your children about communicating with strangers and the risks of disclosing personal information online. You and your child should review the privacy settings applicable to their use of our Website and games.

13. How to Contact Us

If you have questions or concerns regarding this Privacy Policy, or any feedback pertaining to your privacy that you would like us to consider, please contact us at support@next-genium.com.