NETWORK NEXT, INC.
PRIVACY POLICY
Last Modified on May 9, 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 personal information, your rights in relation to your
personal information and on how to contact us and supervisory authorities in the event you have a
complaint.
We recommend that you review the entire Privacy Policy in order to be fully informed about our use of
personal information. However, we have divided this Privacy Policy into sections specifically applicable
to our Clients (Section 3) and our Users (Section 4). Sections 1 and 5 through 11 apply to everyone.
1. Who we are
Network Next, Inc. (“Network Next, “We”, or “Us”) collects, uses and is responsible for certain personal
information, as part of the Network Next service (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 a processor of that personal information for the purposes of those laws.
2. Important Definitions
In this Privacy Policy, the following terms have these definitions:
“Client” means a person or entity that has contracted with Network Next to provide services.
“User” means a person who uses a Client’s services, whose data we process on that Client’s
behalf. For example, if you play a Client’s game, your data will be shared by the Client and
processed by us for the purposes of optimizing game network traffic.
“You” or “your” means either a Client or a User, depending on the context.
3. For Clients
Information you provide to us: In the course of providing Clients with the Service, you provide us with
the following personal information:
Your Users’ IP address and the IP address of any server that you’ve connected the User to; the
User’s general geolocation data as inferred from their IP address (not from GPS or other
geolocation technology); User access times, including when and how long they are connected to
the server; your User’s ISP name; information about your Users’ experience with the Service,
including RTT, jitter, and packet loss statistics (collectively, Analytic Information”).
Your representative’s name and email address collected via a signup form on the Service (your
“Contact Information”).
Your User’s Xbox Live ID, PlayStation Network ID, Steam ID, or other account username, in an
encrypted form (your “Account Information”).
How we use that Personal Information: We use the personal information shared with us as follows:
Account Information is used to allow the Service to function, should the game or other
application using the Service require it.
Analytic Information is used to allow the Service to function, including routing data in the most
efficient way to enable your game or 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.
Contact Information is used to communicate with you about Service-related issues and provide
customer and technical support (including receiving and responding to communications that you
send us through the Service).
Who we share your Personal Information with: We share Personal Information with certain third
parties as part of our operation of the Service. This data sharing enables us to provide you with the
Service in the optimal way, 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 Personal Information with the following third parties:
Suppliers: We share Analytic Information with third party network suppliers in order to (i)
optimize network traffic by matching users with the fastest network and (ii) provide them with
analytic and performance information and trends. We may also share Account Information with
such suppliers in a non-readable, encrypted form for the purpose of coordinating with our Clients.
Website Analytics: We use Google Analytics on our website, which employs cookies to collect
certain Analytic Information to provide data concerning your use of the Service. You can find
their privacy policy here: Google Analytics Privacy Policy.
Newsletters: We may use your Contact Information to send you Service-related newsletters and
other communications about the Service, which requires us to share that Contact Information with
a service like Mailchimp. You can view their privacy policy here: Mailchimp Privacy Policy.
Other Sharing: We will share Personal 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 personal information with any other third party.
How long your Personal Information will be kept: We will keep Personal Information for the length of
time required to provide you with 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 personal data that we collect or that
you provide.
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 Personal Information: The laws in some jurisdictions require that
we notify you of the lawful basis for collecting Personal 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, such as signing up for our newsletter or contacting us for
technical support. This includes Contact Information and Account Information.
To fulfill our contractual obligations: In order to fulfill our contractual obligations to you and
our suppliers, we must collect, process, and store personal data and information. We must handle
personal data in this manner to provide the Service. This includes Contact Information, Account
Information, and Analytic Information.
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 you and our suppliers with 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. This
may include Contact Information, Account Information, and Analytic Information.
Legal compliance: We may collect, process, store, transfer or disclose personal data to comply
with our legal obligations. This includes Contact Information, Account Information, and Analytic
Information.
4. For Users
Information we collect automatically: When you play a Client’s game or use a Client’s application, we
will automatically collect the following information about you:
Your general geolocation data as inferred from your IP address (not from GPS or other
geolocation technology); 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 (your “Analytic Information”).
Information shared with us: Our Clients may share the following data with us:
Your Xbox Live ID, PlayStation Network ID, Steam ID, or other account username, in an
encrypted form (your “Account Information”).
Your IP address and the IP address of any server that you’ve connected to (your “IP
Information”).
How we use your Personal Information: We use your personal information as follows:
Your Account Information is used to allow the Service to function, should the Client’s game or
other application using the Service require it.
Your Analytic Information and IP 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 Personal Information with: We share your Personal Information with certain third
parties as part of our operation of the Service. This data sharing enables us to provide you with the
Service in the optimal way, 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 Personal Information with the following third parties:
Suppliers: We share Analytic Information with third party network suppliers in order to (i)
optimize network traffic by matching Users with the fastest network and (ii) provide them with
analytic and performance information and trends. We may also share Account Information with
such suppliers in a non-readable, encrypted form for the purpose of coordinating with the Client’s
game or application.
Clients: We share Analytic Information with our Clients in order to (i) optimize network traffic
by matching Users with the fastest network and (ii) provide Clients with analytic and
performance information and trends.
Other Sharing: We will share your personal 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 personal information with any other third party.
How long your Personal Information will be kept: We will keep your personal information for the
length of time required to provide you with 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 personal data that we
collect, that you provide, or that is shared with us.
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 Personal Information: The laws in some jurisdictions require that
we notify you of the lawful basis for collecting your Personal 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:
To fulfill our contractual obligations: In order to fulfill our contractual obligations to you and
our Clients and suppliers, we must collect, process, and store personal data and information. We
must handle your personal data in this manner to provide the Service. This includes the Account
Information, Analytic Information, and IP Information.
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 you and our Clients and suppliers with 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. This may include the Account Information, Analytic Information, and IP Information.
Legal compliance: We may collect, process, store, transfer or disclose your personal data to
comply with our legal obligations. This includes the Account Information, Analytic Information,
and IP Information.
5. Other Information About our Collection and Use of Personal Information
Depersonalized Information: We may make personal information shared with and collected by us non-
personally identifiable by either combining or aggregating it with information about other Users, or by
removing characteristics (such as your IP address) that make the information personally identifiable. This
process is known as anonymizing your information and is used to analyze usage and improve the Service,
as well as to provide analytic information to our Clients and suppliers and make other commercial uses of
such anonymized information.
Childrens Privacy: We do not knowingly collect any personal information from children under the age
of 13. In addition, we may limit how we collect, use, and store some of the information of EU users
between 13 and 16.
Cookies and other Technical Information: “Cookies” are small bits of electronic information that a
website sends to a visitor’s browser and are stored on the visitor’s hard drive. Like many websites, we
employ cookies in certain areas of the website to allow us to provide information to make your online
experience more convenient and to enhance your experience with the website. For example, if you are a
Client or supplier and you return to the website after logging in, cookies provide information so that the
website will remember who you are on subsequent visits, speeding up or enhancing your experience of
the website by, for instance, tailoring content to you.
Cookies are not spyware or adware, and can’t deliver viruses or run programs on your computer. You
may configure your web browsers to accept, reject, or delete cookies, or to notify you when a cookie is
being set. We may also use “pixel tags,” otherwise known as web beacons or clear gifs. These are tiny
graphics with a unique identifier, similar in function to cookies, and are used to track the online
movements of website users.
You can read more about our Cookie Policy here.
“Do Not Track” Signals: We respond to web browser-based do-not-track signals, which can disable
Google Analytics tracking when enabled.
6. 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).
7. Your Rights
Under the GDPR, EU residents have several important rights free of charge. In summary, those include
the rights to:
Fair processing of information and transparency over how we use your use personal information
Access to your personal information
Require us to correct any mistakes in your information which we hold
Require the erasure of personal information concerning you in certain situations
Receive the personal information concerning you which you have provided to us, in a structured,
commonly used and machine-readable format and have the right to transmit those data to a third
party in certain situations
Object at any time to processing of personal information concerning you for direct marketing
Object to decisions being taken by automated means which produce legal effects concerning you
or similarly significantly affect you
Object in certain other situations to our continued processing of your personal information, or
otherwise restrict our processing of your personal information in certain circumstances
If you would like to exercise any of those rights, please:
Email us at suppor[email protected]next.com
Give us enough information to identify you, including your username, name, and date of birth
Show us proof of your identity (a copy of your driving license or passport, for example)
Let us know the information to which your request relates
If you would like to unsubscribe from any email newsletter, you can also click on the unsubscribe button
or link at the bottom of each email newsletter.
8. Keeping your Personal 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.
For example:
We limit access to personal information to those who have a genuine business need to know it.
Those processing such 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.
9. How to complain
We hope that we can resolve any questions or concern you raise about our use of your Personal
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.
10. Changes to this Privacy Policy
This privacy policy was first published on November 7, 2018 and last updated on May 9, 2019
We may change this privacy policy from time to time. When we do, we will inform you via email to the
email address you have provided us with through your account, or by sending a message to your account
on the Service.
11. 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 suppo[email protected]next.com, or mail us at our physical
address at ___________________________________________________________________________.