Nurl Privacy Policy
Effective: August 29, 2023
Last Updated: August 29, 2023
- Information you provide to us
- Information we collect automatically
- Information we collect from third parties
- How we use information about you
- How we disclose information about you
- Data retention
- How we protect your information
- How we control your privacy
- International data transfers
- Services provided by others
- Data Protection Officer
- Information for Users in the EEA, United Kingdom, Switzerland, and Brazil
- Information for Users in Certain U.S. States
- Changes to this Privacy Policy
- Contact us
Welcome
This Privacy Policy explains how we collect, use, store, protect, and share your personal information through our services. If you reside in the European Economic Area (“EEA”) or United Kingdom, Nurl Netherlands BV is the “data controller” of your personal information collected through the services (as defined in our Terms of Service). For everyone else, Nurl, Inc. is the data controller. It’s important that you read this entire policy, but here’s a summary to get you started:
We care a lot about privacy. We are committed to creating spaces where people can come together and find a place to belong. Respecting user privacy is a key part of that mission.
We don’t sell your personal information. Our business is based on subscriptions and paid products, not from selling your personal information to third parties.
We limit what information is required. We require the information that enables us to create your account, provide and maintain our services, meet our commitments to our users, and satisfy our legal requirements. The rest is optional.
We care deeply about safety. Our dedicated Trust & Safety team works hard to help keep our community safe. We also use certain information to help us identify violations of our Community Guidelines and prevent harmful content from being distributed through the services.
We give you control. We give you the ability to control your privacy on Nurl.
We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.
Nurl is your place to play role-playing games
We created Nurl to be a platform that brings people together over shared experiences and gives everyone a place to belong. Whether you’re part of a club, gaming group, or just a handful of friends that want to spend time together, Nurl makes it easy to express yourself and find community.
Our “services” has the same meaning as defined in the Terms of Service. They include the Nurl app, which can be accessed on web, console, or even a connected home appliance—any device with a web browser and internet connection. We also have a website, blog, and support center, and we may collect your information through other means like surveys, emails, and social media. If we build another product, our services include that too.
As explained in our Terms of Service, we allow users to add content to the services in a number of different ways, including via direct messages and in smaller and larger spaces. If you share content within larger spaces, that content may be accessed by many people, including people you do not know. For example, some groups are available in the Group Discovery section of the app and do not require an invite link to join. Other group owners may publish their group invite link on public websites. Anyone can access these groups, and you should be aware that group owners or admins set these permissions, and like the size of a group, the permissions may change over time.
We may also use content posted in larger spaces, to help us improve and power features like Highlights Notifications, identify harmful content on the services, and enforce our Terms of Service and Community Guidelines. These things are important to us, and we believe they will make Nurl even better for our users. We will always try to let you know the type of space you are in (although we don’t control where invite links are shared or the permissions for that group). You can limit the extent to which your content is used for these purposes as described in the “How to control your privacy” section below. You should take all of this into account when you are using our services, and choose the spaces, features, and settings that are most appropriate for your content.
We make money from paid subscriptions and the sale of digital (and sometimes physical) goods, not from selling your personal information to third parties.
The information we collect
We collect certain information when you use Nurl. This includes information you provide to us, information we collect automatically, and information we receive from other sources.
Information you provide to us
Account information. When you create a Nurl account, you can come up with a username, and provide a way of contacting you (such as an email address and/or phone number). You’ll also need to provide your birthday. In some cases, you may be required to verify your account or provide additional information (like a verified phone number) to your account. You may also have the option to add your name or nicknames.
Content you create. This includes any content that you upload to the service. For example, you may write messages or posts (including drafts), send voice messages, create custom emojis, create short recordings of GoLive activity, or upload and share files through the services. This also includes your profile information and the information you provide when you create groups. We generally do not store the contents of video or voice calls or channels. If we were to change that in the future (for example, to facilitate content moderation), we would disclose that to you in advance. We also don’t store streaming content when you share your screen, but we do retain the thumbnail cover image for the stream for a short period of time. We may build features that help users engage with voice and video content, like create or send short recordings.
Payment information. If you buy any paid services through Nurl, you may need to submit a valid payment method and associated billing information, including your full name and billing address. Our payment processors, like Stripe and PayPal, receive and process your payment information. Depending on the processor, we may also receive and store certain billing information, including the last four digits of the credit card number associated with the transaction. If you sell something through Nurl, you may be required to provide additional information to our payment processors, such as bank account information to facilitate payments and copies of government issued identification required to identify users in accordance with regulatory obligations. If we decide to process our own payments in the future, we would receive and process this information ourselves.
Information from actions you take. We collect information about your use of Nurl and your activities on the services. This includes the friends you add, the users, bots, and apps you engage with, the games you play on your device, the groups or other communities you join and participate in, your roles in groups, content moderation decisions you make, information about purchases or sales you make on or through Nurl including what you purchased or sold, and other related actions. You can control whether we collect, use, and display this information as described in the “How to control your privacy” section below.
Information used to enable optional features. Certain features, like contact syncing, may require that you provide additional information (or grant us access to such information) to make them work. This also includes third-party integrations you choose to enable and the data you authorize those third-party services to share with us. For example, when you link a music streaming account, we may collect information about that account such as the song you are listening to in order to display that information on your profile or as your status (if you have chosen to do so).
Other information you provide directly to us. You may have the option to submit additional information as you use Nurl. For example, you may choose to participate in our verified group program, which requires that you provide additional information about yourself or your company. Or, you may participate in surveys where you can provide feedback on the services, or submit information to our Nurl Support teams.
Information we collect automatically
We also collect information automatically from you when you use Nurl. This includes:
Information about your device. We collect information about the device you are using to access the services. For example, this includes information like your IP address, operating system information, browser information, and information about your device settings, such as your microphone and/or camera.
Information about your use of the websites. For example, we collect log and event information related to how and when you use our services (such as the pages, groups, and channels you visit, the activities you engage in, or the embedded content you interact with).
Other information that we collect automatically. When you take certain actions on other sites, we may receive information about you. For example, when we advertise for Nurl on third party platforms, if you click on the ad, we may receive information about which ad you saw and on which platform. Similarly, we may also receive certain information when you click on a referral link, such as which website you came from.
We may receive information from cookies (small text files placed on your computer or device) and similar technologies. First-party cookies are placed by us (and our third-party service providers) and allow you to use the services and to help us analyze and improve your experience and the services. You can control cookies as described in the “How to control your privacy” section below. The services use the following types of cookies:
Strictly Necessary Cookies: These are required for services to function and to meet our legal obligations. If you try to use tools to disable these cookies, parts of the services may not work properly.
Functional Cookies: These help us provide enhanced functionality on the services like remembering language preferences. Disabling these could affect some service functionality.
Performance Cookies: These allow us or our third-party analytics providers to learn how you and others use and engage with the services so we can understand and improve them.
Information we collect from third parties
We may receive information about you from other sources, including from other users and third parties, and combine that information with the other information we have about you. For example, if you interact with our social media account on another platform, we may receive certain information about you like your username on that platform.
How we use information about you
We use your information for the following purposes:
To fulfill our contract with you
To provide you with the services. We use your information to provide you with the Nurl services. For example, when you start a video call, we process your images and audio to make that work. We similarly collect and store the messages you send and display them as you direct. We also use the information you provide to us to create and manage your account and to facilitate purchases. When you enable optional features (like connecting your Nurl account to other platforms), we use information from those services to power the feature (like displaying what song you are listening to on another service within the Nurl app).
To meet our commitments to the Nurl community. We work hard to try to make Nurl a safe, positive, and inclusive place. To do so, we use your information to monitor for and take action against users and content that violate our Terms of Service, Community Guidelines, and other policies. This includes responding to user reports, generating transcriptions of content as part of our investigation, detecting fraud and malware, and proactively scanning attachments and other content for illegal or harmful content. We also use certain information, which may include content reported to us, content that violates the Terms, and certain other content widely available on the service (such as public posts, usernames, avatars, banners, user profiles, group names, group icons, and group banners), to create systems and models that can be automated to more swiftly detect, categorize, and take action against prohibited content or conduct.
To contact you. We use your information to contact you in connection with your account, such as to verify or secure it with two-factor authentication. We may also use your information to contact you about important product or policy changes and to send you information about products you have purchased.
To provide customer service. We use your information to respond to your questions about our products and services, and to investigate bugs or other issues.
For our legitimate interests
To protect our services. We use information to keep our services secure, to prevent misuse, and to enforce our Terms of Service and other policies against users who violate them.
To report on our company’s performance. We use your information to track the fundamental metrics of our business, to perform financial reporting, to respond to regulatory obligations, and to debug billing issues.
To personalize the product. We use your information to personalize our services. This information powers our discovery surfaces (so that you see relevant communities or content first), Highlights Notifications, and similar features, and it helps us surface Nurl features and promotions from us and our partners that may be of interest to you. As discussed in the “How to control your privacy” section below, you can choose to what extent we will use your personal information to personalize your Nurl experience.
To improve our services. We use your information to help us understand how users interact with our services, what features or products users may want, or to otherwise understand and improve our services. This includes information about how you use our services and how groups are structured. We may also use certain content that is widely available to better understand, for example, what topics groups cover and what content is most interesting within those groups. Similarly, you can limit to what extent we use your personal information for these purposes.
To advertise our services on Nurl and other platforms. We are proud of the product we've built. We may tell you about our paid services and other features directly in the services and through our own channels, and we spend money advertising Nurl on other platforms. As part of that, we use certain information to assist in the delivery of our advertising, to measure the effectiveness of advertisements for our own products, and to improve such advertisements in the future.
To contact you. We may use your information to let you know about new products or features we think you’ll like. You may opt-out of receiving such marketing communications. Where local law requires, we will obtain your consent before sending such communications.
To comply with our legal obligations
We retain and use your information in connection with potential legal claims when necessary and for compliance, regulatory, and auditing purposes. For example, we retain information where we are required by law or if we are compelled to do so by a court order or regulatory body. Also, when you exercise any of your applicable legal rights to access, amend, or delete your personal information, we may request additional information from you for the purpose of confirming your identity.
With your consent
We may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us at privacy@nurl.app. For example, we may ask for your consent to collect your precise location or to collect your voice data to improve our voice recognition technology.
To protect someone’s vital interests
We may collect or share personal data if we think someone’s life is in danger—for example, to help resolve an urgent medical situation.
How we disclose information about you
When you tell us to. When you add your content to the services, you are telling us to make that content available to certain people or communities. Who can access that information is determined by who can access a particular space. For groups, those permissions are set by group owners or admins. They control whether a group requires an invite link or is open and accessible to anyone. And these permissions, like the size of the group, may change over time. Similarly, if you link your Nurl account with a third-party service (like a music-streaming service or gaming platform), embed content, or participate in a group that has third-party features like bots enabled, we may provide certain information to that service or to other Nurl users to operate that service or feature. Additionally, if you purchase goods or services from other users on Nurl, we may disclose certain information to these users in order to facilitate the delivery of the goods or services purchased or help them understand and improve their business. We may also disclose your information as you otherwise instruct us or provide us your consent to do so.
With our vendors. We may provide information to vendors we hire to carry out specific work for us. This includes payment processors like Stripe and PayPal that process transactions on our behalf and cloud providers like Netlify that host our data and our services. We may also provide limited information to advertising platforms to help us reach people that we think will like our products and to measure the performance of our ads shown on those platforms. We do this to help bring more users to Nurl and make our business successful, and provide only the information required to facilitate these services. This may include information like the fact that you registered to use Nurl.
To comply with the law. We may disclose information in response to a request for information if we believe disclosure is required by law, including meeting national security or law enforcement requirements. Where allowed and feasible, we will attempt to provide you with prior notice before disclosing your information in response to such a request. Our Transparency Report has additional information about how we respond to requests from governments and law enforcement entities.
In an emergency. We may disclose information if we believe in good faith that it's necessary to prevent serious harm to a person.
To enforce our policies and rights. We may disclose information if needed to enforce our Terms of Service, Community Guidelines, or other policies, or to protect the rights, property, and safety of ourselves and others.
With our related companies. We may provide information to our related companies, including parents, affiliates, subsidiaries, and other companies under common control and ownership.
Sale, Acquisition, or Transfer of Assets. We may disclose information if Nurl is evaluating and/or engaging in a merger, acquisition, reorganization, bankruptcy, or sale, transfer, or change in ownership of Nurl or any of its assets.
Aggregated or de-identified information. We may disclose information that has been aggregated or anonymized such that it cannot reasonably be used to identify you. For example, we may share aggregated user statistics in order to describe our business to partners or the public.
Data retention
We retain personal information until we determine it is no longer needed for the processing purposes for which we collected or retain it or for legal compliance. You can learn more about data retention periods in our data retention policy.
How we protect your information
We take a number of steps to help protect your information. All information sent within our services is encrypted both in transit and at rest. For example, we use Transport Layer Security (“TLS”) to encrypt text and images in transit. We also enforce technical and administrative access controls to limit which of our employees and contractors have access to nonpublic personal information. You can help maintain the security of your account by configuring two-factor authentication.
How to control your privacy
We believe that users should be able to tailor their Nurl experience to their preferences, including privacy. And while local laws may require different things, we believe that our users should have at least the same basic ability to shape their experience no matter where they are in the world. Here’s how you can control how we process your information, how to delete or correct certain information, and how to request access to your information. Users in certain places may have specific rights under their local laws. You can learn more about these in the relevant sections below.
Be aware of the Nurl spaces you choose to participate in
You can choose what communities to participate in and what information you add to our services. You can choose what messages to send or post, who to engage with (e.g., one or more particular users or a potentially unlimited group of users), what information to include in your profile, whether to connect any third party services to your Nurl account, and more. For example, if you share content in certain spaces, such as groups listed in Group Discovery or with public invite links, your content may be accessed by anyone.
Customize your personal Nurl settings
We offer a number of settings that allow you to tailor your experience within Nurl. Some of these relate to specific features: for example, you can choose whether to display your current activity (like the game you are playing or the music you are listening to) in your status in your User Settings page (this is the gear icon next to your username).
You can also access other privacy-specific settings in your User Settings. For example, you can decide which types of direct messages are scanned for explicit content, who can add you as a friend, and more. This is also where you can limit certain types of processing of your information:
Limit our ability to use your data to improve our services. We offer certain settings that allow you to limit the information we collect to help us understand how users use our services, what features or products they may want, or to otherwise help us improve our business. If you turn off these settings, we will stop collecting and using certain event and log information as described in these settings.
Limit our ability to personalize Nurl for you. We offer certain settings that control whether and how we may personalize Nurl for you, such as offering you relevant recommendations for in-app content and features. If these settings are disabled, we will stop collecting and using certain event and log information as described in these settings.
You can learn more about these settings in our Help Center.
Disable or delete your account
You can disable or delete your account via the User Settings menu. Disabling your account stops the processing of new data, but allows you to reactivate your account without interruption to you. Deleting your account permanently deletes identifying information and anonymizes other data as described in our data retention policy. You can learn more about how to delete your account by visiting our Help Center.
Manage your content and groups
You may edit or delete specific pieces of information within the services:
You can edit or delete any message you have sent or content you have posted if you still have access to the space where you posted it.
You can edit or delete a Nurl group if you have the permissions needed to do so.
You can edit or delete a player or app from a Nurl group if you have the permissions needed to do so.
Content may be retained by Nurl for use as described elsewhere in this policy and in our data retention policy. Also, in limited circumstances, we may have a legal obligation to retain certain information, even if you delete the information or your account.
Access your information
If you want to see what information we have collected about you, you can request a copy of your data in the Privacy & Safety section of your User Settings. You should receive your data packet within 30 days. Data is delivered in common digital formats including CSV, JSON, and any other file format you used when uploading attachments to the services. You can learn more about how to access your information in our Help Center.
Manage cookies
To control how information is collected and used from cookies on the services, you can take one or more of the following steps.
You can disable and manage some cookies through your browser settings. You will need to manage your settings for each browser you use. You can find instructions for how to manage Cookies in popular browsers such as Internet Explorer, Firefox, Chrome, Safari (iOS), Safari (Mac), and Opera.
To disable analytics cookies, you can use the browser controls discussed above or, for certain providers, you can use their individual opt-out mechanisms, such as Google Analytics Opt-Out.
Your mobile device may also include browser settings to manage the use of cookies. Your device may also have settings to control the collection and use of information in your apps.
Third party groups also enable you to limit how cookies are used for advertising purposes by participating third parties. You can learn more at Network Advertising Initiative, the Digital Advertising Alliance, and for users in the EU, the European Interactive Digital Advertising Alliance.
Depending on where you are accessing our services, you may be able to adjust your cookie preferences at any time through a cookies banner or by selecting “Cookie Settings” from the footer or menu on our website.
If you disable or remove cookies, some parts of the services may not function properly. Information may be collected to remember your opt-out preferences.
Questions or concerns about your privacy? You can email us at privacy@nurl.app.
International data transfers
We are based in the United States, and we process and store information on servers located in the United States. We may also store information on servers and equipment in other countries depending on a variety of factors, including the locations of our users and service providers. These data transfers allow us to provide our services to you. By accessing or using our services or otherwise providing information to us, you understand that your information will be processed, transferred, and stored in the U.S. and other countries, where different data protection standards may apply and/or you may not have the same rights as you do under local law.
When transferring data outside the EEA, we use standard contract clauses (Module 1 and Module 2), and we rely on the European Commission's adequacy decisions about certain countries, as applicable, or other legally compliant mechanisms or conditions for such data transfer.
We also adhere to the EU-U.S. and Swiss-U.S. Privacy Shield Program and comply with its framework and principles. Although the EU-U.S. Privacy Shield Program is no longer a valid basis for certain international data transfers, we continue to comply with the Privacy Shield framework and principles with respect to personal data received from the EU in addition to all other applicable laws.
If you have questions or complaints regarding our compliance with the Privacy Shield principles, please reach out to us at privacy@nurl.app. If we do not resolve your complaint, you may submit your complaint free of charge to JAMS. Under certain conditions specified by the Privacy Shield principles, you may also be able to invoke binding arbitration to resolve your complaint. We are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. In certain circumstances, we may be liable for the transfer of personal data from the EU, Switzerland, or the UK to a third party outside those countries.
For more information about the Privacy Shield principles and to view our certification, please visit the U.S. Department of Commerce’s Privacy Shield site.
Services provided by others
We allow third party developers to build certain features or other services and offer them within the Nurl services. For example, group administrators can add “bots” created by third party developers that provide features like content moderation and interactive games. Similarly, you may have access to games or activities built by third parties within the services.
These third-party services need to follow all policies that apply to them (including often our Developer Terms of Service and Developer Policy). As part of these policies, we require developers to have a privacy policy that makes clear what they do with your information. Please review these privacy policies, as they describe what bots and apps may do with your information. We also require that certain popular bots apply for access to certain data. But because these services are operated by third parties, we don’t control them or what information they collect. It’s up to you whether to participate in a group that uses bots, and whether to engage with third-party services in general.
Data Protection Officer
You can contact Nurl Netherlands BV’s Data Protection Officer at dpo@nurl.app.
We’ve appointed VeraSafe as Discord’s representative in the United Kingdom for data protection matters, pursuant to Article 27 of the UK General Data Protection Regulation. See the section “Contact Us” below. You can contact VeraSafe only on matters related to the processing of personal data.
Information for Users in the EEA, United Kingdom, Switzerland, and Brazil
Certain local laws, such as the European Union’s General Data Protection Regulation (GDPR) and Brazil’s Lei Geral de Proteção de Dados (LGPD), require services to provide information about the information they collect, how they use it, and the lawful basis for processing it. We’ve described most of that already in the earlier portions of this Policy.
Exercising your rights: As described in the “How to control your privacy” section above, all our users have control over their information and can directly edit or delete information from their account and limit what data we process. If you are located in certain regions, including the European Union, you may have additional rights that you can exercise through the Nurl app directly or by contacting us:
Right of access to your personal data
Right to rectify your personal data if they are incorrect
Right to erase your personal data
Right to limit the processing of your personal data
Right to the portability of your personal data
Right to object to the processing of your personal data
Right to withdraw consent. Withdrawing consent does not affect the lawfulness of processing based on consent before withdrawal.
If you have any questions about these rights or wish to exercise control over your information, please reach out to privacy@nurl.app.
Information for Users in Certain U.S. States
Exercising your rights: As described in the “How to control your privacy” section above, all our users have control over their information and can directly edit or delete information from their account and limit what data we process. If you are a resident of California, Colorado, Connecticut, Utah, or Virginia, you may have additional rights that you (or, in certain states, an authorized agent acting on your behalf) can exercise through the Nurl app directly (as described above) or by contacting us, including the right to:
More information about the categories and specific pieces of personal information we have collected and disclosed for a business purpose in the last 12 months
Access and/or receive a copy of certain personal information we hold about you
Correct certain of your personal information
Delete certain personal information we hold you
Receive information about the financial incentives that we offer to you, if any
Opt out of the processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable
You also have the right to not be discriminated against for exercising your rights. You may also have the right to opt out of “sales” of your information and “sharing/processing of your information for targeted advertising.” We do not sell the personal data of our users or share personal data for targeted advertising purposes.
Certain information may be exempt from the requests above under applicable law. For example, we need to retain certain information in order to provide our services to you. We also need to take reasonable steps to verify your identity before responding to a request. If you are an authorized agent submitting a request on a user’s behalf (where permitted), we may require proof of your written authorization before processing the request. Depending on applicable law, you may have the right to appeal our decision to deny your request.
If you have any questions about these rights, wish to exercise them, or request an appeal, please reach out to us at privacy@nurl.app.
Additional Information for Users in California
In addition to the rights described above, consumers residing in California are afforded the right to certain additional information with respect to their personal information under the California Consumer Privacy Act or (“CCPA”). If you are a California resident, this section applies to you.
Our collection and use of personal information: We collect the following categories of personal information: identifiers (such as your username, the email address you used to sign up, and your phone number if you’ve chosen to provide it); commercial information (a record of what you’ve bought from Nurl, if anything); financial data (payment information and your history of purchases from Nurl); internet or other network information (how you interact with the application); location information (because your IP address may indicate your general location); inference data about you (for example, what content you may be interested in); and other information that identifies or can be reasonably associated with you. For more information about what we collect and the sources of such collection, please see the “The information we collect” section above. To the extent we collect or use sensitive personal information as defined by law (such as the CCPA), we do so in accordance with applicable legal requirements, and we do not use or disclose it other than for purposes for which there is not a right to limit under the CCPA.
We collect personal information for the business and commercial purposes described in “How we use your information” above.
Disclosure of personal information: We may share your personal information with third parties as described in the “How we disclose your information” section above. We disclose the categories of personal information mentioned above for business or commercial purposes.
No sale or “share” of personal information: The CCPA sets forth certain obligations for businesses that sell or “share” personal information. We do not sell or share the personal information of our users as defined in the CCPA. We do disclose certain information as outlined in the “How we disclose your information” section above and you can make choices with respect to your information as outlined in this policy.
We retain personal information as described in the “Data retention” section above and in our data retention policy.
Requests received: please see this page for information on the number of data requests we have received.
California’s “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties, as defined under applicable law, for their direct marketing purposes. We do not share your personal information with third-parties for their own direct marketing purposes.
Changes to this Privacy Policy
We will update this Privacy Policy from time to time. We always indicate the date the last changes were published, and if changes are significant, we’ll provide a more prominent notice as required by law, such as by emailing you or highlighting the changes within the services.
Contact Us
Email us at privacy@nurl.app with any questions about this Privacy Policy or how we process your information. We’ll be happy to help.