Network Next, Inc.
Last Modified on October 4, 2019
We ask that you read this privacy notice carefully, as it contains important information on who we are, how and why we collect, store, use, and share certain information, your rights in relation to that information and on how to contact us and supervisory authorities in the event you have a complaint.
1. Who we are
Network Next, Inc. (“Network Next”, “We”, or “Us”) collects, uses, and is responsible for certain information about you, as part of the Network Next internet trafficking and network optimization services (the “Service”).
For those in the European Union, we are regulated under the General Data Protection Regulation (“GDPR”) which applies across the European Union (including in the United Kingdom) and we are responsible as controller of that information for the purposes of those laws.
2. The information we collect and use
Information collected by us: In the course of providing the Service, we collect the following information:
Your IP address and the IP address of any server that you’ve connected to (collectively, the “IP Address”);
Your general geolocation data; your access times, including when and how long you are connected to the server; your ISP’s name; information about your activities on the Service, including RTT, jitter, and packet loss statistics (collectively, your “Analytic Information”).
Information made non-personally identifiable by either combining or aggregating it with information about other users, or by removing characteristics that may make the information personally identifiable (collectively, the “Anonymized Information”).
Information shared with us: In the course of providing the Service, others may share the following data with us:
Your Xbox Live ID, PlayStation Network ID, Steam ID, or other account id (your “Account Information”).
How we use your Information: We use your information as follows:
Your Account Information is used to allow game and application developers to enable statistical analysis and auditing of the Service, should they take advantage of those features.
Your Analytic Information is used to allow the Service to function, including routing data in the most efficient way to enable the application using the Service to function. Analytic information is also gathered and pooled with other users’ information anonymously, and used for the purposes of improving the Service, such as tracking speed improvements and aggregate user activities on the Service.
Who we share your information with: We share your information with certain third parties as part of our operation of the Service. This data sharing enables us to provide you with the Service, including allowing games and other applications to optimize network traffic.
Some of those third-party recipients may be based outside the European Economic Area. For further information, including how we safeguard your personal data when this occurs, see their individual privacy policies linked to above and the section entitled “Transfer of your Information out of the EEA,” below.
We share your Information with the following third parties:
Suppliers: We share Anonymized Information with third party network suppliers in order to provide them with analytic and performance information they need to improve the quality of their service to Network Next’s users.
Game and Application Developers: We share Analytic Information and Anonymized Information with third party game and application developers in order to provide them with analytic and performance information.
Hosting: We host the Service using Google’s Cloud Platform, and your Analytic Information, Anonymized Information, Account Information, and IP Address may be stored there as part of providing the Service.
Other Sub-Processors: We will share your Information with certain Sub-Processors as part of operating the Service. You can find an up to date list of our Sub-Processors, along with more information, on our Sub-Processor page here.
Other Sharing: We will share your Information if we have a good faith belief that (i) access, use, preservation or disclosure of such information is reasonably necessary to satisfy any applicable law, regulation, legal process, such as a court order or subpoena, or a request by law enforcement or governmental authorities, (ii) such action is necessary to detect, prevent, or otherwise address fraud, security or technical issues associated with the Service, or (iii) such action is appropriate to protect the rights, property or safety of Network Next, its employees, clients, or users of the Service.
We will not share your information with any other third party.
How long your information will be kept: We will keep your information for the length of time required to provide the Service, but in any case, no longer than 90 days unless a longer retention period is required by law. Afterwards, we delete all aforementioned data in our possession within a reasonable timeframe. We do not verify the correctness of information that we collect.
Please note that some data may be retained, if necessary, to resolve disputes, enforce Network Next service agreements, and comply with technical and legal requirements and constraints related to the security, integrity, and operation of the Service.
Reasons we can collect and use your information: The laws in some jurisdictions require that we notify you of the lawful basis for collecting your information.
To the extent that such laws apply, we rely on the following as the lawful basis on which we collect and use your personal information:
Consent: At times we may collect, process, store, transfer or disclose personal data on the basis of your implied or explicit consent.
To fulfill our contractual obligations: In order to fulfill our contractual obligations to game and application developers with whom we have a contractual relationship, we must collect, process, and store personal data and information. We must handle your personal data in this manner to provide the Service.
Furtherance of legitimate interests: We may collect, process, store, transfer or disclose your personal data in furtherance of those legitimate interests of ours which are not overridden by your interests or fundamental rights and freedoms as set forth in the applicable laws. These legitimate interests include, but are not limited to, (i) providing the Service, (ii) protecting our users, staff, and property from fraud and other harm, and (iii) collecting information on how you use the Service in order to optimize the functionality of the Service.
Legal compliance: We may collect, process, store, transfer or disclose your personal data to comply with our legal obligations.
Children’s Privacy: We do not knowingly collect any personal information from children under the age of 13, and we require any third party sharing personal information with us to be in compliance with all laws regarding the collection and processing of personal information from children under the age of 13, including getting the appropriate parental consent. In addition, we may limit how we collect, use, and store some of the information of EU users between 13 and 16.
3. Transfer of your Information out of the EEA
Network Next is based in the United States. No matter where you are located, you consent to the processing, transfer and storage of your Information in and to the U.S. The laws of the U.S. and other countries governing data collection and use may not be as comprehensive or protective as the laws of the country where you live.
If you would like further information, please contact us (see “How to contact us” below).
4. Your Rights
EU residents protected under the General Data Protection Regulation in the EEA and those in certain other jurisdictions have a number of important rights with regard to your Information.
If you are an EU resident:
By law, you can ask us what information we hold about you, and you can ask us to correct it if it is inaccurate. If we have asked for your consent to process your personal data, you may withdraw that consent at any time.
If we are processing your personal data for reasons of consent or to fulfill a contract, you can ask us to give you a copy of the information in a machine-readable format so that you can transfer it to another provider.
If we are processing your personal data for reasons of consent or legitimate interest, you can request that your data be erased. However, we may be required to retain some of your data for the purposes of stopping fraud or other legal and contractual requirements.
You have the right to ask us to stop using your information for a period of time, if you believe we are not doing so lawfully.
Finally, in some circumstances, you can ask us not to reach decisions affecting you using automated processing or profiling.
If you would like to exercise any of those rights, please contact us at the addresses below in the section entitled “How to contact us.” We may ask for additional verification information to be sure that you are the owner of that data.
5. Keeping your Information secure
We have taken steps to put appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way.
We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.
We use two-factor authentication and employee role-based access controls for accessing personal information.
We encrypt all data that is collected from users, and any stored data uses redundant backups and anti-virus technology.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
6. How to complain
We hope that we can resolve any questions or concern you raise about our use of your Information. Please contact us via the methods listed below in the section entitled “How to contact us” to let us know about any of your questions or concerns, and we will get back to you to resolve the issue.
If you are an EU citizen, the General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
7. Changes to this Privacy Notice
This privacy notice was published on January 6, 2019 and last updated on October 4, 2019.
We may change this privacy notice from time to time. When we do, we will inform you by publishing it to our website here: www.networknext.com/privacy
8. How to contact us
Please contact us if you have any questions about this privacy notice or the information we collect and store from you.
If you wish to contact us, please send an email to email@example.com, or mail us at our physical address at Network Next, 603 Arizona Ave., Santa Monica, CA 90401.