PRIVACY POLICY

Last modified: 17th November 2020

• Information you provide to us
  • Registration information: for example, if you register to play a game on the Website, you will be asked to provide your date of birth, email address and a password, and to create an avatar.
  • Information collected via our customer support channels: for example, when you interact with us via Zendesk, our customer support provider, we ask you to provide (a) your full name, email and password, and (b) any information you choose to provide to allow us to assist you.
  • Information you provide when using the Games: when you play the Games, we may ask you to choose a username. Also, if you choose to invite your friends to play a game on the Website, we will collect the email address of your friends. Please make sure you have permission from your friends before sharing Information relating to your friends with us.
  • Information collected through surveys: we may ask you to complete surveys about your experience. The Information we collect from you varies depending on the survey, but we typically ask you questions about your interests and habits, your opinion about different products and services and what you’d like to be offered in the future. We also collect your ratings, opinions, preferences, questions, pictures, and responses associated with that survey.
• Information we automatically collect or is generated about you when you play the Games
  • Identifiers, such as your IP address, device and app ID, unique Miniclip ID, city level location data and device information (such as model, brand and operating system).
  • Cookies: we use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience when using the Games. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality. You have the option to permit installation of such Cookies or subsequently disable them. You may accept all cookies, or instruct the device or web browser to provide notice at the time of installation of cookies, or refuse to accept all cookies by adjusting the relevant cookie retention function in your device. However, in the event of your refusal to install cookies, the Game may be unable to operate as designed. For more information about our Cookies policy, click here.
  • Information you generate and display when playing the Games, such as profile photos and chat content.
  • Information regarding your use of the Games, such as date and time stamps of game events, interactions with our teams and ad engagement, and transaction records, or evidence of you using cheating software or using of modified versions of the Games.
• Information received from third parties
  • Information we receive from third party platforms when you register: when you register through a third party account (Apple, Facebook or Google Play), we may receive your third party ID, name, avatar and city level location. If you give our Game permission, we may also collect your email address, friends list and date of birth.
  • Information from payment processors: when you make payments in our Games, we receive information from our payment processors about your transactions, including your Apple ID number for Apple, your postcode and state for Google and user ID and email address for Xsolla transactions.
  • Analytics information: we integrate certain analytics software of Mobius Solutions Ltd, who are based in Israel and trading as Optimove, a third party analytics provider in some of our Mobile Games. Optimove provides reports that help us optimise our in-game features and events to each user of our Mobile Games which include your user ID and information on your in-game activity.
  • Information collected from advertising partners: we receive information from Unity Technologies (a US and Finnish company). This includes user ID and information on your interactions with advertising shown in on our Mobile Games.
  • Information from 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.

• Provide you with the Games. More in particular, 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) and remember your progress, allowing you to play Games with your friends, provide you with a (moderated) in-Game chat functionality (if applicable), and to allow you to make purchases via Google Play, IOS App Store, Facebook or Xsolla, Inc. 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 such as transaction records.
• Improve and monitor Game use. It is in our legitimate interests to improve our Games for our customers. When doing so, we may collect information we automatically collect or is generated about you when you play the Games, as well as non-personal 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, non-personal 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 and our other products and services that may be of interest to you. We will send you promotional offers, and information about other products and services that may be of interest to you. Where it is required, we will only do so where we have your consent. We do so via email, push notification or in Game. When doing so, we process your registration information and the analytics information above. Your consent can be withdrawn at any time by following the unsubscribe mechanism at the bottom of each communication for emails or by adjusting your device settings for push notifications.
• 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 on the basis of our legitimate interests. If you no longer want to receive targeted advertising you can withdraw your consent in the Games settings, or if that option is not available, please see our Cookie Policy which explains how you can opt out and change your browser and device settings. 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 Miniclip 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 aforementioned fraud and 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.
• Conduct surveys. From time to time, we may ask you to participate in surveys we conduct which are in our legitimate interest because they help us understand our userbase and improve the Games. If you choose to participate, we process your registration information and any other information collected through the survey questions.

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. This includes Adjust GmbH, who are based in Germany, Optimove and Flurry, Inc, who are based in the US;
  • Social media. we integrate certain Facebook and Google software to enhance social media features in the game such as accessing your friends list and displaying your profile picture; and
  • 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 personal 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.
• 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 advertising partners. For more information on how to limit or opt-out from personalized advertisement, please see our Cookie Policy.
• Payment processors: For Mobile Games and Facebook Games, we use payment processors such as Google (if you run Android on your mobile device), Apple App Store payments (if you run IOS on your mobile device) and Facebook (if you make a payment in a Facebook Game). To process payments on the Website, we rely on Xsolla Inc. These payment processors 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:
  • Xsolla: https://xsolla.com/privacypolicy
  • Apple: please see the App Store & Privacy policy available on your Apple device
  • Google: https://policies.google.com/privacy
• Companies who belong to the same group as Miniclip. We share your Information with Miniclip (UK) Limited, Testaluna srl (Italy) and Miniclip Portugal to operate Games.
• 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.

• 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

• Identifiers, including name, email address, IP address, device identifiers, advertising ID, Miniclip 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 and user ID and email address for Xsolla transactions. 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.

• 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.