PRIVACY POLICY FOR NETEASE SERVICES
1. INTRODUCTION
This Privacy Policy informs you of your choices and our practices
regarding and use of any personal information you provide to us or
collected through the product(s), service(s) and related websites
(collectively, the “Services”) distributed by NetEase Interactive
Entertainment Pte. Ltd. and its affiliates and subsidiaries (“NetEase”,
the “Company”, “we”, “us” or “our”). It is important for you to understand
how this happens and how you may control the collection and use of your
personal information. This Privacy Policy applies to any Service that
links directly to it.
When you access, use or register for the Services, you accept our rules
and policies regarding your personal information and you expressly consent
to us collecting, processing, using and storing your personal information,
as described in this policy.
This Privacy Policy does not apply to third party websites, online
properties, or systems to which the Services may link or through which the
Services may be accessed, and you accept NetEase is not responsible for
the security or privacy practices of any such third party websites,
properties, or systems. Sometimes, we may direct you to a site, product,
or service operated by a vendor or partner. Even though the page where you
provide information may have the look and feel of the Services, a
different privacy policy may govern that information collection and use by
our vendor or partner.
You acknowledge that you have read and understood this privacy policy. If
you do not agree with this Privacy Policy, you must not access, use or
register for the Services. If you change your mind in the future, you may
withdraw your consent to use of your personal information in accordance
with this policy.
If you have any comments, questions or complaints regarding the processing
of your personal information, you can contact us at
privacy.glo@list.nie.netease.com
or at 11400 West Olympic Blvd. Suite 200, Los Angeles, California 90064,
USA.
2. THE TYPES OF PERSONAL INFORMATION WE USE
This section describes the different types of personal information we
collect and how we collect it. We will collect and use the following
information about you:
2.1 Information You Give Us
(i) When you register for the Services using an email address (including
your email address and your name/nickname/username);
(ii) When you register for the Services using a third-party social media
or similar account (e.g. Facebook, Twitter, Google or Apple, each a
“Social Media Account”) in order to set up your profile (we import from
your connected Social Media Account your personal information which may
include your name/nickname/username as it appears on your social media
profile, your profile picture, your friend list, and your account ID);
(iii) When you set up your profile for the Services (including information
you voluntarily elect to provide, including but not limited to your
name/nickname/username, your gender, your age, etc.) and secure your
account for the Services (including information you provide to help secure
the account, including but not limited to your phone number, email
address, security questions, etc.);
(iv) When you submit your name, date of birth, domestic citizenship or
foreign status information for age verification or compliance with
applicable laws and regulations;
(v) When you submit your contact and other details to us (e.g. your name,
age, email address and physical address) as part of promotional activities
for the Services;
(vi) When you submit your contact details and/or resume to us (including
your name, email address, physical address, employment history, etc.) as
part of applying for a job opportunity; and
(vii) When you use location-based functions in the Services (“Location
Services”) (including GPS location information, cell-ID, Wi-Fi connection
location).
2.2 Information We Collect About You
We automatically collect certain data from you when you use the Services,
including your IP address and device information (such as device type,
network data, operating system) and information regarding your use of and
interaction with the Services, such as date and time stamps of actions. We
also collect and store your data each time you interact with us, for
example, when you use in-app support to communicate with us.
2.3 Information You Generate and Display in the Course of Using the
Services
You may provide additional information as part of your profile. You may
also provide or generate information when you communicate with other users
in the Services (e.g., community forum). You acknowledge and agree that
information generated within the Services should not be considered private
and communications within the Services may be viewed/heard by other users.
Please avoid revealing any personally identifiable or sensitive
information during such communications.
2.4 Cookies and Other Tracking Technologies
We may use cookies and other similar technologies (e.g. web beacons, log
files, scripts and eTags) (“Cookies”) to understand and enhance your
experience with the Services. NetEase and certain third parties, such as
marketing partners and analytics providers may use tracking technologies
such as cookies and/or similar technologies on the Services. For more
information about NetEase's use of cookies, and how you can withhold or
withdraw your consent to using your data for targeted advertising
purposes, please see our Cookie Policy,
which is also incorporated by reference into this privacy policy and made
part of this privacy policy.
3. CHILDREN'S PRIVACY
We do not knowingly collect or store any personal information from
children under 13 in the United States or under the relevant age threshold
in other jurisdictions where the child is located. In some cases, we may
ask the user to provide us with their date of birth date for age
verification. If such information indicates the user is under the age
stipulated by the applicable laws and deemed as child under such laws, we
will not collect further personal information from the child until a
parent/guardian's verifiable consent is obtained. If you believe that we
have unintentionally collected your child's personal information or
otherwise used your child's personal information for another purpose, you
may contact us at
privacy.glo@list.nie.netease.com
or at 11400 West Olympic Blvd. Suite 200, Los Angeles, California 90064,
USA.
We recognize a special need to protect the personal information of
children. We urge parents to instruct their children to never give out
their real names, addresses, phone numbers, or other personal information
without parental permission, when online. We also recommend that parents
familiarize themselves with parental controls available on consoles,
mobile telephones, tablets and other devices they provide to their child
and accompany their child when online. Parents should contact NetEase
immediately at
privacy.glo@list.nie.netease.com
or at 11400 West Olympic Blvd. Suite 200, Los Angeles, California 90064,
USA if they have any concerns.
4. HOW WE USE YOUR PERSONAL INFORMATION
We use and share your information (i) to provide the services under the
Terms of Use, (ii) with your consent,
(iii) in our or others' legitimate interests (such as safety, security,
and providing a tailor service), and (iv) for other legal reasons.
We rely on a number of legal bases to collect, use, share and otherwise
process the information we have about you for the purposes described in
this Privacy Policy. These legal bases include:
Registration Information (such as: ID on Social Media Accounts, email
address, nickname, avatar, username, password, phone number, security
questions, date of birth and other information): We use Registration
Information to set-up user accounts, allow users to log-in to the
Services by using the Registration Information, maintain and secure the
user accounts with us, and provide the Services to users. We use this
information with your consent to this Privacy Policy.
Device Information (such as: device ID, device type, operating system,
CPU, RAM, IP address, MAC address): We use this information to provide
and improve the Services such as: to allow users to download and install
the software on their devices; to record and keep track of requests from
users of the Services; to detect the user network and device status when
the user is using the Services; and to correct bugs or errors that occur
when the user is using the Services. Use of Device Information is
necessary to perform our contract with you to provide the Services.
Contact Information (such as: name, email address, physical address,
phone number): We use this information to send notifications to users to
inform them of any company updates or promotional activities. We use
this information with your consent to this Privacy Policy.
User Profile (such as: age, gender, photo, etc.): We use this
information to provide customized services to users such as personal
information page. We use this information with your consent to this
Privacy Policy.
Applicant Information (such as: name, email address, mailing address,
phone number, employment-related information, education information,
etc.): We use this information when you apply for a job opportunity with
the Company, accepting and evaluating applicant submissions for job
postings, and making hiring decisions. We use this information with your
consent.
Location Data (such as: GPS location information, cell-ID, Wi-Fi
connection location). With your consent, we use this information to
provide Location Services to users and to record and keep track of
requests from users of the Services. Use of Location Data is limited to
the context of location-based services. You can disable Location
Services by turning off the relevant switch in the settings of the
Services or your device.
We may associate all of the foregoing information with your account, the
device you use to access the Services, or email that you use to engage
with us. We use this information with your consent to this Privacy Policy.
In addition to the specific uses of information described above, we may
use all of the above information to provide, improve and develop the
Services, including as we describe in our User Agreement, to comply with
any applicable legal obligations, to enforce any applicable terms of
service, to protect or defend the Services, our rights, the rights of our
users, or others, for the purpose of combatting fraud, or to otherwise
operate our business.
5. HOW WE STORE AND SHARE YOUR PERSONAL INFORMATION
In order to perform our contract with you, your personal information will
be accessible from and will be processed on our servers. Our servers are
hosted on cloud servers such as Amazon Web Services. Your information may
be transferred to and processed in countries outside the country you are
located. We will take steps necessary to comply with applicable legal
requirements, such as using European Commission approved Standard
Contractual Clauses to protect your information. In particular, your
information will be transferred to and processed in Japan where our
central database is based.
We may share your personal information with selected third parties in and
outside your country, including:
Third-party vendors that provide services in support of the Services,
such as WorkDay for the purpose of job postings and job application
submission. Such third-party vendors have limited access to your
personal information and are contractually bound not use it for other
purposes.
Related group companies, with whom we share your information to operate
the Services. The transfers contemplated above are made pursuant to our
contract with you; and
Law enforcement agencies, public authorities or other judicial bodies
and organizations. We disclose information if we are legally required to
do so, or if we have a good faith belief that such use is reasonably
necessary to: (i) comply with a legal obligation, process or request;
(ii) enforce our terms of service and other agreements, policies, and
standards, including investigation of any potential violation thereof;
(iii) detect, prevent or otherwise address security, fraud or technical
issues; or (iv) protect the rights, property or safety of us, our users,
a third party or the public as required or permitted by law (including
exchanging information with other companies and organizations for the
purposes of fraud protection).
Business partners and third parties (e.g., other companies, retailers,
research organizations, advertisers, ad agencies, advertising networks
and platforms, participatory databases, publishers, and non-profit
organizations) that provide advertising or may want to market products
or services to you. If we share personal information with such
unaffiliated third parties for their own marketing purposes, we will
provide you with an opportunity to opt out of such uses either at the
point of collection or through the choice mechanisms set forth in this
Privacy Policy.
In the event of a business transaction, such as if we or one of our
business units or our relevant assets are acquired by, sold to, or
merged with another company or as part of a bankruptcy proceeding or a
business reorganization.
6. THE SECURITY OF YOUR PERSONAL INFORMATION
We are committed to maintaining the privacy and integrity of your personal
information no matter where it is stored. We have information security and
access policies that limit access to our systems and technology. We deploy
a firewall and other security measures (such as encryption) commensurate
to industry standards to prevent unauthorized access to your personal
information. Your personal information will remain subject to our
technical and organizational controls and our policies and procedures
(including this Privacy Policy). Unfortunately, the transmission of
information via the internet is not completely secure. Although we will do
our best to protect your personal information, we cannot guarantee the
security of the information transmitted to the Services; any transmission
of your information is at your own risk.
7. DATA RETENTION
We will retain most of your personal information for the lifetime of your
use of the Services (i.e. until account deletion in accordance with your
request) except that Contact Information obtained from promotional
activities will be retained during the lifetime of such activities.
In the event that the processing and retention period have terminated, but
personal information is required to be retained continuously for other
reasons including for the purposes as prescribed under applicable laws,
the relevant personal information will be stored and maintained separately
from other types of personal information. If you require us to destroy
your personal information before the end of its life cycle, we will
destroy your personal information in accordance with local laws.
8. YOUR RIGHTS
8.1 International Transfer
We operate internationally, and many of our computer systems are currently
based in the United States, which means Information we collect will be
processed by us in the U.S. where data protection and privacy regulations
may not offer the same level of protection as in other parts of the world,
such as the European Union. If you access, use or register for the
Services from outside the United States, you consent to the collection
and/or processing in the United States of Information we collect from you.
8.2 California Collection Notice
This section addresses legal obligations and rights laid out in the
California Consumer Privacy Act (“CCPA”) and other laws that apply only to
California residents. These obligations and rights apply to businesses
doing business in California and to California residents and information
that identifies, relates to, describes, is reasonably capable of being
associated with, or could reasonably be linked, directly or indirectly,
with California consumers or households (“California Information”). It
does not apply to information that has been de-identified or aggregated as
provided by CCPA.
Depending on how you interact with us, we may collect about you the
categories of information summarized below. We also describe below how we
collect and use such categories of information. These categories of
personal information are shared with third parties as described in detail
in Section 5 above.
Categories of Information Collected
Identifiers and Contact or Registration Information, e.g., name, email
address, mailing address, phone number, account username, and third
party account names;
Device Information and Device Identifiers, e.g., IP address; browser
type and language; operating system; platform type; device type;
software and hardware attributes; and unique device, advertising, and
app identifiers;
Geolocation, e.g., city, state and ZIP code associated with your IP
address;
Job applicant Information, e.g., name, email address, mailing address,
phone number, employment-related information, education information,
etc.);
User-generated content, e.g., photos, videos, audio, any information you
submit in forums, chat or message boards;
Customer service information, e.g., questions and other messages you
address to us directly through online forms, chat, by email, or by mail;
Other Information, e.g., any other information you choose to directly
provide to us in connection with your use or access of the Service.
Purposes of Use
Perform the services, and personalizing your experience on the Services;
Commercial purposes, such as operating our business, or sending
newsletters or marketing, and to provide you with targeted advertising;
Detect security incidents and secure our website;
Undertaking activities to verify and maintain the quality of the
Services.
Sources of Personal Information
You, both directly and through your use of the Services
Our vendors and business partners (for example, data analytics
providers, advertisers, media partners or platform providers)
NetEase group companies
Social Media and other third party accounts
We may share information falling into the categories of information
described above with NetEase group companies and third parties for the
specified purposes as follows:
with the various NetEase group companies, including for the group
companies' own marketing purposes;
with NetEase vendors, partners and licensees to provide you with
services you have requested, or create applications and websites that
benefit our community;
if required to do so by applicable law, regulation or legal process;
if necessary to exercise, establish or defend our legal rights;
if necessary to protect the vital interests of any person; and
in connection with the sale of our business or assets.
8.3 Your California Privacy Rights
Without being discriminated against for exercising these rights,
California residents have the right to request that we disclose what
personal information we collect from you, to delete that information, and
to opt-out of the sale of your personal information, subject to certain
restrictions. You also have the right to designate an agent to exercise
these rights on your behalf. This section describes how to exercise those
rights and our process for handling those requests.
8.4 Privacy Information for Nevada Residents
Under Nevada law, Nevada residents who have purchased goods or services
from us may opt out of the “sale” of “covered information” (as such terms
are defined under Nevada law) for monetary consideration to a person for
that person to license or sell such information to additional persons.
“Covered information” includes first and last name, address, email
address, and phone number, or an identifier that allows a specific person
to be contacted either physically or online. As discussed above, we share
your information with certain third parties that we believe can provide
you with offers and promotions for products and service of interest to you
and in the other ways described above. We do not believe that our sharing
in this regard would qualify as a sale under Nevada law. Nonetheless, if
you are a Nevada resident who has purchased goods or services from us, you
may submit a request to record your preference to opt out by emailing us
at
privacy.glo@list.nie.netease.com. Please note we may
take reasonable steps to verify your identity and
the authenticity of the request.
8.5 Privacy Information for Users in the EEA and the UK
We only process or transfer your personal information where we can rely on
legal grounds and appropriate safeguards to do so. We process your
information for the purposes set out below.
Performance of the Services
We process your personal information for the performance of the Services,
to provide or support of our products, or for any other feature you
request or enable. This includes, for example, using your personal
information to:
administer your account;
support game functionality;
provide global customer service; or
Consent
We process your personal information based on your consent. This includes,
for example, providing:
newsletters and direct e-mails about the Services that may be of
interest to you;
targeted ads; and
certain other marketing features.
Legitimate Interest
We process your personal information where we have a legitimate interest
to do so. This includes, for example, processing:
to provide you with requested customer service or technical support;
to debug and improve our current and future Services;
in order to give you personalize your online experience with us and
contact you in accordance with applicable marketing preferences;
to allow third party partners and licensees to create applications and
websites that benefit our users; and
for the establishment, exercise or defense of legal claims or whenever
courts are acting in their judicial capacity.
Legal Obligation
We process your personal information for compliance with a legal
obligation to which we are subject.
8.6 Disclosure to Users Outside the US, the EEA and the UK
In addition, if you are a visitor to our websites or other online products
and services from outside the U.S., the personal information you provide
will be collected, processed and stored directly on, or transferred to,
servers in the United States or other countries where NetEase group
companies or our other partners or vendors maintain facilities or business
operations.
No matter where the Information is located, NetEase takes commercially
reasonable measures to safeguard your privacy rights in accordance with
this Privacy Policy. If you do not agree to the collection, processing,
storage and transfer of your Information, please do not provide your
Information when requested and stop using our websites and other online
products and services.
9. ACCESS
You have the right to access personal information we hold about you, how
we use it, and who we share it with. If you believe we hold any personal
information about you, please contact us at
privacy.glo@list.nie.netease.com
or at 11400 West Olympic Blvd. Suite 200, Los Angeles, California 90064,
USA.
10. PORTABILITY
You have the right to receive a copy of certain personal information we
process about you. This comprises any personal information we process on
the basis of your consent or pursuant to our contract with you, as
described in the section “How We Use Your Personal Information”. You have
the right to receive this information in a structured, commonly used and
machine-readable format. You also have the right to request that we
transfer that personal information to another party.
If you wish for us to transfer such personal information to a third party,
please ensure you detail that party in your request. Note that we can only
do so where it is technically feasible. Please note that we may not be
able to provide you with personal information if providing it would
interfere with another's rights (e.g., where providing the personal
information we hold about you would reveal information about another
person or our trade secrets or intellectual property).
11. CORRECTION
You have the right to correct any personal information held about you that
is inaccurate. If you believe we hold any personal information about you
and that information is inaccurate, please contact us at
privacy.glo@list.nie.netease.com
or at 11400 West Olympic Blvd. Suite 200, Los Angeles, California 90064,
USA.
12. ERASURE
You can delete your account, or remove certain personal information. If
there is any personal information you believe we process that you would
like us to erase, please contact us at
privacy.glo@list.nie.netease.com
or at 11400 West Olympic Blvd. Suite 200, Los Angeles, California 90064,
USA.
You may request that we erase the personal information we hold about you
in the following circumstances:
You believe that it is no longer necessary for us to hold such personal
information; or
You believe the personal information we hold about you is being
unlawfully processed by us.
You can also exercise your right to restrict our processing of your
personal information (as described below) whilst we consider your request.
We may need to retain personal information if there are valid grounds
under data protection laws for us to do so (e.g., for the defense of legal
claims or freedom of expression) but we will let you know if that is the
case. Where you have requested that we erase personal information that has
been made available publicly on the Services and there are grounds for
erasure, we will use reasonable steps to try to tell others that are
displaying the personal information or providing links to the personal
information to erase it too.
13. RESTRICTION OF PROCESSING TO STORAGE ONLY
You have a right to require us to stop processing the personal information
we hold about you other than for storage purposes in certain
circumstances. Please note, however, that if we stop processing the
personal information, we may use it again if there are valid grounds under
data protection laws for us to do so (e.g., for the defense of legal
claims or for another's protection). As above, where we agree to stop
processing the personal information, we will try to tell any third party
to whom we have disclosed the relevant personal information so that they
can stop processing it too.
You may request we stop processing and just store the personal information
we hold about you where:
You believe the personal information is not accurate for the period it
takes for us to verify whether it is accurate;
You wish to erase the personal information as the processing we are
doing is unlawful but you want us to retain the personal information but
just store it instead; or
You wish to erase the personal information as it is no longer necessary
for our purposes but you require it to be stored for the establishment,
exercise or defense of legal claims.
14. OBJECTION
You have the right to object to our processing of personal information
about you. We will consider your request in other circumstances as
detailed below by contact us at
privacy.glo@list.nie.netease.com
or at 11400 West Olympic Blvd. Suite 200, Los Angeles, California 90064,
USA.
15. ANNOUNCEMENTS
We may from time to time send you announcements when we consider it
necessary to do so (such as when we temporarily suspend Service access for
maintenance, or security, privacy or administrative-related
communications). You may not opt-out of these service-related
announcements, which are not promotional in nature.
16. CONTACT & COMPLAINTS
For the purposes of European Data Protection Law, the Data Controller is
NetEase Interactive Entertainment Pte. Ltd.
If you wish to make a complaint about how we process your personal
information, please contact us at:
NetEase Interactive Entertainment Pte. Ltd.
11400 West Olympic Blvd. Suite 200
Los Angeles, California 90064
USA
Attn: Privacy / Legal Department
Email:
privacy.glo@list.nie.netease.com
This is without prejudice to your right to launch a claim with the data
protection authority in the country in which you live or work where you
think we have infringed data protection laws.
17. CHANGES
If we make any material changes to this policy, we will post the updated
policy here and we may notify our users through their account. Please
check this page frequently to see any updates or changes to this policy.
18. LANGUAGE
This Agreement may be translated into the local language in the relevant
territory. In the event of a conflict between this Agreement in the
English language version and the localized version, the English language
version shall prevail.
Effective: September 26, 2022