Play Games at Miniclip.com

Miniclip Privacy Policy

(For War Wings players, please refer specifically to the War Wings Privacy Policy)

Last updated: 11 March 2019. Please check back regularly to keep informed of updates to this Privacy Policy.

You can find information about us and how we collect, use and store your personal data in each section of this Privacy Policy:

• Who we are
• Third party sites
• What data does Miniclip collect from you?
• What does Miniclip do with this data and what is our legal basis for processing this data?
• Does Miniclip send marketing communications and how can I opt out?
• What does Miniclip do to protect data?
• How long does Miniclip keep hold of data?
• What data is shared with or accessed by third parties?
• Third party advertising companies
• Will data be transferred overseas?
• Children's privacy
• How do I erase or restrict or update my data?
• How do I get a copy of my data?
• How can I contact Miniclip?
• What can I do if I have a complaint?

Who we are

Miniclip SA (a company registered in Switzerland (registration number CH-645-4103964-1), whose registered office is at Rue des Beaux-Arts 8, 2000, Neuchâtel, Switzerland) is the data controller of the personal information that we collect from you. Miniclip is a member of a group of companies who may process your personal data, which includes Miniclip (UK) Limited (a company registered in England and Wales (registration number 06432709), whose registered office is at Legal Department, Holborn Gate, 326-330 High Holborn, London, United Kingdom, WC1V 7PP), Miniclip Portugal (a company registered in Portugal (registration number 509371388), whose registered office is at Taguspark, Edificio Ciencia II, Av. Prof. Dr. Aníbal Cavaco Silva, Nº 11 - 1C, 2740-120, Oeiras, Portugal) and Miniclip Italia (Testaluna) (a company registered in Italy (registration number MI1754241), whose registered office is at Via Melchiorre Gioia, 8, 20124, Milano (MI), Italy). Miniclip and its affiliated group companies are referred to in this Privacy Policy as "Miniclip", "us", "we" or "our".

Miniclip SA's EU representative for the purposes of EU data protection laws is Miniclip (UK) Limited (details above).

We are committed to providing fun and exciting digital entertainment. This Privacy Policy explains how and what personal data relating to you we may use in relation to:

• our main website www.miniclip.com or through our other dedicated websites (such as www.agar.io, www.diep.io, www.spaceone.io and any other .io sites which may be offered by us from time to time) ("websites");
• any of our mobile applications ("apps"); and
• any games, products, forums and services we offer through the apps or websites, or otherwise provided by us (all collectively referred to in this Privacy Policy as our "Services").

This Privacy Policy governs the collection, storage and use of personal information by us via our websites, apps and Services. It provides you with details about the personal information we collect from you, how we use your personal information, and your rights regarding the personal information we hold about you. Please read this Privacy Policy carefully.

Third party sites

Please note that the Services may contain or incorporate links to websites or other services owned and operated by third parties. We do not endorse any such third-party services. We are not responsible or liable for anything that happens to you when you visit or use these services. Miniclip strongly recommends that you review the privacy policies and cookie usage of these third parties.

What data does Miniclip collect from you?

In this Privacy Policy, "data" means any personal data about you which could identify you (by itself or in combination with other data) such as your name, address, email address or an online identifier.

We collect data about you in a number of different ways. In this section, we explain the different ways we collect personal data about you and the ways in which that information will be used. For more detail on how we use your data, please see the section titled " What does Miniclip do with this data?"

We will usually collect and store the following data about you when you access and use our Services:

Data you give us directly:

• if you register an account with us directly on our Services, we will collect your date of birth, location, username, avatar, password and email address;
• if you enter into any competitions or complete any surveys on our apps or websites, or when using any of our Services, we will collect and store the data you submit to us, including your name and contact details as well as information on your game scores and ranking in any competition;
• when you complete any in-app or in-game purchases, such as buying in-game currency and other items, we will collect data relating to your purchase history;
• when you participate in any Miniclip chat forums on our Services, we will collect your username, email address and any data that you share within your messages posted to that forum; and
• we will also collect information you provide to us if you raise a complaint, ask for technical support or report a problem with any of our Services, including when you contribute to or post on our Community pages.

Data we may collect when you use our Services (whether or not you register with us):

• data about your location, device type and model, operating system and version and platform, and any apps you are using in conjunction with our Services;
• data about your device's browser version, page loading time, mobile phone network and operator, generated device identifier information, referral source and IP address;
• data generated when you play our games, such as the game version you are playing, your high score, log-in method, VIP level and rankings;
• attribution data (engagement with advertising on third party websites and in-app event data) and advertising ID, for user acquisition campaigns and monitoring the success of the same;
• data relating to your game play history on our Services, including any purchases made;
• the number of times you visit or use any of our Services and the amount of time you spend using the Services; and
• where you are accessing our Services through a third-party account such as Facebook or Google, we will collect certain information relating to your account with those third parties including your name, user ID, location (country and/or city specific), email address, date of birth, information from your public profile including friends and connections, log in details, avatar and other information based on your use of our Services. You can manage the data which is shared by such third parties with us by amending your preferences using the privacy settings which these third parties provide on their platforms.

We will sometimes use third party advertising companies to help us collect this data. Further information is provided below in the section titled "Third party advertising companies".

What does Miniclip do with this data and what is our legal basis for processing this data?

Use of data which is necessary to perform a contract

We collect, store and use certain data as it is necessary in order for us to provide you with access to our Services under the relevant terms and conditions of those Services. This includes:

• providing you with a consistent and personalised Service across different devices and platforms and parts of our Services, for example, ensuring that your progress is saved across devices and displaying your image to your social media contacts (for example, Facebook friends that also use our Services);
• to restrict customers from attempting to use our Services from a restricted territory or who are under-age and attempting to access inappropriate content in breach of our terms and conditions;
• to ensure that you are complying with our terms and conditions when you use our Services and taking any necessary action if you are not complying with our terms and conditions;
• to moderate any chat messages in chat forums, in order to restrict access to harmful, infringing or illegal content; and
• to process any refunds requested by you.

This applies to the following data:

• your username and password in order to allow you to log-in to your account for any of our Services from any device;
• your contact details so that we can contact you with material variations to the legal terms relating to the Services you have asked us to supply (in accordance with our terms and conditions);
• your contact details to communicate with you in relation to any competition that you have entered through our Services (in accordance with the relevant competition terms and conditions); and
• your name and contact details along with details of your device operating system, browser version and IP address, in order to offer you technical support or respond to service questions that you raise.

Use of data which is necessary for our legitimate interests

Sometimes, our use of your data is for purposes which are ancillary to the provision of the Services, which are desirable in order to make them operate more effectively or which are vital to the viability of particular Services. In those circumstances, we believe we have a legitimate interest in handling your data, and do not believe that this storage and use of your data will be of particular concern to you.

We use your data for our legitimate interests in the following ways:

• to detect and prevent fraud, hacking and/or cheating;
• to keep our Services secure;
• to provide you with any newsletter or blog that you subscribe to with us (which you can opt out of at any time using the privacy settings on our apps or through your profile settings on our websites);
• to customise the Services which are available to you;
• to improve the Services, for analysis and reporting purposes (this also includes using data to log any crashes in our provision of the Services, so we may report such interruptions (in this regard, we may use a third party to assist us));
• to track your use of our Services across our different games and platforms in order to provide you with a seamless experience;
• to connect social media accounts which you have actively linked with our Services (such as Facebook or Google+);
• to understand your preferences and personalise your experience of our Services;
• to send you push notifications with service-related information for certain Services (which you can choose not to accept or turn off by visiting the settings section of your device and selecting the appropriate setting);
• to communicate to you details of our events, promotions or updates that you may be interested in, both within a game and via user acquisition campaigns on third party applications;
• to help us manage and provide you with advertising, as further described in the 'Third Party Advertising' section below;
• to serve you with targeted advertising on our websites in certain circumstances so that the advertisements you see are more relevant to you;
• to record your preferences in relation to advertising and marketing communications; and
• to provide you with any customer support you have requested.

Data we use with your consent

We collect, store and use your email address, if you have provided your consent, in order to send to you promotional offers and provide marketing for Services that we believe may be of interest to you (see below for details of our marketing communications). We also use your data to offer you other Services which we think may be of interest to you by email where you have given your consent. You can withdraw your consent for these email communications at any time by clicking the “Unsubscribe” button at the bottom of our emails.

On our apps, some of the third party advertising companies that we work with also collect, use and store data about you with your consent when you access and use our Services in order to provide you with targeted advertising. You can withdraw your consent for targeted advertising on our apps at any point using the privacy settings available on our apps. (On our websites, you can choose to disable targeted advertising at any point using your privacy settings on our websites. Note however that we will still serve you advertising when you visit or use our websites but this will no longer be tailored to you or your preferences). For more details on our relationship with third party advertising companies, please see the section below titled 'Third party advertising companies'.

Anonymous data

We will also collect anonymised details about visitors to and use of our Services for the purposes of creating aggregate statistics or reporting purposes. However, no single individual will be identifiable from the anonymised details we collect for these purposes.

Does Miniclip send marketing communications and how can I opt out?

If you have provided your consent, we may send you marketing communications in relation to our other Services that we think may be of interest to you via email. These messages will only ever be in relation to the named other similar Services of Miniclip that you have provided your consent to receive. We do not provide your data to third parties so that they can send you direct marketing communications via email or push notification without first obtaining your consent. Please also see the section below regarding third party advertising for more information about advertising activities on our Services involving third parties.

You can opt-out of receiving any direct marketing communications that we (or any third party to whom we have disclosed your personal information with your consent) may send you by using the unsubscribe mechanism in those marketing emails, or, in relation to push notifications, by choosing not to accept them or by turning them off by visiting the settings on your device and selecting the appropriate setting.

What does Miniclip do to protect data?

We have implemented appropriate physical, electronic and managerial security procedures to safeguard the data we process from loss, misuse, and alteration and to help prevent unauthorised access, maintain data security and to ensure that we correctly use the data we hold in accordance with the purposes for which we collected that data.

We use industry-standard practices such as encryption, physically secured rooms, firewalls and password protection systems to safeguard the confidentiality of any personal information that we might collect from you. For example, your email address and password will be encrypted which will make it very difficult for someone to discover and use them without our authorisation. We also strive to limit access to your data to employees performing a legitimate business function which requires them to access and use your data in order to supply you with our Services. We review our security procedures periodically to consider appropriate new technology and updated methods to ensure we continue to protect your data.

Whilst we will do our best to protect your data, the transmission of information by you to us over the internet is not completely secure and we cannot guarantee the security of data during its transfer over the Internet to us. Any such transmission is at your own risk. Once we have received your data, we will use the procedures and security features outlined in this section to try to prevent any unauthorised access.

How long does Miniclip keep hold of data?

We will keep data only for as long as it is relevant and useful for the purpose for which it was originally collected and otherwise where required by law. This means that we will only retain your data for the minimum reasonable time period to allow us to provide our Services to you. If you decide to delete an account you have with us, certain data does stay on our Miniclip system for administrative purposes and to defend or bring any legal action. Please email us at dataprotection@miniclip.com for information regarding retention periods.

What data is shared with or accessed by third parties?

Miniclip will share your data with various third parties (including our affiliate companies in other countries) as follows:

• We use third parties to help us manage your information and the Services, such as our cloud service provider, customer service and technical support provider, software and game developers, marketing delivery companies and IT maintenance providers. These are companies who are authorised to process data on our behalf only as necessary to provide the relevant services to us and cannot use it for their own independent purposes.
• Some games available via our websites are only "iFramed". This means that, while such content looks like it is on our websites, it does not belong to us and is served by a third-party game developer and links to their site. In such instance your use of those games will be subject to their terms and conditions and privacy policy. However, the data you provide to them may also be shared with us and be subject to this Privacy Policy as well. We will let you know when you are playing an "iFramed" game through a pop-up message.
• We share your data with our third party payment providers where you have specifically asked us to complete any in-app or in-game purchases. These third-party payment providers may also ask us to share your data with them to confirm the nature of any payment transaction and to verify your identity and payment details.
• You may create a profile for certain Services which may be visible to other users. Other users can choose to add you as a friend. You can change your settings through the 'edit profile' function in our Services at any time.
• We or our third-party partners may disclose your personal data where we are required or permitted to do so by law or to protect or enforce our rights or the rights of any third party. We may also share your data with third parties to prevent fraud, abusive or unlawful behaviour or to demonstrate our compliance with other terms or laws.
• Miniclip may disclose your information to third parties in connection with a purchase, transfer or sale of Miniclip.
• If you choose to access any Services through a third party platform such as Facebook or Google, then that third party may collect other information about you (including about your use of the Services) in accordance with its terms and own privacy policy and sometimes they share some data with us. They have their own privacy settings which you can access on that third party platform in order to change your preferences.

We require any third parties processing your data on our behalf to process it in accordance with your rights, our instructions and applicable law.

Third party advertising companies

We want to make sure that the advertising on our Services and marketing is relevant and interesting to you and our other customers.

To achieve this, we use third-party advertising and technology companies to serve ads and/or provide aggregated data to assist in serving ads when you visit or use our Services. This includes third party technology companies which collect data about you in order to build a profile of your preferences based on your activities when you visit or use our Services. We also use these companies to automatically collect data from you when you use our Services in order to help us identify the ads that are served to you and what you do after seeing those ads. In addition, we share data with providers of web analytics tools, such as Google Analytics, which we use to analyse your use of the Services. A list of the third party advertising and technology companies that we use, and links to their privacy information, is available here: List of advertising partners used in Miniclip's games.

These third party advertising companies collect, store and use data by integrating cookies, tracking code and other software in our Services. The relevant data collected by these third parties will vary but may include your unique device ID, geo-location details, advertising ID, IP address, information on your interaction with advertising, browsing history and other technical information. Data which you provide to Miniclip when using our Services may also be captured by these third parties.

On our apps, these third party advertising companies will collect and use your data to provide you with targeted advertising that is relevant to you and your preferences with your consent. You can control and withdraw your consent at any time by visiting the game settings page of our apps. If you do not provide or withdraw your consent to receive targeted advertising on our apps, or if we know you are under the age of 16, then we will still serve you advertising when you visit or use our Services but this will no longer be tailored to you or your preferences.

On our websites, we rely on our legitimate interests to allow third party advertising companies to collect and use your data to provide you with targeted advertising that is relevant to you and your preferences. Nonetheless, you can still control and disable such targeted advertising by visiting the settings page of our websites. If you disable targeted advertising on our websites, or if we know you are under the age of 16, then we will still serve you advertising when you visit or use our Services but this will no longer be tailored to you or your preferences.

In some cases the third parties advertising companies that we work with will also use the data that they collect for their own purposes, for example they may aggregate your data with other data they hold and use this to inform advertising related services provided to other clients.

Please see our Cookies Policy for more information on the third party advertising companies which collect, use and store data about you, and the use of cookies and other tracking technologies on our Services.

Advertising our products on third party websites and mobile

We will also share your data with social media or other similar platforms, so that you and other people can see relevant content on that platform. For example, we may use the Facebook Custom Audiences service and share your Facebook ID or advertising ID in a protected format with Facebook so that we can: include you in a custom audience that we will serve relevant advertising content to on Facebook; or create an audience of other Facebook users based on the information in your Facebook profile. You can opt-out from Facebook Custom Audiences in your Facebook privacy settings.

We will also share your data with user acquistion partners, via our third party mobile measurement service provider, for the purpose of telling you via third party applications about our new products, promotions and features that maybe of interest to you.  We will also work with these partners to monitor the success of such campaigns.  You can object to such use in accordance with the "How do I erase or restrict or update my data?" below.

Will data be transferred overseas?

The data that we collect from you will be transferred to, and stored at, a destination outside of the UK or the European Economic Area ("EEA"), including the US (where some of our third-party cloud-based servers are based). It may also be processed by other Miniclip group companies or by one of our third-party partners operating outside of the UK or EEA. This transfer is required to host the Services, provide you with technical and customer support services, perform backups of your data, and to process your payment details if you make any in game purchases.

Please be aware that countries which are outside the EEA may not offer the same level of data protection as the UK or countries within the EEA, although our collection, storage and use of your personal data will continue to be governed by this Privacy Policy. Transfers of data to Switzerland are guaranteed to be afforded the same level of data protection as in the EEA on the basis that Switzerland benefits from an adequacy finding from the European Commission.

We will always ensure that any other such transfers of data are conducted in accordance with relevant laws in order to ensure adequate protection. Where we transfer data outside the EEA, other than to Switzerland, we have included in our contracts with the relevant third parties the standard contractual data protection clauses approved by the European Commission for transferring personal information outside the EEA (these are the clauses approved under Article 46.2 of the General Data Protection Regulation, which is the relevant data protection law).

You can find out further information about the rules on data transfers outside the EEA, including the mechanisms that we rely upon, on the European Commission website here https://ec.europa.eu/info/strategy/justice-and-fundamental-rights/data-protection_en.

Children's privacy

Most of our Services are not specifically targeted at children. Where the Services are being used by children under the age of 16, we recommend parents and guardians regularly clear their browser cache and/or browsing history to clear cookies. Please see our Cookies Policy for more information.

For some Services however it may be possible for those under the age of 16 to register an account and access games and other content (with parental or guardian consent). Where children under 16 sign up and use our Services, their account is limited to those aspects of the Services which we deem appropriate for children.

If you are under 16 and have signed up to use any of our Services, we will only collect and process the following limited data about you:

• your date of birth and email address. We collect, use and store this data as it is necessary in order to allow you to log-in and use the Services you have registered for. We need to use your date of birth to make sure that users are not attempting to access Services which we deem inappropriate; and
• data which is necessary to respond to a question or one-off request for customer service support from you. We believe we have a legitimate interest in handling your data for this purpose as it allows us to provide you with customer and technical support and a better experience of our Services and the benefits of this outweigh any potential impact on you in storing and using your personal information in this way.

If you are under the age of 16 and in the EEA, your email address is encrypted. This means that your email address will be put into a secret code, so no one can use it, including us.

As your email address is encrypted, we are not able to contact you by email after registration for any purpose, including to send service emails or promotional offers.

For parents/guardians:

If you would like to review or amend your child's information, ask to have it deleted, and/or refuse to allow any further collection or use of your child's information, then please send an email to our Data Protection Officer at dataprotection@miniclip.com. Please be sure to include your email address and a telephone number where we can reach you. To protect your child's privacy and security, we will take reasonable steps to help verify your identity before granting you access to the information that we collect and maintain about your child.

We recommend that parents take the time to communicate and educate their children about Internet Safety. Please see the Miniclip Internet Safety webpage for information on Internet Safety: https://www.miniclip.com/games/page/en/internet-safety/

How do I erase or restrict or update my data?

If you no longer wish for us to use your data, please get in touch. Please note that this may affect the provision of our Services to you, for example, you may not be able to enter any competitions or make any in game purchases.

You have the right to ask us to amend or update any of your data which is out of date or incorrect, or change the way we may use your data.

You also have the right to ask us to delete any personal information which we are holding about you. You can also object to our processing of data about you, and we will consider any valid objections which you raise. In certain circumstances we may not be able to stop using your personal data but, if that is the case, we'll let you know and tell you why.

If you wish to opt out of receiving any promotional emails or newsletters you can do so by clicking on the "unsubscribe here" link at the bottom of each email. To change or delete push notifications, visit the settings section on your device and select the appropriate setting, or change the settings on your browser if you are accessing any of our websites.

If you have an account with us, in certain games, you can view and edit your profile to change the settings in order to prevent others being able to add you as a friend.

If you wish to exercise any of the above rights, please get in touch with us by emailing dataprotection@miniclip.com.

How do I get a copy of my data?

You have the right to ask us to provide you with copies of personal data that we hold about you at any time. Please contact us by emailing dataprotection@miniclip.com.

How can I contact Miniclip?

If you have any questions about this Privacy Policy or wish to request a copy of the data which we hold about you, please contact our Data Protection Officer at dataprotection@miniclip.com or alternatively you can send a letter to: Miniclip SA, Case Postale 2671, 2001 Neuchâtel, Switzerland or Miniclip, Legal Department, Holborn Gate, 326-330 High Holborn, London WC1V 7PP.

Miniclip SA has designated Miniclip (UK) Limited as its representative in the European Union, who can be contacted at Miniclip at Legal Department, Miniclip (UK) Limited, Holborn Gate, 326-330 High Holborn, London WC1V 7PP.

What can I do if I have a complaint?

If you are not satisfied with the way your query or complaint is handled by Miniclip, please let us know by emailing us at dataprotection@miniclip.com. If you are still unhappy, you may refer your complaint to your local data protection regulator. For example, in the United Kingdom this is the Information Commissioner’s Office and in Switzerland it is the Federal Data Protection and Information Commissioner (FDPIC).

List of advertising partners used in Miniclip's games

As set out in our Privacy Policy, the following advertising partners are integrated into some or all of our games. These advertising partners may process personal data of our end users in accordance with their own privacy policies.

The links to the third party privacy policies below were last checked on 5th October 2018.

MOBILE

WEB

This content was last updated on 5th October 2018.

WAR WINGS PRIVACY POLICY

Last updated: 24th May 2018.

If we make any changes to this policy, we will post them here. Please check back regularly to keep informed of updates to this Privacy Policy.

You can find information about us and how we collect, use and store your personal data in each section of this Privacy Policy:

• Who we are
• Third party sites
• What data do we collect from you?
• What do we do with this data and what is our legal basis for processing this data?
• Does Miniclip send marketing communications and how can I opt out?
• What do we do to protect data?
• How long do we keep hold of data?
• What data is shared with or accessed by third parties?
• Will data be transferred overseas?
• Children's privacy
• How do I erase or restrict or update my data?
• How do I get a copy of my data?
• How can I contact Miniclip?
• How can I contact Sixjoy?
• What can I do if I have a complaint?

Who we are

Miniclip SA (a company registered in Switzerland (registration number CH-645-4103964-1), whose registered office is at Rue des Beaux-Arts 8, 2000, Neuchâtel, Switzerland)(“Miniclip”) and Sixjoy Hong Kong Limited (an affiliate of Miniclip SA), with its registered office address at Room 907, Wing Tuck Commercial Centre, 177-183 Wing Lok Street, Hong Kong (“Sixjoy”), are (except where otherwise stated in this policy) joint data controllers of the personal information that we collect from you in the mobile game promoted as “War Wings”.

Miniclip, Sixjoy and their affiliated group companies are referred to in this Privacy Policy as "us", "we" or "our". A reference in this Privacy Policy to either “Miniclip” or “Sixjoy” is a reference to that specific entity.

We are committed to providing fun and exciting digital entertainment. This Privacy Policy explains how and what personal data relating to you we may use in relation to the mobile game marketed as “War Wings” (“Game”, or “Services”).

This Privacy Policy governs the collection, storage and use of personal information by us via the Services. It provides you with details about the personal information we collect from you, how we use your personal information, and your rights regarding the personal information we hold about you. Please read this Privacy Policy carefully.

If you have any questions about this Privacy Policy, wish to exercise any of the rights described in this Privacy Policy, with respect to the Services, please at first instance contact the Data Protection Officer of Miniclip SA, at dataprotection@miniclip.com or alternatively you can send a letter to: Miniclip SA, Case Postale 2671, 2001 Neuchâtel, Switzerland or to Miniclip at Legal Department, Holborn Gate, 326-330 High Holborn, London WC1V 7PP.

If you wish to contact Sixjoy, including to exercise any of the rights described in this Privacy Policy, please contact warwingsdpo@sixjoy.com.

Third party sites

Please note that the Services may contain links to websites or other services owned and operated by third parties. We do not endorse any such third-party services. We are not responsible or liable for anything that happens to you when you visit or use these services. Miniclip strongly recommends that you review the privacy policies and cookie usage notices of these third parties.

What data do we collect from you?

In this Privacy Policy, "data" means any personal data about you which could identify you (by itself or in combination with other data) such as your name, address, email address or an online identifier.

We collect data about you in a number of different ways. In this section, we explain the different ways we collect personal data about you and the ways in which that information will be used. For more detail on how we use your data, please see the section titled "What do we do with this data?".

Please see our Cookie Policy for more information on the use of cookies and other tracking technologies on our Services.

We will usually collect and store the following data, to the extent possible, about you when you access and use the Services:

Data you give us directly:

• Registration Data (Guest Account): if you set up an account, we process your Nickname, Generated Player ID, device ID;
• Transaction Data: when you complete any in-app or in-game purchases, such as buying in-game currency and other items, we will collect data relating to your purchase history; and
• Support Data: we will collect information you provide to us if you raise a complaint, ask for technical support or report a problem with the Services, including Device ID, Player ID, app version, battery, WiFi strength, free space on device, OS version, network, platform, carrier and country.
• Email Marketing Data: we will collect your email address for the purposes of sending you marketing information, promotions and other offers over email (with your permission).

Data we collect when you use the Services (whether or not you register with us):

• Device Data: data about your location, device type and model, operating system and version and platform; data about your device's browser version, network, and IP address and log data such as session duration.
• Chat Data: your communications to users on the Services;
• Game Data: data relating to your game statistics and progress, including Player ID, IP Address, game statistics, progress and purchase history.
• Analytics Data: data relating to your use of the Game, including Advertising ID and log data (session time, load time, server pings, actions, crash data).
• Registration Data (Social Media): where you are accessing the Services through a third-party account such as Facebook or Vkontakte, we will collect certain information relating to your account with those third parties including:
  • Facebook: Name, Facebook ID, gender, profile picture, friends list (if user voluntary requests this)
  • VKontakte: userID, nickname, legal name, gender, profile picture, friend list. You can manage the data which is shared by such third parties with us by amending your preferences using the privacy settings which these third parties provide on their platforms.

What do we do with this data and what is our legal basis for processing this data?

Use of data which is necessary to perform a contract

We collect, store and use certain data as it is necessary in order for us to provide you with access to the Services under the relevant terms and conditions of those Services. This includes:

• providing you with a consistent and personalised Service across different devices and platforms and parts of the Services, for example, ensuring that your progress is saved across devices and displaying your image to your social media contacts (for example, Facebook friends that also use the Services);
• to ensure that you are complying with our terms of use when you use the Services and taking any necessary action if you are not complying with our terms of use;

This applies to the following data:

• Registration Data (Guest Account, Social Media)
• Transaction Data
• Support Data
• Chat Data
• Game Data

Use of data which is necessary for our legitimate interests Sometimes, our use of your data is for purposes which are ancillary to the provision of the Services, or which are desirable in order to make them operate more effectively. In those circumstances, we believe we have a legitimate interest in handling your data, and do not believe that this storage and use of your data will be of particular concern to you. This applies to the following data: Device Data and Analytics Data.

We use such data for our legitimate interests in the following ways:

• to detect and prevent fraud, hacking and/or cheating;
• to keep the Services secure;
• to customise the Services which are available to you;
• to improve the Services, for analysis and reporting purposes (this also includes using data to log any crashes in our provision of the Services, so we may report such interruptions (in this regard, we may use a third party to assist us));
• to understand your preferences and personalise your experience of the Services; and
• to send you push notifications with service-related information for the Services (which you can choose not to accept or turn off by visiting the settings section of your device and selecting the appropriate setting).

Data we use with your consent

Miniclip collects, stores and uses certain data if you have provided your consent. This applies to Email Marketing Data. For Email Marketing Data, Miniclip uses this information in order to send to you promotional offers and provide marketing for Services that Miniclip believes may be of interest to you (see below for details of Miniclip’s marketing communications).

You can withdraw your consent at any point, which means you will no longer receive these marketing messages. Miniclip also uses your data to offer you other services which Miniclip thinks may be of interest to you by push notifications where you have given your consent or chosen not to opt-out.

Does Miniclip send marketing communications and how can I opt out?

Yes, Miniclip may send you marketing communications in relation to their other services that Miniclip thinks may be of interest to you via email or push notification. These messages will only ever be in relation to other similar services of Miniclip. Miniclip does not provide your data to third parties so that they can send you direct marketing communications via email or push notification without first obtaining your consent.

You can opt-out of receiving any direct marketing communications that Miniclip (or any third party to whom Miniclip has disclosed your personal information with your consent) may send you by using the unsubscribe mechanism in those marketing emails, or, in relation to push notifications, by choosing not to accept them or by turning them off by visiting the settings on your device and selecting the appropriate setting.

What do we do to protect data?

We have implemented appropriate physical, electronic and managerial security procedures to safeguard the data we process from loss, misuse, and alteration and to help prevent unauthorised access, maintain data security and to ensure that we correctly use the data we hold in accordance with the purposes for which we collected that data.

We use industry-standard practices such as encryption, physically secured rooms, firewalls and password protection systems to safeguard the confidentiality of any personal information that we might collect from you. For example, your email address and password will be encrypted which will make it extra hard for someone to discover and use them without our authorisation. We also strive to limit access to your data to employees performing a legitimate business function which requires them to access and use your data in order to supply you with our Services.

We review our security procedures periodically to consider appropriate new technology and updated methods to ensure we continue to protect your data.

Whilst we will do our best to protect your data, the transmission of information by you to us over the internet is not completely secure and we cannot guarantee the security of data during its transfer over the Internet to us. Any such transmission is at your own risk.

Once we have received your data, we will use the procedures and security features outlined in this section to try to prevent any unauthorised access.

How long do we keep hold of data?

We will keep data only for as long as it is relevant and useful for the purpose for which it was originally collected and otherwise where required by law. This means that we will only retain your data for the minimum reasonable time period to allow us to provide the Services to you.

To the extent you have a legal right to request deletion of your personal information, then upon receipt of a lawful, valid request from you to delete your personal information, we will inform you of the action that we have taken in response to such request within thirty (30) days.

If you decide to delete an account you have with us, certain data does stay on our system for analytics, administrative purposes and to defend or bring any legal action. Please email us at dataprotection@miniclip.com or warwingsdpo@sixjoy.com for information regarding retention periods.

What data is shared with or accessed by third parties?

We will share your data with various third parties (including our affiliate companies in other countries) as follows:

• We use third parties to help us manage your information and the Services, such as our customer service and technical support provider, game developer and analytics services provider. These are companies who are authorised to process data on our behalf only as necessary to provide the relevant services to us and cannot use it for their own independent purposes.
• You may create a profile for certain Services which may be visible to other users. Other users can choose to add you as a friend. You can change your settings through the 'edit profile' function in our Services at any time.
• We or our third-party partners may disclose your personal data where we are required or permitted to do so by law or to protect or enforce our rights or the rights of any third party. We may also share your data with third parties to prevent fraud, abusive or unlawful behaviour or to demonstrate our compliance with other terms or laws.
• Miniclip or Sixjoy (as applicable) may disclose your information to third parties in connection with a purchase, transfer or sale of Miniclip or Sixjoy (as applicable).
• If you choose to access the Services through a third party platform such as Facebook or Vkontakte, then that third party may collect other information about you (including about your use of the Services) in accordance with its terms and own privacy policy and sometimes they share some data with us. They have their own privacy settings which you can access on that third party platform in order to change your preferences.

We require any third parties processing your data on our behalf to process it in accordance with this Privacy Policy, your rights and our instructions.

Will data be transferred overseas?

The data that we collect from you will be transferred to, and stored at, a destination outside of the UK or the European Economic Area ("EEA"), including Canada, Hong Kong, Germany, Australia and Brazil. This transfer is required to host the Services, provide you with technical and customer support services and perform backups of your data.

Please be aware that countries which are outside the European Economic Area may not offer the same level of data protection as the United Kingdom, although our collection, storage and use of your personal data will continue to be governed by this privacy policy. Transfers of data to Switzerland, however, are guaranteed to be afforded the same level of data protection as in the United Kingdom on the basis that Switzerland benefits from an adequacy finding from the European Commission.

We will always ensure that any other such transfers of data are conducted in accordance with relevant laws in order to ensure adequate protection. Where we transfer data outside the European Economic Area, other than to Switzerland, we have put in place the following measures to ensure it is afforded appropriate protection: the European Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2004/915/EC (in the case of transfers to a controller) and Decision 2010/87/EU (in the case of transfers to a processor).

Children's privacy

The Services are not specifically targeted at children. If you are under the age of 16 and use the Game, certain functionality may be limited (for example, chat will be restricted).

How do I erase or restrict or update my data?

If you no longer wish for us to use your data, please get in touch. Please note that this may affect the provision of the Services to you, for example, you may not be able to enter any competitions or make any in game purchases.

You have the right to ask us to amend or update any of your data which is out of date or incorrect, or change the way we may use your data.

You also have the right to ask us to delete any personal information which we are holding about you. You can also object to our processing of data about you, and we will consider any valid objections which you raise. In certain circumstances we may not be able to stop using your personal data but, if that is the case, we'll let you know and tell you why.

If you wish to opt out of receiving any promotional emails or newsletters you can do so by clicking on the "unsubscribe here" link at the bottom of each email. To change or delete push notifications, visit the settings section on your device and select the appropriate setting, or change the settings on your browser if you are accessing any of our websites.

If you wish to exercise any of the above rights, please get in touch with us by emailing dataprotection@miniclip.com or warwingsdpo@sixjoy.com.

How do I get a copy of my data?

You have the right to ask us to provide you with copies of personal data that we hold about you at any time.

Please contact Miniclip by emailing dataprotection@miniclip.com or Sixjoy at warwingsdpo@sixjoy.com.

How can I contact Miniclip?

If you have any questions about this Privacy Policy or wish to request a copy of the data which we hold about you, at first instance please contact Miniclip’s Data Protection Officer, at dataprotection@miniclip.com or alternatively you can send a letter to: Miniclip SA, Case Postale 2671, 2001 Neuchâtel, Switzerland or to Miniclip at Legal Department, Holborn Gate, 326-330 High Holborn, London WC1V 7PP.

Miniclip SA has designated Miniclip (UK) Limited as its representative in the European Union, who can be contacted at Miniclip at Legal Department, Miniclip (UK) Limited, Holborn Gate, 326-330 High Holborn, London WC1V 7PP.

How can I contact Sixjoy?

If you wish to contact Sixjoy, including to exercise any of the rights described in this Privacy Policy, with respect to the Services, please contact warwingsdpo@sixjoy.com.

The EU representative for Sixjoy is Tencent International Service Europe B.V. and who can be contacted via email at eudataprotection@tencent.com.

What can I do if I have a complaint?

If you are not satisfied with the way your query or complaint is handled by Miniclip or Sixjoy, please let us know by emailing us at dataprotection@miniclip.com or eudataprotection@tencent.com.

If you are still unhappy, you may refer your complaint to your local data protection regulator. For example, in the United Kingdom this is the Information Commissioner’s Office and in Switzerland it is the Federal Data Protection and Information Commissioner (FDPIC).