PRIVACY POLICY

Last updated: 26/06/2025. Actual version is available at: Privacy Policy.

BY USING OUR SOFTWARE OR PROVIDING YOUR PERSONAL DATA TO US, AND SUBJECT TO YOUR RIGHTS AT LAW, YOU CONFIRM THAT YOU HAVE READ, UNDERSTOOD AND ACCEPTED THIS PRIVACY POLICY.PLEASE ENSURE YOU HAVE READ IT CAREFULLY, PARTICULARLY THE SECTION DETAILING YOUR RIGHTS ABOUT THE PERSONAL DATA THAT WE COLLECT ABOUT YOU.IF YOU DO NOT AGREE WITH ANY ASPECT OF THE PRIVACY POLICY, PLEASE DO NOT ACCESS OR USE OUR SOFTWARE.

1. WHAT THIS POLICY IS ABOUT?

1.1 This policy is about how we ensure your privacy while playing Ninja Party.
This Privacy Policy (the Policy) describes how the Nekki Limited (we, us, our) collects, uses, stores, and discloses Personal Data of a user (you, your), when you use Ninja Party video game as defined by End-User License Agreement (EULA) available at: link to the EULA (Ninja Party).

1.2 What Personal Data is.
For purposes of the Policy, Personal Data means any information that directly or indirectly identifies a particular individual, including any other information that is subject to applicable data protection laws. You may see particular items of your Personal Data we process in clause 4.1. below.

1.3 The Policy is a part of our EULA.
The Policy should be read together with, and forms part of, EULA, which is specified in clause 1.1. hereof. Unless otherwise defined herein, capitalized terms in the Policy have the meaning given to them in EULA. The Policy encompass your usage of any version of Ninja Party (on Android, iOS, Nintendo Switch or others, if any).

1.4 Our privacy principles.
To ensure your privacy, we:

do not collect any Personal Data without sufficient lawful basis, namely your consent;

collect only a minimum amount of Personal Data that is needed for you to enjoy the full Ninja Party’s functionality;

do not monetize your Personal Data;

do not check your Personal Data, except where such a check is necessary for us to fulfill our obligations to you;

process Your Personal Data as transparently as practically possible.

1.5 What you guarantee to us.
By providing access to Ninja Party, we act reasonably as well as in good faith and believe that you:

have all necessary rights to use Ninja Party;

provide true, accurate, current and complete information about yourself;

reach the minimum age in the relevant territory, or your parents or other legal representatives agree that you use Ninja Party;

carefully read, understand and accept the Policy;

if you disclose any third-party Personal Data, you have obtained lawful consent or have another valid legal basis for such disclosure.

1.6 We follow applicable privacy legislation worldwide.
We are guided by relevant laws and regulations regarding privacy and Personal Data protection, including the Regulation (EU) 2016/679 or General Data Protection Regulation (GDPR). Please note that some terms, procedures, rights and obligations related to privacy may vary in different countries, depending on the applicable local laws.

1.6 The Policy applies to players only.
Subject to clause 1.3. hereof, the Policy applies to our collection, use and disclosure of Personal Data related to Ninja Party’s players regardless of the platform (Android, iOS, Nintendo Switch or others, if any) used to access or interact with Ninja Party. The Policy also governs the processing of Personal Data related to cross-game functionality via Nekki ID as described in clause 1.10, when used across supported games within the Nekki ecosystem. The Policy does not apply to job applicants or to our employees and non-employee contractors, whose Personal Data is subject to different privacy policy/notices.

1.7 Your previous consents are reserved.
The Policy supplements but does not supersede or replace any other consents you may have previously provided to us in respect of your Personal Data while using any of our products. Your consents herein are additional to any rights which we may have at law to collect, use or disclose your Personal Data.

1.8 Information provided to us by third parties.
If you access Ninja Party through a supported platform (such as Steam, Nintendo Switch Online, Epic Games Store, Google Play, or Apple App Store), we may receive limited Personal Data (e.g., platform-specific username, platform-specific ID, friend lists, or regional information) as permitted by that platform’s terms and your account settings. This data: 

is processed in accordance with the Policy; 

remains subject to any prior consents you’ve granted under clause 1.8 above; and 

may be governed by additional terms of the respective platform. 

The information we receive from such platforms may also be used to create your internal player identifier (see clause 1.10 below), if you log into Ninja Party using one of the supported Third-Party Accounts.We do not control data collected independently by third-party platforms. Please review their privacy policies for details.

1.10 Cross-Platform Availability within the Nekki Ecosystem.
When accessing Ninja Party, you may use a third-party login methods, such as Google or Apple ID (Third-Party Accounts), or register directly using your email address, to log in and enable cross-platform functionality, including progress synchronization. We do not manage your Third-Party Accounts and are not responsible for your relationship with the respective service providers. 

Whenever you use either a Third-Party Account or your email address to access our games, a technical player identifier (referred to as a “Nekki ID”) is automatically created. This identifier is used within our game ecosystem to support cross-platform login, access across multiple devices, and synchronization of game progress and settings. Nekki ID also enables you to sign in to other games developed by us that support this system using the same credentials and to enjoy a unified, personalized gameplay experience. You may create a Nekki ID in any of our supported games — not only in Ninja Party — and then use it to access that game across different devices or to log in to other Nekki games that support Nekki ID. If you use the same email address across different Third-Party Accounts or our games, we may associate such data under your Nekki ID to ensure a consistent experience across devices and titles.Your Nekki ID may also be used to recognize your activity across our supported games. This allows us to provide additional features and improve your overall experience — for example, by synchronizing your progress between games, unlocking cross-game content, or offering personalized in-game suggestions based on your preferences and behavior.This use of data is limited to personalization within our games and services and is subject to the same data protection standards and legal bases outlined in the Policy.

1.11 How to interpret the Policy.
Headings and subheadings shall be ignored in interpreting the Policy. Unless otherwise specified explicitly, the words “including”, “include”, “in particular” and similar shall not be deemed to limit the general effect of the words that precede them. Definitions imported in plural (or in singular) have the same meaning in singular (or in plural) with appropriate corrections.

2. ABOUT US

2.1 Who are We?
Our legal details are:

  1. Our legal entity: Nekki Limited;
  2. Our legal address: 116, Gladstonos str, M. Kyprianou house; 3rd & 4th floors, 3032, Limassol, Cyprus.

2.2 Our role while processing your data.
We are a data controller. This means that we determine the purposes and means of the Personal Data processing and, therefore, are responsible for handling your Personal Data.

2.3 Who to contact if you have requests related to privacy in Ninja Party? For requests, questions or complaints about processing your Personal Data or our handling of Personal Data, please send requests to a person, that we appointed as a responsible for users’ privacy matters, at any of the following:

  1. official email: dpo@nekki.com;
  2. correspondence address: 116, Gladstonos str, M. Kyprianou house; 3rd & 4th floors, 3032, Limassol, Cyprus.

If you have general questions regarding Ninja Party, please check out EULA for contact details.

2.4 Contact us first if you have questions on privacy in Ninja Party.
Once we receive your request, we contact you to find out how we can help. If you have any complaints about how we process your Personal Data, we will always prefer that you contact us first.

2.5 Rules on responding to your requests.
Before responding to the request, we will take reasonable steps to verify the identity of the person making the request. If we doubt on the identity of the person making the request, we may ask for additional information to confirm the identity. We may refuse to act on the request:

  1. if having requested additional information, we are still not able to identify the person; or
  2. the request at issue is unreasonable or impractical (where such a refuse permitted by local law).

We will respond to your requests in a reasonable timeframe.

3. WE CAN CHANGE THE POLICY

3.1 We have the right to change the Policy.
We reserve the right to change the terms of the Policy at any time and at our discretion to ensure that it is consistent with future developments, industry trends and/or any changes in legal requirements.

3.2 We strive to notify you on changes to the Policy.
If we decide to update the Policy, we are not obliged, but we will do best to notify you about the changes before they take effect via Ninja Party, its official pages on applicable distributions platforms (Apple App Store, Google Play, Steam, Epic Games Store or others, if any), website (https://ninjaparty.com) or email. Choosing the specific way to inform you is solely up to us. Additionally, we will always:

  1. post the new version of the Policy on the webpage specified at the top of the Policy, so that you always know about our current approach to your Personal Data processing;
  2. provide all updates made compared to the previous version of the Policy by modifying section “Notice of Changes” above. We encourage you to periodically check the Policy to monitor the updates on it. We will always post the date our Policy was last updated at the top.

Please, check back regularly for updated information on handling of your Personal Data.

3.3 You agree to follow the newest terms of the Policy.
Subject to your rights at law, you agree to be bound by the prevailing terms of the Policy as updated from time-to-time as prescribed by this section. You may not accept updated terms only by ceasing your further using Ninja Party.

4. WHAT PERSONAL DATA WE PROCESS AND HOW WE DO THIS

4.1 What types of your data do we process?
We process your Personal Data only that you or your legal representative provides us with. The scope of Personal Data we process varies based on the purpose for which we process it. Details of Personal Data processing are specified in the table below:

Purposes for which we process Personal Data Categories of Processed Data Scope of processing The lawful basis for processing Periods for which we retain Personal Data
Creation and maintenance of your game account
  • Account credentials
  • Profile information
  • Device identifiers
  • E-mail address
  • Login
  • IP-address
  • Nickname / account name
  • Account created date
  • Activity log
  • Timestamps
  • Country
  • Language
  • Social media handles
  • Device information
 We process your Personal Data on the basis of your consent. 

Such consent is deemed given by you if you put a tick in the “I agree to the processing of my Personal Data” box that will appear when you register on the Website.

 We only store Personal Data for as long as necessary for the purpose the data was collected for.

This means that Personal Data collection based on your consent will be deleted if you withdraw your consent unless We are required to retain all or part of the data under applicable law. 

After that, Personal Data is destroyed by erasing from our devices.

In any case, the Personal Data is erased if you are inactive (i.e., no login or interaction with Ninja Party video game) for 5 years.
Enabling you to sign into our games via Third-Party Accounts or email registration (including creation of a Nekki ID), supporting cross-platform login within games and access across our Nekki game ecosystem
  • Personal data that you have agreed to share with us
  • E-mail address
  • Platform-specific user ID (e.g., SteamID, Google Play ID)
  • Public profile information 
  • Friend lists (if explicitly shared)
  • Technical player ID (Nekki ID)
  • Account linkage data
  • Device information
  • Data used for login via Third-Party Accounts (e.g., Google, Apple)
Providing functionality of Ninja Party video game (including administration and support of it)
  • Connection data 
  • Performance metrics
  • Support communications
  • E-mail address
  • Login
  • IP-address
  • Nickname / account name
  • Account created date
  • Activity log
  • Timestamps
  • Country
  • Language
  • Device information
  • Support tickets content
  • Network characteristics
  • Performance data
  • Technical player ID (Nekki ID)
Payment Processing
  • Transaction records
  • Purchase history
  • E-mail address
  • Login
  • IP-address
  • Payment amounts
  • Product codes
  • Currency/local pricing
  • Purchase timestamps
  • Purchase count per session
Marketing communications
  • Advertising identifiers
  • Marketing preferences
  • Push notification consent status
  • Install source/campaign data
  • E-mail address
  • Login
  • Nickname
  • Country
  • Language
  • Device information
  • Mobile Advertising Identifiers (IDFA/AAID)
Conducting business optimization, service development, delivering personalized cross-game offers to approve your gameplay experience
  • Usage statistics
  • Technical diagnostics
  • Nickname / account name
  • E-mail address
  • Playtime duration
  • Purchase and refund histories
  • Activity logs
  • Country
  • Device information
  • IP-address
  • Support details
  • Network performance data
  • Crash reports
  • Technical player ID (Nekki ID)

4.2 When we start to process data.
We initiate the processing of your Personal Data in the following scenarios:

  1. Basic Data Processing: When you first interact with Ninja Party (via our Website, Steam, Epic Games Store, Nintendo Switch Online, or mobile platforms), we process minimal data required for functionality (IP-address, Device information);
  2. Full Data Processing: Additional Personal Data is only processed as specified in the table above.

4.3 You are not obliged to provide data.
The provision of Personal Data is not a statutory or contractual requirement, as well as is not a requirement necessary to enter into a contract. You are free to reject the processing of your Personal Data.

But if we don’t have data, we may limit the access to Ninja Party. At the same time, if you reject to consent to our processing of your Personal Data, we may limit your access to Ninja Party’s functionality. We are not liable if the missing Personal Data processing prevents the adequate use of Ninja Party.

4.4 Your rights in relation to processing your data.
You have many rights over your Personal Data and how it may be used. Below are set out the major rights, which are available to you at any time and how to make use of those rights. To use your rights, send us an email via specified in clause 2.3. above with topic “Personal Data Subject Request”.

Type of a right Description
Right to access Personal Data You can ask us about: 

  • What your Personal Data we have (and get a copy of it); 
  • How we use it;
  • Why we process them;
  • Who we shared it with; and more. 
Right to withdraw a consent At any time, you may withdraw a consent to process your Personal Data, which you gave us earlier. This will entail us to stop processing your Personal Data and delete it as it described in section “Right to erasure” below.
Right to erasure (“Right to be forgotten”) You can ask us to delete all Personal Data that we have about you – it is your right to be forgotten, as if we have never met before. If you do so, you will no longer have access to Ninja Party.

However, we have the right not to erase your Personal Data and process it insofar as the processing is permitted by the applicable law on Personal Data, including purposes of settling claims and disputes, as well as sending responses to requests from public authorities.

In case you request to erasure your Personal Data, we may request your email and login to verify your identity.

You agree that such erasure implies loss of access to the functionality (its part) of Ninja Party, considering clause 4.3. above.
Right to rectify Personal Data You can ask us to update, block or delete your Personal Data if the data is incomplete, outdated, incorrect, unlawfully received or there is no need to proceed with it anymore. If you do not provide correct Personal Data, we may suspend access to Ninja Party due to the lack of necessary data.
Right to restrict the use of Personal Data For example, if you think that your Personal Data is not accurate and we need time to check it, we can pause in processing your Personal Data enough to clarify, whether it is so or not.
Right to data portability You can ask us to download (export) all your Personal Data that we have in the format acceptable to give it to someone else or ask us to give them your data directly (on a basis of your consent).
Right to lodge a complaint with a supervisory authority You always can complain about us and about the way we process your Personal Data. Please, note that authority depends on location where you reside. 

4.5 Confidentiality of your data.
We deem confidential any of your Personal Data. Nevertheless, we can disclose them in cases stipulated in applicable local laws, including GDPR. In particular, to public authorities.

4.6 We may process your communications to us.
We may collect information about you from any emails or letters that you send to us. We only use any such information in accordance with the Policy. Such information may be received by us via, in particular:

  1. email: np@nekki.com
  2. email: dpo@nekki.com
  3. Discord: https://discord.gg/ninjaparty

 

4.7 Be elective on sharing your Personal data in Ninja Party.
There are possible cases when Personal Data may be provided to us through the usage of Ninja Party’s functionality. For example, Ninja Party may allow an import of information, which may theoretically contain Personal Data (e. g., you upload to your in-game profile a photo containing your real image). In such cases, we would not perform purpose-based data processing but in any way, we take all necessary measures to keep such data safe and secure.

Please, note that such uploaded information may be displayed to other users of Ninja Party. We cannot control and we are not responsible for actions of such other users who can process such information in their own interests. Therefore, please, be cautious and elective on what data you share while using Ninja Party’s functionality.

4.8 We send marketing emails to you with your Consent.
We can send regular newsletter or marketing messages related to Ninja Party in case if you provide separate consent to receive such marketing e-mails.

You may refuse to receive it. If you wish to stop receiving our marketing communications, you can unsubscribe at any time by clicking the “unsubscribe” link at the bottom of our emails. Your request will be processed promptly, and you will no longer receive marketing emails from us.

4.9 Who can obtain your data from us?
We use services of some processors in order to process your Personal Data, namely:

Processor What it does Privacy details
Amazon Web Services, Inc. Cloud hosting services AWS Privacy Policy
Unity Software, Inc. Cloud hosting services Unity Privacy Policy
Valve Corporation – Steam Store (distribution)

– Steam Wallet (payments)

 Steam Privacy Policy
Google LLC – Google Pay (payment processing)

– Google Play Store (app distribution)

– Firebase (analytics)

– Google Analytics

 Google Privacy Policy
Apple, Inc. – Apple Pay (payment processing)

– App Store (app distribution)

 Apple Privacy Policy
Xsolla, Inc. Payment processing services Xsolla Privacy Policy
YooMoney Payment processing services YooMoney Privacy Policy
Meta Platforms, Inc. Facebook Analytics Meta Privacy Policy
AppsFlyer Ltd. Mobile attribution analytics AppsFlyer Privacy Policy
AppLovin Corporation Ad mediation services AppLovin Privacy Policy
Helpshift, Inc. Customer support services Helpshift Privacy Policy
Functional Software, Inc. (Sentry) Error monitoring (PC) Sentry Privacy Policy

These processors store your Personal Data on their servers and provide us with other services of support for the products.They process your Personal Data in accordance with the terms of the written contracts concluded between us and them. These contracts provides that the processors shall process and use your Personal Data only to the extent provided in the contracts. The terms of these contracts do not violate our obligations to you and your rights as a data subject.

4.10 No sensitive data processing.
We do not process any special categories of Personal Data. If such data accidentally comes to us, we immediately delete it and use any other reasonable measures to prevent the disclosure of such information to third parties.

4.11 No scraping of data.
We do not receive your Personal Data from publicly accessible sources.

4.12 No automated decision-making.
We do not process your Personal Data automatically, so you cannot be the subject to a decision based solely on automated processing, including profiling.

5. HOW WE SECURE YOUR DATA

5.1 We apply security measures for your data.
We are committed to protecting the security of your Personal Data. We use reasonable information security measures, including physical, administrative, and technical safeguards. The latter include firewalls, authorization, antivirus and SSL encryption. We apply these safeguards in order to protect your Personal Data from: unauthorized access modification or alteration; improper use or disclosure; unlawful destruction or accidental loss.

These measures vary based on the sensitivity of Personal Data that we collect, process and store and the current state of technology.

5.2 Parties receiving your data from us also secure it.
Our affiliates, employees, contractors and other third parties receiving Personal Data in accordance with clause 6.3 (a, c, d). below are obliged to keep your Personal Data confidential when accessing it. Anyone who has such access is subject to strict contractual obligations regarding confidentiality and may be subject to liability if it does not fulfill these obligations. Also, we take care to ensure that parties, which receive your Personal data from us (regardless of where they are located at) have sufficient safeguards in place to properly process and protect your Personal Data in line with our own data protection and information security standards.

5.3 We do our best to prevent data leakage.
We are constantly improving our data security systems. We are doing everything in our capacity to prevent its breach. In case such a breach occurs, we undertake to notify you and the regulators about the incident as quickly as possible, as well as to make every effort to minimize negative consequences.

6. WHERE WE STORE YOUR DATA & TO WHERE WE TRANSFER IT

6.1 Your data may be stored and processed worldwide.
Personal Data we collect may be stored and processed for the purposes set out in the Policy in any country in which we operate. Besides, your Personal Data may be transferred, stored, and processed by recipients in various countries around the world where our servers are located, and our databases are operated. We do all necessary to make sure all recipients understand the necessity to process Personal Data only on a legal basis considering any and all applicable legislation.

6.2 Our servers’ location.
Our servers are located in the European Economic Area (EEA). Such servers are provided by Amazon and Unity Multiplay, so it should be noted that they have technical access to your Personal Data to provide the services.

6.3 To whom we may transfer your data.
We do not sell your Personal Data. We also do not allow any Personal Data to be used by third parties for their own marketing purposes, except in cases where you explicitly request or provide consent for us to do so. However, we do need to share Personal Data to provide you with smooth Ninja Party’s operation. Below are the different scenarios under which we may share your data with third parties.

  1. any third party to whom we assign or novate any of our rights or obligations under a relevant agreement;
  2. any national or international regulatory, enforcement, exchange body, central or local government department, and other statutory or public bodies or court where we are required to do so by applicable law or regulation at their request;
  3. any third parties, if you expressed your consent to such transfer and it is necessary for your use of certain services or performance of a particular agreement or contract with you;
  4. third parties mentioned in clause 4.9. above.

6.4 What happens if We’re going to transfer Your data overseas?
The use of Ninja Party may involve the transfer of Personal Data to recipients and third parties both inside and outside the EEA, including the USA.

One of the important steps We take when it comes to international data transfers involving third parties is due diligence and vetting. As part of the third-party vetting process, we ensure that Personal Data will only be transferred to a third party located outside the place of our servers with the required cross-border transfer mechanism and safeguards in place as specified below. We consistently monitor changes to the international transfer mechanisms permitted under applicable privacy laws to ensure ongoing compliance with international data protection standards.When we engage a third party that is located outside the place of our servers, we agree on the appropriate level of data protection, including additional contractual, technical, and organizational measures and the execution of a transfer impact assessment where necessary, to ensure the ongoing protection of the rights and freedoms of all individuals concerned by our processing.We only transfer your Personal Data to those third parties where we can be sure that we can protect your privacy and your rights, for example, the third party is located in a country that the EU has deemed to have adequate data protection laws in place or to a country which has not been recognized by the European Commission as providing an adequate level of Personal Data protection but where we have a contract in place with that third party which includes the European Commission’s standard data protection clauses.Whenever we are sending data to countries that are not providing the same level of protection as European laws, i. e. to countries that have not been recognized by the European Commission as providing an adequate level of protection, we use appropriate safeguards to protect your Personal Data, including Standard Contractual Clauses for Processors.

6.5 You consent to transfer your data to countries with non-adequate protection.
By using our products, you authorize the transfer of your Personal Data to countries that have not been recognized by the European Commission as providing an adequate level of Personal Data protection, where our service providers process data for customer care, account management, and service provisioning, and to other locations, where we and/or our service providers operate, and to its (and their) storage and use as specified in the Policy and any applicable EULA or other agreement between you and us.