Second Dinner
Privacy Notice for Marvel Snap
Date of update: June 2, 2025
This privacy notice (the “Privacy Notice”) is designed to provide users (“you”) of Marvel Snap (the “Game”) with clear information relating to how Second Dinner Studios, Inc., (“Second Dinner” or “we”, “us” or “our”), processes your Personal Information (as defined below) for our own purposes. From a general perspective, Second Dinner is committed to protecting your privacy.
In this Privacy Notice, you will find the following information:
Second Dinner is a Delaware (US) corporation, with its principal place of business at 1920 Main Street, Suite 880, Irvine, CA 92614, USA.
The identity and contact details of our European Economic Area (EEA) and United Kingdom (UK) representatives are specified at the end of this Privacy Notice.
“Personal Information” generally means any information that is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, back to you or your device, including personal identifiers, such as your name, email address, physical address, phone number, IP address, or device identifier, subject to definitions and exceptions under applicable law. Personal Information includes information that you provide to us, that we collect automatically, and that we obtain from third parties.
We collect and process the Personal Information detailed below from you, from third parties (e.g., our third-party partners) and/or automatically when you use the Game:
Chat data (e.g., the content of the chat message you send or receive through the Game’s chat services feature, Account ID assigned to you while using the chat).
We use your Personal Information only for the purposes outlined below:
Surveys, challenges or competitions: We process your Personal Information to manage and complete your participation in surveys, challenges and competitions, including delivering prizes to you;
For the purposes referred to under this Privacy Notice, we may share certain Personal Information with certain recipients. Such recipients will either act as another independent controller or as processor acting on behalf and upon our instructions.
We may share your Personal Information with our third-party services providers, acting as data processors, as listed below:
Name of the service provider | Processing activity |
Amazon Web Services, Inc. (AWS), United States 410 Terry Avenue North, Seattle, WA 98109-5210, ATTN: AWS Legal | Data storage |
Databricks, Inc., United States (privacy@databricks.com) | Data analytics |
Braze, Inc., United States (privacy@braze.com) | Customer relationship management |
Stream.io, United States (legal@getstream.io) | Hosting of the in-Game chat services feature and storage of the related data |
Helpshift, United States 520 E. Vine Street #587 Keller, TX 76244 1-800-245-9165 | Customer Support Service |
In addition, we may communicate your Personal Information to independent controllers, i.e.:
We do not sell your Personal Information to third parties.
If you are in the EEA or UK, please refer to this section in relation to the processing of your Personal Information.
What Personal Information do we collect, for which purposes do we use it and what are our legal basis?
We use your Personal Information for the purposes and under the legal basis described in the table below:
In which context is your personal data collected? | What Personal Information do we collect about you? | Why do we use your Personal Information? | What is our legal basis for processing your Personal Information? |
When you register an account with us | You may provide us with your:
|
| Performance of our contract with you or to take precontractual steps at your request. |
| Our legitimate interests which consist of marketing our own products and services similar to the Game, unless you opt-out from such marketing communications by contacting us using the details provided at the end of this Privacy Notice. | ||
| Your consent that you may withdraw at any time by contacting us using the details provided at the end of this Privacy Notice. | ||
| Legal obligations to which we are subject (e.g. detect abuse, fraud and illegal activity) and our Legitimate Interests which consist of complying with non-EEA or non-UK laws, as relevant, responding to requests from, and other communications with, competent public, governmental, judicial, or other regulatory authorities and responding to valid legal process, investigating, or participating in civil discovery, litigation, or other legal proceedings and protecting or defending your rights, property or security or ours, including by investigating potential violations of or enforcing our terms of use.
| ||
When logging in, signing up, or linking to the Game via third party accounts such as Meta, Apple or Google | You may provide us with your:
| Same purposes as those described above | Same legal basis as those described above |
When using the Game and its features | You may provide us with your:
We may also automatically collect the following Personal Information about you:
|
| The performance of our contract with you or to take precontractual steps at your request. |
| Legal obligations to which we are subject (e.g. detect abuse, fraud and illegal activity) and our Legitimate Interests which consist of complying with non-EEA or non-UK laws, as relevant, responding to requests from, and other communications with, competent public, governmental, judicial, or other regulatory authorities and responding to valid legal process, investigating, or participating in civil discovery, litigation, or other legal proceedings and protecting or defending your rights, property or security or ours, including by investigating potential violations of or enforcing our terms of use. | ||
We may also automatically collect via cookies and similar technology Personal Information about you, including IP address, cookie ID and settings. |
| Depending on the purpose of the cookie, our legitimate interests which consist of providing the Game and ensuring the security of the Game or, for non-essential cookies, your consent that you may withdraw at any time by contacting us using the details provided at the end of this Privacy Notice. | |
When choosing to enter surveys, challenges, competitions, and reward programs with us | You may provide us with your:
|
| The performance of our contract with you or to take precontractual steps at your request. |
When using in-Game chat services feature | You may provide us with:
Please note that your chat messages are personal, and we will not be able to access or read them. Chat data are stored by our third-party partner (Stream.io) for no more than 24 hours. |
| The performance of our contract with you or to take precontractual steps at your request. |
We will collect indirectly from our third-party partner providing the chat services feature (the company Stream.io) the account ID assigned to you. |
| Legal obligations to which we are subject. | |
When contacting us | You may provide us with your:
|
| Our legitimate interests which consist in communicating with you, responding to your requests, or providing you with updates and information. |
If you wish to obtain further details regarding our legitimate interests, please contact us by sending a request using the contact details specified at the end of this Privacy Notice.
Data Subject Rights
When the General Data Protection Regulation (“GDPR”) or the UK General Data Protection Regulation (“UK GDPR”) applies, you have various rights in relation to the processing of your Personal Information, depending on the relevant situation:
In order to exercise any of your rights, or if you have any other questions about our use of your Personal Information, please send a request using the contact details specified at the end of this Privacy Notice. Please note that we may request that you provide us with additional information in order to confirm your identity.
In any case, you also have the right to lodge a complaint with the competent data protection authority, in particular in the country of your habitual residence, place of work or place of an alleged infringement if you consider that the processing of your Personal Information carried out by us infringes the GDPR or the UK GDPR.
Is any of your Personal Information transferred internationally?
As we are located in the United States, your Personal Information needs to be transferred to the United States for the purposes referred to under this Privacy Notice.
Considering that our designated data processors are also located in the United States whose legislation has not been recognized by the European Commission or the UK Secretary of State as having an adequate level of protection, except for the entities participating in the Data Privacy Framework, we ensure that the transfer is governed by the European Commission’s standard contractual clauses (as amended by the UK Addendum issued by the UK Information Commissioner, where relevant). If you wish to obtain further details regarding the transfer and the applicable safeguards, please send us a request using the contact details specified at the end of this Privacy Notice.
We retain your Personal Information for no longer than necessary for the purposes identified under this Privacy Notice, and as permitted by applicable law.
Accordingly, please note that the data retention period actually applied by us may vary, depending on the relevant purpose as described herein and/or if you request the erasure or deletion of your Personal Information in accordance with applicable data protection laws.
With respect to the Game provided to you, we will keep your Personal Information during the period of our contractual relationship, extended by the applicable statute limitation period.
With respect to your inquiries, informing you about our services and events, we will keep your Personal Information for communication purposes for three (3) years after the last contact with you or until you withdraw your consent, whichever is earlier.
With respect to the processing carried out in order to protect or defend your rights, property or security or ours, we will keep your Personal Information for the time of the relevant dispute or statute limitation period.
As to the processing carried out in order to comply with a legal obligation, we will keep your Personal Information for the duration of such obligation.
Upon expiry of the applicable data retention period, we will securely erase or anonymize the relevant Personal Information.
California Privacy Rights
The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”) requires us to disclose the categories of Personal Information we collect, our purpose(s) for collecting the Personal Information, whether the Personal Information is “sold” to third parties for monetary or other valuable consideration or “shared” with third parties for cross-context behavioral advertising, and the length of time we retain each category of Personal Information, or if that is not possible, the criteria we use to determine the retention period, among other information. This Privacy Notice, in section 2, section 3, section 4 and this section 6, along with any other terms provided to you at or before the collection of your Personal Information, contain such information; please read them carefully.
The CCPA provides California residents the right to request from us, subject to certain exceptions:
As required by the CCPA, we will not discriminate against you for exercising any of these rights.
You may exercise your rights by sending a request to dpo@seconddinner.com. We will acknowledge receipt of your request within 10 business days, and provide a substantive response or notify you of the reason and extension period within 45 days. Under the CCPA, only you or an authorized agent may make a request related to your Personal Information. You may designate an authorized agent to make a request on your behalf by providing written permission (including power of attorney) and verifying your identity. We must verify your identity to respond to certain requests. We may do so by requiring you to log into the Game, provide information that matches information we’ve already collected about you (e.g., purchases, game statistics), or give a declaration as to your identity under penalty of perjury.
California’s Shine the Light Law
California Civil Code Section 1798.83, also known as “Shine the Light” law, permits California residents to annually request, free of charge, information about the disclosure of their Personal Information (if any) to third parties for the third parties’ direct marketing purposes in the preceding calendar year. We do not share Personal Information with third parties for such purposes.
Retention Period
We retain your Personal Information for no longer than necessary for the purposes identified under this Privacy Notice, unless a longer retention period is permitted or required by applicable law.
We use the following criteria to determine our retention periods:
Do-Not-Track
Do-Not-Track is an initiative that developed a signal that an Internet user may activate to inform websites that the user does not want to have their data tracked. We do not currently respond to such signals.
If you are in Taiwan, please refer to this section in relation to the processing of your Personal Information.
Under the Taiwan Personal Data Protection Act (the "PDPA"), you have the following rights:
To exercise your rights above, please contact us by sending a request using the contact details specified at the end of this Privacy Notice.
Furthermore, while it is at your discretion as to whether to provide us with your Personal Information, if you refuse to allow us to collect, process or use certain of your Personal Information, we may not be able to provide you with the Game.
For further information regarding the Personal Information that we collect about you and the purposes for which we use it, please refer to the table in section 5 above.
If you are in Korea, please refer to this section in relation to the processing of your Personal Information.
Personal Information Collected about You and for which Purposes do we Use it
For further information regarding the Personal Information that we collect about you and the purposes for which we use it, please refer to the table in section 5 above.
Provision of Personal Information to a Third Party
We do not provide Personal Information to third parties for their own purpose and benefit. If we intend to provide your Personal Information to such third parties, we will comply with the requirements applicable under your local law.
Entrustment of Personal Information Processing
We may entrust the processing of your Personal Information to our third-party services providers, in particular for the following purposes: cloud services, data storage, back-end operations, payment processors, analytics and advertising services, as further detailed in section 4 above.
Cross-Border Transfer of Personal Information
Based on the performance of the contract concluded between Second Dinner and you, we transfer all your Personal Information to:
These transfers are carried out, over secure network, when needed for the purpose of the performance of the contract. Such transfers are necessary for the provision of the Game. If you refuse the transfer, you will not be able to use the Game. In such case, please delete your account, if any, or contact us.
How long do we retain your Personal Information?
Personal Information Destruction Process and Method
We destroy without delay Personal Information that has been collected and retained when it becomes unnecessary due to the expiration of the retention period and takes the following measures to ensure that such information cannot be recovered or revived after destruction: (i) in case of electronic file format, Personal Information is permanently deleted in a way that makes recovery impossible (however, in case permanent deletion is clearly difficult due to technical characteristics, measures are taken to make recovery impossible by anonymization) and (ii) in case of other records, printed matter, written documents, or other recording media, Personal Information is destroyed by shredding or incineration.
Measures to Ensure Security of Personal Information
We take appropriate technical, managerial and physical measures to ensure the security of your Personal Information, such as:
The Game is not intended for children under the age of 13 (under the age of 16 if you are in the EEA or in the UK) and we do not knowingly collect or solicit Personal Information from children under 13 (under 16 if you are in the EEA or in the UK).
If you believe that we have Personal Information about or collected from a child under the relevant age, please contact us using the contact details specified at the end of this Privacy Notice and we will ensure that it is deleted.
Second Dinner uses “cookies” (small data files) through the Game. For detailed information about “cookies” and how they are used through the Game, please refer to our Cookie Notice.
We reserve the right to change this Privacy Notice at any time. In case there is a material or substantial change, we will notify you in this respect. If such change to this Privacy Notice requires your consent, you will have the choice to consent as to whether or not we may use your Personal Information in a different manner.
If you have any query, you may contact our Data Protection Officer, Tikwiza Nkowane, by email at the following address: dpo@seconddinner.com.
If you are in the EEA, you may address privacy-related inquiries to our representative pursuant to Article 27 of the GDPR: EU-REP.Global GmbH, Attn: Seconddinner, Hopfenstr. 1d, 24114 Kiel, Germany; seconddinner@eu-rep.global.
If you are in the UK, you may address privacy-related inquiries to our representative pursuant to Article 27 of the UK GDPR: DP Data Protection Services UK Ltd., Attn: Seconddinner, 16 Great Queen Street, Covent Garden, London, WC2B 5AH, United Kingdom; seconddinner@eu-rep.global.