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.

Table of Contents:

1. SCOPE AND APPLICATION: What and who this Policy covers

2. COLLECTION OF INFORMATION: The sources of and methods by which we, our service providers and our advertisers collect information from and about you, including information about your interaction with the FoxNext Services

3. USE AND DISCLOSURE: How we use the information we collect from and about you, and who we might share it with and why

4. SECURITY: How we protect your information from loss or misuse

5. USER ACCESS AND CONTROL: How you can access and control the information we maintain about you

6. OTHER IMPORTANT INFORMATION: Other things you should know about this Policy and how we handle your information

7. CONTACT US: How to contact FoxNext about this Policy

1. SCOPE AND APPLICATION

FoxNext Games LLC (“FoxNext”, “we”, “us” or “our”) wants you to be familiar with how we collect, use and disclose information from and about you. This Privacy Policy describes our practices in connection with information collected through services such as websites, mobile sites, applications (“apps”), and widgets (collectively, the “FoxNext Services”). By using FoxNext Services, you agree to the terms and conditions of this Privacy Policy. Our Affiliates include members of The Walt Disney Family of Companies (“FoxNext Affiliates”). For further information on Company Affiliates please contact foxnextgames.tou@fox.com.

As set forth in our Terms of Use, the FoxNext Services are for a general audience, are not targeted to children, and do not knowingly collect personal information from children or any person under the age of 13.

This Privacy Policy applies to all users, including both those who use the FoxNext Services without being registered with a FoxNext Service and those who have registered with a FoxNext Service. This Privacy Policy applies to FoxNext’s collection, use, and disclosure of your personal information (i.e., information that identifies a specific person, such as full name or email address). It also describes generally FoxNext’s practices for handling non-personal information (for example, interests, demographics and services usage).

2. COLLECTION OF INFORMATION

FoxNext and our service providers may collect the following kinds of information from and about you:

Registration Information is the information you submit to register for a FoxNext Service, for example, to create an account, post comments, receive notifications, newsletters and other communications, or enter a contest or sweepstakes. Registration Information may include, for example, name, username, email address, phone number, gender, zip or postal code and birthday.

Public Information and Posts consist of comments or content that you post to the FoxNext Services and the information about you that accompanies those posts or content, which may include a name, username, 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.

Information 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 information we collect may also include your user ID and/or username 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 information 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 information and content in accordance with this Privacy Policy.

Activity Information. When you access and interact with the FoxNext Services, FoxNext and its service providers 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, geolocation data (including your precise location), or other transactional information for that device. When you use the FoxNext Services to participate in our mobile games, we may collect scores, rankings, transaction information, and other information regarding your gameplay. Additionally, when you communicate with FoxNext, we may retain information regarding these communications.

Cookies and other tracking technologies (such as browser cookies, pixels, beacons, and Adobe Flash technology including cookies) are comprised of small bits of data. FoxNext’s websites, apps and other services send this data to your browser when you first request a web page and then store the data on your computer or other device so the website or app can access information when you make subsequent requests for pages from that service. These technologies may also 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.

Third parties that support the FoxNext Services by serving advertisements or providing services, such as allowing you to share content or tracking aggregate FoxNext Services usage statistics, may also use these technologies to collect similar information when you use the FoxNext Services (such as websites and emails) or third-party services. These third parties may also use these technologies, along with Activity Information they collect, to recognize you across the devices you use, such as a mobile device and a laptop or other computer. FoxNext does not control these third-party technologies and their use is governed by the privacy policies of third parties using such technologies. For more information about third-party advertising networks and similar entities that use these technologies, including your choices with respect to them, see the section entitled “To deliver relevant advertisements,” below.

Most browsers are initially set to accept cookies, but you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the "Help" section of your browser for more information. Users can manage the use of Flash technologies, with the Flash management tools available at Adobe’s website, see http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html . Please note that by blocking any or all cookies you may not have access to certain features, content or personalization available through the FoxNext Services.

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, commercially available sources and information from our FoxNext Affiliates or business partners.

Do Not Track Signals. At this time we do not respond to browser 'Do Not Track' signals, as we await the work of interested stakeholders and others to develop standards for how such signals should be interpreted.

3. USE AND DISCLOSURE

We may use and disclose the information we collect from and about you to provide the FoxNext Services and features to you, including: to measure and improve those FoxNext Services and features and to develop new products and services; to improve your experience with both online and off-line FoxNext Services by delivering content you will find relevant and interesting, including advertising and marketing messages; to allow you to comment on content, and participate in online games, contests, other promotions, or rewards programs; to provide you with customer support and to respond to inquiries. In order to provide you with content and advertising that is more interesting and relevant to you, we may use the information from and about you to make inferences and predictions about your potential areas of interest. When the information collected from or about you does not identify you as a specific person, we may use that information for any purpose or share it with third parties, to the extent permitted by applicable law.

We may use and disclose the information we collect from and about you for these additional purposes:

To allow service providers to assist us in providing and managing the FoxNext Services. The information we collect from and about you may be made available to certain third party service providers, such as contractors, analytics and other measurement companies, agents or sponsors, who help us analyze and understand your use of the FoxNext Services, provide customer support, advertising and marketing, and manage and/or provide the FoxNext Services.

To allow social sharing functionality. If you log in with or connect a social media service account with FoxNext Services, we may share your username, 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 information with the social media service provider. By logging in with or connecting your FoxNext Services account with a social media service, you are authorizing us to share information we collect from and about you with the social media service provider, other users and your friends and you understand that the social media service’s use of the shared information will be governed by the social media service’s privacy policy. If you do not want your personal information shared in this way, please do not connect your social media service account with your FoxNext Services account and do not participate in social sharing on FoxNext Services.

To provide co-branded services and features. We may offer co-branded services or features, such as certain content, contests, sweepstakes or other promotions together with a third party (“Co-Branded Services”). These Co-Branded Services may be hosted on FoxNext Services or on the third party’s service. By virtue of these relationships, we may share the information you submit in connection with the Co-Branded Service with the third party. The third party’s use of your information will be governed by the third party’s privacy policy.

To deliver relevant advertisements. FoxNext and our service providers may use the information we collect from and about you as described in this Privacy Policy to deliver relevant ads to you when you use the FoxNext Services or another service (on any of your devices). As noted above, third-party advertising networks and advertisers may use cookies and similar technologies to collect and track information such as demographic information, inferred interests, aggregated information, and information about the different devices you use and your activity on such devices, to assist them in delivering advertising that is more relevant to your interests. The information may also be used to deliver more relevant advertising to you across marketing channels, including email. To find out more about third-party advertising networks and similar entities that use these technologies, see www.aboutads.info. If you would like to opt-out of such ad networks’ and services’ advertising practices on the particular device on which you are accessing this policy, go to http://optout.aboutads.info/ to opt-out in desktop and mobile web browsers. You may download the AppChoices app at www.aboutads.info/appchoices to opt-out in mobile apps.

To contact you. FoxNext may use your personal information to periodically send promotional materials or notifications related to the FoxNext Services where you have consented to us doing so, or where otherwise permitted by law. If you want to stop receiving promotional materials, you can follow the unsubscribe instructions at the bottom of each email. There are certain service notification and other non-promotional emails that you may not opt-out of, such as notifications regarding any transaction or notice of changes to the FoxNext Services or policies. If you have installed a mobile app and you wish to stop receiving push notifications, you can change the settings either on your mobile device or through the app. You may also contact us as described in Section 7 below.

To share with our FoxNext Affiliates . FoxNext may share your information with FoxNext Affiliates for the purposes described in this Privacy Policy. A link to a website that lists FoxNext Affiliates can be found at the beginning of this policy. Users who visit FoxNext Affiliates’ services should still refer to their separate privacy policies, which may differ in some respects from this Privacy Policy.

To share with Marvel . FoxNext may share your information with Marvel Entertainment, LLC and its affiliates to permit them to send you marketing communications where you have consented to us doing so, or where otherwise permitted by law.

To share with business partners . FoxNext may share your information with business partners to permit them to send you marketing communications where you have consented to us doing so, or where otherwise permitted by law.

To protect the rights of FoxNext and others. There may be other instances when FoxNext may use or disclose your information, including situations where FoxNext has a good faith belief that such use or disclosure is necessary in order to: (i) protect, enforce, or defend the legal rights, privacy, safety, or property of FoxNext, our FoxNext Affiliates or their 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; (iv) comply with the law or legal process; or (v) respond to requests from public and government authorities.

To complete a 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 (including in connection with a bankruptcy or similar proceedings), FoxNext may transfer your information to the party or parties involved in the transaction as part of that transaction.

By using the FoxNext Services, you consent to us using and disclosing your information for the purposes described in this section.

4. SECURITY

FoxNext uses commercially reasonable administrative, technical, personnel and physical measures designed to safeguard information in its possession against loss, theft and unauthorized use, disclosure or modification. However, no one can guarantee the complete safety of your information. To increase the effectiveness of the security features incorporated through the FoxNext Services, please ensure that any mobile application utilizing the FoxNext Services is kept updated.

5. USER ACCESS AND CONTROL

If you would like to access, review, correct, update, suppress, delete, or otherwise limit our use of your personal information in our custody or control, you may contact us as outlined in Section 7. 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. We will respond to your request as soon as reasonably practicable and in accordance with applicable law.

You may request that we not share your personal information on a going-forward basis with FoxNext Affiliates or unaffiliated third parties for their direct marketing purposes by contacting us at the information provided at Section 7 below. Note that we may be required to request certain personal information from you for the purposes of verifying the identity of the individual seeking access. We will try to comply with your request(s) as soon as reasonably practicable and in accordance with applicable law.

If you are under 18 and a registered user of the FoxNext Services, you may ask us to remove content or information that you have posted to the FoxNext Services by writing to foxnextgames.tou@fox. com. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.

6. OTHER IMPORTANT INFORMATION

Updates to Privacy Policy. FoxNext may modify this Privacy Policy. If we make any material changes to this Privacy Policy, we will notify you of those changes by sending you an in-app message or other notification. Your continued use of the FoxNext Services after receiving such notification will constitute acceptance of any modifications to this Privacy Policy. If you do not agree to any changes we have made to our Privacy Policy, you may stop using the FoxNext Services at any time and without charge. 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 post the revised Privacy Policy on the FoxNext Services.

Location of Data. The FoxNext Services are hosted in and managed from the United States. Your personal information will be stored securely on FoxNext’s database, or a database maintained by a third party cloud or database storage provider. If you are a user located outside the United States, we may disclose your personal information (which may include information collected through the use of cookies and other technologies, as described above) to recipients located in countries other than the country where you reside for the purposes described in Section 3. Recipients of your personal information may be located in the United States or in any other country in which we have facilities or in which we engage service providers. United States and other countries’ data protection laws may not be the same as those in your jurisdiction. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in the United States may be entitled to access your personal information. We take reasonable steps to make sure that any overseas recipient of your personal information does not breach applicable law in relation to such information. By using the FoxNext Services and disclosing your personal information to us, you consent to such overseas use and disclosure of your personal information. For more information regarding the location of the data, please contact us using the information provided at Section 7 below.

Linked Services. The FoxNext Services may be linked to sites operated by unaffiliated companies, and may carry advertisements or offer content, functionality, games, newsletters, contests or sweepstakes, 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.

In addition, FoxNext is not responsible for the privacy or data security practices of other organizations, such as Facebook, Tumblr, Twitter, Apple, Google, Microsoft or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including in connection with any information you disclose to other organizations through or in connection with the FoxNext Services.

Collection of Personal Financial Information by a Payment Service. In some cases, we may use an unaffiliated payment service to allow you to make an in-app purchase or make payments (“Payment Service”). If you wish to make an in-app purchase 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.

Data Retention. We will retain your information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law. After this period, we will destroy or de-identify your data, as required by law.

Remember that even after you cancel your account, or if you ask us to delete your personal information, 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, for fraud detection or to comply with applicable law or our internal security or recordkeeping policies. It may not always be possible to completely remove or delete all of your information due to technical constraints or contractual, financial or legal requirements.

Sensitive Information. We ask that you not send us, and you not disclose, any sensitive personal information (such as social security numbers, information related to racial or ethnic origin, political opinions and associations, religion, philosophical or other beliefs, health information, criminal background, trade union or professional memberships and associations or information about sexual orientation or practices) on or through the FoxNext Services or otherwise.

7. CONTACT US

If you have questions about this Privacy Policy, or if you believe that we have not complied with this Privacy Policy or our privacy obligations at law, 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

If you are contacting us to complain about an alleged breach of this Privacy Policy or our privacy obligations at law, please provide us with as much detail as possible in relation to your complaint. We take any privacy complaint seriously and any complaint will be assessed with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need.