Thanks for using our games, websites,
marketing and advertising activities or related services (“Service” or
“Services”).
1.1. This policy describes: what information MINISTONE
GAMES LLC. and its other affiliated and related companies ("MINISTONE” or
“we” or “us” or “our”) and its third parties collect through the Services,
whether on your mobile device, computer, or any other device, platform or
website, and why we collect it, how we use that information, and how you can
exercise your privacy rights.
1.2. By installing, using or otherwise
accessing the Services, you consent to collection, storage, processing and
sharing your Personal Data in the manners set forth in this Privacy Policy. We
may use this data in different ways, but always do so lawfully in accordance
with the legal bases set out in Section 10 below.
1.3. If you are at all concerned about the
way that your Personal Data is used as authorized in this Privacy Policy,
please refrain from using our Services.
1.4. It is not our policy to allow anyone
under the age of 16 to provide personal data and we do not knowingly collect or
solicit personal data about or direct or target interest-based advertising to
anyone under the age of 16 or knowingly allow such persons to use our Services.
In some countries you must be older than 16
years old to use our Services.
No one under the relevant age may provide any
personal data.
If we discover that we have collected
personal data about a child under the relevant age, we will delete that data as
quickly as possible. If you believe that we might have any data from or about a
child under the relevant age, please contact us.
We may collect and receive information which
may be considered personal data according to applicable laws in a variety of
ways. More specifically:
2.1. When you play our games, we may collect
and store:
2.1.1. Information that you provide
voluntarily such as name, email address, phone number or other contact
information, player name and password, profile photo, information submitted to
our support via Services or email, the content of messages sent using our chat
and messaging systems or other information you send us (such as data to
identify a lost account).
2.1.2. Information that is collected and
stored automatically from you and/or your device when you use our games, such
as:
– data about your account, nickname and how
you use the Services and interact with the Services (such as gameplay data,
game progress, levels, scores, session length, preferred setting; which in-game
adverts you may have viewed, in-game references or just game preferences, what
friends you connect with);
– your IP address, Internet status, broad
geographic location (e.g., country or city-level location), cookie identifiers;
– Device information, including type of
device, device model, device operating system, device settings, its language or
other technical data like device settings, screen size or processor, or
combination of this data available from a device for a developer for checking
the device compatibility with a particular application, application IDs, device
ID, Advertising ID (unique identifiers associated with your device that
advertisers use for interest-based advertising), Vendor ID.
Whether we collect some or all of this
information often depends on the type of device used and its settings. These
technologies allow us and third parties (including marketers and advertisers)
to recognize your device when you use websites and applications. They are
consistent across all apps and thus allow cross-app tracking.
2.1.3. Data we collect from our partners:
· Data we receive if you link a third-party tool with the Service (such
as Facebook);
· Data to fight fraud (such as refund abuse in games or click fraud in
advertising);
· Details of orders (such as items, date, amount, status, description, broad
geographic location (e.g., country or city-level location));
· Data for advertising and marketing purposes;
· Data for analytics purposes, so we can provide you a better Service;
· Data from other group companies or third-party companies who have
obtained your consent or have another legal right to share such information
with us (including publishing partners, platforms, advertising platforms and
partners and data aggregator). This may include attributes about you and your
interests, as well as other games and services you use, demographic and general
location information. We will use this information as described in this Privacy
Policy and subject to any limitations in the privacy policy of the company that
collected the information from you.
2.2. When you visit our website
2.2.1. When you provide us with any feedback
through means available to you on this website, including but not limited to
the Job Application we may collect and process personal data which you provide
to us, such as your name, e-mail address, telephone number or any other
information you send us.
2.2.2. Information collected and stored when
you use website automatically from your device or browser including your
device’s model, operating system, screen size, browser type, information of how
you use the website (such as time and user’s number of visits, time spent on
the website, IP address, data collected with cookies and similar technologies
(such as “software development kits, or “SDKs”).
2.3. If you are representatives of our
Business Partners, Vendors or Corporate Customers
When you are representatives of our business
partners, vendors of corporate customers, we may collect and receive:
2.3.1. Any information from you directly;
2.3.2. Any information from your employer or
other third parties (e. g. from publicly available sources or during networking
events).
2.4. We may from time to time ask you for
your consent to collect other information from you or your device. If we do
this, we will tell you what information we would like to collect, why we need
it and what we’ll use it for.
2.5. Please note we do not collect or store
any payment information from you when you purchase items via our mobile apps
(such as those you can purchase in the App Store, Google Play, Microsoft Store,
Amazon Appstore, Facebook or other platform).
2.6. Some of this information may be
collected using cookies, small files that store information on your device to
help us optimize the use of our Services and/or similar technologies (such as
“SDKs” or software development kits). Some of the cookies are “1st party,” from
the website itself, and others are “3rd party,” belonging to advertising and
analytics entities or social networks. Cookies are typically used to quickly
identify your device and to “remember” your device during subsequent visits for
purposes of functionality, preferences, and website performance. You can
disable cookies on your device or set your device to alert you when cookies are
being sent to your device; however, disabling cookies may affect your ability
to use the Services.
2.7. Please note MINISTONE does not guarantee
the protection of any Personal Data you decide to make public in your account,
or that you may post in comments, submitted through the Services or make
otherwise visible to others including but not limited to, chats, forums, blogs
where you can post your Content. We have no responsibility for how that
information is used by other parties. So please be careful when you submit any
data through the Services.
2.8. We may also create a Support ID which
helps us identify you for supporting purposes when you use the Service.
3.1. First and foremost, we use personal data
when processing is necessary for the performance of a contract to which you are
a party or in order to take steps at the request of the data subject prior to
entering into a contract.
Accordingly, we use your data as follows:
– to provide you with the Services;
– to contact you, whether for customer
service purposes or to send information regarding our Services;
– to manage your account and improve your
experience when using our Services;
– to research, survey and interact with you,
for example via email or other communications;
– to develop and improve the Service and
player experience;
– to customize your Service experience;
– to provide you our offers in the Service as
well as in other websites and services;
– when it is necessary to do as you have
requested for sending you related information, security alerts, and support
messages;
– to provide social features as part of the
Service;
– to moderate chats either automatically or
manually:
– to enable you to communicate with other
players.
3.2. To show personalized advertisements in
the Service as well as in other websites and services (including email); track
the content you access in connection with the Service and your online behavior;
deliver, target and improve our advertising and the Service.
3.3. We may use the data when processing is
necessary for compliance with a legal obligation to which MINISTONE is subject
in order to keep the Service and its social features safe and fair, to fight
fraud, prevent crime or cheating and ensure acceptable use otherwise, take
action against fraudulent or misbehaving players.
3.4. We may use the data when processing is
necessary for the purposes of the legitimate interests pursued by us to
analyze, profile, and segment, except where such interests are overridden by
the interests or fundamental rights and freedoms of the data subject which
require protection of personal data, in particular where the data subject is a
child under the relevant age.
In all of the above cases and purposes, we
may analyze, profile and segment all collected data (e. g. create reports,
analyses or similar for our own research or market purposes, for example to
track trends or problems using our Services).
3.5. With your consent.
With your consent, we may process your data
for additional purposes, such as using your GPS location to show you local events.
4.1. We may share your information with (i) third parties providers and partners who provide data
processing services to us and with whom we have relevant signed agreements, or
who otherwise process personal information for purposes that are described in
this Privacy Policy or notified to you when we collect your personal
information (such as technical support providers, software providers,
advertising and marketing partners, professional advisers, consultants (such as
solicitors, accountants, tax advisors, auditors and insurance brokers); (ii)
public authorities, court, government representative or other third party as
necessary in accordance with applicable law and regulations; (iii) to third
party when there is a corporate restructuring or sale of assets involving
MINISTONE, or as a result of a change in control of MINISTONE or affiliate, or
to prepare for any of these events. Any third party who is the recipient of
such a transfer or sale is authorized to continue using your Personal Data as
provided to us, according to this Privacy Policy; or (iv) to any other
individuals or entities with your consent to disclosure.
4.2. By accepting this Privacy Policy and
downloading or continuing to play our games or use our Services, and unless you
opt out of interest-based advertising as explained in Section 11, you consent
to us and our collecting and using information about you to improve
advertising, targeting and measurement systems so that we can show you direct
or target interest advertising according to your preferences.
4.3. We do not sell or rent your personal
data to any third party unless it is related to one of the above reasons.
4.4. By accepting this Privacy Policy and
downloading or continuing to play our games or use our Services, you are also
authorizing us to, at any time and in our sole discretion, provide third
parties with anonymous and statistical data contains no personal data.
5.1. In the event you use a third-party
social network or platform to access our Services, this third party may provide
your personal data to us if you so allow. These websites or applications are
created by a third party that is not affiliated with or controlled by
MINISTONE. Please be sure to carefully read their terms of service and privacy
policy so that you understand how they use your Personal Data and what might be
shared.
5.2. When you allow any interaction between
our Services and any social network or platform that belongs to a third party,
we also may share your personal data with your contacts for you to enjoy
playing with others (your name, your profile avatar and your scores/progress in
our games).
5.3. You may, at any time, make changes to
the data that these third-party social networks or platforms share with us by
changing your settings for that provider, or stop allowing our Services to
interact with that provider. In doing so you may not experience our Services’
special features to the fullest extent.
6.1. Your personal data will be stored as
long as is necessary to provide you with Services or to complete whatever
purpose it was originally provided for. But please note even after you have
closed your account or have stopped using our Services, we may continue to
store your Personal Data if doing so is necessary for us to fulfill our legal
obligations.
7.1. We take the security of your Personal
Data very seriously. We implement the appropriate technical and physical
safeguards to ensure that your Personal Data is protected against accidental or
unlawful loss, destruction, alteration, unauthorized access or disclosure, or
any other use or unlawful processing of Personal Data you have provided to us.
Our security mechanisms for Personal Data are similar to those of other game
developers. Please keep in mind, though, that the Internet is not 100% secure and
any access, disclosure, alteration or destruction of the Personal Data you have
provided through our games due to breach of our safeguards cannot be
guaranteed.
8.1. In our Services and on our website(s),
we may embed links to third-party websites. It must be understood that when you
click on any of these links, you will be taken to a third-party site and
therefore any Personal Data you provide will not be protected under this
Privacy Policy, but rather that of the third party. Of course
we take great care in selecting reputable links, but we have no control over
and assume no responsibility for the content, privacy policies, or practices of
any third-party sites or services.
9.1. Our Service is global by nature and your
data can therefore be transferred to anywhere in the world. Because different
countries may have different data protection laws than your own country, we
take steps to ensure adequate safeguards are in place to protect your data as
explained in this Policy. These include implementing the European Commission’s
Standard Contractual Clauses for transfers of personal data between our group
companies and third-party service providers and partners, which require all group
companies to protect personal data they process from the EEA in accordance with
European Union data protection law. It also includes transferring personal data
to third party service providers and partners which are certified under the
EU-US and Swiss-US Privacy Shield.
10.1. In each case where we process your
Personal Data, we do so lawfully in accordance with one of the legal bases
according to the applicable law. The legal bases which we rely upon are the
following:
· We need the personal data to perform a contract with you. This
applies when data used by us in order to provide you with Services that you
have requested – and that we have agreed – to provide to you, such as our
games, customer services, chat functionality and third-party social network
connectivity;
· Legal Obligation. This applies when data used by us to comply with a
legal obligation, such as the preventing a crime or fraud or maintaining tax
record;
· Legitimate Interests. This applies when data used for analytics,
research and optimization of the Services, and marketing purposes, including
direct or target interest-based advertising; and
· Consent. This applies when you voluntarily give us specific, informed
and unambiguous indication of you wishes by which you signify agreement to the
processing of your personal data.
If you are in the European Economic Area, you have the following data
protection rights:
11.1. Right to access your Personal Data.
You have a right to know what Personal Data
we hold about you, how and why we handle your Personal Data. You can ask us for
a copy of your Personal Data and in some cases to have the information
communicated to you. If you would like to exercise your right of access, please
contact us as described below and let us know what information in particular
you would like to receive. We reserve the right to ask for reasonable evidence
to verify your identity before we provide you with any information. Please note
that we may not be able to provide all the information you ask for, for
instance if the information includes personal information about another person.
Where we are not able to provide you with information that you have asked for,
we will endeavor to tell you why.
11.2. Right to correct or update your
Personal Data.
You have a right to request an update or
correction to any of your Personal Data which is out of date, incomplete or
incorrect.
11.3. Right to delete your Personal Data.
In certain specific circumstances you have a
right to ask us to delete your Personal Data which we are holding about you. We
will pass your request onto other recipients of your personal information
unless that is impossible or involves disproportionate effort. If you would
like to ask us for further information on the specific circumstances, and who
the other recipients are, and/or exercise your right to erasure please contact
us, using the contact details described in Section 13 below. Please note some
things can only be deleted when you delete our games from your mobile devices
and clear our cookies from any device that you have used for our Services. In
that case you will permanently lose all your game progress, Virtual Currency
and Virtual Goods without the right to data recovery or refund. Where we delete
Personal Data about you, we may still retain some or all of that information
for other purposes such as maintaining financial records, protecting or
enforcing legal rights, maintaining marketing suppression lists or for
technical reasons such as maintaining technical security or our database
integrity. We may also retain your information in an anonymized form. In some
instances, personal information about you that is visible through gameplay such
as username, avatar, your high scores and any chat messages may be cached on
other players’ devices and we may not be able to remove or update that data
from those devices, for example if that device is not connected to a network.
You can ask us for further information on the specific circumstances and who
the other recipients are, using the contact details described in Section 13
below.
11.4. Right to restriction of processing your
personal data.
In certain specific circumstances you have a
right to object to the processing of personal data about you which is processed
on the grounds of legitimate interests. You can ask us for further information
on the specific circumstances using the contact details described in Section 13
below.
11.5. Right to object at any time to
processing of your personal data when processing is necessary for the purposes
of the legitimate interests pursued by us or by a third party, except where
such interests are overridden by the interests or fundamental rights and
freedoms of the data subject which require protection of personal data, in
particular where the data subject is a child.
11.6. Right to opt-out of direct or target
interest advertising on mobile applications by checking the privacy settings on
your device settings menu. Please note that even if you use your right to
opt-out it you will still receive advertising, but not direct or target
interest. On Apple you can opt-out this by going to Settings > Privacy >
Advertising and turning on “Limit Ad Tracking”. On Android you can opt-out by
going to Settings > Google services > Ads and turning on choosing “Opt out of Ads Personalization”.
11.7. Right to portability of your personal
data. In some circumstances, you may have the right to request that data which
you have provided to us is provided to you, so you can transfer this to another
data controller.
11.8. Right to withdraw your consent at any
time if we are processing your personal data with your consent.
11.9. Right to complain to a data protection
authority about our collection and use of your personal information. For more
information, please contact your local data protection authority.
11.10. In some instances, our use of your Personal
Data may result in automated decisions being taken (including profiling).
Automated decisions mean that a decision concerning you is made automatically
on the basis of a computer determination (using software algorithms), without
our human review. For example, we use automated decisions to provide direct or
targeted interest-based advertising on our Services. You can opt out of direct
or targeted interest-based advertising by following the instructions in Section
11.6 above.
12.1 If you have never logged into the game before, uninstalling the game directly will delete all game progress, and we will no longer retain any data.
12.2 If you have logged into the game with a Facebook, Apple account
or any other third-party account, you can click "Logout" in the game
settings. Then, in the confirmation dialog that appears, check the option
"Permanently delete this account and its data on the server." By
doing so, all game progress and related user data stored both locally on your
device and on the server will be deleted.
13.1 Should you have any questions regarding this Privacy Policy or
would like to use your Personal Data protection rights described above, please
contact us at contact@ministonegames.com.
14.1 In the event our Privacy Policy is
changed or updated, any changes or updates will be posted to keep you aware of
the Personal Data that we collect, how it is used and stored, and when we are
authorized to disclose it.
14.2. We reserve the right to make any
necessary changes to this Privacy Policy at any time, so please view it often.