MARVEL Strike Force

Privacy Policy

Updated March 20, 2019

The Walt Disney Company has acquired certain 21st Century Fox businesses, including those providing the services described below. This policy has been updated to reflect that transaction.

INTRODUCTION

FoxNext Games LLC (“FoxNext,” “we,” “us, or “our”), which can be contacted at the email address foxnextgames.tou@fox.com, wants to inform you about how we collect, use and disclose personal data from and about you, through our website, mobile sites, applications and widgets (collectively, the “FoxNext Services”).

You can find a Table of Contents and a brief summary of this Privacy Policy in the chart below. For further details with regard to the data processing carried out by FoxNext click to the links in each section of the summary.

Table of Contents:

1. WHAT AND WHO THIS PRIVACY POLICY COVERS?

2. WHAT KIND OF PERSONAL DATA DO WE COLLECT ABOUT YOU?

3. HOW DO WE USE YOUR PERSONAL DATA?

4. ON WHAT LEGAL BASIS DO WE PROCESS YOUR PERSONAL DATA?

5. HOW DO WE PROCESS YOUR PERSONAL DATA?

6. WHO CAN ACCESS YOUR PERSONAL DATA?

7. IS YOUR PERSONAL DATA TRANSFERRED ABROAD?

8. WHAT ARE YOUR RIGHTS WITH REGARD TO YOUR PERSONAL DATA?

9. WHAT IS GOING TO HAPPEN FROM MAY 25, 2018?

10. UPDATES TO THIS PRIVACY POLICY

11. HOW CAN I CONTACT YOU WITH REGARD TO THE PROCESSING OF MY PERSONAL DATA?

Summary:

Issue

Information

1.

What and who this Privacy Policy covers?

FoxNext is the data controller of the personal data we collect from and about you through the FoxNext Services.

This Privacy Policy applies to all users, including both those who use the FoxNext Services without being registered or having subscribed and those who have registered with or subscribed to a FoxNext Service.

For further information click here.

2.

What kind of personal data do we collect about you?

We might collect data from and about you.

More in particular, we collect (1) registration data, (2) public data and posts, (3) data that you have permitted social media to share with FoxNext and (4) activity data.

However, we do not collect either financial information from a payment service provider or sensitive data relating to you.

For further information click here.

3.

How do we use your personal data?

The main reason why we collect data about you is to provide you with FoxNext Services and to allow you to interact with such services.

In addition, with your prior consent, we can send you offers promotions and marketing communications, also based on your personal preferences and habits. You will be able to opt-out from receiving these communications at any time.

For further information click here.

4.

On what legal basis do we process your personal data?

Your personal data are mainly collected in order to provide you with FoxNext Services.

Your personal data are also used to comply with legal obligations or to protect the legitimate interests of FoxNext.

Failure to provide such data may make it impossible for FoxNext to provide you with its Services.

When your personal data are collected for marketing purposes, you have the option not to provide FoxNext with your personal data.

For further information click here.

5.

How do we process your personal data?

The security of your data is a priority for us. For this purpose, FoxNext has implemented adequate administrative, technical and physical measures to safeguard your personal data against loss, theft and unauthorized use, disclosure or modification.

For further information click here.

6.

Who can access your personal data?

We might share your personal data with (i) service providers, (ii) our affiliated companies and (iii) public and government authorities, when allowed by applicable laws.

For further information click here.

7.

Is your personal data transferred abroad?

Your personal data might be transferred to other countries within and outside the European Economic Area. In any case, we make sure that appropriate and suitable safeguards compliant with applicable laws are in place to protect your personal data.

For further information click here.

8.

What are your rights with regard to your personal data?

You have among others the right to access, integrate, update, amend and delete your personal data.

For further information click here.

9.

What is going to happen from May 25, 2018?

The EU General Data Protection Regulation 2016/679 becomes effective on May 25, 2018, introducing among other changes additional rights for individuals.

For further information click here.

10.

Updates to this Privacy Policy

We may modify or update this Privacy Policy including to comply with changes in applicable law.

Please look at the Effective Date at the top of this Privacy Policy to see when this Privacy Policy was last revised.

For further information click here.

11.

How can I contact you with regard to the processing of my personal data?

You can contact us at the email address foxnextgames.tou@fox.com.

For further information click here.

WHAT AND WHO THIS PRIVACY POLICY COVERS?

FoxNext is the data controller of the personal data (i.e., information that identifies a specific person, directly or indirectly, such as full name or email address) we collect from and about you through the FoxNext Services that is processed in compliance with the terms of this Privacy Policy.

This Privacy Policy and our Cookie Policy apply to all users, including both those who use the FoxNext Services without being registered with or subscribing to a FoxNext Service and those who have registered with or subscribed to a FoxNext Service.

As set forth in our Terms of Use, the FoxNext Services are for a general audience and are not targeted to children under 13. We do not knowingly collect or store personal data from children under 13. In relation to teenagers under 16, we will take into consideration available technologies to prevent teenagers under 16 from accessing certain FoxNext Services or features absent parental consent.

WHAT KIND OF PERSONAL DATA DO WE COLLECT ABOUT YOU?

We collect (1) registration data, when you sign up or for a FoxNext Service, (2) public data and posts that you share through the FoxNext Services, (3) data that you have permitted social media to share with FoxNext, (4) activity data when you access and interact with FoxNext Service. More in particular, we collect the following data from and about you:

  1. Registration data is the information you submit to register for a FoxNext Service, for example to create an account, post comments, receive a newsletter, or enter a contest. Registration Information may include, for example, name, surname, email address, gender, country, postcode and age.
  2. Public data and posts consist of comments or content that you post to the FoxNext Services and the personal data about you that accompanies those posts or content, which may include a name, user name, comments, likes, status, profile information and picture. Public information and posts are always public, which means they are available to everyone and may be displayed in search results on external search engines.
  3. Data from social media . If you access or log-in to a FoxNext Service through a social media service or connect a FoxNext Service to a social media service, the data we collect may also include your user ID and/or user name associated with that social media service, any information or content you have permitted the social media service to share with us, such as your profile picture, email address or friends lists, and any personal data you have made public in connection with that social media service. When you access the FoxNext Services through social media services or when you connect a FoxNext Service to social media services, you are authorizing FoxNext to collect, store, and use such personal data and content in accordance with this Privacy Policy.
  4. Activity data. When you access and interact with the FoxNext Services, we may collect certain information about those visits. For example, in order to permit your connection to the FoxNext Services, our servers receive and record information about your computer, device and browser, including potentially your IP address, browser type, and other software or hardware information. If you access the FoxNext Services from a mobile or other device, we may collect a unique device identifier assigned to that device, general location data, or other transactional information for that device. Cookies and other tracking technologies (such as browser cookies, pixels, beacons, and Adobe Flash technology including cookies) may also be collected. These technologies may be used to collect and store information about your usage of the FoxNext Services, such as pages you have visited, the video and other content you have viewed, search queries you have run and advertisements you have seen. For more information please visit our Cookie Policy.
  5. Information from Other Sources. We may supplement the information we collect with information from other sources, such as publicly available information about your online and offline activity from social media services and commercially available sources.

When the information collected from or about you does not identify you as a specific person, directly or indirectly, we may use that information for any purpose or share it with third parties, to the extent permitted by applicable law.

We do not collect:

  • Financial information from a payment service provider: in some cases, we may use an unaffiliated payment service to allow you to purchase a product or make payments (“Payment Service”). If you wish to purchase a product or make a payment using a Payment Service, you will be directed to a Payment Service webpage. Any information that you provide to a Payment Service will be subject to the applicable Payment Service's privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, any Payment Service's use of information collected through any Payment Service.
  • Sensitive Information: we ask that you do not send us, and you do not disclose, any sensitive personal data (such as social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through the FoxNext Services or otherwise.

Linked Services

Finally, FoxNext Services may also be linked to sites operated by unaffiliated companies, and may carry advertisements or offer content, functionality, games, newsletters, contests or applications developed and maintained by unaffiliated companies. FoxNext is not responsible for the privacy practices of unaffiliated companies, and once you leave the FoxNext Services or click an advertisement you should check the applicable Privacy Policy of the other service.

HOW DO WE USE YOUR PERSONAL DATA?

We use the personal data we collect from and about you to:

  1. provide the FoxNext Services and features to you;
  2. measure and improve those FoxNext Services and features;
  3. improve your experience with both online and off-line FoxNext Services by delivering content you may find relevant and interesting;
  4. allow you to comment on content, and participate in online games, contests, or rewards programs;
  5. provide you with customer support and to respond to inquiries;
  6. protect the rights of FoxNext and others. There may be instances when we disclose your personal data, including situations where we have a good faith belief that such processing is necessary in order to: (i) protect, enforce, or defend the legal rights, privacy, safety, or property of FoxNext, our FoxNext Affiliates or our or our Affiliates’ employees, agents and contractors (including enforcement of our agreements and our terms of use); (ii) protect the safety, privacy, and security of users of the FoxNext Services or members of the public; (iii) protect against fraud or for risk management purposes;
  7. comply with applicable laws or legal process and/or respond to requests from public and government authorities;
  8. complete a potential merger or sale of assets. If FoxNext sells all or part of its business or makes a sale or transfer of its assets or is otherwise involved in a merger or transfer of all or a material part of its business, FoxNext may disclose and transfer your personal data to the party or parties involved in the transaction as part of that transaction;
  9. allow social sharing functionality; if you log in with or connect a social media service account with FoxNext Services, we may share your user name, picture, and likes, as well as your activities and comments with other FoxNext Services users and with your friends associated with your social media service. We may also share the same personal data with the social media service provider;
  10. send with your prior consent, via email, SMS, telephone, chat and social media, offers, promotions and marketing communications of the FoxNext Services or services/products of third parties, including Marvel Entertainment, LLC, operating in the entertainment sector, including group companies and co-branded services or features, such as contests or other promotions arranged together with a third party that may be hosted on the FoxNext Services or on the third party’s service;
  11. send with your prior consent marketing communications customized on your interests and needs by means of the channels of communication set out under letter j) above.

When the information collected from or about you does not identify you personally, either directly or indirectly, we may use that personal data for any purpose or share it with third parties, to the extent permitted by applicable law.

ON WHAT LEGAL BASIS DO WE PROCESS YOUR PERSONAL DATA?

The processing of your personal data for the purposes of:

  • Section 3, letters a) through f) of this Privacy Policy is necessary for the performance of the contract regarding the provision of the requested services and is therefore mandatory since otherwise the services could not be provided;
  • Section 3, letter g) of this Privacy Policy is requested under applicable laws and is therefore mandatory; and
  • Section 3, letter h) of this Privacy Policy is performed under applicable laws of the relevant jurisdiction and with effect from 25 May 2018 on the basis of legitimate interest of FoxNext and of its counterparties to perform such economic activities which are adequately balanced with your interest since the data processing is performed within the limits strictly necessary to perform such economic activities, and is therefore mandatory.

The processing of your personal data for the other purposes of:

  • Section 3, letter i), is discretionary, but the lack of provision of consent would mean it is impossible to connect a social media service account with the FoxNext Service so that you will have to logon to the FoxNext Services using a different mechanism; and
  • Section 3, letters j) and k), is discretionary, but the lack of provision of consent would mean it is impossible for FoxNext and/or third parties to provide you with generic marketing communications or communications based on your interests and needs or to provide co-branded services.

You can revoke your consent to the processing of your personal data for the purposes of Section 3, letters i) through k) at any time by sending a communication to the email or postal address indicated in Section of 11 below.

HOW DO WE PROCESS YOUR PERSONAL DATA?

Your personal data is processed through both electronic and manual means and is protected through adequate security measures. In particular, FoxNext uses appropriate administrative, technical, personnel and physical measures to safeguard personal data in its possession against loss, theft and unauthorized use, disclosure or modification.

WHO CAN ACCESS YOUR PERSONAL DATA?

We may share your personal data for the purposes of Section 3 above to the following categories of recipients located within or outside of the European Union in compliance and within the limits of the provisions of Section 7 below:

  1. Third party service providers entrusted with processing activities and duly appointed as processors when required by applicable laws e.g. cloud service providers, other entities of the group, providers of services instrumental to or supporting the FoxNext Service and thus, by way of example and without limitation, companies that provide IT services, experts, consultants and lawyers;
  2. Third party companies, including companies resulting from possible corporate mergers, sale of assets, demergers, or other corporate transactions or transformations;
  3. FoxNext Affiliates, in their capacity as data controllers or data processors. Our affiliates include members of The Walt Disney Family of Companies. For further information on FoxNext Affiliates, please contact foxnextgames.tou@fox.com.
  4. Business partners, operating in the entertainment sector to permit them to send you marketing communications;
  5. Marvel. FoxNext may share your information with Marvel Entertainment, LLC and its affiliates to permit them to send you marketing communications consistent with your choices and as otherwise set out in this Privacy Policy; and
  6. Competent authorities, in order to comply with applicable laws.

The data processors appointed by FoxNext include Community Sift. A complete list of the data processors may be requested to FoxNext at the email or postal address indicated in Section 11 of this Privacy Policy.

IS YOUR PERSONAL DATA TRANSFERRED ABROAD?

Your personal data may be transferred to countries within and outside the European Economic Area, in particular in the United States (“US”) and Canada. Some non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards. The full list of these countries is available at http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm . We may also transfer your data from the EEA to countries not considered adequate by the European Commission (i.e. providing a non-equivalent level of protection to personal data), such as the US. In any event, we will put in place appropriate and suitable safeguards to protect your personal data and for the transfer of your personal data to be in compliance with the requirements and the obligations provided by applicable data protection laws as per Articles 45 and 46 of the EU General Data Protection Regulation 2016/679 (the “EU Privacy Regulation”).

You have the right to request a copy of the above measures, your personal data or to know where your personal data is stored by contacting FoxNext at the email or postal address indicated in Section 11 of this Privacy Policy.

WHAT ARE YOUR RIGHTS WITH REGARD TO YOUR PERSONAL DATA?

You have the right, in any given time, to:

  1. obtain confirmation as to whether or not your personal data exists and to be informed of its content and source, verify its accuracy and request its integration, update or amendment;
  2. request the deletion, anonymization or restriction of the processing of your personal data processed in breach of the applicable law,
  3. object to the processing, in all cases, of your personal data for legitimate reasons.

Until May 25, 2018 you have the right to issue directives regarding the disposition of your personal data upon your death. You may send your request at the email or postal address indicated in Section 11 below. In your request, please include your email address, name, address, and telephone number and specify clearly what information you would like to access, change, update, suppress, or delete.

Remember that even after you cancel your account, or if you ask us to delete your personal data, copies of some information from your account may remain viewable in some circumstances where, for example, you have shared information with social media or other services. Because of the nature of caching technology, your account may not be instantly inaccessible to others. We may also retain backup information related to your account on our servers for some time after cancellation or your request for deletion, to comply with applicable law.

We give you also many choices regarding our use and disclosure of your personal data for marketing purposes. You may revoke your consent for:

  • Receiving electronic communications from us . If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these marketing-related emails by following the unsubscribe instructions in our communications or sending a request to the email or postal address indicated in Section 11 of the Privacy Policy.
  • Our sharing of your personal information with FoxNext Affiliates or business partners for their marketing purposes . If you would prefer that we do not share your personal information on a going-forward basis with FoxNext Affiliates or business partners for their direct marketing purposes, you may opt-out of this sharing by sending a request to the email or postal address indicated in Section 11 of the Privacy Policy. You can find a list of the FoxNext Affiliates here.

Also, the additional rights outlined in Section 9 below will be effective from May 25, 2018.

WHAT IS GOING TO HAPPEN FROM MAY 25, 2018?

From May 25, 2018, the EU General Data Protection Regulation 2016/679 (the “EU Privacy Regulation”) will become effective and the following additional provisions will apply:

Retention periods applying to your personal data

We will retain your data only for the period necessary to fulfill the purposes for which the data was collected as outlined in this Privacy Policy. In any case, the following retention periods will apply to the processing of your personal data for the purposes indicated below:

  • Data collected for the purposes as per Section 3, letter from a) to h) of this Privacy Policy is retained during the provision of the FoxNext Service, plus the duration of the statute of limitation period under applicable laws, following the termination of the FoxNext Service;
  • Data collected for the purposes as per Section 3, letter i) of this privacy policy is retained for the time necessary to log to the FoxNext Service through a social network and we will not retain your data if you decide to log to the FoxNext Service through a different mechanism; and
  • Data collected for the purpose as per Section 3, letters j) is retained for the duration of the provision of the FoxNext Service plus _ years, unless otherwise required by applicable law.
  • Data collected for the purpose as per Section 3, letter k) is retained for a period of the duration of the provision of the FoxNext Service plus _ years, unless otherwise required by applicable law.

At the end of the retention period your personal data will be either deleted, anonymized or aggregated.

Additional rights

In addition to the rights as indicated in the Section 8 of this Privacy Policy, when the EU Privacy Regulation will become effective, you will have the right, at any given moment, to:

  1. request FoxNext to limit the processing of your personal data where:
    • you contest the accuracy of the personal data until we have taken sufficient steps to correct or verify its accuracy;
    • the processing is unlawful but you do not want us to erase your personal data;
    • we no longer need your personal data for the purposes of the processing, but you require them for the establishment, exercise or defense of legal claims; or
    • you have objected to processing justified on legitimate interests, pending verification as to whether FoxNext has compelling legitimate grounds to continue processing.
  2. object to the processing of your personal data;
  3. object to decisions which are based solely on automated processing or profiling;
  4. request the erasure of your personal data without undue delay;
  5. receive an electronic copy of your personal data, if you would like to port your personal data to yourself or a different provider, when we are relying upon your consent or the fact that the processing is necessary for the provision of the FoxNext Service and the personal data is processed by automatic means; and
  6. lodge a complaint with the relevant data protection supervisory authority.

UPDATES TO THIS PRIVACY POLICY

We may modify or update this Privacy Policy, including to follow different interpretations, decisions, opinions and orders relating to the EU Privacy Regulation.

Please look at the Effective Date at the top of this Privacy Policy to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we publish the revised Privacy Policy on the FoxNext Services. If we make material changes to this Privacy Policy that expand our rights to use the personal data we have already collected from you, we will notify you and provide you with a choice about our future use of that personal data.

CONTACT US

If you have questions about this privacy policy, please contact our Privacy Officer at:

Email: foxnextgames.tou@fox.com

Mail: C/O Privacy Office

FoxNext

2121 Avenue of the Stars, 7th Floor

Los Angeles, CA 90067