Privacy Policy
This Privacy Policy explains how New Generation Games Limited ("NGG", "we", "us" or "our") processes personal data when you use our website https://ngg.top and the games, mobile applications, educational products and related services that we publish or operate and that link to this Policy (together, the "Services"). NGG is the controller of that personal data.
Some Services may have their own or a supplementary privacy notice (for example, Services designed for children). Where they do, that notice applies to the relevant Service together with this Policy.
This Policy is a notice and not a contract. Using the Services does not mean that you consent to any processing. Where we rely on your consent, we ask for it separately.
1. WHO WE ARE AND HOW TO CONTACT US
Controller: New Generation Games Limited, a company incorporated in Hong Kong (registration number 3257356)
Registered address: Flat/Rm 7022, Block D, 7/F, Tak Wing Industrial Building, 3 Tsun Wen Road, Tuen Mun, New Territories, Hong Kong
Privacy contact: info@ngg.top
2. PERSONAL DATA WE COLLECT
2.1Data you provide to us:
(a)Business enquiries and game submissions: name, email address, company, position, your messages and the materials you send us through the forms on our website or by email;
(b)Job applications: name, contact details, CV, cover letter, professional history and any other information you choose to include;
(c)Customer support and feedback: email address, player or user ID, messages, attachments, bug reports and survey answers;
(d)Account data (where a Service offers accounts): nickname, player ID and the identifier and basic profile data of a platform account you choose to link (for example, Apple Game Center, Google Play Games or Facebook);
(e)User content (where a Service has such features): chat messages, nicknames, profile images and other content you share.
2.2Data collected automatically:
(a)Device and technical data: advertising identifiers (Google Advertising ID; Apple IDFA, only if you allow tracking), identifier for vendors (IDFV), IP address, device model, operating system and version, language, time zone, screen resolution and mobile carrier;
(b)Usage and gameplay data: sessions, in-app actions, progress, achievements, virtual item balances and transactions, crash logs and performance diagnostics;
(c)Approximate location: country or city derived from your IP address. We do not collect precise (GPS) location;
(d)Advertising and attribution data: ads shown and clicked, installs attributed to advertising campaigns and campaign identifiers;
(e)Website data: IP address, browser type, pages visited and data from cookies and similar technologies (see Section 8).
2.3Data we receive from third parties: app stores (purchase confirmations, transaction identifiers and refunds; we do not receive your full payment card details), platform login providers (with your permission), advertising and attribution partners (for example, which campaign led to an install), and game development and publishing partners who operate a Service with us.
2.4We do not intentionally collect special categories of personal data (such as health data or religious beliefs). Please do not include such data in your messages or job applications.
2.5Providing personal data is generally voluntary. Some data is necessary to provide the Services (for example, device data to run a game or contact details to answer you); without it, we may not be able to provide the relevant feature.
3. WHY WE USE PERSONAL DATA AND OUR LEGAL BASES
The table below sets out our purposes and the legal bases under the EU and UK General Data Protection Regulation ("GDPR"). Where we rely on legitimate interests, the interest is stated in the table.
| Purpose | Data | Legal basis |
|---|---|---|
| Providing and operating the Services: running games, saving progress, accounts, restoring purchases and virtual items | Account, device, gameplay and purchase data | Performance of a contract (Art. 6(1)(b)) |
| Customer support and handling your requests, including privacy requests | Contact, support and account data | Performance of a contract; legal obligation (Art. 6(1)(c)) |
| Security, prevention of fraud and cheating, enforcement of our Terms of Use | Device, usage, IP and transaction data | Legitimate interests: keeping the Services secure and fair (Art. 6(1)(f)) |
| Crash reporting, diagnostics and service stability | Crash logs, device data | Legitimate interests: keeping the Services working |
| Analytics and product improvement | Usage and device data | Consent where the law requires it for access to your device (for example, in the EEA and UK); otherwise legitimate interests: improving our products |
| Personalised advertising in our Services and measuring our advertising campaigns (attribution) | Advertising identifiers, IP address, ad interaction data | Consent (Art. 6(1)(a)); on iOS, also your App Tracking Transparency choice |
| Non-personalised (contextual) advertising | Limited device data, approximate location | Legitimate interests: funding free Services; consent where the law requires it for access to your device |
| Personalising in-game offers | Gameplay and purchase data | Legitimate interests: showing relevant offers (you may object at any time) |
| Business enquiries, game submissions and partnerships | Contact and business data, submitted materials | Legitimate interests: evaluating and developing business relationships; steps prior to a contract |
| Recruitment | Applicant data | Steps prior to a contract; legitimate interests: hiring; consent if we keep your application for future vacancies |
| Marketing emails and newsletters, if you subscribe | Email address | Consent |
| Legal compliance, accounting and tax; establishing, exercising or defending legal claims | Transaction records, communications, logs | Legal obligation; legitimate interests: protecting our legal rights |
3.1Automated decisions. We use automated means to personalise advertising (with your consent) and in-game offers, and automated tools to detect fraud and cheating. We do not make decisions based solely on automated processing that produce legal or similarly significant effects for you. Where an automated tool flags your account, you may ask for a decision to be reviewed by a person.
4. WHO WE SHARE PERSONAL DATA WITH
4.1Service providers acting on our behalf under contract: hosting and cloud providers, website and form providers, customer support, email, analytics and crash-reporting tools.
4.2Advertising, attribution and analytics partners, which may act as our processors or as independent controllers under their own privacy policies:
(a)Analytics: Google Analytics for Firebase, Unity Analytics;
(b)Attribution: AppsFlyer, Adjust;
(c)Advertising networks and mediation: Google AdMob, Unity Ads, AppLovin; Meta.
4.3Platforms such as Apple, Google and Facebook, for login, purchases and distribution of our apps.
4.4Game development and publishing partners whose games we publish or who publish our games, to the extent needed to operate, support and improve the relevant game.
4.5Companies in our group, for the purposes described in this Policy.
4.6Professional advisers and auditors, under duties of confidentiality.
4.7Authorities and other parties where required by law or necessary to protect our rights, our users or others, including to prevent fraud.
4.8A buyer or successor in a merger, acquisition, reorganisation or sale of assets, subject to confidentiality. We will inform you if your data becomes subject to a different privacy policy.
4.9We do not sell personal data for money. For residents of certain US states, see Section 10.
5. INTERNATIONAL TRANSFERS
5.1NGG is established in Hong Kong, and our service providers and partners may process personal data in other countries, including the United States, countries of the European Economic Area and other geos.
5.2Where personal data from the EEA, the UK or Switzerland is transferred to a country that does not have an adequacy decision (including Hong Kong), we use the European Commission's Standard Contractual Clauses or the UK equivalent and, where needed, additional safeguards, or we rely on the recipient's certification under the EU-U.S. Data Privacy Framework. You may request a copy of the relevant safeguards at info@ngg.top.
6. HOW LONG WE KEEP PERSONAL DATA
We keep personal data only as long as necessary for the purposes described in this Policy. Unless a longer period is required by law or needed for legal claims:
| Data | Retention period |
|---|---|
| Account and gameplay data | While you use the Service; deleted or anonymised within 30 days after your account is deleted (see Section 9) |
| Analytics and advertising data linked to device identifiers | No longer than 26 months |
| Purchase and transaction records | 7 years (accounting and tax requirements) |
| Customer support communications | 2 years after the request is closed |
| Business enquiries and game submissions | 3 years after our last contact, unless we enter into an agreement |
| Job applications | 6 months after the recruitment decision, or longer with your consent |
| Security and fraud prevention logs | 12 months |
| Backups | Overwritten within 90 days |
7. YOUR RIGHTS
7.1Depending on where you live, you have the right to: access your personal data; have it corrected; have it deleted; restrict its processing; receive it in a portable format; object to processing based on legitimate interests; object at any time to direct marketing and related profiling; withdraw your consent at any time (without affecting processing before the withdrawal); and not be subject to decisions based solely on automated processing that significantly affect you.
7.2To exercise your rights, use the in-app privacy settings where available or contact us at info@ngg.top. We may ask for information to confirm your identity, such as your player ID. We respond within one month; this may be extended by two further months for complex requests, in which case we will tell you. Requests are free of charge, except that we may charge a reasonable fee where a request is manifestly unfounded or excessive, or where Hong Kong law permits a fee for a data access request.
7.3You also have the right to lodge a complaint with a data protection supervisory authority, in particular in the country where you live or work or where an alleged infringement occurred. In Hong Kong, this is the Office of the Privacy Commissioner for Personal Data; in the UK, the Information Commissioner's Office.
7.4Advertising controls. You can limit personalised advertising at any time:
(a)iOS: Settings > Privacy & Security > Tracking;
(b)Android: Settings > Privacy > Ads, or Settings > Google > Ads (depending on your device) > Delete advertising ID;
(c)in the Services: the privacy or consent settings, where you can withdraw consent you have given.
8. COOKIES ON OUR WEBSITE
8.1Our website uses cookies that are strictly necessary for it to work.
9. USER DATA DELETION
9.1You may ask us to delete your account and the personal data associated with it at any time, free of charge. Uninstalling an app does not delete your data.
9.2How to request deletion:
(a)In the app: where available, go to Settings > Account > Delete account;
(b)By email: write to info@ngg.top with the subject "Data Deletion Request" and include the name of the game or Service, your player or user ID (shown in Settings) and, if applicable, the email address or platform account linked to the Service. You do not need to reinstall the app;
(c)Website enquiries and job applications: by email as described above.
9.3We may ask for information to confirm that the request comes from you, limited to what is necessary.
9.4What we delete. Within 30 days after confirming your request, we delete or irreversibly anonymise your account, profile, gameplay progress, virtual items and other personal data associated with your account, and instruct our service providers to do the same. Copies in backups are overwritten within 90 days. We will confirm to you when the deletion is complete.
9.5Deletion is permanent. Your progress, unused virtual items and purchases linked to the account cannot be restored afterwards.
9.6What we may keep. We may keep only: (a) transaction records required by accounting and tax law; (b) data needed to prevent fraud or abuse, such as records of account suspensions; (c) data needed to comply with legal obligations or to establish, exercise or defend legal claims; (d) a record of your deletion request; and (e) anonymised or aggregated data that no longer identifies you. Such data is kept only for these purposes and for the periods set out in Section 6.
9.7Data held by others. App stores and partners acting as independent controllers hold some data under their own privacy policies (for example, your purchase history with Apple or Google). We forward deletion requests to our service providers and, where they provide the means, to our advertising and attribution partners. You can also reset or delete your advertising identifier (Section 7.4).
9.8Partial deletion. You may also ask us to delete specific data (for example, support communications) without deleting your account.
10. ADDITIONAL INFORMATION FOR US RESIDENTS
10.1Under the privacy laws of certain US states, including California, you may have the right to know, access, correct and delete your personal information and to opt out of its "sale" or "sharing" for targeted (cross-context behavioural) advertising.
10.2We do not sell personal information for money. However, allowing advertising partners to collect device identifiers for personalised advertising may be considered a "sale" or "sharing" under these laws. You can opt out through your device settings (Section 7.4), the in-app privacy settings or by contacting us at info@ngg.top. Where required, we honour Global Privacy Control signals on our website.
10.3The categories of personal information we collect, their sources, our purposes, the recipients and the retention periods are described in Sections 2 to 6. We do not discriminate against you for exercising your rights. You may use an authorised agent, whose authority we may verify. We do not knowingly sell or share personal information of consumers under 16.
11. CHILDREN
11.1Unless a Service states otherwise, our Services are intended for a general audience and are not directed to children under 13, or a higher age set by the law of your country (up to 16 in the EEA). We do not knowingly collect personal data from such children without parental consent where it is required.
11.2Services designed for children are subject to their own privacy notice and parental consent process. Where we know that a user is below the applicable age, we do not use their personal data for personalised advertising.
11.3If you believe that a child has provided us with personal data without the required consent, contact us at info@ngg.top and we will delete it.
12. SECURITY
12.1We use appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse or alteration, and we require our service providers to do the same. No transmission over the internet is completely secure. Where required by law, we will notify you and the competent authorities of a personal data breach.
13. CHANGES TO THIS POLICY
13.1We may update this Policy to reflect changes in law or in our Services. We will notify you of material changes in advance through the Services, on our website or by email, and will ask for your consent where the law requires it. The "Last updated" date shows when this Policy was last changed.
13.2If you have any questions about this Policy, contact us at info@ngg.top.