PRIVACY
POLICY
This
privacy policy was last modified on 24th January 2024.
Overview
About us
and how to contact us
MGS
provides free games online and will process your personal information when you
play our games. If you have any questions about our data practices, your rights
or have any concerns or complaints, you can contact us at dataprotection@mobilegamingstudios.com,
or send a letter to the address provided in this Privacy Policy.
Personal
information we collect
We
collect personal information from you directly, e.g. when you play games or
register for an account, and also generate information about your use of our
games, including game play and log data. If you log in to a game with your
social media account, we will receive information about you including your
name, profile picture and email address. We also receive information from third
parties such as social media platforms. More information.
How we use
your personal information
We
use your Information to provide you with our games, support and analyse your
use, and improve them. We will also use your Information to respond to your
questions. We sometimes send you push notifications and show you ads targeted
to you in our games. You can choose to stop receiving these at any time, by
opting out or changing your browser or device settings. More information.
Who we
share your personal information with
We
rely on third parties for the purposes set out in this Privacy Policy,
including support services, such as game servers, support ticketing and game
analytics. We also work with certain advertising partners to show you ads.
Additionally, we share your Information within our group and as required by
law. More information.
Where we
process your personal information
Your
Information is processed by us or our service providers in different countries
around the world, including Ireland, Portugal, the United Kingdom, the United
States of America and other locations. More information.
Your
rights
You
may have rights to access, receive a copy of, or delete, your Information or
restrict processing of your Information, and you also have the right to object
to our use of your Information for certain purposes, including tailored
marketing and advertising. More information.
Changes to
the Privacy Policy
Any
updates or changes to this Policy will be published here. If there are any
significant changes, we will notify you in-game.
Introduction
This
privacy policy ("Policy") informs you of your choices and our practices
in relation to your Information (as defined below). In this Policy, ("MGS"),
"we" or "us" refers to Mobile Gaming Studios Limited , a company
registered in England with registration number 08324771 with its office located
at 2nd Floor, Bureau, 90 Fetter Lane, London, England, EC4A 1EN. We
choose why we need to use your Information and how it is used, which means we
are considered the data controller in certain countries.
For
the purpose of this Policy, "Information" means any information relating
to an identified or identifiable individual. This includes Information relating
to your use of: (a) our mobile games ("Mobile Games"). When you use the
Mobile Games (the "Games"), you accept our rules and policies which set
out how we handle your Information, and you understand we collect, process, use
and store your Information as described in this Policy. If you do not
agree with this Policy, you must not play any of the Games. If you change your
mind in the future, you must stop playing the Games and you may exercise your
rights in relation to your Information as set out in this Policy.
1.
PERSONAL INFORMATION WE COLLECT
We
will process and use the following Information about you:
- Information
you provide to us
- Account
information: you can choose a profile name, avatar and your
language.
- Information
collected via our customer support channels: when you
interact with us via Zendesk, our customer support provider, we ask you
to provide (a) your full name, username and email, and (b) any
information you choose to provide to allow us to assist you like Game ID,
team/club name, device brand and model, advertising ID, transaction
records or device language.
- In-Game
Communication: in some Games you can interact with
other players via chat. In this case we would process Information
regarding such interactions, including timestamps or chat content. In
some cases, these functionalities may be provided by third parties, in
which case we may not have access to the content of such communications.
- Information
we automatically collect or is generated about you when you play the Games
- Identifiers: your
IP address, advertising ID, HTTP header, MAC address, device ID,
third-party app IDs (apptoken), unique MGS ID, country and city level
location data and device information (such as model, brand, language, and
operating system).
- Information
regarding your use of the Games: game ID, install
and uninstall timestamps. date and time stamps of game events, game time,
achieved scores, interactions with our teams, advertising and promotions
engagement, transaction records, evidence of you using cheating software
or using modified versions of the Games.
- Information
received from third parties
- Registration
via third parties: when you register using a third-party
account (e.g. Facebook, Google, Steam or Apple) we receive your third-party
ID.
- Payment
providers. When you make payments in our Games, we receive the
following Information from our payment providers about your transactions:
transaction ID, country, payment provider used, purchased item, currency,
value, and payment timestamp.
- Analytics
Information: we integrate analytics software from third party
analytics providers in some of our Games. We then receive reports that
help us optimise our in-game features and events to each user of our
Games which include your user ID and information on your in-game
activity.
- Advertising
partners: we receive Information from third-party advertising
providers, including user ID and Information on your interactions with
advertising shown in on our Mobile Games.
- Mobile
measurement partners: we receive information from third
parties to allow us to track performance of our marketing campaigns and
to detect fraud in such campaigns. This includes advertising ID, IP
address, location, and transaction information.
CHILDREN
Our Games
are not targeted at people who are under the age of 18 ("Child" or "Children").
If you are a Child, we recommend that you obtain permission from your parents
or legal guardian ("Parents") to play our Games. You should also read this
Policy with your Parents so they can help you understand anything you may not
understand. If you are a Parent and are concerned about your Child's use of our
Games or have any questions, you can contact us using the details in section 7
below.
2. HOW WE
USE YOUR PERSONAL INFORMATION
We
use your Information to:
- Provide
you with the Games. We will use your Information to perform
our contractual obligation towards you to allow you to create an account,
play the Games (including as a guest), remember your progress, allow you
to play Games with your friends and communicate with them via in-Game
chat. We will also use your Information to allow you to make purchases and
maintain a record of such purchases. The Information we process when doing
so includes your registration Information, Information you provide to us
when playing the Games, identifiers, Information you generate and display
when playing the Games, and Information regarding your use of the Games.
- Improve
and monitor Game use. It is in our legitimate interests to
improve our Games for our customers. When doing so, we may automatically collect
information or generate Information about you when you play the Games, as
well as Information about your device such as battery, Wi-Fi strength,
device manufacturer, model and operating system, and the amount of free
space on your device.
- Provide
you with support and to respond to your requests or complaints. If you
reach out to us for support, we will use your Information to create a
support account for you, respond and resolve your queries and complaints,
facilitate support (e.g., retrieval of a forgotten password). When doing
so, we perform our contractual obligation towards you. The Information we
process when doing so includes your registration Information, your
identifiers, information about your device such as your Wi-Fi strength and
the amount of free space on your device, and any other Information about
you collected via our customer support channels.
- Conduct
analytics. It is in our legitimate interests to analyse the use
of and inform, our Games, newsletters and advertising campaigns, and any
other interaction or interest in the same. When doing so we will process Information
we automatically collect or is generated about you when you play the Games
or interact with our newsletters and advertising campaigns to (a) create
anonymised and aggregated data; (b) create segments of users who show
particular characteristics or interests; and (c) conduct predictive
analytics about your interests.
- Send you
updates about in-Game offers. We will show you promotional
offers and information about virtual items that can be purchased in-game,
which will be tailored to you based on gameplay, geography, device data
and in-game interactions.
- Provide
you with advertising. We will present you with ads and
suggestions in our Games and elsewhere. These may be ads relating to our
own Games or other services you may be interested in. These ads and
suggestions may be tailored specifically to you. Where it is required, we
will only do so where we have your consent. In situations where your
consent is not required, or where we provide contextual advertising, we do
so based on our legitimate interests. If you no longer want to receive
targeted advertising you can withdraw your consent in the Games settings, when
available. To tailor ads and to allow our advertising partners to tailor
ads, we process Information we automatically collect or is generated about
you when you play the Games and Information received from third parties.
- Prevent
fraud, defend MGS against legal claims or disputes, enforce our terms and
to comply with our legal obligations. It is in our
legitimate interests to protect our users against online abuse and other
anti-social or illegal activity (e.g., when moderating conversation in our
Games). Furthermore, it is also in our legitimate interest to protect our
interests by (1) monitoring Game use to detect fraud or any other user
behaviour which prejudices the integrity of our Games, (2) taking steps to
remedy fraud and concerning behaviour, (3) defending ourselves against
legal claims or disputes, and (4) enforcing our terms and policies. When
doing so, we will process the Information relevant in such a case,
including Information you provide us, Information we automatically collect
about you, and Information which is provided to us by third parties.
3. WHO WE
SHARE YOUR PERSONAL INFORMATION WITH
We
share your Information with selected third parties, including:
- Other
players and users will see your profile Information
and in-game activities, as well as any other Information you choose to
share with them, such as chat data;
- Vendors
and service providers we rely on for the provision of the Games, for
example:
- Cloud
service providers who rely on for data storage,
including Amazon Web Services who are based in the U.S.;
- Customer
support solution providers, who help us manage and respond to
our customer questions and complaints. This includes Zendesk Inc., who
are based in the U.S. and who host our customer support function;
- Analytics
providers: we work with a number of analytics, segmentation
and mobile measurement service providers who help us understand our
userbase.
- User
acquisition. We work with a variety of user acquisition partners
to help us report on the success of our marketing campaigns. We may use
some of your Information to participate in Custom Audience and Lookalike
Audience programmes, which enable us to display adverts to both existing
and prospective supporters when they visit one of our partners' websites.
We may provide an identifier (i.e. your Advertising ID or Facebook ID) to
them so they can determine whether you are a registered account holder
with them. Our adverts may then appear when you access their
websites. See our list of partners below.
- Advertising
partners. We are an ad-supported service. Subject to your
settings, we provide certain Information to advertisers who will use them
to serve you with ads in our Games, and we measure who sees and clicks on
their ads. We also share advertising identifiers, along with the interests
or other characteristics of a device or the person using it, to help
partners decide whether to serve an ad to that device or to enable them to
conduct marketing, brand analysis, personalise advertising, or similar
activities. See our list of partners below.
- Payment
processors: we use payment processors such as Google (if you run
Android on your mobile device) or Apple App Store payments (if you run IOS
on your mobile device). These payment providers are responsible for the
processing of your Information, and may use your Information for their own
purposes in accordance with their privacy policies as below:
- Companies
who belong to the same group as MGS. We share your
Information with different entities which are part of our group of
companies.
- Law
enforcement agencies, public authorities or other judicial bodies and
organisations. We disclose Information if we are
legally required to do so, or if we have a good faith belief that such use
is reasonably necessary to comply with a legal obligation, process or
request; enforce our terms of service and other agreements, policies, and
standards, including investigation of any potential violation thereof;
detect, prevent or otherwise address security, fraud or technical issues;
or protect the rights, property or safety of us, our users, a third party
or the public as required or permitted by law (including exchanging
information with other companies and organisations for the purposes of
fraud protection).
- Change
of corporate ownership. If we are involved in a merger,
acquisition, bankruptcy, reorganisation, partnership, asset sale or other
transaction, we may disclose your Information as part of that transaction.
THIRD PARTY PRIVACY PRACTICES
If
you access any Games through a third-party platform such as Facebook, Google or
Steam ("Third-Party Services"), you must understand that those
Third-Party Services may collect other Information about you (including
Information you share with them directly or about your use of the Games) in
accordance with their own terms and privacy policies. The privacy practices
described in this Policy do not apply to Third Party Services. Any links in the
Games to Third Party Services do not imply that we endorse or have reviewed the
Third-Party Services.
SECURITY
Although
we have in place security measures to maintain the privacy and integrity of
your Information, unfortunately, the transmission of Information via the
internet is not completely secure. We may also take extra steps to protect your
Information and minimise the Information we process. For example, when you
provide us with your password as part of the registration process, we apply a
one-way hash.
4. WHERE
WE PROCESS YOUR PERSONAL INFORMATION
We
process your Information in several countries, including countries within the
European Economic Area ("EEA"), the United Kingdom ("UK"), the United States of
America and others.
When
we transfer your Information outside the UK or the EEA, we may transfer it to
countries that have been recognised as offering an adequate protection by the
EEA or the UK. When this adequacy status has not been offered, we use standard
contracts that can be used in the EEA or the UK to safeguard your Information
while transferring it outside the EEA or the UK.
5. HOW
LONG WE STORE YOUR INFORMATION
Your
Information is kept for as long as you are registered or using our games, and
then for up to three years from the date you stop interacting with the games.
When
deleting Information, we will take measures to make the Information
irrecoverable or irreproducible, and electronic files which contain Information
will be deleted permanently.
6. YOUR
RIGHTS
If
you are based in the EEA, Switzerland or are a legal resident of California in
the U.S., you have certain rights in relation to your Information. For
Californian residents, please refer to Addendum 1 - California Privacy Rights..
For EEA, United Kingdom, Switzerland, Brazil based, you will find more
information below on when which rights can apply.
To
exercise your rights, please follow the procedure set out below, use our web form (and choose: Type of issue
'Related to my account' > 'I have data related question') or email us
at dataprotection@mobilegamingstudios.com.
- Access. You
have the right to access Information, and to receive an explanation of how
we use it and who we share it with. This right is not absolute. For
example, we cannot reveal trade secrets, or give you Information about
other individuals.
- Erasure. You
have the right to request deletion of your Information. We may need to
retain some of your Information where there are valid grounds for us to do
so under data protection laws. For example, for the defence of legal
claims, respect freedom of expression, or where we have an overriding
legitimate interest to do so, but we will let you know when this is the
case. Note that where the Information is held by a third-party data
controller, such as an advertising partner or a payment processor, we will
use reasonable steps to inform them of your request, but we recommend you
contact them directly in accordance with their own privacy policies to
ensure your personal data is erased.
- Objection
and withdrawal of consent: You have the right to (i) withdraw
your consent where you previously provided such consent; or (ii) object to
our processing of your Information where we process such Information on
the basis of our legitimate interests (see above under How we use your personal information). You
may exercise this right as follows:
- To stop
receiving personalized advertising: (a) on the
Website please opt-out in Privacy Settings; (b) for Mobile
Games, please withdraw your consent in the in-app Settings. You can also
find more information in our Cookie Policy.
- To stop
receiving marketing emails: please follow the unsubscribe
mechanism at the bottom of each email communication.
- To stop
our cookies being placed: please refer to our Cookie
Policy.
- To stop
receiving push notifications: please change your device or
browser settings.
- Portability. You
have the right to receive a copy of Information we process on the basis of
consent or contract in a structured, commonly used and machine-readable
format, or to request that such Information is transferred to a third
party.
- Correction. You
have the right to correct any Information held about you that is
inaccurate.
- Restriction. You
have a right in certain circumstances to stop us processing Information
other than for storage purposes.
7. CONTACT
& COMPLAINTS
We
welcome questions, comments, and requests regarding this Policy. These should
be addressed to dataprotection@mobilegamingstudios.com.
You can also send a letter to Data Protection, Mobile Gaming Studios Limited,
2nd Floor, Bureau, 90 Fetter Ln, London EC4A 1EN, United Kingdom.
If
you wish to make a complaint about how we process your Information, please
contact us at dataprotection@mobilegamingstudios.com and
we will endeavour to deal with your complaint as soon as possible. This is
without prejudice to your right to start a complaint with a data protection
authority.
8. CHANGES
Any
updates or changes to this Policy will be published here. If there are any
significant changes, we will notify you in-Game.
ADVERTISING
AND USER ACQUISITION PARTNERS
We
use the following user acquisition and advertising partners, that are
integrated into some or all the Games. Please check the following privacy
policies to learn more about their privacy practices, including how you may
exercise your data subject rights.
This
list was last updated on 23rd January 2024.
MOBILE GAMES
ADDENDUM 1
- CALIFORNIA PRIVACY RIGHTS
The
terms of this Addendum apply to residents of California under the California
Consumer Privacy Act of 2018 (California Civil Code & sect; §§ 1798.100 to 1798.199) and its implementing
regulations, as amended or superseded from time to time ("CCPA"). For the
purposes of this addendum, Personal Information means information that
identifies, relates to, describes, is reasonably capable of being associated
with, or could reasonably be linked, directly or indirectly, with a particular
consumer or household, or as otherwise defined by the CCPA. Personal
Information does not include information that is: lawfully made available from
government records, deidentified or aggregated, or otherwise excluded from the
scope of the CCPA.
COLLECTION AND DISCLOSURE OF PERSONAL
INFORMATION
Over
the past 12 months, through your use of the Games, we may have collected and
disclosed the following categories of Personal Information from or about you:
- Identifiers,
including name, email address, IP address, device identifiers, advertising
ID, MGS ID, and profile photos. This information is collected directly
from you or your device. If you have registered through a third party
account (Apple, Facebook, or Google), we may have also collected from
those third party services your third party ID, name, and avatar.
- Internet or other
electronic network activity information, including your use of in-game
features and events and information on your in-game activity, and
information on your interactions with advertising shown in on our Games.
This information is collected from our selected third party analytics
providers and advertising partners.
- Geolocation data,
including city level location data. This information is collected directly
from you or your device and from third party services when you register
through them.
- Commercial
information, including records of products or services purchased,
obtained, or considered, your Apple ID number for Apple, your postcode and
state for Google. This information is collected directly from you or your
device, and from our payment processors.
In
the preceding twelve months, we have collected Personal Information from the
following categories of sources:
1.
You/Your Devices directly.
2.
Advertising Networks and other advertising partners.
3.
Analytics Providers.
4.
Social Networks, to the extent this applies to you and within
the limits of your permission.
We
collect personal information for the following purposes:
- To operate and
administer the Games;
- To improve the
Games;
- To communicate with
you;
- To serve
advertising;
- For security and
verification purposes, including to prevent and detect fraudulent
activity;
- To address and
remediate technical issues and bugs.
For
additional information about what each type of personal information is used
for, see "How We Use Your Personal Information" in the
main portion of the Privacy Policy.
We
may disclose personal information to the following types of entities:
- Other players and
users who will see your profile information and in-game activities, as
well as any other information you choose to share with them, such as chat
data;
- Our affiliate
companies within our corporate group who process personal information in
order to operate the Games;
- Marketing and
advertising partners who use your information to serve you ads in the
Games and on other sites;
- Other companies
that provide services on our behalf who are prohibited by contract from
retaining, using, or disclosing personal information for any purpose other
than for providing the services to us;
- Regulators,
judicial authorities and law enforcement agencies;
- Entities that
acquire all or substantially all of our business.
For
additional information about how we disclose personal information is used for,
see "Who we share Your Personal Information With"
in the main portion of the Privacy Policy.
SALES OF PERSONAL INFORMATION / NOTICE OF RIGHT
TO OPT-OUT
Over
the past 12 months, we have used third party advertising and other tracking
technologies on our Games to collect information about you, your device(s), and
your use of our Games. We share that information with selected third parties
such as advertising partners who use it to target advertisements to you online.
You
can opt-out and exercise control over the use of these technologies at any time
by using the Privacy Settings, and, for certain of our Mobile
Games, by adjusting the in-app settings. Alternatively, you can also submit
your request to opt-out using our use our web form.
RIGHTS UNDER THE CCPA
The
CCPA provides California residents with certain legal rights; these rights are
not absolute and are subject to certain exemptions. If you are a California
resident, and the CCPA does not recognize an exemption that applies to you or
your personal information, you have the right to:
- Submit a verifiable
request for the following information covering the 12 months preceding
your request:
- the
categories of Personal Information about you that we collected, sold, or
disclosed;
- the
categories of sources from which the Personal Information was collected;
- the
purpose for collecting or selling Personal Information about you;
- the
categories of third parties to whom we disclosed Personal Information
about you and the categories of Personal Information that was disclosed
(if applicable) and the purpose for disclosing the Personal Information
about you; and
- the
specific pieces of Personal Information we collected about you;
- Submit a verifiable
request that we delete Personal Information we collected from you; and
- Be free from
unlawful discrimination for exercising your rights, including providing a
different level or quality of services or deny goods or services to you
when you exercise your rights under the CCPA, subject to certain
limitations.
We
aim to fulfil all verified requests within 45 days pursuant to the CCPA. If
necessary, extensions for an additional 45 days will be accompanied by an
explanation for the delay.
HOW TO EXERCISE YOUR RIGHTS
You
can exercise your rights by using our web form (and choosing: Type of issue
'Related to my account' > 'I have data related question') or by emailing us
at dataprotection@mobilegamingstudios.com.
If
you wish to opt-out or update your preferences, you may do so in the Privacy
Settings of our Website, and in-app for certain of our Mobile Games.
VERIFICATION
Requests
for access to or deletion of Personal Information, whether submitted by you
directly or via an authorized agent, are subject to our ability to reasonably
verify your identity in light of the information requested and pursuant to
relevant CCPA requirements, limitations, and regulations. To verify your access
or deletion request, please be prepared to provide us with identifying
information (such as your User ID, Game name etc.) that and we can match
against our records in order to confirm you are the rightful account holder.
AUTHORIZING AN AGENT
To
authorize an agent to make a request to know or delete or opt out on your
behalf, please email us at dataprotection@mobilegamingstudios.com.
SHINE THE LIGHT
We
do not rent, sell, or share Personal Information with nonaffiliated companies
for their direct marketing uses as contemplated by California's "Shine the
Light" law (Civil Code § 1798.83), unless we have your permission.
DO NOT TRACK
There
is no accepted standard on how to respond to Do Not Track signals, and we do
not respond to such signals.