PRIVACY POLICY

INTRODUCTION

This policy gives a description on how ManyGames (“us”, “we”, or “our”) collects, uses, shares, and protects information about you for our games on mobile devices, PCs, or on other platforms in order to provide you with excellent service and develop our products. 

All ManyGames activities regarding marketing, advertising, and other services (“Services”) are governed by this Privacy Policy. Using or accessing a Service on any platform means that you agree to the use of your information in compliance with this Privacy Policy. This policy also describes how you can withhold or withdraw your consent to the use of your data, including for targeted advertisements, and how to request to know about, correct, or delete the information we hold.

ManyGames is dedicated to transparency, data privacy, and security, and follows the strict regulations required by the CCPA (California Consumer Privacy Act) and GDPR (General Data Protection Regulation), as detailed in this privacy policy.

If you have any concerns, please contact us using the methods provided in the Contact Us section of this document. If you disagree with your information being used as described in this Privacy Policy, please do not install or use the Services. 

This Privacy Policy was last updated on 09.05.2022.

INFORMATION COLLECTION

Your information is collected at the start of using our games and/or other Services. We use this data to provide you with better game experiences and Services for the purpose of optimization, preventing fraud, and for marketing and advertising. We may also collect information from advertising platforms and partners and other third parties such as information about purchases and interests.

We may collect and process the following types of information:

• The type of your device, IP address, your game ID when using the app, and the country or region that you’re playing in;
• Your Advertising ID, Device ID numbers (for more see here Advertising IDs and Device IDs);
• Details about your gameplay on our app, including: amount of time played, if you have left the game on a specific level or if you have cleared it, and your scores on levels, and items you own or use;
• Purchase history on behalf of our payment service providers to keep a record on if a purchase has been successfully made. We do not collect credit card information;
• Information we collect via cookies and other similar technologies, as explained further below;
• Information which is needed for evaluation of possibility to enter employment relationship with you, such as: you name, email address, phone number, address, CV, Certificate of career, Transcript, English proficiency requirement;
• Information to communicate with the developer about your application for publishing, such as: Game title, link to your app, email address, your name, company name, the country, Portfolio;
• Communications between you and us, whether in-game, via email, or through social media channels. We keep a record of these communications to provide customer service by answering your questions and providing you with a better experience using our app;
• Information from our other group companies or other third party companies who have your consent or have other legal rights to share granted information with us (advertising networks and publishing partners, platforms). This may include your interests, other games you played, demographic and general location information. We use this information as described in this Privacy Policy;
• Information that you provide when you connect to your social network account when creating an account with us. This may include, but is not limited to: your name, address, email address, or other information; 
• Information as further set out in this Privacy Policy, including Social Sharing Features, Marketing, and Advertising.

If you choose not to connect to your social network accounts when using our games, we still collect anonymous information. There will still be device level identifiers and other information described here, but there will be no personally identifiable information.

We may ask for your approval to collect other information in some circumstances from you or your device. If this situation arises, we will inform you what information we are to collect, the reason we collect it, and how we will be using that information.

INFORMATION USAGE AND SHARING

Optimizing Our Services

We analyze and optimize to provide you the best possible products by using your information from the use of our Services and analysis of de-identified or aggregated data to analyze the performance of our games, troubleshoot problems, verify that our websites work properly on all devices, create updates, and develop and improve the quality of our products.

Customer Services

We may use your information delivered or provided directly to us in any communications in terms of customer service and through its channels will be used. We may use such information to contact you and to manage your account and relationship with us to improve your experience in our Services.  

Analytics and Research

We collect information using analytics tools such as third party analytics tools to see how you play our games or use our Services. Those tools may contain cookies or other similar tracking technologies. We may use your data for research and analytics purposes to engage with you directly. We may also create reports, analysis or similar services for use by us for the purposes of research or business intelligence.

Social and Community

There are social and community channels we use to communicate with our players. We receive your information only when you initiate interaction on those channels, and any information you provide may be used in connection with those channels. If you choose to interact with our channels, we may communicate with you through those channels and may republish your posts on those channels.

Social Sharing

Our Services may offer social sharing features and other integrated tools that allow you to connect with other media. You must be over the minimum age limit prescribed by the legislation in your country and local government to use such social sharing features which may, depending on the settings you set with the provider, share information with your friends or the public.

Job Applicants

We may collect personal data related to job applicants for positions advertised on our website. We do this in order to carry out the application process and to evaluate if the applicant meets requirements for each advertised position to be capable to enter employment relationship with us.

We do not request or intend to collect any Sensitive information according to art. 9 GDPR

Developers submitting their games for publishing

We may collect personal data related to developers who wish to submit their Games to ManyGames for publishing. We do this in order to carry out the application process and to have a possibility to contact the developers. We do not request or intend to collect any Sensitive information according to art. 9 GDPR. We do not transfer your personal data to third parties.

Other Usage and Sharing

The other main way that we use and share information is for marketing and advertising reasons. This usage is described in more detail below. We do not sell your information.

MARKETING

We may serve ads based on your information we collect about you within our Services, or place ads on third party websites, apps and internet-connected devices. This information may include: 

• Ad identifiers and other non-personal information collected from your device
• Your interactions with our game and Services, including game play information 
• Your age, country or region, and gender
• Other information collected from third parties who have obtained your consent or have a legal right to share it with us. 

This information is used to try to make sure that you only see marketing from us that you are interested in, including our other games. Please note that if you opt-out, you may still have advertisements in the game, but they will not be targeted advertisements (advertisements that are tailored to your interests by using your information).

Marketing Partners

There are various third party marketing partners we use to help market our games. With the help of your information collected when you use their services, they make assumptions to ensure that most relevant advertising that you would prefer to see is presented and evaluate the effectiveness of advertisements. 

This Privacy Policy does not cover the data use of our marketing partners, but they are required to have a legal basis to use your data for marketing purposes and to provide you the details on how it’s being used. 

ADVERTISING

Our games include advertising for third party products and services. We and our partners use your information to improve advertising and targeting for third party ads that are shown in our games. This information is used to make sure that the ads that you see might be of interest to you or relevant to you. 

This information may include: 

• Ad identifiers and other non-personal information collected from your device
• Your interactions with our game and Services, including game play information 
• Your age, country or region, and gender
• Other information collected from third parties who have obtained your consent or have a legal right to share it with us. 

Please note that if you opt-out, you may still have advertisements in the game, but they will not be targeted advertisements (advertisements that are tailored to your interests by using your information).

Advertising Partners

Non-personal identifiers and other information that is collected from your device when you play our games or use our Services may be shared with advertising partners in order to deliver ads to your device. Such information may be combined with information that our advertising partners collect separately to serve you with more relevant ads (targeted ads) and to enhance the accuracy of their targeting.

Ad Identifiers

We use ad identifiers that are non-permanent, non-personal identifiers such as the Android and/or Apple’s ID for advertising associated with your device, and similar technologies such as tracking pixels within ads to provide interest-based advertising. These technologies enable us and our third party advertising partners to recognize you and your device, allow our Services to interact with a third party social network or platform, and help our payment processors to complete your payment instructions.

YOUR RIGHTS AND CONTROL OF DATA

Right of Access/Right to Know

All users have a right to know what information we collect about them and how we use or share that information. If you wish to know which information we collect and hold about you, please use the methods described in the Contact Us section so we can verify your identity to provide you with requested information. You may only request your own personal information, and information will not be provided about other users. You will be required to follow the verification process listed under the “Verification Process” section below for security reasons. 

Right to correct your data

If there is any information we hold about you that you would like to correct, please let us know using one of the methods listed in the Contact Us section. We will make corrections as soon as possible. You will be required to follow the verification process listed under the “Verification Process” section below for security reasons. 

Right to have your Data Deleted

ManyGames retains the personal information described in this Privacy Policy while you use our Services in order to fulfill the purpose(s) for which it was collected, resolve disputes, conduct audits, or to fulfill legal purposes. All personally identifiable user data is retained for 6 months, and is permanently deleted afterward. If you wish to have your data deleted sooner, please contact us using the methods described in the Contact Us section. You will be required to follow the verification process listed under the “Verification Process” section below for security reasons.  Please be aware that if you want to delete your user ID completely, you may be asked to delete our game(s) from your mobile devices. 

There may be some information that will be maintained for record-keeping and legal purposes, which will not be shared with Third Parties unless legally required. Some de-identified information or data collected in aggregate that does not contain personally identifiable information may be retained as well.

Right to withdraw your consent

You may withdraw your consent to show personalized ads to you, by loading Terms & Privacy from your Game settings and following instructions in section Personalized Ads Consent Withdrawal in Privacy Policy.

Right to restrict processing

You can contact us if you want to restrict processing. You have the right, under certain circumstances, to restrict the processing of your Data. In this case, we will not process your Data for any purpose other than storing it.

Right to data portability

You have the right to request the data provided to us to be transferred to another data controller in some circumstances according to the laws in the country where you live.

Right to Object

You have the right to object to the processing of your personal data in some circumstances according to the laws in the country where you live.

Account Deactivation

You can deactivate the account you created in our game by contacting us using the methods described in the Contact Us section. You will be required to follow the verification process listed under the “Verification Process” section below for security reasons. Please note that your unspent virtual items will not remain or be recoverable after your account is deactivated.

Verification process 

If you request to know about, correct, or delete your personal information, you will be required to open the relevant game to send us a second message using the in-app messaging system to allow us to verify your user ID and use that ID to retrieve any requested information. Without this step we will not be able to verify and provide information related to your account.

Authorized Agents

Authorized agents, including parents or guardians, may make a request on behalf of the user in the same ways as listed above. If you have any questions, please contact us using one of the methods listed in the Contact Us section.

Opt Out 

To show you personalized advertisements in our apps we use specific advertising networks and their partners to deliver advertisements that are tailored to you based on a determination of your characteristics or interests.

To do so they use personal and non-personal information such as advertising identifiers, such as the Android advertising ID and/or Apple’s ID for advertising(IDFA) and/or other tracking technologies to enable and optimize this advertising procedure.

You can opt-out of the personalized advertisement experience at any time by following the instructions below from your device settings.

When you choose to opt-out, advertising networks will consider this choice as a withdrawal of consent to personalized advertisement experience and they will show only non-personalized advertisement which will not be based on your interests.

Here’s what you can expect when you use these settings:

• You might see the same number of ads as before, but they might be less relevant because they aren’t based on your interests.
• You might still see ads related to the content in an application or based on other non-personal information.

Preferences for Advertising

You may reset your ad identifier being used for interest-based advertising by changing the settings of your device, usually found under “privacy” or “ads”. You can also opt-out from your information being collected if you live in the USA, Europe or Canada by visiting

http://www.aboutads.info/choices/ (for US users),

http://www.youronlinechoices.com/ (for European users) or

http://youradchoices.ca/choices (for Canadian users).

If you would like to withdraw your consent for targeting advertisements, please contact us using one of the methods in the Contact Us section. Please note that if you opt-out, you may still have advertisements in the game, but they will not be targeted advertisements (advertisements that are tailored to your interests by using your information).

CHILDREN’S PERSONAL INFORMATION

We do not knowingly collect any personal information from anyone under the age of 13 (under the age of 16 in Europe), unless consent is given by a parent or legal guardian. If you are under 13 years of age (16 in Europe), please do not send us any information about yourself, and you should not use or attempt to use our Services. Some of our Services have age restrictions which may vary depending on countries, regions, OS, platforms, etc. If you are under the applicable age restrictions, please do not send us any information about yourself and you should not use or attempt to use our Services.

In the event we learn that we have inadvertently gathered personal information from children under the age of 13 (16 in Europe), we will take reasonable measures to promptly delete such information from its records in a secure manner. If you believe that we may have any information from or about children under the age of 13 (16 in Europe), please let us know by sending us an email at [email protected] 

Please note that all persons under the age of majority are required in their respective jurisdictions to have a parent or guardian read and accept this Privacy Policy and the Terms of Service on their behalf. Parents are encouraged to supervise their children’s use of our Services and to become familiar with the types of content available through our Services. Parents should oversee their children’s use of e-mail, forum and other online communications.

OTHER IMPORTANT POLICIES

[California Privacy Rights]

According to the California Consumer Privacy Act (CCPA), users who are California residents may request and obtain a list of the Third Parties to whom we have disclosed their personal information (if any) and the type of personal information disclosed to those parties during the prior calendar year. This list may be requested once per year and free of charge.

This notice to California residents is provided under California law, including the California Consumer Privacy Act (“CCPA”). This notice supplements our Privacy Policy by explaining your privacy rights if you are a California resident, providing our “notice at collection,” and providing certain mandated disclosures about our treatment of California residents’ information, both online and offline.

We also make the following disclosures for purposes of compliance with the CCPA:

1) Personal information we collected (in last 12months)

Player ID, your progress in the game (including a private conversation using our Services), device ID, hardware type, OS, device name, email address, advertising ID, IP and/or other location-based information, commercial information including financial information (such as methods of payment), name, password, shipping address, phone number, records of your use of our services, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies for purchase of digital and physical items, Internet or other electronic network activity information, your service request information, browser type, language, referring web address, your usage of the site

The sources of personal information from whom we collected are: directly from our users, third-party sites or platforms that you link with your registration account, analytics tools, social networks, advertising networks, and third-party services that update or supplement information we hold about you.

Please refer to our Privacy Policy concerning the categories of sources from which the personal information is collected and the purpose for such collecting.

2) Personal information we disclosed for a business purpose (in last 12months)

Internet or other electronic network activity information

We disclosed each category to third-party business partners and service providers, third-party sites or platforms such as social networking sites, and other third parties as described in the “Third-party Privacy Policy” section of the Privacy Policy.

3) We do not sell your personal information.

California residents have the right to “opt out” of the “sale” of their “personal information” to “third parties” (as those terms are defined in the CCPA).

We do not sell your personal information. But we may share your personal information for marketing purposes described in the section “Disclosure of Your Information” in the Privacy Policy. You may opt out of said sharing by following the steps described in the “section opt-out of marketing emails and other direct marketing” in the Privacy Policy.

Opt-out of marketing emails and other direct marketing

You may opt-out of receiving promotional communications, such as marketing emails from us by following the instructions in such communications.

Opt-out of targeted advertising

You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your Android or iOS device and selecting “Limit Ad Tracking” (Apple iOS) or “Opt-out of interest-based ads” (Android).

Third-party Privacy Policy

Some parts of our Services are provided by a third-party Service Providers, who may collect and record information about your use of our Services. Additionally, other companies that place advertisements on our Websites, Games and/or Applications may collect information about you when you view or click on their advertising through the use of cookies. We cannot control the activities of such third parties and cannot guarantee that they will adhere to the privacy and security practices same or similar to ours. You should contact them directly if you have any questions about their use of the information that they collect. We do not “sell” personal information of known minors under 16 years of age.

4) Privacy Rights of California Residents

You have the following rights under the CCPA.

Right to Access

If you are a California resident, you have the right to request, up to two times each year, access to categories and specific pieces of personal information about you that we collect, use, disclose, and sell.

Right to Request Disclosure of Your Personal Information

• You have the right to request that we disclosed to you any of the following:
• The categories of personal information we have collected about you;
• The categories of personal information we have disclosed about you for a business purpose;
• The categories of sources from which the personal information is collected;
• The business or commercial purpose for collecting personal information;
• The categories of third parties with whom we share personal information; and
• The specific pieces of personal information we have collected about you.

Right to Request Deletion

You have the right to request that we delete your personal information we have collected from you.

Right to Non-Discrimination

We will not discriminate against you because you exercised any of your rights under the CCPA.

If you want to exercise any of these rights, please feel free to contact us by sending an email to [email protected]

In the request, please provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative.

Your request may be denied if an authorized representative does not submit accepted information to subrogate or we are unable to verify your identity. If it is needed, we may ask some specific information about service usage your order history, or personal information in order to confirm your identification. Also, please describe in your request which right you wish to exercise and the scope of your request.

We will give you a notice confirming receipt of your request and informing how to manage your request promptly upon our receipt of your request. We will disclosed and deliver to you the required information within 45 days of receiving your verifiable request.

[Updates to Our Privacy Policy and Practices]

We may revise this Privacy Policy from time to time, as needed. We will notify you via our apps if there are any material changes that affect your use of our services, as required by applicable laws. Changes will also be posted on this website, and the revised version will be applicable immediately after it is posted or notice is received. If you continue to use our services after any changes have been made, you hereby provide your consent to the changes.

We commit to provide information to our users before using their information for any new purpose not stated in this Privacy Policy and give them the opportunity to opt out if they do not agree. If consent for information usage or processing is required by law or contract, ManyGames will comply with the law or contract. 

[Cookies]

Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer’s hard drive.

We use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some options of our Service.

Cookies we may use

• Maintain your session when you use the Service.
• Enhance security.
• Remember information about your browser and your preferences.
• Understand how people use the Services in order to improve the Service.

How to provide or withdraw consent

You can provide or withdraw consent to the use of Cookies and other Identifiers by setting your preferences within the cookie notice or by updating such preferences via the settings in your web-browsers. Additionally, you can manage preferences regarding Identifiers directly from within your own device settings and prevent – for example – the storing of third-party Identifiers. It is also possible, via relevant browser or device features, to delete previously stored Identifiers, including those used to remember your initial consent. You can manage your preferences and withdraw your consent by clicking the related opt-out link (where provided), by using the means indicated in the third party’s privacy policy, or by/ contacting the third party.

DATA SECURITY

We store the personal information that you provide on servers located in secured facilities and protected by industry-standard protocols and procedures to ensure security, such as passwords, firewalls and data encryption. In the unlikely event of a security system’s breach, we will attempt to notify all affected users electronically by posting a notice on our website and sending an in-app message or push notification. By using our Services, you agree that we may communicate with you regarding security and administrative issues related to your use of our Services.

INTERNATIONAL TRANSFER

Your personal information may be transferred to and processed in countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.

This means that when we collect your personal information, we may process it in other countries. However, we ensure appropriate safeguards are in place so that your personal information will remain protected in accordance with this Privacy Policy. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between us and third party service providers and partners, which require us to protect personal information they process from the EEA in accordance with European Union data protection law. It also includes transferring personal information to third party service providers and partners which are certified under the EU-US Privacy Shield.

CONTACT US

If you have any questions or concerns about this Privacy Policy, including to exercise any of your rights, there are several ways to contact us:

Via email to [email protected] 

For information collected under this Privacy Policy, the data controller is ManyGames, Inc. Our Data Protection Officer can be contacted here: [email protected] . 

This Privacy Policy was last updated on: May 09, 2022