New World Interactive

PRIVACY POLICY

Last Modified on May 25, 2018

We ask that you read this privacy notice carefully, as it contains important information on who we are, how and why we collect, store, use, and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

WHO WE ARE

New World Interactive, LLC (“NWI,” “We,” or “Us”) collects, uses and is responsible for certain personal information about you, as part of the “Day of Infamy”, “Insurgency” and “Sandstorm” games and the various NWI websites, located within the domain newworldinteractive.com, insurgency.game, sandstorm.game, and dayofinfamy.game (collectively, the “Service”).

For those in the European Union, we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as controller of that personal information for the purposes of those laws.

The Personal Information we collect and use

Information collected by us

In the course of providing you with the Service, we collect the following personal information either automatically or when you voluntarily provide it to us:

  • Your name and email address are collected when you sign up for our newsletter, contact us about a Service-related issue or support ticket, or fill out a survey (your “Identity Information”)
  • Your IP Address, platform type, hardware settings, hardware components, and software version (your “Technical Information”)
  • Your game save data, gameplay data, play history, in-game inventory, and other Game-related data (your “Game Information”)

Information shared with us by others

If you purchase the games on a third-party service like Steam or PSN, your Platform ID from that third-party service will be shared with us (your “Platform Information”).

How we use your Personal Information

We use your personal information as follows:

  • Newsletters: NWI may use your Identity Information to send you commercial or marketing messages including, without limitation, newsletters and email communications about our products or services.
  • Technical Support: NWI uses Identity Information, Technical Information, and Game Information, as needed, to provide you with technical support for the Service.
  • Online Multiplayer: NWI uses your Technical Information, Game Information, and Platform Information to provide you with advertised game features, including online multiplayer.
  • Surveys and Feedback: NWI may offer you the chance to participate in surveys and other Service feedback. We may use your Identity Information to receive and process any surveys and feedback from you and other users in order to improve the Service.

Who we share your Personal Information with

We share your Personal Information with certain third parties as part of our operation of the Service. This data sharing enables us to provide you with the Service in the optimal way.

Some of those third-party recipients may be based outside the European Economic Area — for further information, including how we safeguard your personal data when this occurs, see their individual privacy policies linked to above and the section entitled “Transfer of your Information out of the EEA,” below.

We share your Personal Information
with the following third parties:

  • Game Hosting: We use certain cloud services for multiplayer games that you play on the Service. We share your Technical Information, Game Information, and Platform Information with them for these purposes. These third-party services are:
  • Digital OceanPrivacy Policy
  • VultrPrivacy Policy
  • Anti-Cheat: We use a third-party service to prevent users from cheating in online games on the Service. We share Technical Information with them for these purposes. You can view their privacy policy here.
  • Newsletters: We use Robly to help manage our newsletter mailing list. We share your Identity Information with them for these purposes. You can view their privacy policy here.
  • Support Tickets: We use HappyFox to handle support tickets on the Service. Your Identity Information and Technical Information is shared with them when you submit a request for support on the Service. You can view their privacy policy here.
  • Surveys and Feedback: We use SurveyMonkey to help us gather survey data and feedback about the Service. Any information you enter into a survey is shared with them, as is certain Identity Information and Technical Information. You can view their privacy policy here.

Other Sharing:

We will share your Personal Information if we have a good faith belief that (i) access, use, preservation or disclosure of such information is reasonably necessary to satisfy any applicable law, regulation, legal process, such as a court order or subpoena, or a request by law enforcement or governmental authorities, (ii) such action is necessary to detect, prevent, or otherwise address fraud, security or technical issues associated with the Service, or (iii) such action is appropriate to protect the rights, property or safety of NWI, its employees, clients, or users of the Service.

We will not share your personal information
with any other third party.

How long your Personal Information will be kept:

We will keep your Personal Information for the length of time required to provide you with the Service, unless a longer retention period is required or permitted by law. Afterwards, we delete all aforementioned data in our possession within a reasonable timeframe. We do not verify the correctness of personal data that we collect or you provide.

Please note that some data may be retained if necessary to resolve disputes, enforce NWI user agreements, and comply with technical and legal requirements and constraints related to the security, integrity and operation of the Service.

Reasons we can collect and use your Personal Information:

The laws in some jurisdictions require that we notify you of the lawful basis for collecting your Personal Information.

To the extent that such laws apply, we rely on the following as the lawful basis on which we collect and use your personal information:

  • Consent: At times we may collect, process, store, transfer or disclose your personal data on the basis of your implied or explicit consent.
  • To fulfill our contractual obligations: In order to fulfill our contractual obligations to you, we must collect, process, and store your personal data and information. We must handle your personal data in this manner to provide you with advertised features of the Service, such as multiplayer-related features.Additionally, we may at times have to transfer or receive your personal data to or from third parties, in order to fulfill other contractual obligations to you. For example, we may have to transfer your information to prevent cheating in the multiplayer portion of the Service.
  • Furtherance of legitimate interests: We may collect, process, store, transfer or disclose your personal data in furtherance of those legitimate interests of ours which are not overridden by your interests or fundamental rights and freedoms as set forth in the applicable laws. These legitimate interests include, but are not limited to, (i) providing you with the Service, (ii) protecting our users, staff, and property from fraud and other harm, (iii) collecting information on how you use the Service in order to optimize the design and functionality of the Service, (iv) to prevent cheating on the multiplayer gameplay portion of the Service, and (v) communicating with you via e-mail for communications you have explicitly opted into (e.g., notifications about new products and services) or for important communications with you regarding the Service.
  • Legal compliance: We may collect, process, store, transfer or disclose your personal data to comply with our legal obligations.

Depersonalized Information:

We may make your Personal Information non-personally identifiable by either combining or aggregating it with information about other users, or by removing characteristics (such as your name or email address) that make the information personally identifiable. This process is known as de-personalizing your information and is used to analyze usage and improve the Service.

Children’s Privacy:

We do not knowingly collect any personal information from children under the age of 13, allow them to create accounts, sign up for newsletters, make purchases, or browse the Service. In addition, we may limit how we collect, use, and store some of the information of EU users between 13 and 16. NWI takes children’s privacy seriously and encourages parents to play an active role in their children’s online experience at all times. We urge parents to instruct their children never to give out their real names, addresses, or phone numbers, without parental permission, when online. If you have any concerns about your child’s personal information, please contact us at [email protected]

Cookies:

When you use the Service, cookies may be used by us and by third parties to allow the Service to function, to collect useful information about visitors, and to help to make your user experience better. Some of the cookies we use are strictly necessary for our Service to function, and we don’t ask for your consent to place these on your computer. For more information about our use of cookies, please see our cookie policy.

Links to Other Sites:

The Service may contain links to other sites or services. If you click on a third-party link, you will be directed to that site or service. These external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites or services. We have no control over, and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Transfer of your Information out of the EEA

NWI is based in the United States. No matter where you are located, you consent to the processing, transfer and storage of your information in and to the U.S., in accordance with the privacy policies of third parties with whom we share your Personal Information. The laws of the U.S. and other countries governing data collection and use may not be as comprehensive or protective as the laws of the country where you live.

If you would like further information, please contact us (see “How to contact us” below).

Your Rights

Under the laws of some jurisdictions, including the General Data Protection Regulation in the EEA, you have a number of important rights with regard to your Personal Information.

  • By law, you can ask us what information we hold about you, and you can ask us to correct it if it is inaccurate. If we have asked for your consent to process your personal data, you may withdraw that consent at any time.
  • If we are processing your personal data for reasons of consent or to fulfill a contract, you can ask us to give you a copy of the information in a machine-readable format so that you can transfer it to another provider.
  • If we are processing your personal data for reasons of consent or legitimate interest, you can request that your data be erased.
  • You have the right to ask us to stop using your information for a period of time, if you believe we are not doing so lawfully.
  • Finally, in some circumstances, you can ask us not to reach decisions affecting you using automated processing or profiling.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please email us at [email protected]. We may ask for additional verification information, such as your username and other information required to be sure that you are the owner of that data.

Keeping your Personal Information secure

We have taken steps to put appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorized way.
For example, we limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

We hope that we can resolve any questions or concern you raise about our use of your Personal Information. Please contact us via the methods listed below in the section entitled “How to contact us” to let us know about any of your questions or concerns, and we will get back to you to resolve the issue.

If you are an EU citizen, the General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.

Changes to this Privacy Notice

This privacy notice was last updated on May 25, 2018.

We may change this privacy notice from time to time. When we do, we will inform you via email to the email address you have provided us with through your account, or by posting a message about the change on the Service.

How to contact us

Please contact us if you have any questions about this privacy notice or the information we hold about you.

If you wish to contact us, you can do so by email to [email protected], or by postal mail to 400 S. Broadway, Denver, CO 80209, USA.