Effective: January
1, 2024
This Privacy Policy describes how the National Mah Jongg League (“NMJL”)
collects, uses and discloses information in connection with the use of our
applications, including but not limited to NMJL Online, and what choices you
(the “Customer”) have with respect to such information.
Applicability Of This Privacy Policy
This Privacy Policy applies to the NMJL Online game applications (the “Games”) released under the National
Mah Jongg League label, and to our Web presence at https://faqs.nmjlonline.com (the “FAQ
Site”), together referred to as the “Services”. If you do not agree
with these terms, do not access or use the Services or any other aspect of NMJL’s
business.
NMJL may subcontract the administration of the Games and the FAQ Site to
third parties experienced in technical matters. Any such third parties will
also be bound by the policies described in this document.
Information We Collect and Receive
NMJL requires minimal personal information related to Customers of the Games
or the FAQ Site. For NMJL Online, we do not require Customers to provide us
with contact information such as phone numbers, physical addresses or even real
names.
However, NMJL Online needs a valid email address as the primary user
identifier, so we do require that in order for users to sign on and actually
play games. Such email addresses are required in order to enable certain forms
of contact with Customers, such as password resets and account expiration
alerts; Customers who are unable or unwilling to provide emails will be unable
to access the Services.
We also ask users to create a “User Name” for use in the Games. This
name will be displayed to other players in the game and in end-game screens, as
well as on the FAQ Site.
The FAQ Site does not require or track any personal information other than
the user email.
We may obtain and retain certain information that is necessary for the
operation of the Games or the FAQ Site, such as chat logs, access logs and
error logs, but only for amounts of time required to ensure the proper and
efficient operation of our online systems. Logs may also record IP Addresses of
Customers, which we use for security purposes such as blocking of malicious
content. Such information is regularly purged as a part of the normal operation
of our systems.
NMJL may collect and receive Customer Data, Game Login Data and other
information and data (“Other
Information”) in a variety of ways:
- Customer Data.
In addition to providing emails for login purposes and User Names in the
Games, Customers may send optional requests for contact via a form on our FAQ
Site, which will request an email address.
- Game Login Data. Customers
are required to log in to the Games in order to play. For the NMJL Online
game, this requires a unique, valid email address and password.
- The Games and FAQ Site obtain Customer email addresses
from the parent organization, the National Mah Jongg League, which is
solely responsible for providing authorized Customer lists. Customers
cannot create accounts directly in the Games or on the FAQ Site.
- First-time Customers will be required to create a
password when logging in to the NMJL Online game. This password is unique
to the game and is not shared outside of the Games and FAQ Site.
- In no case do we retain the Customer’s password in clear
text; it is always stored in an obfuscated form and then is used only to
verify the validity of the login credentials that were previously entered
by the Customer.
- For their own safety, we recommend that Customers use
unique usernames and passwords for the Games that are different from the
credentials that they use for other games, Web Sites and Services,
although we cannot require Customers to do so.
- In-Game
Communications. As part of the normal operations of our game lobbies
and games, we allow optional direct communication between one or more
Customers. We retain logs of such activity for compliance monitoring and
security purposes, but only for amounts of time required
to ensure the proper and efficient operation of our online systems and to
respond to lawful requests from law enforcement or government agencies. Logs are regularly
purged as a part of the normal operation of our systems.
- Gameplay
Performance Data. For some of the Games, we track winners and losers
and certain game scoring data such as winning or losing hands. Since each
game normally includes more than one other human player, these records in
our user database will indirectly connect multiple Customers and include
data regarding their in-game performance as well as times of actions. Such
records use internal User ID numbers as their primary keys; if the email
associated with a given User ID is deleted from our records, this will
break the association in our records between than ID and that email
address even though the game performance data continues to exist in the
database.
- Other Information.
NMJL also collects, generates and/or receives Other Information:
- Log data.
As with most websites and technology services delivered over the
Internet, our servers automatically collect information when you access
or use the Services and record it in log files. This log data may
include the Internet Protocol (IP) address, the address of the web page
visited before using the Services, browser type and settings, the date
and time the Services were used, information about browser configuration
and plugins, language preferences and cookie data.
- Device information.
NMJL may collect information about devices accessing the Services,
including type of device, what operating system is used, device
settings, application IDs, unique device identifiers and crash data.
Whether we collect some or all of this Other Information often depends
on the type of device used and its settings.
- Location information.
We do not collect location information from you.
- Cookie Information. NMJL uses cookies and similar
technologies in our FAQ Site that help us provide a good user experience
while using the Games, but we do not use this information for purposes
other than ensuring efficient operation of the Games.
- Contact Information. In accordance with the consent
process provided by your device, any contact information that a Customer
chooses to provide may be retained in order to allow us to provide
requested information.
- Additional Information Provided to NMJL. We receive Other
Information when submitted via the Services or if you participate in a
focus group, contest, activity or event, apply for a job, request
support, interact with our social media accounts or otherwise communicate
with NMJL via our Games or FAQ Site.
Generally, no one is under a statutory or contractual obligation to provide
any Customer Data or Other Information (collectively, “Information”). However, certain
Information is collected automatically and, if some Information is not
provided, we may be unable to provide the full range of services available in the
Games. For example, if no email address is provided, you will not be able to
log in to the Games.
Information We Do Not Collect
The Games and FAQ Site do not collect the following types of Customer
information:
- Financial
Information (including but not limited to payment, credit, salary and
other similar data)
- Health and Fitness Data
- Location Data (i.e., latitude and longitude)
- Contacts from your personal Contact List
- Browsing History and Search History
- Purchase History
How We Use Information
Customer Data and Game Login Data will be used by NMJL in accordance with
Customer’s instructions, including any applicable terms in the Customer license
agreement for the Games, and as required by applicable law. NMJL is a processor
of Customer Data and Customer is the controller.
NMJL uses Game
Login Data and Gameplay Performance Data in furtherance of our
legitimate interests in operating the Games. More specifically, NMJL uses Game Login Data:
- To allow users to
play the Games. In order for us to be able to record game activity
and enable online play, we must maintain unique accounts for each
Customer. Such accounts maintain only enough information to perform such
functions. Game Login Data is used only to create and maintain such
Customer accounts and to enable resetting of the user’s password.
- To allow users to
see the results of their actions within the Games. In some Games, we allow
users to see who won and lost games, and to see cumulative scoring data. Typically,
such displays use the User Name and not an email address. Additionally,
our support staff may have ongoing access to gameplay records, which is
used to analyze system performance and also to design new gameplay features.
- To display player
rankings. In some games, we may retain player ranks or
handicaps in order to enable players to evaluate potential game opponents
based, for example, on skill level or experience. These may be displayed
in “leaderboards” or other ranking reports. Customer Data such as email
addresses or real names (if known) will not be displayed in any such
leaderboards or ranking reports.
- As required by
applicable law, legal process or regulation.
- To investigate and
help prevent security issues and abuse.
NMJL
uses In-Game Communications Data to provide the ability for Customers to
organize games together, ask and answer questions, and discuss game strategies.
In general, we do not monitor or censor such communications, and Customers
should be aware that some such communications may contain content that is offensive
or inappropriate for some Customers. Any such content is the responsibility of
the Customer sending it; NMJL is not liable for any In-Game Communications
Data. Notwithstanding the foregoing, NMJL reserves the right to monitor, censor
and remove content that we in our sole discretion deem inappropriate or
offensive, as further documented in our Terms of Service.
NMJL
uses Other Information in furtherance of our legitimate interests in operating
our Services, Web sites, Games and business. More specifically, NMJL uses Other
Information:
- To provide,
update, maintain and protect our FAQ Site and business.
This includes use of In-Game Communications Data, Game Performance Data
and Other Information to support delivery of the Services under a Customer
Agreement, prevent or address service errors, security or technical
issues, analyze and monitor usage, trends and other activities or at a
Customer’s request.
- As required by
applicable law, legal process or regulation.
- To communicate
with you by responding to your requests, comments and questions.
If you contact us, we may use your Other Information to respond.
- To send emails and
other communications, if an email address was provided to us.
We may send you service, technical and other administrative emails,
messages and other types of communications. We may also contact you to
inform you about changes in our offerings, and important FAQ Site-related
notices, such as security and fraud notices. These communications are
considered part of the Services and you may not opt out of them.
- To investigate and
help prevent security issues and abuse.
If Information is aggregated or de-identified so it is no longer reasonably
associated with an identified or identifiable natural person, NMJL may use it
for any business purpose. To the extent Information is associated with an
identified or identifiable natural person and is protected as personal data
under applicable data protection law, it is referred to in this Privacy Policy
as “Personal Data.”
Data Retention
NMJL will retain Customer Data in accordance with a Customer’s instructions,
including any applicable terms in the Customer Agreement and Customer’s use of Game
and FAQ Site functionality, and as required by applicable law. The deletion of
Customer Data and other use of the Games by Customer may result in the deletion
and/or de-identification of certain associated Other Information. NMJL may
retain Other Information pertaining to you for as long as necessary for the
purposes described in this Privacy Policy. This may include keeping your Other
Information after you have deactivated your account for the period of time
needed for NMJL to pursue legitimate business interests, conduct audits, comply
with (and demonstrate compliance with) legal obligations, resolve disputes and
enforce our agreements. Under typical circumstances, such information will be
kept for no more than one calendar year.
To request deletion of your Customer Data, please email privacy@nmjlonline.com or visit our
Web site Deletion Request page at https://faqs.nmjlonline.com/legal/deletion_form.html.
How We Share and Disclose Information
This section describes how NMJL may share and disclose Information.
Customers determine their own policies and practices for the sharing and
disclosure of Information, and NMJL does not control how they or any other
third parties choose to share or disclose Information. As used in the following
sections, the term “Information” includes Customer Data, Game Login
Data, Other Information, In-Game Communications Data and Gameplay Performance
Data, as defined above.
- Customer’s
Instructions. NMJL will solely share and disclose Information
in accordance with a Customer’s instructions, including any applicable
terms in the Terms of Service and Customer’s use of Game or FAQ Site functionality,
and in compliance with applicable law and legal process. Our terms of
service may be found at:
- Customer Access.
Administrators may be able to access, modify or restrict access to
Information. This may include, for example, exporting logs of Game or FAQ
Site activity, In-Game Communications, or emails sent.
- Corporate
Affiliates. NMJL may share Information with its corporate
affiliates, parents and/or subsidiaries, including subcontractors tasked
with administrative duties for the Games and the FAQ Site.
- To Implement App
Functionality. NMJL uses certain third-party tools
to implement functionality to contact the user, with the user’s
permission, for its products. These tools include:
- SocketLabs:
reliable delivery of password reset emails and account-related
notifications
- Firebase:
implementation of “push notifications” to applications in order to inform
players of the status of their turns
- During a Change to
NMJL’s Business. If NMJL engages in a merger, acquisition,
bankruptcy, dissolution, reorganization, sale of some or all of NMJL’s
assets or stock, financing, public offering of securities, acquisition of
all or a portion of our business, a similar transaction or proceeding, or
steps in contemplation of such activities (e.g., due diligence), some or
all Information may be shared or transferred, subject to standard
confidentiality arrangements.
- Aggregated or
De-identified Data. We may disclose or use aggregated or
de-identified Information for any purpose. For example, we may share
aggregated or de-identified Information with prospects or partners for
business or research purposes, such as measuring time spent on our FAQ
Site or in the Games.
- To Comply with
Laws. If we receive a request for information, we may
disclose Information if we reasonably believe disclosure is in accordance
with or required by any applicable law, regulation or legal process.
- To enforce our
rights, prevent fraud, and for safety. To protect and
defend the rights, property or safety of NMJL or third parties, including
enforcing contracts or policies, or in connection with investigating and
preventing fraud or security issues.
- With Consent.
NMJL may share Information with third parties when we have consent to do
so.
Security
NMJL takes security of data very seriously. NMJL works hard to protect
Information you provide from loss, misuse, and unauthorized access or
disclosure. These steps take into account the sensitivity of the Information we
collect, process and store, and the current state of technology. Given the
nature of communications and information processing technology, NMJL cannot
guarantee that Information, during transmission through the Internet or while
stored on our systems or otherwise in our care, will be absolutely safe from
intrusion by others.
Information sent to and from our servers is encrypted in transit, and key
elements such as passwords are obfuscated in our databases.
Age Limitations
To the extent prohibited by applicable law, NMJL does not knowingly request
personal information from anyone younger than 16 years old. If you learn that
anyone younger than 16 has unlawfully provided us with personal data, please
contact us and we will take steps to delete such information in accordance with
our standard deletion policies.
Changes To This Privacy Policy
NMJL may change this Privacy Policy from time to time. Laws, regulations and
industry standards evolve, which may make those changes necessary, or we may
make changes to our business. We will post the changes to this page and
encourage you to review our Privacy Policy to stay informed. If we make changes
that materially alter your privacy rights, NMJL will provide additional notice,
such as via email or through the Games. If you disagree with the changes to
this Privacy Policy, you should discontinue use of our Games and FAQ Site.
Data Protection Officer
To communicate with our Data Protection Officer, please email privacy@nmjlonline.com.
Identifying The Data Controller and Processor
Data protection law in certain jurisdictions differentiates between the
“controller” and “processor” of information. In general, the Customer is the
controller of Customer Data. In general, NMJL is the processor of Customer Data
and the controller of all other Information.
Your Rights
Individuals located in certain regions, including the State of California
and the European Economic Area, have certain statutory rights in relation to
their personal data. Subject to any exemptions provided by law, you may have
the right to request access to Information, as well as to seek to update,
delete or correct this Information. You can do this by contacting us via email
at privacy@nmjlonline.com.
To the extent that NMJL’s processing of your Personal Data is subject to the
California Consumer Privacy Act (CCPA) European General Data Protection
Regulation (GDPR), NMJL relies on its legitimate interests, described above, to
process your data. NMJL may also process Information that constitutes your
Personal Data for direct marketing purposes; you have a right to object to NMJL’s
use of your Personal Data for this purpose at any time.
Data Protection Authority
Subject to applicable law, you also have the right to (i) restrict NMJL’s
use of Information that constitutes your Personal Data and (ii) lodge a
complaint with your local data protection authority or directly with NMJL at privacy@nmjlonline.com.
Contacting NMJL
Please feel free to contact NMJL if you have any questions about this
Privacy Policy or NMJL’s practices, or if you are seeking to exercise any of
your statutory rights. You may contact us with general queries or data deletion
requests at privacy@nmjlonline.com.
NMJL Online is a Trademark of the National Mah Jongg League. Other marks
are the property of their respective owners.