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.