Privacy Policy

Last Updated: October 14, 2024

This Privacy Policy (“Policy”) explains how we collect, use, store, protect, and share your personal information through our services.  NantG Mobile, LLC (dba Nantgames) is the data controller of the personal information collected through the services (as defined in our Terms of Service (“Terms”).  NantG Mobile, LLC (dba Nantgames) is referred to in this Policy as “Company”, “we”, “our” or “us”.  This Policy also describes how your personal information is used in regard to augmented reality mobile game MythWalker.

This Policy governs the collection of personal information in conjunction with the operation of our games, including MythWalker, as well as any associated applications, websites, or interaction that you may have with us (the “Services”).  We provide an augmented reality platform that requires precise geolocation regarding you to operate.  This Policy explains how we collect your personal information, which is information that is associated with a unique individual, and how we use that information, including in conjunction with the Services.  You should also consult our Terms which set out the agreement between you and the Company when you use our Services. 

How we handle your information depends on which Services you use, and how you use them.  This Policy is grouped into these sections:

• about us and this Policy;

• information we collect & why we use it;

• when we disclose information to others;

• how to control your privacy; and

• information about local privacy laws. 

We encourage you to read this Policy carefully.  If you have questions, please contact us.

This Policy is designed to explain how we process your personal information and how you can exercise control over our processing.  Capitalized terms that are used but not defined in this Policy are defined in our Terms.  The Terms describe how the Services works in general, and establish a contract between you and us governing your use of the Services.

Contact us

If you have any questions or feedback about this Policy, email us at support@mythwalker.com or write us at NantGames, 450 Duley Rd., El Segundo, California 90245.

Changes to this Policy

Because the Services change often, this Policy may change over time.  Anytime we modify the Policy, we will post a revised version on the Services and update the Last Updated date above.  If we intend to use your personal information in a way that is materially different from the ways described at the time of collection, we will notify you before the material changes to this Policy take effect, so you have time to review them.  If we have your contact information (such as your email or phone number), we will notify you that way.  We may also post a temporary notice on the Services, or notify you by other means to the extent required by law.

We encourage you to review the Last Updated date periodically to ensure you’re aware of the current Policy.   By using or accessing the Services, you signify that you have read, understand and agree to be bound by this Policy and the Terms. 

We collect the personal information from you for the following purposes and to fulfill our legitimate interests:

• To authenticate you as a registered user;

• To record your in-game achievements and actions;

• To personalize your gameplay and user experience;

• To improve our Services;

• To provide technical and customer support;

• To analyze who is using our Services and which portions of the Services you use;

• To provide updates and news;

• To show and provide rewards, promotions or other offers;

• To implement anti-fraud and anti-cheating measures and to protect our intellectual property and prevent and monitor violations of our Terms;

• To personalize your gameplaying environment;

• To make legal or regulatory disclosures and defend against legal claims.

A note regarding precise geolocation information:

MythWalker is an augmented reality (AR) platform for mobile devices.  This means that your precise geolocation in the real world is incorporated into gameplay.  Your precise geolocation information is necessary to play the game.  You will be unable to play MythWalker without providing such geolocation information.  Your geolocation information is also necessary to play the game with other individuals.  In other words, you must provide your geolocation both to us and to other players with whom you interact. 

We obtain your location through GPS, databases provided by a third party, and Wi-Fi.  We obtain your in game location to allow you to pay the game and interact with others.  We track your actions and movements in gameplay as well as your achievements through the game.  This information is conveyed to us through your device.

We understand the importance of the privacy of information relating to your location and the fact that such information may be considered sensitive information under some privacy laws.  We collect precise geolocation information because it essential to playing the game.  If you do not want to share precise geolocation information do not use our Services. 

This Policy applies to you when you use the Services, effective as of the Last Updated date above.  However, some collection and use of information falls outside this Policy:

• Outside services:  Some areas of the Services contain links to third-party websites, resources and advertisers (“Outside Materials”). Outside Materials are not part of the Services.  We do not control (and are not responsible for) third party content or privacy practices.  Information you provide to third parties is not covered by this Policy.  These third parties have their own policies and practices about data, which may include what information they share with us, your rights and choices on their services and devices, and where they store information.  We encourage you to familiarize yourself with their privacy notices and applicable contractual terms.

• Our personnel: If you are a current or former employee or contractor of ours, this Policy does not apply to you.  Reach out to your human-resources partner or supervisor with any inquiries about your personal information.

This section describes how and why we exchange personal information with contractors and third parties.  It also describes exchanges made for certain purposes, like advertising, legal reasons, consensual direct marketing and for purposes of playing MythWalker.  We may also disclose deidentified and/or anonymized data for these purposes.

We do not ‘sell’ or ‘share’ personal information

That means we don’t provide or exchange your personal information with others to facilitate behavioral ads (i.e., ads targeted to you) or otherwise sell it.  For clarity, we haven’t shared or sold any personal information for that purpose in the past twelve (12) months. 

Sensitive Information

We do not share “sensitive” information, including precise geolocation information, with any third party.

With our Affiliates

We may share, link or pool user information among affiliates, which means companies under common ownership with us, but always in accordance with applicable law, applicable agreements and this Policy. 

Functional disclosures

In addition to the use of trackers described above, we contract with companies or individuals to provide certain services related to the functionality and features of the Services, including payment processing, email and hosting services, software development, shipping and fulfillment, data management, and administration of contests and other promotions.  We refer to them as “contractors.” 

We may disclose information about you, such as Personal Identifiers, Commercial Information, Internet Activity and Device Information, to contractors as necessary for them to perform their services.  Contractors are not permitted to use information about you for any other purpose.  In the past twelve (12) months, we have disclosed these types of information to the following types of contractors:

• Analytics providers, namely Unity  Azure Servers, and Firebase Analytics, to tell us how the Services is doing, such as which parts interest visitors, the Services are functioning, and how long they visit before leaving.  Among other data, they may receive your IP address.

• Various hosting services and data processors to provide the infrastructure of the Services, which ensures that traffic is from real people, not computers.  Among other data, they may receive your IP address.

• Support providers, namely ZenDesk, to provide assistance to you when you request it.  They are able to retrieve information about you that is relevant and necessary to your requests, such as account information and order details.

For legal reasons

Finally, we may disclose personal information:

• In response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law.  In such cases we reserve the right to raise or waive any legal objection or right available to us;

• When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of our company, our users, or others; and in connection with the enforcement of our Terms and other agreements; or

• In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy. 

With your consent or at your request

We may periodically ask for your consent to disclose your information to third parties.  Whenever we ask your consent for this reason, we will summarize the purpose and scope of the disclosure.  For example, we may offer discounts to you if you consent to join our mailing list or participate in a promotion involving direct marketing communications. 

• In those cases, the Services will display a tickbox near an email-entry field explaining that by submitting your information, you agree to share your email with the content provider.

• To be clear, we only exchange information about you with third parties for direct marketing purposes if you opt in, and will only do so until you opt out. 

We retain your information only as long as we need it for the purposes described under Information we collect & how we use it, except when longer retention is required by our compliance policies and efforts toward applicable legal, tax, accounting and regulatory requirements. 

How long we need information for those purposes varies by category, and even within categories.  These retention determinations always consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from its unauthorized use or disclosure, whether we can achieve those purposes without using the personal information.

For example, we delete some Internet Activity at some soon as you exit the Services, whereas we may retain records of your orders for services and products for several years as required by law or contract, such as agreements with our payment processors or under our accounting standards.

The Services are intended for users over the age of thirteen (13).  We do not knowingly collect information from anyone under the age of 13, and we do not share or sell information about anyone under 13 without affirmative authorization.  If we learn that we have collected information from a person under age 13, we will delete that information as quickly as possible. 

• If you are under 13:  sorry, but please leave the Services.  If you’ve already sent us information, please contact us first so we can delete it. 

If you are a parent or guardian of a person under 13 years of age and you believe that person provided information to us, please contact us.

In General

As a user of the Services, you have rights and choices about your personal information.  We want you to be in control of your information, so we want to remind you of the following options and tools available to you:

• Content opt-outs:  you may opt-out of any newsletters or promotional communications from us by following the unsubscribe instructions in the communication you receive.  We may continue to send you communications regarding the Services, such as notices about updates, transaction reports, and changes to the Services, this Policy or the Terms.

• Exercising rights:  If any of the local privacy laws listed below apply to you, see Requesting information to exercise your rights.

• Location Data Collection: When you access certain Services through a mobile device, you consent to share your precise (GPS level) geolocation with us so we can customize your experience and the content you receive.  The use of precise geolocation information is necessary for operation of the game and your gameplay, as well as using interactive features with other users.  Note that if you discontinue use of location data collection you will not be able to operate the game or use its interactive features.

International Data Transfers

If you reside outside the United States, we transfer information about you for processing in the United States.  By providing your information to us, you consent to the processing of the information in the United States.  The transfer of this information to the United States is necessary for the performance of our contract for use of the Services.

Note that U.S. law is not equivalent to laws in other countries, such as GDPR in Europe or PIPEDA in Canada.  As of the Last Updated date, the U.S. has not been deemed an ‘adequate’ jurisdiction under GDPR for the purposes of international data transfers.

The Services operates from the United States, but this Policy applies worldwide.  Our practices generally do not differ based on your location, but your rights and choices depend in part on the law where you live. 

If any of these local privacy laws apply to you, this section overrides any contrary descriptions elsewhere in the Policy as they relate to you.  If you have questions about your rights under other data privacy laws, please contact us. 

Requesting information

Submitting requests

To exercise any rights described in this Policy, please contact us.  Your request must:

• provide sufficient information to identify you and the law that applies to you, such as your name, e-mail address, home or work address, or other information we maintain. 

• not include social security numbers, driver’s license numbers, third-party account numbers, credit or debit card numbers, or health information.

Verifying requests

We verify requests by first confirming the source of the request and then by matching the information submitted to the information we maintain.  If your request is unclear or we are unable to authenticate your identity, we will respond with direction on how to remedy the deficiencies, in accordance with law that applies to you. 

If we cannot verify the identity of the individual making the request, we may deny it, in full or in part.

Responses to requests

We will respond to your request as quickly as we can, taking into account the nature of your request and the volume of pending requests.  The content of our response will vary with the nature of your request, but will always respond in accordance with any deadlines or requirements specified by the laws that applies to you.

Under certain circumstances, we may be unable to provide responsive personal information, such as when disclosure would create a substantial, articulable and unreasonable risk to the security of the information, customers’ account with us, or the security of our systems or networks.  We do not disclose account passwords or any other non-personal information that enables access to an account.

Please understand, however, that we reserve the right to retain an archive of any deleted information, to the extent permitted by law.  We may also retain deidentified or aggregate data derived from information about you.

Appealing decisions

Residents of California, Colorado, Connecticut, and Virginia may appeal a decision we have made regarding their requests by contacting us.

Information for Users in Certain U.S. States

Exercising your rights: As described in the “How to control your privacy" section of the Policy, all our users have control over their information and can limit what data we process. If you are a resident of California, Colorado, Connecticut, Utah, Virginia or another state with a similar data-privacy law, you may have additional rights that you (or, in certain states, an authorized agent acting on your behalf) can exercise by contacting us, including the right to:

•    Information about the categories and specific pieces of personal information we have collected and disclosed for a business purpose in the last 12 months

• Access and/or receive a copy of certain personal information we hold about you

• Correct your personal information

• Delete certain personal information we hold about you

• Receive information about the financial incentives that we offer to you, if any

• Opt out of the processing your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable

• You also have the right to not be discriminated against for exercising your rights. You may also have the right to opt out of “sales” of your information and “sharing/processing of your information for targeted advertising.”  We do not sell the personal data of our users or share personal data for targeted advertising purposes.

Certain information may be exempt from the requests above under applicable law. For example, we need to retain certain information in order to provide our services to you. We also need to take reasonable steps to verify your identity before responding to a request.  If you are an authorized agent submitting a request on a user’s behalf (where permitted), we may require proof of your written authorization before processing the request.  Depending on applicable law, you may have the right to appeal our decision to deny your request. 

If you have any questions about these rights, wish to exercise them, or request an appeal, please reach out to us at support@mythwalker.com.

Additional Information for Users in California

In addition to the rights described above, consumers residing in California are afforded the right to certain additional information with respect to their personal information under the California Consumer Privacy Act (“CCPA”). If you are a California resident, this section applies to you.

• Our collection and use of personal information: We collect the following categories of personal information: identifiers (such as your username, the email address you used to sign up, and your phone number if you’ve chosen to provide it); commercial information (a record of what you’ve bought from the Company if anything); financial data (payment information and your history of purchases from the Company); internet or other network information (how you interact with the services); location information (because your IP address may indicate your general location); precise geolocation information required to operate the game; inference data about you (for example, what content you may be interested in); and other information that identifies or can be reasonably associated with you. For more information about what we collect and the sources of such collection, please see the “Information we collect & why we process it” section of the Privacy Policy. To the extent we collect or use sensitive personal information as defined by law (such as the CCPA), we do so in accordance with applicable legal requirements, and we do not use or disclose it other than for purposes for which there is not a right to limit under the CCPA.

• We collect personal information for the business and commercial purposes described in the “Information we collect & why we process it” section of the Policy.

• Disclosure of personal information: We may share your personal information with third parties as described in the “Our disclosures of information to others” section of the Policy. We disclose the categories of personal information mentioned in that section for business or commercial purposes.

• No sale or “share” of personal information: The CCPA sets forth certain obligations for businesses that sell or “share” personal information. We do not sell or share the personal information of our users as those terms are defined in the CCPA. We do disclose certain information as outlined in the “Our disclosures of information to others” section of the Policy and you can make choices with respect to your information as outlined in that policy.

• We retain personal information as described in the “How long we retain your information” section of the Policy.

California’s “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties, as defined under applicable law, for their direct marketing purposes. We only share your personal information with third-parties for their own direct marketing purposes with your consent and, if you have consented, only until you withdraw your consent.

Information for Users in the European Union, EEA, Switzerland and United Kingdom

Overview: As described in the “How to control your privacy" section of the Policy, all our users have control over their information and can limit what data we process. In addition to these rights, users residing in the European Union, the European Economic Area (“EEA”), Switzerland and the United Kingdom are afforded the right to certain additional information with respect to their personal information under the GDPR and similar laws.  If you reside in any of those jurisdictions, this section applies to you.

• Data retention and destruction: We retain personal information until we determine it is no longer needed for the processing purposes for which we collected or retain it or for legal compliance.

• Exercising your rights: All our users have control over their information and can directly edit or delete information from their account and limit what data we process. Users in the European Union and Switzerland have additional rights that you can exercise by contacting us. Those rights include:

»   Right of access to your personal data

»   Right to rectify your personal data if they are incorrect

»   Right to erase your personal data

»   Right to limit the processing of your personal data

»   Right to the portability of your personal data

»   Right to object to the processing of your personal data

»   Right to withdraw consent. Withdrawing consent does not affect the lawfulness of processing based on consent before withdrawal.

‍Additionally, you may contact the Company’s Privacy Officer by emailing support@mythwalker.com.

Information for users in Brazil

• Overview: As described in the “How to control your privacy" section of the Policy, all our users have control over their information and can limit what data we process. In addition to these rights, users residing in Brazil are afforded the right to certain additional information with respect to their personal information under the  Lei Geral de Proteção de Dados (LGPD). If you are a Brazilian resident, this section applies to you.

• Exercising your rights: All our users have control over their information and can directly edit or delete information from their account and limit what data we process. Users in Brazil have additional rights that you can exercise by contacting us. Those rights include:

»   Right of access to your personal data

»   Right to rectify your personal data if it is incorrect

»   Right to erase your personal data

»   Right to limit the processing of your personal data

»   Right to the portability of your personal data

»   Right to object to the processing of your personal data

»   Right to withdraw consent. Withdrawing consent does not affect the lawfulness of processing based on consent before withdrawal

»   Right to the review of decisions based on the processing of personal data carried out exclusively by automated means

Questions or concerns about your privacy? You can email us at support@mythwalker.com.

Information for users in Canada

• Overview: As described in the “How to control your privacy" section of the Policy, all our users have control over their information and can limit what data we process. In addition to these rights, users residing in Canada are afforded the right to certain additional information with respect to their personal information under the Personal Information and Electronic Documents Act (PIPEDA). If you are a Canadian resident, this section applies to you.

• Exercising your rights: Users in Canada have additional rights that you can exercise by contacting us. Those rights include:

»   Right of access to your personal data

»   Right to rectify your personal data if they are incorrect

»   Right to withdraw consent. Withdrawing consent does not affect the lawfulness of processing based on consent before withdrawal

»   Right to file a complaint regarding the processing of your personal data with the Office of the Privacy Commissioner of Canada

Additionally, you may contact us by emailing support@mythwalker.com

Information for Users in the Republic of Korea

Overview: As described in the “How to control your privacy" section of the Policy, all our users have control over their information and can limit what data we process. In addition to these rights, users residing in the Republic of Korea are afforded the right to certain additional information with respect to their personal information under the Personal Information Protection Act. If you are a Republic of Korea resident, this section applies to you.

• Data retention and destruction: We retain personal information until we determine it is no longer needed for the processing purposes for which we collected or retain it or for legal compliance.

• Exercising your rights: All our users have control over their information and can directly edit or delete information from their account and limit what data we process. Users in the Republic of Korea have additional rights that you can exercise by contacting us. Those rights include:

»   Right of access to your personal data

»   Right to rectify your personal data if they are incorrect

»   Right to erase your personal data

»   Right to limit the processing of your personal data

»   Right to the portability of your personal data

»   Right to object to the processing of your personal data

»   Right to withdraw consent. Withdrawing consent does not affect the lawfulness of processing based on consent before withdrawal.

‍Additionally, you may contact us by emailing support@mythwalker.com.