NIO PLAY PRIVACY POLICY
Version 1.1.3
Last updated: April 9, 2024
AT NIO, WE ARE COMMITTED TO PROTECTING THE PRIVACY OF OUR CUSTOMERS AND MAINTAINING TRANSPARENCY.
NIO OPERATES THE NIO PLAY WEBSITE AND ANY SUBPAGES, SUBDOMAINS, SUCCESSOR SITES OR ANY APPLICATION ACCESSIBLE VIA OUR WEBSITE (WWW.NIOPLAY.NET).
AT NIO, WE PRIORITIZE YOUR PRIVACY AND AIM TO MAINTAIN YOUR TRUST. THIS POLICY EXPLAINS HOW WE COLLECT, USE, MAINTAIN, AND SHARE INFORMATION OBTAINED FROM OUR WEBSITE.
WE ARE DEDICATED TO FULFILLING OUR OBLIGATIONS UNDER VARIOUS NORTH AMERICAN DATA PRIVACY LAWS, SUCH AS THE CALIFORNIA CONSUMER PRIVACY ACT (CCPA) AND ITS AMENDMENTS LIKE THE CALIFORNIA PRIVACY RIGHTS ACT (CPRA), ALONGSIDE THE VIRGINIA CONSUMER DATA PROTECTION ACT AND THE CANADIAN PERSONAL INFORMATION PROTECTION AND ELECTRONIC DOCUMENTS ACT (PIPEDA).
TABLE OF CONTENTS
1. DEFINITIONS
2. DATA CONTROLLER
3. TYPE OF INFORMATION WE COLLECT
4. HOW WE COLLECT YOUR INFORMATION
5. PERSONAL INFORMATION COLLECTED VIA TECHNOLOGY
6. HOW WE USE COLLECTED INFORMATION
7. HOW WE SHARE INFORMATION
8. YOUR PRIVACY RIGHTS
9. HOW WE PROTECT YOUR INFORMATION
10. HOW LONG WILL WE RETAIN YOUR INFORMATION
11. SHARING YOUR INFORMATION
12. MINORS
13. CHANGES TO THIS PRIVACY POLICY
14. CONTACTING US
1. DEFINITIONS
Aggregate Information pertains to data concerning groups or categories of customers, which lacks the ability to identify or reasonably be utilized to identify individual customers.
Anonymous Information denotes data that does not directly or indirectly identify, and cannot reasonably be utilized to identify, an individual. If this anonymous information becomes linked with personal information, the resulting data is considered Personal Information.
Personal Information refers to any information regarding you, regardless of its accuracy, that can reasonably be utilized to identify you or make you identifiable.
NIO - The term "NIO" (referred to as “NIO Consolidated, LLC”, “Nio Virtual Interactive, Limited”, “We”, “Us”, or “Our”) encompasses NIO Consolidated, LLC and its subsidiary companies, including Nio Virtual Interactive, Limited, Enam 21 Consulting, LLC, Artisan 9, Incorporated, collectively forming the NIO Consolidated Group. These entities are responsible for collecting, using, maintaining, and disclosing information obtained from the Website, in accordance with this Privacy Policy.
2. DATA CONTROLLER
NIO Consolidated, LLC is the organization entrusted with managing the data gathered from your usage of the Website, including any information you provide during product or service purchases, or participation in promotions or competitions.
3. TYPE OF INFORMATION WE COLLECT
3.1. These are the three types of information which are defined in section 1, Definitions.
v Anonymous Information
v Aggregated Information
v Personal Information
Any further information that we receive and classify as your Personal Information will also be regarded as such by NIO.
3.2. The kinds of information we may handle depend on the business context and the reasons for its collection. This could involve:
3.3. Personal Information, such as gender, age, age range, or images of you; and account login details, including your username, password, and profile pictures associated with your account.
3.4. Contact Details, comprising your given name and surname, email address, home address, and mobile or alternative phone numbers.
3.5. Transaction Information - Information regarding transactions that you provide when making a purchase, requesting a redemption, or engaging with the Website. This may include your postal address, phone number, as well as payment or redemption details, such as banking and financial information, credit card details, and bank account statements (please note that we do not retain your complete card details).
3.6. Geolocation Information, which includes approximate location details obtained from a mobile device or other interacting device on the Website, or linked to your IP address, where processing such data is permitted by law.
3.7. Sensitive Information, which could consist of government-issued identification (like driver's licenses, passports, and social security numbers), geolocation, and financial details, necessary to fulfill our business, legal, and regulatory requirements.
3.8. Usage Data consists of information regarding your usage of the Website, including activity, technical details, and device information. This may cover the content you view, the duration of your visits, how frequently you use our services, how you discovered our website initially, your preferences, interaction with Website content, hardware details, unique device identifiers, operating system version, browser type, and IP address.
3.9. Information sourced from third parties, such as site or platform providers (including Facebook and Google), regarding your usage of our services or your interest in them.
4. HOW NIO COLLECT YOUR INFORMATION
4.1. Information you provide to us directly.
4.2. This involves data collection occurring when you visit our website, sign up, make purchases, participate in surveys, complete forms, and engage in other activities, services, features, or resources available on our Website.
4.3. We obtain information from you via telephone, video calls, or correspondence (including email, live chat, mail, text message, or social media). Please be aware that any telephone or video calls with NIO representatives may be recorded for training, quality control, and compliance purposes. Your continued participation in such calls implies your consent to recording.
4.4. Information gathered while you utilize our services.
4.5. We also gather information about how you use our products and services through various technologies deployed when you visit our websites, including the Website, or utilize our applications on third-party sites or platforms, regardless of whether you are logged in or registered. These technologies include cookies, flash cookies, application programming interfaces (APIs), pixels, and tags. More details can be found in Section 5, "Personal Information Collected via Technology." Additionally, we use analytics tools to collect information when you visit our website or use our applications or services on third-party sites or platforms.
4.6. Data obtained from third-party service providers.
4.7. Lastly, we utilize reliable sources to update or complement the information you've provided, or we've gathered. This includes verification or validation of data, such as postal addresses, documentation, and names.
5. PERSONAL INFORMATION GATHERED THROUGH TECHNOLOGY
5.1. We and our service providers utilize industry-standard identifiers like cookies or similar technologies to offer an improved user experience.
5.2. These technologies allow us to gather certain details whenever you visit or interact with the Website. This information may include your browser type, operating system, device type, an approximate geographic location based on your IP address, the location of your mobile device, the served page, the time, referring URLs, and other standard information transmitted in HTTP requests.
5.3. This statistical data provides insights into your usage of our services, including your engagement with pages, the type of content viewed, and the duration of each visit. While this information is usually non-identifying, if NIO connects it to you as an identifiable individual, it will be treated as Personal Information according to our policies.
5.4. Examples of such technologies include:
a. APIS. APIs serve as a notable instance. They enable different software systems to communicate with each other, simplifying tasks for programmers and improving user experiences.
b. These are small text files placed in your device's browsers to store preferences. Cookies aid in understanding your behavior, including for security and fraud prevention purposes. They inform us about visited websites and facilitate advertisements and web searches. Upon first accessing our website, you'll have the option to enable or disable cookies via our cookie banner. You can revisit this choice anytime by accessing the cookie toolbar in your browser. While most browsers enable you to block and delete cookies, disabling all cookies may result in certain features of the service being unavailable or functioning improperly.
c. Event tagging. Event tagging, which includes Facebook App Events, enables us to monitor actions happening on the website, such as application installations and purchase events. By tracking these events, we can analyze analytics, measure ad performance, and develop ad targeting audiences. D
d. Mobile device Identifiers. Mobile device identifiers: When you download or access our products on a mobile device, we and our service providers may gather information, including your geolocation (derived from your IP address), and details about your mobile device such as advertising identifiers, hardware type, operating system, and in-game activity. We may share your mobile device or tablet's advertising identifier (e.g., Apple's IDFA, Google's Advertising ID) with advertisers to deliver tailored advertising and content. If you download or access our games on your mobile device, we may request permission to track your activity. You can revoke this permission later through your device settings. Furthermore, if you prefer not to receive personalized advertisements from third parties, you can opt-out by adjusting your device's ad tracking settings (e.g., enabling "Limit Ad Tracking") and resetting the advertising identifier. Depending on your platform provider (e.g., Apple, Google), you may also have the option to download apps like the Digital Advertising Alliance's "AppChoices," which allow you to control the collection and use of your cross-app data for personalized advertising. For more information about advertising choice mechanisms, you can visit the NAI's Mobile Choices page [here](insert link).
e. Pixel tags/web beacons: A pixel tag, also known as a web beacon, is a code snippet embedded on the website to collect information about user engagement on that webpage. Using a pixel allows us to track activities such as user visits to specific webpages or clicks on particular advertisements. Additionally, we may include web beacons in emails to gauge if messages have been opened, acted upon, or forwarded.
5.5. For more details about these technologies and how to exercise your rights, please consult our Cookie Notice.
6. HOW WE USE COLLECTED INFORMATION
6.1. We utilize the collected information to operate our website and deliver our products and services effectively. This includes facilitating financial transactions, addressing inquiries, and meeting all relevant regulatory obligations, such as conducting anti-fraud checks and other checks mandated by applicable anti-money laundering and other legislation.
6.2. There might be instances where we gather and utilize your information for the following particular purposes:
a. To deliver and oversee the services you request: This encompasses tasks such as processing your registration, establishing and maintaining your account, and conducting necessary checks to prevent fraud.
b. Enhancing customer service and refining our services: The information you provide enables us to respond to your customer service inquiries more effectively. Additionally, we may utilize the feedback you offer to enhance our products and services.
c. Facilitating payment processing: The information you provide when placing an order is used to fulfill that order, including meeting our customer due diligence requirements and establishing the source of funds when necessary.
d. Customizing user experiences: We may utilize aggregated information to gain insights into how our users, as a collective, utilize the services and resources available on our website.
e. Contacting you regarding our services, including marketing purposes: We may communicate with you via email, live chat, telephone, text message, mail, or social media regarding your use of our services and products. This includes information about your accounts, offers, promotions, competitions, online surveys, new features, and other important updates. Please refer to section 8, "Your Privacy Rights," for details on how to opt out.
f. Sending crucial notifications to you: Occasionally, we may send significant notices to you, such as communications regarding purchases you've made or legal notices about changes to our terms and conditions or other policies. These communications are vital to your engagement with us, and you recognize that opting out of receiving these messages may not be possible.
g. Adhering to our legal and regulatory responsibilities: We may use the information we collect about you to analyze your social gameplay activity for responsible social gaming purposes, taxation requirements, compliance with fraud and anti-money laundering laws (including determining the source of funds for transactions), or fulfilling other legal or regulatory obligations (including identifying, investigating, and preventing activities that violate our Terms and Conditions or may be illegal).
h. Providing alternative dispute resolution services: We may disclose the information we gather about you to our service provider for the sole purpose of resolving any disputes that remain unresolved through our internal processes.
i. Performing market research and analysis: We may use the information we collect about you to study your engagement with our products and services, track and analyze usage trends and activities, and for other research, analytical, and statistical objectives.
6.3. Targeted Advertising based on User Behavior
a. We may collaborate with a third-party service provider to: (a) showcase advertising on our Website or any application accessible via our Website; and (b) oversee our advertising on other websites (for instance, employing custom audiences on Facebook) to enhance the relevance of advertisements. As per certain US state privacy laws, consumers retain the right to opt out of the sharing or sale of their Personal Information with third parties for targeted advertising, also referred to as behavioral advertising. In this context, "behavioral advertising" denotes advertisements that may be tailored to you based on your data collected through technologies like cookies, which gather information about your activities on our Website and other websites.
6.4. If you prefer to opt-out of behavioral advertising, please click here (or if you are located in Canada, click here). Please be aware that you will still receive generic advertisements.
7. SHARING INFORMATION
7.1. For behavioral advertising purposes, the following data categories may be shared:
A. Licensing data and Subscription
B. Contact data and Name.
C. Demographic data.
D. Interactions
7.2. The above data may be shared with third parties who provide online advertising services for NIO, with the intention of delivering personalized advertising tailored to your interests.
7.3. If you prefer not to receive personalized ads from third parties, you can opt-out by adjusting your device's ad tracking settings, such as enabling "Limit Ad Tracking." Additionally, you can reset your device's advertising identifier (e.g., IDFA) from the settings, which will stop the use of existing behavioral data associated with the previous advertising identifier. Depending on your platform provider, like Apple or Google, you might have access to apps such as the Digital Advertising Alliance's "AppChoices" app, allowing you to control the collection and use of cross-app data for personalized advertising. It's important to note that these opt-out tools are provided by third parties, not NIO. NIO does not manage or operate these tools, nor the choices provided by advertisers and others through these tools.
8. YOUR PRIVACY RIGHTS
8.1. We acknowledge that by law, and subject to specific conditions, you have several rights concerning the Personal Information we hold about you. Additional information and guidance regarding your rights can be obtained from the data protection regulator in your country or state.
8.2. Your rights may encompass, but are not restricted to, the following:
a. The right to access - You are entitled to access the Personal Information we process about you, along with certain other details akin to those outlined in this Privacy Policy.
b. The right to rectify or correct: You have the entitlement to have any inaccurate or incomplete Personal Information corrected. You may request us to rectify any errors in the information we hold about you.
c. The right to receive information: You have the right to understand how we collect and utilize your information, as well as your rights concerning your Personal Information.
d. The right to oppose processing: You have the right to object to certain forms of processing, including processing for direct marketing and advertising.
e. The right to deletion: You have the right to request the deletion or removal of your Personal Information, with certain exceptions applicable.
f. The entitlement to data portability: With specific exceptions, you have the right to access and reuse your information in a format that is easy to understand.
g. The right to opt out of data sharing: You retain the right to opt out of sharing your Personal Information with third parties for cross-context behavioral advertising.
h. The right to lodge a complaint with a supervisory authority: You also retain the right to lodge a complaint with the relevant data protection supervisory authority concerning NIO 's processing of your Personal Information. Please complete the NIO Play Privacy Request form here. Alternatively, you can email support@nioplay.com.
8.3. Additional Rights. Residents of California have the right to:
a. Request to know more about the categories and specific pieces of Personal Information we collect, use, and disclose.
b. Request deletion of their Personal Information.
c. Opt out of the sale of their Personal Information (if any).
d. Not face discrimination for exercising these rights.
e. Limit the use of their sensitive Personal Information if we use it to infer characteristics about them. Currently, we do not use sensitive Personal Information for such purposes. In some states, obtaining consent before collecting sensitive Personal Information may be required.
f. According to certain US state privacy laws, consumers retain the right to opt out of sharing or selling their Personal Information to third parties for targeted advertising (behavioral advertising). For additional details, please see section 6.4 above.
g. If you no longer wish to receive promotional communications from us, you can click on the "unsubscribe" link found in any promotional email you receive from us.
8.4. How to Assert Your Rights.
a. To exercise any of these rights, you can fill out the NIO Play Privacy Request Form here or alternatively, send an email to support@nioplay.com. We will not discriminate against you (for example, by denying products and services or providing different levels or qualities of goods or services) for exercising any of the rights available to you.
b. You have the choice to unsubscribe from receiving commercial messages from us by following the instructions included in those messages or by contacting Customer Support. If you object to processing for direct advertising purposes, we will discontinue processing your Personal Information for such purposes.
c. If you intend to utilize an agent authorized according to applicable law to exercise your rights, we may request proof that you have granted such agent power of attorney or possess valid written authority for the agent to act on your behalf in exercising those rights.
8.5. Cookies.
a. You can adjust your preferences regarding cookies and other trackers at any time by clicking on the "Your Privacy Choices" link located at the bottom of our website.
8.6. OUR INFORMATION PROTECTION MEASURES.
a. We utilize physical, electronic, and procedural protections to safeguard the information we collect. Our procedures for data collection, storage, and handling adhere to best practices, complemented by security measures aimed at preventing unauthorized access, alteration, exposure, or loss of your Personal Information. We regularly assess and update our security measures to keep pace with technological advancements.
8.7. In the event that we suspect a notifiable data breach has transpired, we will adhere to legislative obligations by promptly notifying you of the breach and detailing any measures undertaken by NIO to contain and investigate the incident.
9. DURATION OF INFORMATION RETENTION.
9.1. We will keep the categories of Personal Information listed in section 3 above for different periods to adequately serve the purposes outlined in this Privacy Policy. These periods will be determined based on several factors, including:
a. The duration necessary to fulfill the business or commercial purpose for which the information was collected.
b. Any applicable legal, accounting, reporting, or regulatory requirements.
c. Internal operational needs; and
d. Any necessity for the information in relation to ongoing or anticipated investigations, disputes, or litigation.
9.2. We will undertake reasonable measures to either destroy or permanently de-identify any Personal Information in the following circumstances:
a. We no longer require the Personal Information for any purpose for which it was initially collected; and
b. We are not obligated by law, regulatory requirement, or court/tribunal order to retain the Personal Information.
10. DISCLOSURE OF YOUR INFORMATION
10.1. We provide your Personal Information to the following categories of third parties.
a. Service providers: other companies that provide services to you on our behalf.
b. Third parties who engage with us in relation to the services we provide.
c. Affiliates – other companies in the NIO Consolidated, LLC.
10.2. If we share your Personal Information with a third party, we will take reasonable measures to ensure that your information is protected to the same standards as we protect our own. Additionally, we will prohibit the third party from using your Personal Information for purposes other than those requested by us or mandated by law.
10.3. Third Parties: We share information with third parties only under limited circumstances, including the following:
a. When you grant us permission to share your information with third parties.
b. When delivering products and services to you and informing you about significant changes or enhancements to the features and operation of those products and services.
c. We engage with service providers who assist us in delivering our services, including companies that support us with technology, data storage and integration, payment processing, and promotions. Additionally, they provide relevant marketing and advertising for our products and services. In instances where service providers use Personal Information for their own purposes, where permitted by law, they will act as data controllers, either individually or jointly with others, determining the purposes and methods of processing that data.
d. In accordance with lawful requests from public authorities, including those related to national security or law enforcement obligations, we may disclose information. This includes situations where we are mandated to do so by any regulatory body or under legal provisions outlined in the governing law of a specific jurisdiction.
e. When instructing and authorizing the financial institution where a user's account is held to disclose any requested information to a regulator regarding the user's account.
f. To uphold the terms and conditions specified on our website, safeguard our rights and property, along with those of our customers and third parties, detect fraud or other unlawful activities, and comply with legal requirements or processes.
g. While conducting web analytics to assess traffic and player activity; and
h. To carry out customer due diligence, including identity verification.
10.4. GOOGLE
We provide access to a Google Maps API to enable an address auto-complete feature on our website. Your use of Google Maps for this purpose is subject to the current Google Maps/Google Earth Additional Terms of Service and Google Privacy Policy.
10.5. We offer a Google-provided API that enables you to sign into the website using your Google Account. You have the ability to manage this connection through your Google Account at any time. Further details can be found here.
10.6. Google Analytics
NIO employs Google Analytics to gather information (such as cookies, IP addresses, pixels, and tags). This data aids in understanding your interactions with our website, facilitating improvements in its functionality and performance, and serving marketing and internal business objectives.
With your permission, Google Analytics will process and collect this information. You can learn more about how Google utilizes data by visiting here, and review Google's Privacy Policy.
10.7. You have the option to opt out of Google’s collection and processing of data by visiting here.
Google Sign-In
10.8. We provide access to Google's API service, Google Sign-In, allowing you to register and log in to the website using your Google Account. This feature offers a secure and convenient login option that protects your personal information. Google Sign-In verifies your identity through secure protocols without sharing your actual password with us. Your login details are securely transmitted and stored by Google according to their Privacy Policy, solely for registration and identification purposes.
10.9. When you register on the website using Google Sign-In, we will receive the following Personal Information: first and last name, profile picture, and email address. We use this data exclusively to facilitate your account creation, login process, and provide personalized features within our website. Rest assured; we will not disclose this information to any third parties without your explicit consent.
10.10. You have the ability to manage your permissions and revoke access at any time through your respective Google account settings or here. Alternatively, you can choose to create an account with NIO using an email address and password if you prefer not to utilize Google Sign-In
10.11. Other Third Parties
We may request your image to help verify your identity, utilizing facial recognition technology provided by service providers such as Jumio Corporation. This technology determines whether the photo you provide matches the one on your identification document. The service providers collect information from your image capture on our behalf and may share this confirmation with us. We do not collect or store biometric information. Your biometric data is stored by our third-party service provider in accordance with their privacy policy. They will retain it until they have achieved the original purpose for collecting it or until three years after your last interaction with us, whichever comes first, provided there are no other legal obligations requiring retention for a longer period.
10.12. Furthermore, we reserve the right to share anonymized demographic data, devoid of any personal identification information, concerning visitors to and users of our website with our service providers, affiliates, and advertisers for the aforementioned purposes.
10.13. Transfer of data
The NIO Group operates across numerous international jurisdictions, and the Personal Information we gather may be transferred to, stored, and processed by affiliates within the NIO Consolidated or service providers in various countries, including the European Union, the United States, Canada, Costa Rica, or any other country where we or our service providers maintain facilities. We will ensure that any transfers of Personal Information to any country or organization are conducted with suitable safeguards in place.
11. MINORS
NIO places great emphasis on safeguarding the privacy of children. Consequently, we do not knowingly collect or maintain information from individuals under the age of 18, and our Website is not structured to attract anyone under this age. Moreover, NIO does not offer or direct any of its services or products, including Nio Play, to individuals under 18 years old.
12. CHANGES TO THIS PRIVACY POLICY
12.1. This Privacy Policy is subject to occasional updates to reflect alterations in our practices or regulatory frameworks. We will notify you of substantial changes and, where necessary by law, seek your consent. Notification may involve publishing such revisions on our Website or utilizing other methods in compliance with relevant laws.
12.2. Any modifications to the Privacy Policy will take effect upon the posting of the updated policy on our Website.
12.3. We recommend checking this page regularly to stay informed about any changes in how we protect the Personal Information we collect.
12.4. As of the last modified date provided below, this Privacy Policy takes precedence over and replaces all previously effective Privacy Policies.
13. CONTACTING US
If you have particular queries about your Personal Information, its processing, or utilization, or if you wish to exercise your rights, please contact our Privacy Team directly via email at support@nioplay.net. Alternatively, you can fill out the Privacy Request Form available here.
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