Nicolas Guillaume Handheld Software (“NGHS”), its parent and its subsidiaries respect the privacy rights of our users and are committed to protecting the information collected through its online products, online services, applications, mobile applications, and websites (together “Services”). NGHS has adopted this privacy policy (“Privacy Policy”) to explain how NGHS collects, stores, and uses the information collected in connection with NGHS’s Services.

Should you have any questions relating to this Privacy Policy, please contact us at ng(at)

BY INSTALLING, USING, REGISTERING TO OR OTHERWISE ACCESSING THE SERVICES, YOU AGREE TO THIS PRIVACY POLICY AND GIVE AN EXPLICIT AND INFORMED CONSENT TO THE PROCESSING, USE AND DISCLOSURE OF YOUR PERSONAL DATA IN ACCORDANCE WITH THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT INSTALL, USE, REGISTER TO OR OTHERWISE ACCESS THE SERVICES. NGHS reserves the right to modify this Privacy Policy at reasonable times, so please review it frequently. If NGHS makes material or significant changes to this Privacy Policy, NGHS may post a notice on NGHS’s website along with the updated Privacy Policy. Your continued use of Services will signify your acceptance of the changes to this Privacy Policy.

Non-personal data

For purposes of this Privacy Policy, “non-personal data” means information that does not directly identify you. Additionally, non-personal data means “aggregate” and “de-personalized” information, which is data NGHS collects about the use of NGHS Services, from which any personally identifiable data has been removed.

NGHS may use tools or third party analytical software to automatically collect and use certain non-personal data that does not directly enable NGHS to identify you. The types of non-personal data NGHS may collect and use include, but are not limited to: (i) device properties, including, but not limited to IP address and unique device identifier or other device identifier ("UDID"); (ii) platform version, software version and language; (iii) game progress and score; (iv) other non-personal data as reasonably required by NGHS to enhance the Services and other NGHS products and services.

NGHS may use and disclose to NGHS’s partners and contractors the collected non-personal data for purposes of analyzing usage of the Services, advertisement serving, managing and providing the Services and to further develop the Services and other NGHS services and products.

You recognize and agree that the analytics companies utilized by NGHS may combine the information collected with other information they have independently collected from other services or products relating to your activities. These companies collect and use information under their own privacy policies.

Ad Serving Technology

NGHS reserves the right to use and disclose the collected non-personal data for purposes of advertisement by NGHS or NGHS’s partners and contractors. NGHS may employ third party ad serving technologies that use certain methods to collect information as a result of ad serving through Services. NGHS or third parties operating the ad serving technology may use demographic and location information as well as information logged from your hardware or device to ensure that appropriate advertising is presented within the Service. NGHS or third parties may collect and use data for this purpose including, but not limited to IP address (including for purposes of determining your coarse location), UDID, MAC, software, applications, hardware, browser information, internet and on-line usage information and in-app information. The foregoing data may be used and disclosed in accordance with this Privacy Policy and the privacy policy of the company providing the ad serving technology.

You recognize and agree that the advertising companies who deliver ads for NGHS may combine the information collected with other information they have independently collected from other services or products. These companies collect and use information under their own privacy policies. These ad serving technologies are integrated into Services; if you do not want to be subject to this technology, do not use or access Services. Although NGHS takes commercially reasonable steps to instruct such advertising companies to comply with the terms and conditions of this Privacy Policy, NGHS does not have access to or control of third party technologies.

Personal Data

For purposes of this Privacy Policy, “personal data” means personally identifiable information that specifically identifies you as an individual.

Likely situations when you make personal data available to NGHS include, but are not limited to: (i) registration for Services; (ii) accessing Services using a third party ID, such as social networking sites or gaming services; (iii) subscribing to newsletters; (iv) requesting technical support; and (v) otherwise through use of NGHS Services where personal data is required for use and/or participation.

The types of personal data may vary depending on the type of activity you are engaged in. The personal data NGHS may collect, process and use may include, but are not limited to your name, language, screen/nick name, NGHS Services or third party service ID and e-mail address.

NGHS may use collected personal data for purposes of analyzing usage of the Services, providing customer and technical support, managing and providing Services (including managing advertisement serving) and to further develop the Services and other NGHS services and products. NGHS may combine non-personal data with personal data.

NGHS may use your personal data to send messages or notifications to you with informative and/or commercial content about NGHS’s services or third party products and services NGHS thinks may be of interest to you, such as new features and services, special offers and updated information.

Disclosure and Transfer of Personal Data

NGHS collects and processes personal data on a voluntary basis and it is not in the business of selling your personal data to third parties. Personal data may, however, occasionally be disclosed in accordance with applicable legislation and this Privacy Policy. Additionally, NGHS may disclose personal data to its parent companies and its subsidiaries in accordance with this Privacy Policy.

NGHS may disclose your personal data to third parties as required by law enforcement or other government officials in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose you or NGHS to legal liability. NGHS may also disclose your personal data to third parties when NGHS has a reason to believe that a disclosure is necessary to address potential or actual injury or interference with NGHS’s rights, property, operations, users or others who may be harmed or may suffer loss or damage, or NGHS believes that such disclosure is necessary to protect NGHS’s rights, combat fraud and/or comply with a judicial proceeding, court order, or legal process served on NGHS. To the extent permitted by applicable law, NGHS will make reasonable efforts to notify you of such disclosure through NGHS’s website or in another reasonable manner.

Data Retention and Correctness

NGHS retains the data collected pursuant to this Privacy Policy for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Thereafter if the collected data is no longer needed for purposes specified in this Privacy Policy, NGHS deletes all aforementioned data in its possession within a reasonable timeframe. NGHS does not verify the correctness of personal data.

NGHS may still retain some of the data to the extent such retention is necessary to resolve disputes, enforce NGHS user agreements, and comply with technical and legal requirements and constraints related to the security, integrity and operation of Services.

In compliance with the French Data Protection Act of 6 January 1978, as amended by the Act of 6 August 2004 on the processing of personal data and the protection of individuals, the user has a right to access, modify, rectify or delete any data concerning him, by contacting NGHS.


The Services may use “cookies” and other similar technologies. NGHS treats information collected by cookies and similar technologies as non-personal data.

Cookies: A “cookie” is a small bit of record-keeping information that websites often store on a user's computer. NGHS’s cookies do not include personal data and are typically used to quickly identify your device and to “remember” you. You can disable cookies or set your browser to alert you when cookies are being sent to your device; however, disabling cookies may affect your ability to use the Services.


NGHS follows generally accepted industry standards and maintains reasonable safeguards to attempt to ensure the security, integrity and privacy of the information in NGHS’s possession. Only those persons with a need to process your personal data in connection with the fulfillment of their tasks in accordance with the purposes of this Privacy Policy and for the purposes of performing technical maintenance, have access to your personal data in NGHS’s possession. Personal data collected by NGHS is stored in secure operating environments that are not available to the public. To prevent unauthorized on-line access to personal data, NGHS maintains personal data behind a firewall-protected server. However, no system can be 100% secure and there is the possibility that despite NGHS’s reasonable efforts, there could be unauthorized access to your personal data. By using the Services, you assume this risk.


NGHS regularly reviews its compliance with this Privacy Policy. If NGHS receives a formal written complaint from you, it is NGHS’s policy to attempt to contact you directly to address any of your concerns. NGHS will cooperate with the appropriate governmental authorities, including data protection authorities, to resolve any complaints regarding the collection, use, transfer or disclosure of personal data that cannot be amicably resolved between you and NGHS. TO THE EXTENT YOU AND NGHS ARE NOT ABLE TO AMICABLY RESOLVE ANY DISPUTE THAT MAY ARISE, YOU AGREE THAT YOU MAY BRING CLAIMS AGAINST NGHS ONLY IN YOUR INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE PROCEEDING.