Neropin Terms of Use

Please read these Terms of Use ("Terms") carefully before using our Services. Nero Pin L.L.C., a company incorporated in the US ("we", "our" and "us"), provides e-commerce services ("Services") using our online Neropin platform (the "Platform") to facilitate the sale and purchase of (i) credits (“Game Credits”) which may be used to purchase virtual goods and items (such as weapons) (“Gaming Items”), or such virtual goods directly, for use within games ("Game(s)") operated by our affiliates and other third parties (the "Operators"); or (ii) subscriptions for Game Credits or Gaming Items or other digital content operated or otherwise provided by the Operators (together, the "Items"). By taking any step to register for and/or use all or any portion of the Services, you accept and agree to be bound by all the terms and conditions of these Terms. If you do not agree to any terms and conditions of these Terms, you must not use the Services.

If you live in the European Union, United Kingdom, Switzerland, or Norway, please note there are some different terms which apply to you, which can be found in Clause 21.

Please also read the Privacy Policy and any other policies we communicate to you from time to time, which, together with these Terms, constitute the entire agreement between you and us regarding your use of the Services, and the terms of which are incorporated by reference into these Terms.

If you are under the age of 18 (or the relevant age in your jurisdiction where you are considered a minor), your parent or guardian must agree to these Terms (both for themselves and on your behalf) before you can use the Platform.

We may translate these Terms into multiple languages. If there is any difference between the English version and any other language version of these Terms, the English version will prevail and apply (to the extent permitted by applicable laws and regulations).

Our registered office is at: 30 N Gould St Ste N, Sheridan, WY 82801, US. Please contact us at [email protected] if you have any complaints or queries about the Services.

IMPORTANT NOTE ABOUT ITEMS AND OPERATOR'S TERMS

1.1 It is crucial that you thoroughly review and understand the terms and conditions set forth by the Operator governing: (i) the sale of Items by the Operator as seller to you as buyer; (ii) your rights concerning the Items; and (iii) your use of the relevant Game or Items (collectively, the "Operator's Terms") prior to purchasing any Items through our Services. The Operator's Terms define the terms under which you acquire the Items, as well as your rights and responsibilities regarding their use, including their value, and the terms and conditions related to their use, transfer, redemption, or cancellation.

1.2 We do not endorse or take responsibility for any specific Game or Item. We do not provide you with any rights to use the Items under these Terms. Any such rights are determined solely between you and the Operator under the Operator's Terms.

1.3 We are not a party to the Operator's Terms; these terms are solely between you and the Operator.

YOUR INFORMATION

We prioritize your privacy and will handle any personal data you provide in accordance with our Privacy Policy, which may be updated periodically.

LICENCE AND ACCESS

3.1 Subject to your compliance with these Terms and payment of any applicable fees, we grant you a limited, personal, non-exclusive, non-transferable, non-sublicensable, royalty-free, and revocable licence to access and use the Services and any associated software for personal and non-commercial purposes. This licence does not extend to or include any resale or commercial exploitation of the Services or their content; the collection and use of any product listings, descriptions, or prices; any derivative use of the Services or their content; downloading or copying of account information for the benefit of any third party; or using the Services in conjunction with data mining tools, robots, scrapers, or similar data gathering and extraction tools.

3.2 All rights not expressly granted to you by these Terms are reserved and retained by us, our affiliates, licensors, suppliers, publishers, rights holders, or other content providers, as applicable. The Services, or any part thereof, may not be reproduced, duplicated, copied, sold, resold, visited, or otherwise exploited for any commercial purpose. Use of any intellectual property rights owned by us, our affiliates, licensors, suppliers, publishers, rights holders, or content providers is subject to these Terms.

3.3 Any goodwill arising from the use of our and our affiliates' trademarks, trade names, business names, and service marks under these Terms shall be vested in us and our affiliates, as applicable.

3.4 We reserve the right to refuse to provide the Services to any individual for any reason, at our sole discretion, without the obligation to provide any justification or notification.

YOUR OBLIGATIONS AND USE OF THE SERVICES

4.1 You may use the Services in accordance with these Terms to search for information regarding Items, and to pre-order and purchase Items as made available on the Platform from time to time.

4.2 To use the Services, you must adhere to the requirements outlined in these Terms. Failure to comply with these requirements at any time necessitates an immediate cessation of your use of the Services. To the extent permitted by applicable law, you will be responsible for any legal consequences, including costs, losses, or damages that we may suffer or incur as a result of your non-compliance.

4.3 You are required to provide all necessary information and supporting documents (including, but not limited to, proof of your billing address and mobile phone number) as reasonably requested by us for your use of the Services, tax purposes, and/or compliance with applicable laws in any jurisdiction. We reserve the right to seek redress from you for any legal consequences, including costs, losses, or damages that we may suffer or incur if any information or documents you provide are false, inaccurate, incomplete, or misleading.

4.4 You must not use the Services: (a) in any manner that causes, or is likely to cause, interruption, damage, or impairment to the Services or any access thereto; or (b) for fraudulent purposes, or in connection with criminal offenses or other unlawful activities.

4.5 You must not use fraudulent methods to purchase Items or employ any payment methods for fraudulent purposes or in connection with criminal activities or other unlawful activities. If such activity is detected, we may refuse to process any purchase or initiate a refund for such Items. In the event that we initiate a refund, the relevant Operator will disable your access to the Items and/or retrieve them from you. We reserve the right to seek redress for any legal consequences, including costs, losses, or damages that we may suffer or incur as a result.

4.6 In addition to the restrictions specified in these Terms, you must not use the Services:

(a) to impose or potentially impose an unreasonable or disproportionate burden on the Services;

(b) to interfere or attempt to interfere with the Services or our ability to provide the Services; or

(c) to manipulate any transactions conducted via the Services in a manner that breaches these Terms, any Operator's Terms, or applicable law.

4.7 You acknowledge and agree that Operators, and not us or any of our affiliates, are responsible for accurately listing their Items. You are responsible for reviewing the descriptions of Items listed by Operators and making your own judgments before completing a purchase. All sales are final, and you agree to fulfill all obligations related to such sales.

WARRANTY

Our Services are provided to you on an "as is" and "where-is" basis, utilizing current technology. However, we warrant that we will provide the Services with reasonable skill and care. Subject to applicable law, we do not make any other representations, conditions, or warranties, express or implied, and you hereby waive all such representations, conditions, and warranties, including, without limitation: (a) that the Services or Items will meet your expectations, will always be available, accessible, uninterrupted, timely, secure, or free from errors; (b) that Items or information or content related to the Items included on or available through the Services will match what Operators have represented, will be available for sale at the time of listing, will be lawful to sell, or that Operators will fulfill their obligations as stated; (c) that Items will hold their value, retain their worth, or otherwise meet your expectations concerning their value, exchangeability, or utility; and (d) without limiting the generality of the foregoing: (i) any implied warranties of merchantability, fitness for a particular purpose, title, and non-infringement; (ii) any implied warranty arising from course of dealing or usage of trade; (iii) any implied obligation, liability, right, claim, or remedy under contract; and (iv) any obligation, liability, right, claim, or remedy in tort, whether or not arising from our negligence, in equity, or otherwise. To the fullest extent permitted by applicable law, we disclaim all such representations, conditions, and warranties.

OUR ROLE

6.1 We facilitate transactions conducted on the Platform, but we are neither the buyer nor the seller of the Items involved in these transactions. Any agreement for the sale of Items is strictly between you, as the buyer, and the Operator, as the seller. We are not a party to that agreement, nor do we assume any responsibility in relation to it. We are not acting as an agent for the Operator.

6.2 Please note that we do not directly provide credit or debit, stored value, or payment processing services for sales or purchases made on the Platform. These services are provided by, and remain the responsibility of, the issuer or operator of your respective credit or debit card, stored value facility, or payment service (each referred to as a "Payment Instrument" and such issuers and operators as "Payment Provider") under separate terms and conditions agreed upon between you and the Payment Provider.

6.3 You acknowledge and agree that:

(a) we are authorized by the Operators to collect and receive payments on their behalf for transactions made on the Platform between you, as the buyer, and the Operator, as the seller; and

(b) your payment obligation to the Operator is discharged once your payment to us is successfully completed for a particular transaction.

OUR RIGHTS AND OBLIGATIONS

7.1 We reserve the right, at our sole discretion, to suspend or terminate the Services, prevent or restrict access to the Services, or take any other action to limit your access to or availability of the Services. We may also suspend or terminate your access to the Services if we believe that you have breached these Terms or otherwise misused the Services.

7.2 You acknowledge and agree that we are entitled to cooperate with and provide information, including information about you or provided by you, to any administrative or judicial authority in any jurisdiction.

ADVERTISEMENT AND PROMOTIONS

8.1 We may offer you options to close or minimize advertisements on the Platform, but you must not screen or filter the advertisements in any way that is not explicitly authorized by us in writing. From time to time, we may also conduct marketing and promotional activities related to the Platform, such as "red packet" giveaways or top-up gifts.

8.2 Except as required by applicable law, we are not liable for any loss or damage you may incur as a result of transactions you engage in based on reliance on such advertisements, promotional or marketing information.

PRICE, DELIVERY OF ITEMS, AND SUBSCRIPTIONS

9.1 Price

The price you will pay for purchasing Items is determined by the Operator and denominated in a currency chosen by the Operator ("Purchase Currency") at the relevant time. Please note that the prices of Items available on the Platform may vary based on the Purchase Currency. Be mindful of recurring charges that may arise from purchasing Items. Additionally, you may be provided with an estimated value in your local currency of the actual Purchase Currency price for your purchase. This estimate is based on historical, not real-time, exchange rates and serves as an approximation of the Purchase Currency price.

If the Payment Instrument you use is not denominated in the Purchase Currency, you will pay the equivalent amount in your local currency (as determined by your Payment Provider) based on the Purchase Currency price. Your Payment Provider may also impose other fees (e.g., currency conversion or transaction fees) if you use a different currency. Please check with your Payment Provider for more information on these additional charges. You are solely responsible for any taxes, charges, or fees imposed by your Payment Provider. We and our affiliates are not liable for any exchange rate used by your Payment Provider. Taxes shall be determined based on the information and declarations you provide.

9.2 Delivery of Items

The Operator is responsible for delivering the Items you purchase through the Services, and we will not be responsible for any delivery issues.

If you request a refund for any Items, or if the Operator is unable to charge your payment method (e.g., due to insufficient funds or an expired card), the Operator may revoke your access to the relevant Items or retrieve them from you. We are not responsible for compensating you for any loss of access or other damages that may result.

In case of disputes regarding Items, including price or quality issues, such disputes must be resolved between you and the Operator without our involvement. By using the Services, you release us (and our affiliates, Payment Provider, employees, representatives, and agents) from any claims, demands, and damages arising from such disputes. However, we may, at our discretion, assist in resolving disputes but are not obligated to be a party to them.

You irrevocably authorize us to help settle disputes arising from your use of the Services. This may involve instructing the Payment Provider to hold or transfer funds related to the dispute. In such instances, you agree to indemnify us for any liabilities resulting from our decision.

9.3 Subscriptions

The Services may allow you to purchase content on a subscription basis, either as a recurring monthly subscription ("Monthly Subscription(s)") or as a one-time fixed-term subscription ("One-off Subscription(s)").

Monthly Subscriptions are automatically charged every 30 days, and you will be billed no more than 24 hours before the beginning of each billing period. If we are unable to charge your payment method, your subscription will be terminated for the following month. From time to time, we may offer promotions for Monthly Subscriptions at our discretion, and the specific terms will be communicated when you purchase.

You can cancel a Monthly Subscription at any time before the next billing period, and the cancellation will take effect in the following billing period. For example, if you cancel your subscription during a current billing period, you will still have access until the period ends, but the cancellation will be effective in the next period, with no refund for the current month.

To cancel, visit our website or contact your Payment Provider directly. Any instructions we receive from your Payment Provider are deemed authorized by you, and we are not liable for following such instructions. By canceling, you also authorize us to instruct the Operators to cancel your Monthly Subscription.

One-off Subscriptions are charged once upon purchase, and no refunds are provided.

OUR INTELLECTUAL PROPERTY RIGHTS

10.1 All intellectual property rights related to the Platform and any software we provide for your use of the Services (including any future updates, upgrades, and new versions of such software) (the "Software") will remain our property or the property of our licensors. Except as explicitly stated in these Terms, you do not have any rights to use our intellectual property, including trademarks, product names (such as "Neropin"), logos, domain names, or other distinctive brand elements without our prior written consent.

10.2 You are not permitted to copy, modify, create derivative works, reverse compile, reverse engineer, or extract source code from the Software. Additionally, you may not sell, distribute, redistribute, or sublicense the Software unless we provide prior written consent or where applicable laws or regulations allow you to do so. If applicable laws or regulations entitle you to reverse compile or extract source code, you must contact us first to request the necessary information.

10.3 We may, from time to time, provide updates for the Software, either automatically or manually. Please note that the Software may not function correctly or at all if you do not install updates or new versions. We do not guarantee that we will provide updates for the Software or that any updates will be compatible with your device or system. All updates to the Software are subject to these Terms unless otherwise specified by us.

10.4 We may, at our discretion, offer technical support for the Platform (whether free or for a fee). Any technical support we provide is offered without any guarantees or warranties, and always subject to these Terms.

OPEN SOURCE SOFTWARE

11.1 The Software may include components subject to “open source” licenses (the "Open Source Software"). In cases where we utilize such Open Source Software, please note the following:

• Certain provisions in the Open Source Software's license may explicitly override these Terms, and in such instances, those provisions will take precedence to the extent of any conflict with these Terms.
• We will appropriately credit the relevant Open Source Software used in the Software within an Appendix to these Terms and/or directly within the relevant Software.

·      YOUR DEVICE

·      12.1 To access and use the Services, you may require a stable internet connection. Additionally, certain functionalities within the Platform may need to be activated as specified within the Platform itself. If these requirements are not met, some functionalities may not be available for use.

·      12.2 Please be aware that we are not responsible for any third-party fees or charges (such as those from your internet or telecommunications provider) that you may incur as a result of your use of the Software or the Services.

PAID SERVICES

13.1 Some features of the Services may be offered as paid services. If you choose to utilize these paid services, you will incur a fee.

13.2 We reserve the right to modify, at our sole discretion, the fees we charge and the payment methods for these paid services. Additionally, we may introduce fees for services that were previously offered free of charge. We will provide advance notice of such changes through announcements or notifications. If you do not agree with these amendments or changes, you must cease using the affected service immediately.

COMPLIANCE WITH LAWS

14.1 You are solely responsible for understanding and adhering to all laws and regulations that apply to your use of the Services. You must not use the Services in any manner that violates applicable laws.

14.2 If the laws of the country or region where you are located prohibit or restrict any part of the Services, you must immediately discontinue using the Services.

OUR LIABILITY

15.1 We will exercise reasonable care to ensure that the Services operate without interruption and that your instructions are executed promptly and accurately. However, due to the inherent nature of the Services, which depend on the internet, payment systems, and third parties such as Operators and Payment Providers, we cannot guarantee uninterrupted or error-free operation. Additionally, you acknowledge and agree that access to the Services may be intermittently suspended, disrupted, or restricted due to: (i) system and network maintenance, repairs, or the implementation of new features or services; and/or (ii) processing, clearing, and settlement times of banking and payment systems.

15.2 To the fullest extent permitted by applicable laws and regulations, our total aggregate liability, including that of our affiliates, for any claims related to these Terms and the Services, arising from any circumstances, shall be limited to the greater of the following amounts: (i) the amount you have paid to us for the Services in the six months immediately preceding the date of the most recent claim; or (ii) USD 100.

15.3 To the extent permitted by applicable laws and regulations, neither we nor our affiliates shall be liable or responsible for:

(a) Any losses or damages caused by natural disasters or other circumstances beyond our reasonable control;

(b) Any damage caused by computer viruses, trojans, malware, or hackers;

(c) Any malfunction or failure of our or your software, systems, hardware, or connectivity;

(d) Losses that were not caused by any breach of these Terms by us;

(e) Risks and losses resulting from your non-compliance with applicable laws or these Terms;

(f) Any business losses (including loss of profits, revenue, contracts, anticipated savings, data, goodwill, or wasted expenditure);

(g) Any indirect or consequential losses (regardless of whether such losses are foreseeable by us), or any incidental, punitive, special, or consequential damages, arising out of or in connection with these Terms, any other agreements applicable to the Services, the Services themselves, your inability to use the Services, or in connection with any Items purchased, obtained, messages received, or transactions paid for through the Services, whether or not we were advised of the possibility of such damages.

15.4 We shall not be liable for any depreciation of currency, foreign exchange losses, interest losses, or other risks related to amounts held, collected, or paid on your behalf or incurred as a result of using the Services. We are not obligated to pay you any accrued interest, and you agree that we or the Payment Provider are entitled to retain such interest.

15.5 To the fullest extent permitted by applicable law, we shall not be liable to you for any interruption or disruption of the Services or any potential losses that may occur in circumstances that are not reasonably foreseeable by us (including any direct losses that would otherwise arise).

15.6 To the fullest extent permitted by applicable law, we shall be exempt from any liability in relation to the following risks you may encounter:

(a) Information containing threatening, defamatory, or illegal content, including content from anonymous sources or individuals using fictitious names;

(b) Being misled or deceived by any person, resulting in psychological or physical harm and/or economic loss;

(c) Destruction, paralysis, or inability of your computer system to operate normally;

(d) Credit or debit card fraud; or

(e) Identity theft.

15.7 Upon receiving your payment instruction for any purchase of Items (including but not limited to Monthly Subscriptions and One-Off Subscriptions), you authorize us to allow the Payment Provider, or our or the Payment Provider’s bank, third-party partners, service providers, or agents, to charge or debit the amount specified in your payment instruction from your debit or credit card. In such cases, you shall not request a refund from us, and we shall not be liable to you for any actual or purported payment instruction due to unsigned receipts, inconsistent signatures, transactions not aligning with your intention, or any other reasons. You also authorize us, the Payment Provider, and our or the Payment Provider’s bank, third-party partners, service providers, or agents to initiate credits, debits, or other charges to your debit or credit card for processing refunds, chargebacks, or other adjustments related to your payment transaction. If you change your payment method or any relevant details (including but not limited to your credit card number, expiration date, and/or billing address), or if your payment account expires or is canceled for any reason, you agree to promptly notify us of such changes.

15.8 You hereby release us (and our affiliates, excluding Operators whose liabilities are covered under the Operator’s Terms, as well as our employees, representatives, and agents) from any claims, demands, and damages (whether actual, direct, consequential, or otherwise) of every kind and nature, known and unknown, suspected and unsuspected, disclosed and undisclosed, arising out of or connected with any dispute regarding the purchase or sale of Items through the Platform.

15.9 We do not guarantee the legality, authenticity, or quality of Items listed for sale via the Services, nor do we guarantee your ability to complete a transaction with an Operator or make a payment through a Payment Provider. We will not be liable to compensate or indemnify you for any loss suffered due to the authenticity or quality of the Items purchased via the Services.

15.10 Nothing in these Terms limits or excludes any of the following liabilities, except to the extent that such liabilities can be waived, limited, or excluded under applicable laws and regulations:

(a) Liability for death or personal injury caused by either Party’s negligence;

(b) Liability for fraud or fraudulent misrepresentation;

(c) Liability for willful misconduct; or

(d) Any other liability to the extent that such liability cannot be waived, limited, or excluded under applicable laws and regulations.

15.11 Nothing in these Terms affects your statutory rights (to the extent applicable) to have Items provided to you by the relevant Operator within a reasonable time or to receive a refund from the relevant Operator if the ordered Items cannot be supplied within a reasonable time.

15.12 To the extent permitted by applicable law, you agree to indemnify us, our partners, and our affiliates (excluding Operators) against any claim, suit, action, demand, damage, debt, loss, cost, expense (including litigation costs and attorneys’ fees), and liability arising from: (i) your use of the Services; or (ii) your breach of these Terms and Conditions.

INTERRUPTION, SUSPENSION, AND TERMINATION OF THE SERVICE

16.1 Without limiting the general provisions of Clause 15.1, we may, in accordance with our business or risk control requirements or those of our affiliates, including the Payment Provider, suspend, interrupt, or terminate your access to the Services or impose limitations on your use of the Services.

16.2 We reserve the right to interrupt, suspend, or terminate the Services without prior notice under the following circumstances:

(a) You provide false or incorrect information;

(b) You breach applicable laws or the provisions of these Terms;

(c) The Services are required to be interrupted, suspended, or terminated by applicable laws or competent authorities;

(d) You infringe upon the lawful rights and interests of third parties;

(e) The Services need to be interrupted, suspended, or terminated for security reasons; or

(f) You fail to pay any fees charged to you.

16.3 For the avoidance of doubt, the exercise of any suspension or termination rights by us under these Terms shall not incur any liability to you and shall not affect any other rights or remedies available to us under these Terms or applicable laws.

16.4 Provisions of these Terms that are intended, whether expressly or impliedly, to survive the termination or expiration of these Terms shall remain in effect and continue to bind both you and us.

16.5 If we suspend or terminate the Services due to a breach by you, we may direct the Payment Provider to instruct your bank to transfer funds or charge or debit your credit card to settle any outstanding obligations. In such cases, you agree not to hold us or the Payment Provider liable for such actions.

AMENDMENTS TO THESE TERMS

We reserve the right to modify these Terms at any time. The terms and conditions in effect at the time of your use of the Services will govern your use. Continued use of the Services following any amendment or change to these Terms will be considered acceptance of those changes. If you do not agree with the amendments, you must cease using the Services immediately.

ELECTRONIC COMMUNICATIONS

We will communicate with you via email or by posting notices on the Platform. You consent to receive electronic communications from us for contractual purposes, acknowledging that all agreements, notices, disclosures, and other communications delivered electronically will satisfy any legal requirements for written communication, unless specific laws dictate otherwise.

GOVERNING LAW AND DISPUTE RESOLUTION

Unless otherwise mandated by the applicable laws (such as statutory rights related to local court claims), these Terms and any disputes or claims arising from or in connection with them will be governed by the laws of the United States. Disputes, controversies, or claims (whether contractual, tortious, or otherwise) related to these Terms, including their existence, validity, interpretation, performance, breach, or termination, will be resolved in accordance with the laws of the state where Nero Pin is incorporated and in accordance with the procedures established under the Truth in Lending Act (TILA).

MISCELLANEOUS

20.1 The headings in these Terms and clauses are for convenience only and should not be used to interpret these Terms. Any amendments, supplements, novations, or restatements of these Terms will become an integral part of these Terms and have the same legal effect.

20.2 If any provision of these Terms is found to be invalid, void, or unenforceable, that provision will be deemed severable and will not affect the validity or enforceability of the remaining provisions.

20.3 You may not assign or transfer any of your rights or obligations under these Terms without our prior written consent. We may assign our rights or transfer our obligations under these Terms without your consent, including in the event of an acquisition of us or our assets, and you consent to any such transfer. In the event of an assignment or novation by us, we are authorized to transfer any or all of your data related to the Services.

20.4 These Terms constitute the entire agreement between you and us. No third party shall have any rights to enforce any part of these Terms.

TERMS SPECIFIC TO THE EUROPEAN UNION, UNITED KINGDOM, SWITZERLAND AND NORWAY

21.1 Clause 5 Warranty is replaced with the following:

Our Services are provided to you on an "as is" and "where-is" basis based on existing technology. However, we warrant that we will provide the Services with reasonable skill and care. When deciding whether to use the Services, please be aware that we cannot guarantee that Items or information or content related to the Items on or available through the Services will be as represented by Operators, that Operators will perform as promised, or that Items will maintain their value, meet your expectations, or represent fair value.

21.2 Clause 9.2 Delivery of Items is replaced with the following:

The Operator shall be responsible for the delivery of Items transacted through the Services. If you request a refund for any Items, or if the Operator cannot process payment due to issues such as insufficient funds or expiration of your payment method, the relevant Operator may disable your access to the Items and/or retrieve the Items from you.

In case of a dispute regarding Items, including disputes about the price and/or quality of Items bought and sold through the Services, you should attempt to resolve the issue directly with the Operator. We may assist in facilitating such disputes.

21.3 New Clause 9.4 is inserted as follows:

Your right to change your mind

When you purchase Items or paid services (as described in Clause 13), you have 14 days from the day we confirm acceptance of your order to change your mind and cancel the order. However, you will forfeit this right once you receive the Items or services if you agree to and acknowledge this upon ordering. To exercise your right to cancel, please contact us at [email protected]. You may also use the model cancellation form included in Schedule 1 to these Terms.

21.4 Clause 13.2 Paid Service is replaced with the following:

We may make changes to the amount of fees we charge and the payment methods for paid services. We may also impose fees on previously free services. We will announce or notify you before such changes take effect. If you disagree with these changes, you must cease using the relevant service before we start charging for it and may cancel your contract with us by contacting us at [email protected].

21.5 Clause 15 Our Liability is replaced with the following:

(a) We will exercise reasonable care to ensure that the Services are uninterrupted and that your instructions are promptly executed and error-free. However, due to the nature of the Services and their dependence on the internet, payment systems, and third parties such as Operators and Payment Providers, we cannot provide any guarantees in this respect. Additionally, you acknowledge and agree that access to the Services may occasionally be suspended, disrupted, or restricted due to: (i) systems and network maintenance or the introduction of new facilities or services; and/or (ii) processing times for banks and payment systems.

(b) If defective digital content we supply damages your device or other digital content, and such damage is due to our failure to exercise reasonable care, we will either repair the damage or provide compensation. However, we will not be liable for damage that you could have prevented by following our advice to apply updates provided free of charge, or for damage resulting from your failure to follow installation instructions or meet the minimum system requirements advised by us.

(c) Our Services are intended for domestic and private use only. If you use the Services for commercial, business, or resale purposes, we will not be liable for any loss of profit, business loss, business interruption, or loss of business opportunity.

(d) We are not responsible for delays caused by factors beyond our control. If our provision of the Services is delayed due to such an external event, we will notify you via the Platform and take steps to minimize the delay’s impact. Provided we do this, we will not be liable for delays caused by the event. However, if there is a risk of substantial delay, you may contact us to terminate the contract and receive a refund for any Items or paid services that you have paid for but not received.

(e) We do not accept responsibility for any loss or damage:

(i) that was not caused by our breach of these Terms; or

(ii) that was not, at the time you agreed to these Terms, a reasonably foreseeable consequence of our breach (a loss or damage is foreseeable if it was obvious that it would occur or if both parties knew it might occur at the time of entering into these Terms).

(f) As long as we have complied with these Terms, including our obligation to exercise reasonable care in providing the Services, we will not be responsible for the following, and you should take reasonable steps to protect yourself against these risks:

(i) information with threatening, defamatory, or illegal content, including from anonymous sources or individuals using fake or fictitious names;

(ii) being misled or deceived by any person resulting in psychological or physical harm and/or economic loss;

(iii) destruction, paralysis, or malfunction of your computer system;

(iv) credit or debit card fraud; or

(v) identity theft.

(g) Upon receipt of your payment instruction for any purchase of Items (including but not limited to Monthly Subscriptions and One-Off Subscriptions), you authorize us to allow the Payment Provider, or our or the Payment Provider’s bank or third-party partners, service providers, or agents, to charge or debit the amount requested from your debit or credit card according to your payment instruction. In such cases, you will not be entitled to request a refund from us, and we will not be liable for any issues related to actual or purported payment instructions due to unsigned receipts, inconsistent signatures, or transactions not matching your intention. You also authorize us, the Payment Provider, and our or the Payment Provider’s bank or third-party partners, service providers, or agents to initiate credits, debits, or other charges to your debit or credit card to process subsequent refunds, chargebacks, or adjustments related to your payment transaction. Should you change your payment method or relevant details (including but not limited to your credit card number, expiration date, and/or billing address), or if your payment account expires or is canceled for any reason, you agree to promptly notify us of such changes.

(h) We do not guarantee the legality, authenticity, or quality of Items listed for sale via the Services. We will not be liable to compensate you for any loss resulting from the authenticity or quality of Items purchased through the Services.

(i) We do not exclude or limit our liability to you where it would be unlawful to do so. This includes liability for death or personal injury resulting from our negligence or the negligence of our employees, agents, or subcontractors, and for fraud or fraudulent misrepresentation.

(j) Nothing in these Terms affects your statutory legal rights (where applicable), such as the right to have Items provided by the relevant Operator within a reasonable time or to receive a refund from the relevant Operator if Items ordered cannot be supplied within a reasonable time.

21.6 New Clause 16.6 is inserted as follows:

We reserve the right to withdraw or suspend the Services or Platform at any time. We will provide you with reasonable advance notice before taking such action and will issue a refund for any Services or Items that have been paid for but will not be delivered.

21.7 New Clause 16.7 is inserted as follows:

You may discontinue your use of the Services and terminate your contract with us at any time by contacting us at [email protected].

21.8 Clause 17 Amendments to these Terms is replaced with the following:

We may revise these Terms at any time due to changes in laws, regulatory requirements, or to implement minor technical adjustments or improvements. We will notify you of such changes, including through the Platform. The terms and conditions in effect at the time of your use of the Services will apply. Continuing to use the Services after any amendment signifies your acceptance of the changes. If you do not agree with any amendments, you must cease using the Services before the changes take effect and may cancel your contract with us by contacting us at [email protected]. We will refund you for any Services or Items already paid for but not yet received.

21.9 Clause 19 Governing Law and Dispute Resolution is replaced with the following:

These Terms are governed by the laws of the country in which you reside, and you may bring legal proceedings in your local courts. Additionally, if you are located in the European Economic Area, disputes may be submitted for online resolution through the European Commission Online Dispute Resolution platform.

21.10 New Clause 20.5 is inserted as follows:

Even if we do not immediately enforce these Terms or delay in taking action against you for any breach, this does not waive our right to enforce them later. A delay in insisting on your compliance or in addressing your breach does not release you from your obligations, nor does it preclude us from pursuing enforcement at a later time.

Schedule 1 - Model Cancellation Form

(Complete and return this form only if you wish to withdraw from the contract)

To Nero Pin L.L.C., 30 N Gould St Ste N, Sheridan, WY 82801, US, [email protected]:

I/We [] hereby give notice that I/We [] cancel my/our [] contract of sale of the following goods []/for the provision of the following service [*],

Ordered on []/received on [],

Name of consumer(s),

Address of consumer(s),

Signature of consumer(s) (only if this form is notified on paper),

Date

[*] Delete as appropriate

NERO PIN

PRIVACY POLICY

Last modified: 16/09/2024

We appreciate you choosing to use our products and services. Your privacy is important to us, and we are grateful for the trust you have placed in our company.

This document ("Privacy Notice") applies exclusively to Nero Pin ("Service"). For other products or services you may be using, please review the privacy policy specific to those offerings.

If you have any concerns or would like to learn more about your privacy rights, feel free to contact us. Our contact information is available here.

For the purposes of data protection regulations, Nere Pin L.L.C. is the entity responsible for handling your personal data in connection with the Service.

General Information

You can find information regarding the general overview of our privacy policy below:

1-   What data do we require in order to deliver the Service?

 If you create an account to access the Service, we will require certain information from you to set it up. Should you choose to create your profile via a social media account, we will also gather details such as your email address, profile picture, and username from that account. If you reach out to us for support, we will retain some of your information in order to respond to your inquiries and resolve any issues. Additionally, when you use the Service (for instance, to process transactions) or simply browse the Neropin website as a guest (if this feature is available in your region), we will process some of your information. Depending on how you use the Service and the legal requirements of your location, additional information may also be required to assist in setting up your account.

 2-   In what ways will we utilize your data?

We collect your data to enable the various features and services that are part of the Service. Additionally, your data is used for verifying your account, ensuring security, performing AML/KYC checks, and enhancing the Service. We do not disclose your data to third parties, except when it is essential for providing the Service (such as using local cloud storage or backing up your information, or involving our global affiliates to assist in delivering the Service), or when mandated by a court order, authority, or by law.

3-   With whom do we disclose your data?

 We engage certain third-party providers to assist us in delivering an optimal service experience (e.g., cloud storage for data backup, fraud detection services, payment processing, and data analytics). When utilizing third-party services, we do so strictly for the purposes outlined in this Privacy Policy, ensuring that your information is processed or stored only as necessary. Additionally, we work with affiliates worldwide who contribute to the delivery of the Service. In specific situations, we may be legally required to disclose certain information, either by court order or due to other legal obligations.

4-   In which locations is your data handled?

Our servers are based in the United States. Your data may be accessed by our support, engineering, and other relevant teams located in the United States, even if you reside in a different country. We ensure that any cross-border access is conducted in compliance with applicable data protection laws.

5-   For what duration do we retain your data?

We retain your personal data for as long as you continue to use the Service or hold credits that can be applied toward the purchase of virtual goods or items (“Game Credits”). Once this period has ended, your data will be deleted, unless retention is required by applicable legal obligations, as outlined further in this Privacy Policy.

6-   What steps can I take to manage my rights concerning my personal data?

Depending on your jurisdiction, you may have certain rights concerning your personal data. These rights could include accessing your data, requesting a copy, initiating its deletion or destruction, or seeking to restrict or object to how your information is processed.

7-   By what means will we inform you of any updates?

Any modifications to this Privacy Policy will be updated on this page. We recommend regularly reviewing this section to stay informed of any revisions or updates to the Privacy Policy.

This Privacy Policy outlines when, how, and why your personal data is processed in connection with the Neropin service, including the Neropin website (the "Service"), and explains your rights and options regarding that information. We encourage you to read this document carefully so that you fully understand how we handle your data and how you can manage it.

Please note, this Privacy Policy applies only to the Service. If you use any other products or services, please refer to the respective privacy policy for that product or service.

If you disagree with the way we handle your personal data as described in this Privacy Policy, please refrain from providing your information when requested and discontinue use of the Service. By continuing to use the Service, you acknowledge and agree to the terms of this Privacy Policy concerning the processing of your personal data.

For the purposes of data protection laws, the entity responsible for the processing of your personal data in relation to the Service is Nero Pin L.L.C. The registered address of Nero Pin L.L.C. is 30 N Gould St, Sheridan, WY 82801, US.

Should you have any questions or wish to exercise your rights regarding your personal data, you can find our contact details here. You can also reach our data protection officer at [email protected]. Additionally, our representatives for data protection matters are listed here.

1.    About Cookies

We use cookies and similar technologies ("Cookies") to improve your experience while using the Service. Cookies are small data files that, once placed on your device, enable us to offer specific functionalities and features.

For more detailed information regarding our use of Cookies, please refer to our Cookie Policy available on our website.

2.    Minors

Minors are not permitted to use the Service unless their parent or legal guardian has provided valid consent, where such consent is applicable in your region.

By minors, we refer to individuals under the age of 18, or in regions where the minimum age for processing personal data is different, the applicable legal age in that region. For users in certain areas, we have outlined the relevant minimum age as of the date of this policy in the table below. It is recommended that you consult the laws in your jurisdiction to confirm you are above the required legal minimum age.

Except as stated above, we do not knowingly collect personal information from individuals under these age limits for any purpose. If you believe we have obtained personal information from a minor without proper consent, or if you are a parent or guardian who wishes to withdraw consent, please contact us immediately.

Region in which the user is located

Minimum age of the user

European Economic Area

16

Switzerland

16

Türkiye

18

United Arab Emirates

21

United Kingdom

13

3.    How We Handle Your Personal Information

This section outlines the types of personal data we collect from you and the reasons for doing so.

For users residing in the European Economic Area, Switzerland, Türkiye, or the United Kingdom, it also specifies the legal grounds on which we base the processing of your data.

a-   Information for Guest Users (those who do not submit a player ID and simply navigate the website): IP address.

 We utilize this information to identify your geographic location.

 It is within our legitimate interest to gather this information to enable your access to the website.

b-   Guest User Information (for guests who provide a player ID and browse the website): game nickname, game open ID, and device details such as web browser and browser version, device location, IP address, open ID, cookie information, operating system version, country, internet connection, page loading time, type of mobile or computing device, number of visits, time spent on the Neropin platform, networks, demographic estimates, flow-through the Neropin platform or referral source, and device fingerprint data.

We use this information to enable your access to the Neropin platform, verify your player ID, and perform data analytics.

For browser version, operating system version, country, internet connection, page loading time, type of mobile or computing device, number of visits, time spent using the Neropin platform, networks, and flow-through the Neropin platform or referral source: It is within our legitimate interest to process this information for data analytics purposes and to understand how you interact with the Neropin platform to optimize our services.

For other data: It is necessary to process this information in order to fulfill our contractual obligations to you, such as processing your payment and providing the Service.

 c-    User Information: date of birth (not stored), name, username, email address, and Facebook nickname and profile picture. If you access the Service through a Game Operator or Third Party Website, we will also collect the information provided by that third party, such as the referring website.

We use this information to create your Neropin account and facilitate your purchases on Neropin in accordance with your request.

Necessary to fulfill our contractual obligations to you in order to provide the Service.

d-   Transaction Data: bank details, invoice information such as billing address, email address, credit card type, phone number, account holder information (e.g., account name, user name), Neropin registration date, number of successful orders in the past three months, whether the card number was manually entered or pasted, game ID, login method, IP address, device fingerprint (which includes details such as time zone, browser information, CPU class, and platform used, i.e., iOS, Android, or web), card details, and shipping information, as well as your payment information provided by third-party payment processors (purchase payment date, merchant transaction ID).

We use this information to detect fraudulent activity and verify transactions. It is in our legitimate interest to ensure the integrity of the Service and to prevent the fraudulent use of your details.

e-    Support Information: If you contact us, we will process the email address you used for communication, along with any other personal information you choose to include in your email.

We use this information to assist in managing your support request.

It is essential for us to process this information in order to fulfill our contractual obligation to provide the Service.

f-    Sweepstakes Participation Information: name, country, player ID, email address, phone number, and payment method.

If you participate in a sweepstakes event, we use this information to send your prize and provide a rebate or top-up if you win. We collect this information based on your consent.

g-   Advertising / information used to create customer/audience lists (via Facebook) (for the United States only): email address, phone number, first and last name, city, state and country, zip/postal code, and Facebook user ID.

We use this information to generate a customer/audience list to share with Facebook, allowing us to deliver better and more targeted marketing to you and others.

The processing of your personal data by Facebook is governed by Facebook’s Privacy Policy.

It is within our legitimate interest to provide more effective and accurate marketing to potential users of Neropin.

h-   Marketing emails: email address.

We use this information to send you news, special offers, and discounts related to our products and services, as well as those of our partners and affiliates, which may be of interest to you.

We collect this information based on your consent.

i-     Website notifications: user ID.

We use this information to send website notifications about news, special offers, and discounts related to our products and services, as well as those of our partners and affiliates. We process this information based on your consent.

j-    Payment information (native or from payment processor) such as card number, CVV, expiry date, cardholder's name, user's billing address; transaction cost, time and date; payer ID/Open ID; order reference ID.Notification of payment status (from payment processor): country, payment status, device type, currency, funding source, phone number, email address, card hash, card name and details, card issuing bank, billing address, expiry date, amount, date, time, payment method, browser code, payment account reference, authentication code, card bin.For tax purposes: country, province, zip code, IP address.

We use this information to process your transaction and verify the validity of your identity and transaction. Additionally, we use this information for tax purposes.

We process this information in accordance with our contract with you to handle transactions.

k-   Card binding function data (if and to the extent applicable): card number (encrypted), expiry date, cardholder's name, user’s billing address, CVV (not stored after verification), muid (the user ID for Neropin), openid (the player ID for the game), portal serial number (the tracking number for the payment).

We use this information to provide a card binding function for the Neropin platform.

We process this information in accordance with our contract with you to facilitate transactions.

l-     Social Connect Information (if you choose to log in via your social media account on these networks):Via Facebook: user email, user token

Via Google: user email, user token

We use this information to create your account for the Service based on your request. We process this information with your consent.

m- Account Information: user ID.

We generate a unique user ID when you create a Neropin account. It is necessary to fulfill our contract with you to provide the Service.

n-   Browser and Device Information: details of your browser version, operating system version, country, RFID tag, IP address, open ID, internet connection, page loading time, type of mobile or computing device, date and time stamps of actions, number of visits, time spent on the Neropin platform, networks, flow through the Neropin platform or referral source, and player ID.

We use this information to facilitate your purchase on Neropin in accordance with your request. It is necessary for us to use this information to fulfill our contract with you to provide the Service.

o-   In-game status information: If you have made a purchase using our Service, we confirm with a Yes or No whether you are active in-game within the country where your online payment account is registered.

We use this information to detect fraudulent activity and verify transactions. It is within our legitimate interest to ensure the integrity of the Service and to prevent the fraudulent use of your information.

p-   Mobile device fingerprint data (a digital signature that does not collect any biometric data): your device fingerprint, time of creation, time zone, device OS information, browser type, platform information, QQ login state, node, screen size and font, audio fingerprint, battery status, domain, and adblock status.

We use this information for fraud verification purposes. It is within our legitimate interest to ensure the integrity of the Service and to prevent your details from being used fraudulently.

q-   Purchase Information: items purchased and their cost, the time, date, and currency of the purchase, order ID, open ID, player ID, country, game account balance, and purchase history. If you pay with Paytm, we will collect your email address. If you pay with Tpay, we collect your telephone number. If you pay with your bank card, we will collect the card number, expiry date, cardholder's name, and billing address.

We use this information to facilitate your purchase on Neropin in accordance with your request and to provide access to your transaction history. It is necessary for us to use this information to fulfill our contract with you to provide the Service.

4.    Handling and Sharing of Your Personal Information

In accordance with our contractual obligations, we may transfer your data to locations outside of your primary jurisdiction for the purposes outlined in this Privacy Policy.

Our Service operates on servers located in US. The specific servers utilized for your service will be determined based on your geographic location. Additionally, our support, engineering, and other teams, which provide assistance to the Service, are also based in US.

For users in the EEA/UK, any data transfers between our affiliates or to third parties are conducted with appropriate safeguards in place, such as implementing standard contractual clauses, obtaining your explicit consent, or considering adequacy decisions.

We will only disclose your personal information to third parties when it is necessary. Instances in which such disclosures may occur include:

Third parties that provide services to support the Service, including cloud service providers that process information identified in this policy on their servers to provide the Service, service providers used to identify fraudulent or suspicious transactions (e.g., Cybersource International Inc., Boku Payments, Razer Online Pte Ltd), and third-party payment processors to ensure the completion of your transactions (e.g., Adyen N.V.) or to conduct data analysis (e.g., Centauri Technology Pte. Ltd). All companies providing services for us are prohibited from retaining, using, or disclosing your personal information for purposes other than providing their services or complying with legal obligations under applicable laws.

Companies within our corporate group that process your personal information solely to provide the Service to you. All such group companies may only use your personal information in accordance with this Privacy Policy.

Regulators, judicial authorities, and law enforcement agencies. In certain circumstances, we may be legally required to disclose your information, such as to comply with legal obligations or legal processes. When complying with valid legal processes (such as a subpoena or search warrant), we may not be able to obtain your consent or notify you in advance of such disclosures.

Third parties to ensure safety, security, or compliance with laws. We may disclose your information to:

o  Enforce our terms and conditions and other agreements, including investigating potential violations;

o  Detect, prevent, or address security, fraud, or technical issues; or

o  Protect the rights, property, or safety of us, our users, third parties, or the public, as required or permitted by law (e.g., sharing information with other companies and organizations for fraud protection and credit risk reduction).

A third party that acquires all or substantially all of our business. We may disclose your information to third parties if we: (a) sell, transfer, merge, consolidate, or reorganize any part of our business, or merge with, acquire, or form a joint venture with another business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such a change; or (b) sell or transfer any of our assets, in which case your information may be sold or transferred as part of those assets and disclosed to any prospective buyer, new owner, or other third party involved in such a sale or transfer.

5.    The Security of Your Personal Information

We have implemented information security and access policies that restrict access to our systems and technology, and we protect data through the use of technological safeguards such as encryption.

Unfortunately, transmitting information over the internet is not completely secure. While we will apply and maintain reasonable measures to protect your personal information, we cannot guarantee the security of information transmitted through the Service or over the Internet; any transmission is done at your own risk.

6.    Data Retention

We do not retain your data for longer than necessary to fulfill the relevant purposes described above, unless required or permitted by law. If we retain your information beyond the specified retention periods, for example, to comply with applicable laws, we will store it separately from other types of personal information.

For further details on how long we retain your data, please refer to the time periods outlined below.

Personal Information

Retention Policy

Guest User Information (for guests that do not provide a player ID and browse the website): IP address

1 year

Guest User Information (for guests that provide a player ID and browse the website)

7 days

User Information (other than date of birth which we do not store), Browser and Device Information, In-game status information, Purchase Information, Support Information, Transaction Data, Account Information, Payment Information

We generally store this data for the lifetime of your use of the Service (i.e. until account deletion in accordance with your request) and then delete it within 30 days.

However, we retain transaction data (which includes your name and user ID as well as bank details) for 160 days from the date of the last transaction involving the credit card. We do this even where you request that we delete your account because this is in line with our legal obligations and is also necessary to ensure that we can perform our contract with you.

Where you do not request account deletion, the data will be retained for one year after each applicable Game is closed, before it is deleted.

 Sweepstakes Participation Information

Stored for the duration of the sweepstakes event and then deleted within 10 days

Marketing emails and website notifications

Stored for the lifetime of your use of the Service (i.e. until account deletion in accordance with your request) and/or when you choose to unsubscribe from receiving marketing emails or adjust your website notification settings, whichever is earlier.

Information used to create customer/audience list (via Facebook) (for the United States only)

Store for the duration of the advertising event and then deleted within 10 days

Device Fingerprint Data

Retained for up to one week after collection for verification purposes and deleted thereafter.

Account Registration Information

Facebook Log-In Information

Google Log-In Information

Level Infinite Account Log-In Information

Stored for the lifetime of your use of the Service and then deleted within 30 days after the end of the Service, or deleted manually within 30 days of your request, whichever is earlier.

7.    Your Rights

Some jurisdictions’ laws grant specific rights to users of the Service. Please refer to the Supplemental Jurisdiction-Specific Terms, or the applicable laws in your jurisdiction, for an overview of specific rights that apply to individuals subject to data protection laws in the listed jurisdictions and how these can be exercised.

You may have certain rights regarding the personal information we hold about you. Some of these rights only apply in specific circumstances (as detailed below). You can exercise some of these rights directly by accessing and updating the information in your account. If you believe we hold any other personal information about you, please contact us.

Access

You may have the right to access personal information we hold about you, understand how we use it, and see who we share it with. You can access the personal information you have provided by logging into your account.

Portability

You may have the right to receive a copy of certain personal information we process about you. For example, in some jurisdictions, this could include personal information processed with your consent (e.g., survey information) or pursuant to our contract with you (e.g., account name), as outlined in the section "How We Use Your Personal Information." Upon request, we will provide further details on how to transfer this data.

Correction

You may have the right to correct any inaccurate personal information we hold. You can access and correct your personal information by logging into your Service account.

Erasure

You may be able to delete your account or remove specific personal information by logging into your Service account. However, we may need to retain certain personal information if there are valid legal grounds to do so (e.g., for the defense of legal claims or freedom of expression), and we will inform you if this is the case. If you request the erasure of publicly available personal information, and there are legal grounds for its deletion, we will take reasonable steps to notify others who display or provide links to that information to delete it as well.

Restriction of Processing to Storage Only

You may have the right to request that we stop processing your personal information (except for storage purposes). Please note that even if we stop processing the information, we may still use it if there are valid legal grounds to do so (e.g., for the defense of legal claims or for the protection of others). If we agree to stop processing your personal information, we will notify any third party to whom we have disclosed the relevant information so that they too can stop processing it.

Objection

You may have the right to object to our processing of your personal information. If you wish to do so, please contact us at [email protected] or using the contact details provided below, and we will consider your request.

Consent Withdrawal

To the extent permitted by applicable laws and regulations, you may withdraw the consent you previously provided to us for certain processing activities by contacting us at [email protected]. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent, we may not be able to provide the expected service. Please note that the right to withdraw consent is only applicable when the legal basis for processing is consent.

Announcements

From time to time, we may send you announcements when we deem it necessary (for example, if we temporarily suspend access to the Service for maintenance, or for security, privacy, or administrative-related communications). These are essential system and service-related announcements, and you cannot opt out of receiving these notifications, as they are not promotional in nature.

8.    Contact

Please get in touch with us if you have any questions. You can reach us at:

Email: [email protected]

Mailing Address:

30 N Gould St Ste N

Sheridan, WY 82801, US

We will endeavor to address your request as soon as possible. This is without prejudice to any right you may have to file a claim with a data protection authority in the region where you live or work if you believe we have violated data protection laws.

9.    Changes

If we make any changes to this Privacy Policy, we will post the updated Privacy Policy here and notify you in accordance with relevant legal requirements.

10. Language

Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and the local language version of this Privacy Policy, the English version shall prevail.

SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

Some jurisdictions’ laws contain additional terms for users of the Service, which are outlined in this section.

If you are a user located in one of the jurisdictions listed below, the terms specified under the name of your jurisdiction apply to you in addition to the terms set out in our Privacy Policy above.

France

Instructions for the processing of your personal data after your death. You have the right to provide us with general or specific instructions for the retention, deletion, and communication of your personal data after your death. The specific instructions are only valid for the processing activities mentioned therein, and the processing of these instructions is subject to your specific consent. You may amend or revoke your instructions at any time.

You may designate a person responsible for the implementation of your instructions. This person will be informed of your instructions in the event of your death and will be entitled to request their implementation from us. In the absence of designation or, unless otherwise provided for, in the event of the death of the designated person, their heirs will have the right to be informed of your instructions and to request their implementation from us.

When you wish to make such instructions, please contact us as outlined in Section 8 (Contact).

Turkey

Under Article 11 of the Turkish Data Protection Law (DPL), you are granted certain legal rights regarding your personal data. As a data subject in Turkey, you may apply to the data controller and, where permitted by applicable laws and regulations, exercise the following rights:

·      Inquire whether your personal data has been processed;

·      Request details about how your personal data has been processed, if applicable;

·      Understand the purpose of processing your personal data and whether it has been used in line with that purpose;

·      Learn about the third parties, within Turkey or abroad, to whom your personal data has been transferred;

·      Request correction of incomplete or inaccurate personal data and request that any changes be communicated to third parties to whom the data has been transferred;

·      Request the deletion or destruction of your personal data under the conditions set out in Article 7 of the DPL and ensure that such actions are reported to the third parties to whom your data has been transferred;

·      Object to any adverse outcomes resulting from the automated processing of your personal data;

·      Seek compensation for damages incurred due to the unlawful processing of your personal data.

In accordance with Article 9 of the DPL, your personal data may be transferred internationally under the following conditions:

To fulfill our legal obligations and perform company operations as required by the user agreement, your personal data, including user information, is transferred to our website servers located in the United States.

United Arab Emirates

By using our services, you consent to the collection, use, disclosure, transfer, export (to the extent allowed by applicable laws), sharing, and storage of your personal information as outlined in our Privacy Policy.

We may choose to voluntarily report a cyber-security incident if it qualifies as a crime under UAE law (for instance, under the UAE Cybercrime Law). Such incidents may be reported to the relevant authorities for investigation purposes. Additionally, voluntary reporting of cyber-security incidents can be submitted to the UAE Computer Emergency Response Team ("CERT"), which is a security organization dedicated to logging incidents and advising on recognized cyber-security threats within the UAE.