We hope that through this Policy we will introduce you to how we handle your personal data and provide you with access to and control over your personal data.
Please read and fully understand this Policy before using this Product. If you have any questions about this Policy, or have any complaints or suggestions, please contact us through the contact information shown in this Policy.
This Policy aims to explain to you the following:
·How we collect and use your personal Data
·Data processing using third-party services
·How we protect your personal data
·How to access and control your personal data
·How we show you ads.
·Minor data processing
·How your personal data flows around the world
2.How We Collect and Use Your Personal Data
In the process of providing services, we may collect your personal data as follows. These data are crucial to the realization of various functions of this Product. We will use this data to help us develop and improve this Product to provide better services. We will use your personal data in strict compliance with the purposes set out in this Policy. When we need to use data for purposes other than those described in this Policy, or to use personal information collected for other purposes, we will inform you in advance and obtain your consent.
2.1.Types of personal data we collect and their use
This Product is a full-featured game product. Depending on this Product’s functional properties, we will collect your different types of personal data in different scenarios and use it to fulfill the needs of respective functionality.
2.1.1. Pre-activation service
In order to strictly abide by the laws and policies of the relevant countries or regions, we need to use pre-activation services to determine your country or region. During pre-activation, we will send your IP address, country code (MCC), mobile phone language, system version and other information to our server. This information is only used to determine your country or region, thus providing you with agreements and services that are consistent with that country or region. This information will be deleted within a short period of time after it is completed and will not be permanently saved.
2.1.2. Basic Information Acquisition
In order to provide you with a stable service, we will collect the following relevant information for locating, analyzing and improving problems. The information obtained is only used for this purpose. Some will upload our server, others will not be stored.
Upload data stored on the server: Get user time, unique device identifier (for example, IDFV of iOS device and Android ID of Android device), operating platform type, operating system and version running on the system or device, CPU information (such as model number, The number of CPUs present, frequency and instruction set support flags, read screen size, memory size.
Don’t do server-stored data: sensor flags, unique ad identifiers for iOS and Android devices, which graphics APIs are in use and languages.
2.1.3. Record game settings and progress
To make it easier for you to find and use previous game records, we provide you with records of the progress of the game, including but not limited to points, points, virtual currency, etc., as well as recording user’s game settings, including but not limited to sound, vibration, etc. When you log in this Product, you can choose to skip the previously passed levels without starting over. We also record your game’s highest score and game achievements for leaderboard features. We provide the ability to delete history, you can delete the history as needed.
2.1.4. Provide better service quality
In order to improve the service quality of this Product and thus provide you with better services and new services, we will collect the following information during your use of this Product, and the information obtained will only be used for this purpose.
Statistics: Including each interface’s dwell time, game running, click settings, click on leaderboards, click to collect, click on honors, click on draw/unlock button and the number of gold coins at the time, the game is over, active click incentive ads after the game is over, collect Active clicks on the interface to motivate ads, autoplay video ads and duration, achievement activation, click on the ads button.
2.1.5. Anti-fraud and anti-cheat
In order to prevent fraud and prevent cheating, and to provide you with better services and better ecological environment. We needs to obtain your information including: application package name, application time information, application version number, installation path, application size and other application information; CPU, screen resolution, total memory and other hardware general information; country code, start-up time, system time and other system information; mobile phone brand, mobile phone model, memory and other device hardware information. The information obtained will only be used for this purpose.
2.1.6. Cloud service
We provide you with a wealth of features and services through cloud service interfaces, such as event and product updates. In order to ensure the operation of cloud services, we need to collect some necessary data, including: application information such as application package name, application version, and application installation time; system information such as country code, system language, and system time zone; screen resolution and other devices Information; network information such as operators.
2.2. Your Personal Data We Obtained from Third Parties
For now, we do not obtain your personal data from any third party. If certain services may require your personal data from a third party, we will notify you in advance and obtain your consent.
2.3. No Special Categories of Information
We do not request or intend to collect any “special categories of information” such as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
2.4. We need to get some of your rights
2.4.1. Get your location information (based on GPS and mobile network)
This authorization will allow us to provide you with a location-based check-in feature service. You can refuse authorization in the pop-up window or close the authorization in the settings. This information will not be traced.
2.4.2. Installing Shortcuts
This permission is used to install shortcuts on the launcher so that users can use the game more easily and improve the game experience.
2.4.3. Modifying System Settings
This permission is used to adjust the volume and brightness levels when using the game.
2.4.4. Finding Accounts on the Device
This permission is used to see if you are logged into Google Play and APP Store to provide you with the appropriate installation and download services.
This privilege is used to start the game to provide services for you.
2.5. In-App Purchases
This Product enables in-app purchases. We do not process payments for in-app purchases nor have access to your credit card information.
Payment transactions: in order to maintain a record of your transaction history and provide restore purchase service for payments on Google Play or iOS App Store, we needs to obtain your information including: UUID, transaction ID, purchased time, cost, product purchased, IP Address details of transactions linked to user ID, and device details including OS version, phone model, device root status.
To make it easier for you to open web pages, we provide web page caching. We allow websites you visit to store some web page data, such as web page pictures and other information. When you next visit the site, the site will directly read the saved data for display, thereby speeding up the opening of the page. The cache will expire due to expiration or manual removal. We will not upload any cached content.
4.How we share, transfer and disclose your personal data
We will share, transfer or disclose your personal data to third parties with your consent or your explicit instructions. In addition, in order to improve the quality of our services, we may also share your personal data with third parties or transfer or disclose them to third parties in the following situations.
We may share your personal data in relation to this Product to provide a more consistent experience and better service in our products. We guarantee that it will treat your personal data in accordance with the purposes and requirements shown in this policy. If your product wishes to use your personal data for purposes other than those set out in this Policy, we will seek your consent again.
We may share your personal data with our affiliates and guarantee that it will treat your personal data in accordance with the purposes and requirements shown in this Policy. If an affiliate wishes to use your personal data for purposes other than those set out in this Policy, we will seek your consent again.
4.3. Third-Party Service Providers
We may cooperate with third-party service providers in specific areas to provide services for you. Third-party service providers may collect data when providing services, and they will ensure that they follow our instructions, follow the purposes and requirements set out in this Policy to process your personal data, and take appropriate confidentiality and security measures to ensure data security.
We may share such information to:
·Our analytics providers. We use third-party analytics such as Unity，Flurry for the purposes of delivering our services, conducting analysis, and research. The device data we share with such providers are encoded.
·Third-party advertising partners. We have contracted with certain third-party advertising networks that assist us in delivering advertising to you that allows us to continue offering this Product for free or at low cost.
·Advertising partner’s third-party tracking provider. We allow our advertising partners to track impressions, clicks, installs or other advertising campaign performance indicators through their tracking providers for the purposes of measuring their advertising campaign performance. They may use their own third-party tracking providers.
·Tracking providers. In order to collect statistics on source of installation and provide you with better services, we use Facebook and Branch to collect information on installation of users’ mobile applications.
We may contract with additional Partners or change existing Partners in the future to perform any services in connection with this Product. These changes shall be updated from time to time or promptly in case of material changes in our data processing practices.
4.4. Sharing for legal reasons
Without prejudice to the requirements of this Policy, we may need to share or disclose your personal data in certain circumstances, such as compliance with laws and regulations, mandatory requirements of government directives, and to protect the legal rights of you, us, and third parties; prevent or deal with fraud, security or technical issues.
4.5. Changes to the company’s organizational structure and status
If our organizational structure or the company’s survival status has changed (such as a reorganization, merger or bankruptcy), your personal data may be transferred to the changed corporate entity or our affiliates (“Data Transferee”) . The data transferee will continue to be bound by the requirements of this Policy.
5.Data processing when using third-party services
In addition, we may use third-party interfaces to improve product functionality. For example, the search module will request search engine interfaces based on user-entered keywords to obtain search suggestions and keyword-related web content.
6.How we store and protect your personal data
6.1. Personal Data Security
We are committed to safeguarding your personal data. We use a variety of possible security technologies and procedures to protect your personal data from unauthorized access, use, modification, destruction, or disclosure. We have mainly adopted the following security measures:
a) We store your personal data in a computer system located in a controlled location and take security measures such as encryption.
b) We only allow Machbird employees who have to process relevant data for the purpose of product operations to access personal data and require them to perform strict confidentiality obligations.
c) We are constantly striving to ensure the security of your personal data, and we use full encryption to protect your information from unauthorized access, use, modification, destruction or disclosure during the transmission of data.
d) We will be more careful in the transmission and storage of your specific types of personal data, and take technical security measures such as encryption to ensure data security.
In the event of personal data security incidents, we will promptly notify you in the form of push notifications or announcements in accordance with the requirements of laws and regulations. We will inform you of the basic conditions and possible impacts of the security incidents, the treatment measures we have taken or will take, and you can advice on self-prevention and reduction of risks, remedial measures for you, etc. We will promptly handle security risks such as system vulnerabilities, cyber attacks, virus attacks, and network intrusions.
6.2. Storage period of personal data
We will store your personal data for the necessary period of time for data collection and processing purposes. Beyond the above period, we will delete or anonymize personal data.
Game data are all stored locally and are available throughout the application lifecycle. You can manually delete this data at any time.
The access records, application execution logs, and application debug logs of the cloud service are stored on the server for a short period of time, typically 7 days. If this period expires, we will delete or anonymize the data.
Application usage data is pseudo-persistently stored on the server for data analysis. You can access, edit or delete your data in the manner described in section. After you log off your account, for technical reasons, we may not be able to immediately delete your personal data, but we will delete it at the next system update, and we guarantee that we will not continue to process your personal account during your time to log off the account until we update the system data.
7.How to access and control your personal data
7.1. Accessing, Modifying Your Personal Data
You can requires access and edit your personal data by e-mailing us following section 10 herein.
7.2. Change your consent
If you wish to change the scope of our consent for your personal data processing, you can choose to contact us by e-mail following section 10 herein. Please note that the various features of this Product require some basic personal data to function properly. When you withdraw certain personal data processing consents, some of the product’s functions may not function properly.
Upon receiving your withdrawal agreement, we will no longer process your corresponding personal data.
7.3. Delete Your Personal Data
You can ask us to delete your personal data when:
a) Your personal data is no longer necessary for the purpose of collection or processing;
b) You have withdrawn our consent to your personal data processing;
c) Personal data is illegally processed;
d) According to legal requirements of EU member states, we are obliged to delete your personal data.
For technical reasons, we may not be able to delete your personal data immediately. We will delete this data when the system is updated. After we receive your request to delete personal data until the system is updated, we will not do any processing of your collected personal data.
7.4. In response to your request
Upon receipt of your request, we may verify your identity first and may ask you to provide the necessary information for authentication.
We will respond to your request and communicate with you in an appropriate manner 30 days after we receive your request. If necessary, we may extend the aforementioned period (up to a maximum of 30 days) and notify you of the reason for the extension of the period on the 30th day after receiving your request. If we have reason to believe that we do not need to take any action on your request, we will inform you of our decision and give you a corresponding explanation 30 days from the date of receipt of your request.
We will do our best to help you solve related problems. If you are dissatisfied with our response, you can file a complaint with the relevant regulatory authority or file a lawsuit with a jurisdictional jurisdiction.
8.1. In General
We use advertising to fund our Services and to make our games available for free. We offer this Product for free or at low cost and in order to do that we need to share information we collect from you with our third-party advertising partners. As a safeguard to protect your privacy, we only store personal information temporarily. The information collected helps us to improve our websites and Games and – at the same time – keep our Games free for a wide player base.
If you are an European Economic Area (EEA) – based user be aware that: Before sharing any information with our advertising partners for the purposes of personalized advertising, we always ask for your consent, given when you press START at relevant button at loading of this Product. We allow our advertising partners to show personalized ads to you only if you have pressed START in relevant pop-up window and so consented to the sharing of your personal information for the purposes of personalized advertising. You can withdraw your consent pursuant to the section 8.5 herein. When you decide to withdraw your consent of if you do not provide your consent, you may still see the same number of ads on your device; however, these ads may be less relevant because they won’t be based on topics you like, your interest, behavior, demographics, etc. Our advertising partners may continue to show you ads based on the content of the application you are using.
8.2. In-game advertising (i.e. when you view ads in Our Games)
To enable us to show in-game ads, we may send your advertising ID and IP-address to advertisers (or ad networks) to enable them to find appropriate ads to serve to you in our games and on third-party properties. You can control and limit our use of your advertising ID in your device settings. We do not control which specific ads are shown in our games (it is controlled by ad networks), but we do blacklist certain categories of ads.
Advertising IDs are used by the ad networks for a number of purposes (please refer to the Privacy Notices of our advertising partners listed here) including:
·limit the number of times you see the same ad;
·ensure they are dealing with humans with real devices and not ‘automated’ bots;
·serve you with advertisements likely to be relevant to you based on your advertising ID engagement with other brands and ads, also recorded using your advertising ID and using your general geographic area. Other brands buy advertisement placement via an ad network or ad exchange to advertise their products in this Product. The ad network or ad exchange acts as intermediary between the other game companies and Us. In order for an ad network to charge the company buying the ad, clicks from the ad and potentially installs of other developers’ applications party apps are tracked. Views, clicks, and installs from ads are measured using Advertiser ID;
·keep track what games you have used to market you similar kind of games. IP-address is typically used by advertisers to broadly see the general geographic area you are coming from for example country, state, and sometimes at city level).
8.3. View of Our ads on third-party services
We also advertise this Product in other apps by asking ad networks to serve them to audiences that will be interested in them (determined using Advertising IDs).
The Advertising IDs are used by the ad networks for a number of purposes (please refer to the Privacy Notices of our advertising partners listed here) including:
·measuring ad effectiveness (looking at aggregated views, clicks and installs they generate through their advertising in other publishers’ games);
·informing players, that have not been playing for a while, about new content in this Product. We give a list of these users in the form of Advertising IDs to an ad network. Ad network then shows these users ads about the new content;
·not showing ads on a game which a player is already playing. We can send a list of active players in the form of Advertising IDs to an ad network. Ad network then excludes these players from seeing the ad;
·marketing games to a group of potential players.
8.4. WHO CAN SHOW PERSONALIZED ADS TO YOU?
Please see the list of advertising providers that are allowed to show personalized advertising and review their data processing practices, including the technologies they use for the purposes of personalized advertising here.
8.5. Refused to receive personalized advertising
You can always choose whether to receive promotional emails, text messages, telephone calls and letters from us or third parties. You can also choose to no longer receive personalized advertisements by sending us e-mail following section 10 herein.
When we receive your request to refuse to receive personalized advertising, we will no longer use your personal data for the above mentioned commercial promotion. However, based on our free services, you will still receive non-personalized ads. Your corresponding information will not be used to mark or identify you personally, but will only be used to calculate the frequency of advertisements, advertising reports, or to screen for fraud and dishonesty.
In addition, as we explained in section 4.3, some of the personalized advertisements are provided by third-party service provider. If you wish to opt out from these third-party services, please contact us following section10 herein.
9.Treatment of minor data
This product is not intended for minors under the age of 16 (or the minimum age set by the domestic law of EU member states). For such minors, we will process their information only with the consent of the minor guardian, to the extent permitted by law.
We will use relevant technical means and do our utmost to verify whether the processing of minor information has obtained the consent of the guardian. If we find that we have collected personal data of minors without first obtaining the verifiable guardian’s consent, we will try to delete the relevant data as soon as possible.
If you have any questions or suggestions about this Policy, or you need to exercise your data management power to manage your privacy data, please feel free to contact us at: firstname.lastname@example.org
If you find any violation of this policy, please contact our DPO at: email@example.com
12.How Your Personal Data Circulates Globally
As we provide products and services worldwide, we may transfer your personal data to other jurisdictions outside your country of use, or may be subject to the needs of a global business. These jurisdictions include, but are not limited to, Singapore, the United States, and China.
Please note that we only return demographic information to China, which do not include information on individual user identities. At the same time, in order to provide you with better services, our third-party partners may transmit your data to other countries. For example, in order to detect robots or cheating, we have purchased a Chinese supplier’s traffic monitoring service. The merchant may return the user information to China in order to assist us in analyzing whether there is cheating in the user.
These jurisdictions may have different personal data protection legislation and do not even have a legal system in place. In these circumstances, we will endeavor to take various measures to ensure the security of your personal data. For example, before transmitting your personal data, we will obtain your explicit consent and take security measures such as encryption and de-identification in the transmission process; after your personal data flow to these jurisdictions, we will also protect your personal data base on the requirements of this Policy. We will also strive to adopt various measures stipulated in Articles 46 and 47 of the EU General Data Protection Regulation to escort your personal data.
Last updated: Aug 23, 2019