Citibank

Privacy Policy

I. INTRODUCTION

Super Evil Mega Corp, Inc., a Delaware corporation, (“Super Evil”) is committed to respecting the privacy rights of the customers, visitors, and other users of Super Evil’s free-to-play computer game, Vainglory (the “Game”) and its related websites, including https://www.vainglorygame.com, and http://www.superevilmegacorp.com (collectively, the “Site”) and our mobile application. We created this Privacy Policy (this “Policy”) to give you, the user, confidence as you visit and use the Site or the Game, and to demonstrate our commitment to fair information practices and the protection of privacy. By visiting the Site or using the Game, you consent to our collection, use, storage, deletion and disclosure of information relating to you as set forth in this Policy. This Policy is only applicable to the Site and the Game, and not to any other third-party websites that you may be able to access from the Site, each of which may have data collection and use practices and policies that differ materially from this Policy.

If you have questions or concerns regarding this Statement, you should first contact .

II. GENERAL INFORMATION AND CERTIFICATIONS

A. General Disclosure

For the purpose of applicable data protection legislation, the data controller of your personal data is Super Evil Megacorp Inc. of 119 S B St, Ste A, San Mateo, CA, 94001, USA. Our EU Representative can be contacted by mailing them at one of the following addresses. Please make sure to address your letters to the DPR Group and not Super Evil Megacorp.

Country	Address
Austria	DPR Group, City Tower, Brückenkopfgasse 1/6. Stock, Graz, 8020, Austria
Belgium	DPR Group, Place de L’Université 16, Louvain-La-Neuve, Waals Brabant, 1348, Belgium
Bulgaria	DPR Group, 132 Mimi Balkanska Str., Sofia, 1540, Bulgaria
Croatia	DPR Group, Ground & 9th Floor, Hoto Tower, Savska cesta 32, Zagreb, 10000, Croatia
Cyprus	DPR Group, Victory House, 205 Archbishop Makarios Avenue, Limassol, 3030, Cyprus
Czech Republic	DPR Group, IQ Ostrava Ground floor, 28. rijna 3346/91, Ostrava-mesto, Moravska, Ostrava, Czech Republic
Denmark	DPR Group, Lautruphøj 1-3, Ballerup, 2750, Denmark
Estonia	DPR Group, 2^nd Floor, Tornimae 5, Tallinn, 10145, Estonia
Finland	DPR Group, Luna House, 5.krs, Mannerheimintie 12 B, Helsinki, 00100, Finland
France	DPR Group, 72 rue de Lessard, Rouen, 76100, France
Germany	DPR Group, 3rd and 4th floor, Altmarkt 10 B/D, Dresden, 01067, Germany
Greece	DPR Group, 24 Lagoumitzi str, Athens, 17671, Greece
Hungary	DPR Group, EMKE Building, Rákóczi Út 42, Budapest, 1072, Hungary
Ireland	DPR Group, Phoenix House, Monahan Road, Cork, T12 H1XY, Republic of Ireland
Italy	DPR Group, BPM 335368, Via Roma 12, 10073 , Turin, Italy
Latvia	DPR Group, 4th & 5th floors, 14 Terbatas Street, Riga, LV-1011, Latvia
Lithuania	DPR Group, Vilniaus g.31, Vilnius, LT- 01402, Lithuania
Luxembourg	DPR Group, BPM 335368, Banzelt 4 A, 6921, Roodt-sur-Syre, Luxembourg
Malta	DPR Group, Tower Business Centre, 2nd floor, Tower Street, Swatar, BKR4013, Malta
Netherlands	DPR Group, Cuserstraat 93, Floor 2 and 3, Amsterdam, 1081 CN, Netherlands
Poland	DPR Group, Budynek Fronton ul Kamienna 21, Krakow, 31-403, Poland
Portugal	DPR Group, Torre de Monsanto, Rua Afonso Praça 30, 7th floor, Algès, Lisbon, 1495-061, Portugal
Romania	DPR Group, World Trade Centre, Piata Montreal no 10, Entrance F, 1st Floor, Sector 1, Bucharest, 11469, Romania
Slovakia	DPR Group, Apollo Business Centre II, Block E / 9th floor, 4D Prievozska, Bratislava, 821 09, Slovakia
Slovenia	DPR Group, Trg. Republike 3, Floor 3, Ljubljana, 1000, Slovenia
Spain	DPR Group, Puerta de las Naciones, Ribera del Loira 46, Madrid, 28042, Spain
Sweden	DPR Group, S:t Johannesgatan 2, 4th floor, Malmo, SE – 211 46, Sweden
United Kingdom	DPR Group, BPM 335368, 372 Old Street, EC1V 9AU, London, United Kingdom

Subject to the next paragraph, we ask that you not send us, and you do not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Site or Game or otherwise to us.

If you send or disclose any sensitive personal data to us when you submit user-generated content to the Site or Game, you consent to our processing and use of such sensitive personal data in accordance with this policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such user generated content to the Site or the Game.

B. EU-U.S. Privacy Shield

Super Evil participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Super Evil is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s https://www.privacyshield.gov/list.

Super Evil is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Super Evil complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Super Evil is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Super Evil may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the Privacy Shield Principles, Super Evil commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Super Evil at:

Super Evil has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the US. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you.

Under certain conditions, more fully described on the https://www.privacyshield.gov/welcome, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

III. INFORMATION COLLECTION AND USE PRACTICES

A. What Basic Information Does Super Evil Collect?

We typically collect personal information that you provide to us on a voluntary basis, and you may visit areas on the Site without choosing to do so. However, in order to use certain parts of the Site and/or log-on to play the Game, you will be required to create an account by providing us your email address and selecting a unique username and password (an “Account”). In the course of maintaining your Account, you might also be asked to participate in online surveys about the Game, or in other Game-related promotional contests, participation in which is entirely voluntary. You might also desire to contact our customer support team via the “Support” tab found on the Site. In participating in such promotional activities or in contacting customer support, you might be requested to provide additional information beyond your email address, including your name, full address and phone number. In operating the Site or otherwise offering the Game, we might also request other information from you, including hardware specs, software performance metrics, game experience, and other demographic information that might be associated with your personal information, such as your gender, hobbies, occupation, platform preferences, and other game ownership information.

When you download and use our Services, we automatically collect information on the type of operating system, device you use.

We send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you may turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.

We use mobile analytics software to allow us to better understand the functionality of our Mobile Software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.

Please note that in utilizing certain areas of the Site (e.g. purchasing merchandise) or the Game (e.g. purchasing in-game currency), you will be requested to provide additional information in order to complete a purchase, such as your name, full address, phone number, internet protocol address (for fraud tracking purposes) and Our shopping cart is hosted by our e-commerce solutions provider. They host our ordering system, and collect your billing information directly from you for the purpose of processing your order. This company does not use this information for any other purpose. Please see Section V below regarding how third parties working on behalf of Super Evil use your personal information.

In the event that you choose to create an Account and play the Game, we also collect certain information regarding your in-Game performance and/or interactions with other users (e.g., wins / losses, recent heroes played, average number of kills / deaths etc.). These statistics are associated with your in-Game name and are publicly accessible by members of the Super Evil community. In addition, we may share your in-Game statistics with third parties in accordance with the terms and conditions set forth in this Policy. To be clear, no personal information about you, such as your email address, IP address, or other sensitive information, will be shared as a part of this process.

B. What Additional Information Does Super Evil Collect?

(1) AUTOMATIC COLLECTION. Our servers automatically recognize visitors’ domain names and internet protocol (IP) addresses (the number assigned to computers on the Internet). In addition, your web browser or Game software may transmit to Super Evil certain geographic information or other information regarding your computer, including its capabilities, hardware specs and game data processing. No personal information about you is revealed in this process. The Site may also gather anonymous “traffic data” that does not personally identify you, but that may be helpful for marketing purposes or for improving the services we offer.

(2) COOKIES. The Site or Game uses Analytics and Performance Cookies. These cookies are used to collect information about traffic to the Site. The information gathered does not identify any individual visitor. The information is aggregated and anonymous. It includes the number of visitors to the Site, the websites that referred them to the Site, the pages they visited on the Site, what time of day they visited the Site, whether they have visited the Site before, and other similar information. We use this information to help operate the Site more efficiently, to gather broad demographic information and to monitor the level of activity on the Site.

We use Google Analytics. Google Analytics uses its own cookies. It is only used to improve how the Site works. You can find out more information about Google Analytics cookies here:
https://developers.google.com/analytics/resources/concepts/gaConceptsCookies.

You can find out more about how Google protects your data here:
https://www.google.com/analytics/learn/privacy.html.

You can prevent the use of Google Analytics relating to your use of the Site by downloading and installing the browser plugin available via this link:
http://tools.google.com/dlpage/gaoptout?hl=en-GB.

We use the Conversion Tracking Pixel service of Facebook, Inc. This tool allows us to follow the actions of users after they are redirected to a provider’s website by clicking on a Facebook advertisement. We are thus able to record the efficacy of Facebook advertisements for statistical and market research purposes. The collected data remains anonymous. This means that we cannot see the personal data of any individual user. However, the collected data are saved and processed by Facebook. Facebook is able to connect the data with your Facebook account and use the data for their own advertising purposes, in accordance with Facebook’s Data Use Policy found under: https://www.facebook.com/about/privacy/.

Facebook Conversion Tracking also allows Facebook and its partners to show you advertisements on and outside of Facebook. In addition, a cookie will be saved onto your computer for these purposes.

Only users over 13 years of age may give their permission. If you are younger than this age, please consult your legal guardians.

Please click here if you would like to revoke your permission: https://www.facebook.com/ads/website_custom_audiences/.

Super Evil also works with Unity Ads and Iron Source to serve ads within the game. If you wish to limit behaviorally targeted advertising, you can do so by limiting ad tracking in your device settings. Please note that opt-outs are specific to each browser and device and it may take a little bit of time before your opt-out will take effect.

Ad networks can use cookies, web beacons, and other tracking technologies to collect or receive data about you and might claim controller rights over your personal data. For more information about their privacy practices and opt-out possibilities, please review their privacy policy:
Unity Ads – https://unity3d.com/legal/privacy-policy

Iron Source – https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy

C. Why do we need your personal data?

We will only process your personal data in accordance with applicable data protection and privacy laws. We need certain personal data in order to provide you with access to the Site or Game. If you created a profile, you will have been asked to check a tick box indicating your agreement to provide this data in order to play the Game. This consent provides us with the legal basis we require under applicable law to process your data. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your personal data in line with this policy, please do not use the Site or Game.

D. What Does Super Evil Do With Collected Information?

(1) PERSONAL INFORMATION. We will not share your personal information with any third parties without your consent, except as necessary to provide you with the services offered by us, to comply with the law or as otherwise described in this Policy. We may use your personal information to verify your identity or to check your qualifications, to inform you of any changes to the Site or Game, or to send you additional information about Super Evil. We may also use your information to contact you should we believe that you are in violation of the Terms of Use Agreement (“Terms of Use”). If you do not want us to share your personal information with these companies, you may contact us at: .

(2) COMPELLED DISCLOSURES OF PERSONAL INFORMATION. In certain situations, Super Evil may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may disclose personal information if required to do so by law or in the good-faith belief that such action is necessary to (a) comply with requirements of the law or comply with legal process served on Super Evil (b) protect and defend the rights or property of Super Evil or the users of the Site or Game, or (c) act under unusual, extraordinary or emergency circumstances to protect the safety of the public or users of the Site or Game.

(3) SALE OF INFORMATION. In order to accommodate changes in our business, we may sell or buy portions of our company or other companies or assets, including the information collected through the Site or otherwise collected in connection with the Game. If Super Evil or substantially all of its assets are acquired, customer information and personal information will be one of the assets transferred to the acquirer. Should such an event occur, we will use reasonable means to notify you, either through email and/or a prominent notice on the Site.

(4) ACCESS TO INFORMATION. At any time you may request access to the information that we have from you, or request that we remove all information about you from our database by contacting us in accordance with Section VII.A below.

(5) Your data, including personal data that we collect from you, may be transferred to, stored at and processed by us and our affiliates and other third parties outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using the Site or Game, you agree to this transfer, storing or processing. As noted in Section II of this Privacy Policy we are a participant in the EU-U.S. Privacy Shield and we will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy.

(6) We will only retain your personal data until you request to close your account unless a longer retention period is required or permitted by law (for example, for regulatory purposes).

(7) We do not use your personal data for the purposes of automated decision-making. However, we may do so in order to fulfil obligations imposed by law, in which case we will inform you of any such processing and provide you with an opportunity to object.

E. Notice Concerning Children

PLEASE NOTE: We are a general audience site, and do not direct any of our content specifically at children under 16 years of age. The Site and the Game are not intended for children under the age of 16. We understand and are committed to respecting the sensitive nature of children’s privacy online, and as such do not knowingly collect any personal information from any user under age 16. If we learn or have reason to suspect that a Site or Game user is under age 16, we will promptly delete any personal information in that user’s Account.

IV. SECURITY

The Site and the Game have security measures in place to help protect against the loss, misuse, and alteration of the information that we obtain from you. We store your personal information on our servers, which are located in secured facilities with restricted access, and protected by protocols and procedures designed to protect the security of such information. In addition, we restrict access to personal information to Super Evil employees, independent contractors and agents who need to know this information in order to develop, operate and maintain the Site and the Game. However, no server, computer or communications network or system, or data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect user information, we cannot ensure or warrant the security of any information you transmit to us through the use of the Game or the Site and we make no assurances about our ability to prevent any such loss or misuse to you or to any third party. You acknowledge and agree that you provide such information and engage in such transmissions at your own risk.

When you enter information, we encrypt the transmission of that information using secure socket layer technology (SSL). If you have any questions about the security of your personal information, you can contact us at .

V. WEBSITE AREAS BEYOND OUR CONTROL

A. Third Party Websites

The Site contains links to other websites. If you choose to visit other websites, we are not responsible for the privacy practices or content of those other websites, and it is your responsibility to review the privacy policies at those websites to confirm that you understand and agree with their policies.

B. Opt-Out Preferences

Opt-out. You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) automated decision-making and/or profiling; (iii) our collection of sensitive personal data; (iv) any new processing of your personal data that we may carry out beyond the original purpose; or (v) the transfer of your personal data outside the EEA. Please note that your use of some of the Site or Game may be ineffective upon opt-out.

Access. You may access the data we hold about you at any time by contacting us directly.

Amend. You can also contact us to update or correct any inaccuracies in your personal data.

Move. Your data is portable – i.e. you to have the flexibility to move your data to other service providers as you wish.

Erase and forget. In certain situations, for example when the data we hold about you is no longer relevant or is incorrect, you can request that we erase your data.

You may contact us at or 400 1st Ave, San Mateo, CA, 94401, USA anytime for any other questions you may have about your personal data and our use of such personal data.

VI. SERVICE PROVIDERS

We may share your personal information with service providers that we engage for the purpose of processing information on our and your behalf, such as to fulfill product orders, collect billing information and process payments. While providing services for us, these companies may access your personal information.

To the extent applicable, we require these entities to comply with this Policy and appropriate confidentiality and security measures. Some of the pages within the Site utilize masking techniques to serve content to you from our partners while preserving the look and feel of our Site. Please be aware that you are providing your personal information to these third parties, and are doing so pursuant to the third party’s privacy policy.

VII. CONTACT INFORMATION AND POLICY UPDATES

A. Contacting Us

If you have any questions about this Policy, our practices regarding your personal information related to the Site or Game, or if you would like to have us remove your information from our database and deactivate your Account, please feel contact us at . Upon request Super Evil will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. If your personally identifiable information changes, or if you no longer desire our service, you may correct, update or amend it by emailing our Customer Support at , or by contacting us by postal mail at the contact information listed below. We will respond to your request to access within 30 days of receipt of the request. Please note that the deletion of your data will lead to the termination of your Account and applicable services.

B. Updates and Changes

We may update this privacy statement to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

BY USING THE SITE AND/OR THE GAME, YOU SIGNIFY THAT YOU HAVE READ, UNDERSTAND AND AGREE TO THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, PLEASE DO NOT USE THE SITE OR THE GAME.

C. Additional Policies

There are additional Super Evil legal policies that govern your use of the Site and the Game. Please take time to review and familiarize yourself with the Terms of Use.

Effective Date: June 19, 2019

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