Privacy Policy

INTRODUCTION

This privacy policy (“Policy”) informs you of your choices and our practices in relation to your Information (as defined below). In this Policy, “MrM Programming”, “we” or “us” refers to the data controller under the applicable privacy laws. 

For the purpose of this Policy, “Information” means any information relating to an identified or identifiable individual.  This includes Information relating to your use of our mobile games (“Mobile Games”, “Games”). When you use the Mobile Games, you accept our rules and policies which set out how we handle your Information, and you understand that we collect, process, use and store your Information as described in this Policy. If you do not agree with this Policy, you must not play any of the Games. If you change your mind in the future, you must stop playing the Games and you may exercise your rights in relation to your Information as set out in this Policy.

1. PERSONAL INFORMATION WE COLLECT

We will collect and use the following Information about you:

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

Children

Our Games may be targeted for children. When Children under 16 use our Games, we advise that they obtain the permission of a parent or guardian.


2. HOW WE USE YOUR PERSONAL INFORMATION

We use your Information to:

  • Provide you with the Games. More in particular, we will use your Information to perform our contractual obligation towards you to allow you to create an account, play the Games (including as a guest) and remember your progress, allowing you to play Games with your friends, provide you with a (moderated) in-Game chat functionality (if applicable), and to allow you to make purchases via Google Play and IOS App Store, and maintain a record of such purchases. The Information we process when doing so includes your registration information, information you provide to us when playing the Games, identifiers, information you generate and display when playing the Games, and information regarding your use of the Games such as transaction records. 
  • Improve and monitor Game use. It is in our legitimate interests to improve our Games for our customers. When doing so, we may collect information we automatically collect or is generated about you when you play the Games, as well as non-personal information about your device such as battery, Wi-Fi strength, device manufacturer, model and operating system, and the amount of free space on your device. 
  • Provide you with support and to respond to your requests or complaints. If you reach out to us for support, we may use your Information to create a support account for you, respond and resolve your queries and complaints, facilitate support (e.g. retrieval of a forgotten password). When doing so, we perform our contractual obligation towards you. The Information we process when doing so may include your registration information, your identifiers, non-personal information about your device such as your Wi-Fi strength and the amount of free space on your device, and any other information about you collected via our customer support channels. 
  • Conduct analytics. It is in our legitimate interests to analyse the use of and inform, our Games, newsletters and advertising campaigns, and any other interaction or interest in the same. When doing so we will process information we automatically collect or is generated about you when you play the Games or interact with our newsletters and advertising campaigns to (a) create anonymised and aggregated data; (b) create segments of users who show particular characteristics or interests; and (c) conduct predictive analytics about your interests. 
  • Send you updates about in-Game offers and our other products and services that may be of interest to you. We will send you promotional offers, and information about other products and services that may be of interest to you. Where it is required, we will only do so where we have your consent. We do so via email, push notification or in Game. When doing so, we process your registration information and the analytics information above. Your consent can be withdrawn at any time by following the unsubscribe mechanism at the bottom of each communication for emails or by adjusting your device settings for push notifications. 
  • Provide you with advertising. We will present you with ads and suggestions in our Games and elsewhere. These may be ads relating to our own Games or other services you may be interested in. These ads and suggestions may be tailored specifically to you. Where it is required, we will only do so where we have your consent. In situations where your consent is not required, or where we provide contextual advertising, we do so on the basis of our legitimate interests. If you no longer want to receive targeted advertising you can withdraw your consent in the Games settings. To tailor ads and to allow our advertising partners to tailor ads, we process information we automatically collect or is generated about you when you play the Games and information received from third parties. 
  • Prevent fraud, defend MrM Programming against legal claims or disputes, enforce our terms and to comply with our legal obligations. It is in our legitimate interests to protect our users against online abuse and other anti-social or illegal activity, e.g. when moderating conversation in our Games. Furthermore, it is also in our legitimate interest to protect our interests by (1) monitoring Game use to detect fraud or any other user behaviour which prejudices the integrity of our Games, (2) taking steps to remedy aforementioned fraud and behaviour, (3) defending ourselves against legal claims or disputes, and (4) enforcing our terms and policies. When doing so, we will process the Information relevant in such a case, including information you provide us, information we automatically collect about you, and information which is provided to us by third parties. 
  • Conduct surveys. From time to time, we may ask you to participate in surveys we conduct which are in our legitimate interest because they help us understand our userbase and improve the Games. If you choose to participate, we process your registration information and any other information collected through the survey questions. 

3. WHO WE SHARE YOUR PERSONAL INFORMATION WITH

We share your Information with selected third parties, including:

  • Other players and users may see your profile information and in-game activities, as well as any other information you choose to share with them, such as chat data; 
  • Vendors and service providers we rely on for the provision of the Games, for example: 
    • Cloud service providers who rely on for data storage, including Amazon Web Services who are based in the U.S.;
    • Customer support solution providers, who help us manage and respond to our customer questions and complaints;
    • Analytics providers. we work with a number of analytics, segmentation and mobile measurement service providers who help us understand our userbase. This includes, but not limited to, Unity Technologies who are based in the US;
    • Social media. we integrate certain Facebook and Google software to enhance social media features in the game such as accessing your friends list and displaying your profile picture;
    • User acquisition: we work with a variety of user acquisition partners to help us report on the success of our marketing campaigns. We may use some of your personal information to participate in Custom Audience and Lookalike Audience programms, which enable us to display ads to both existing and prospective supporters when they visit one of our partners’ websites. We may provide an identifier (i.e. your Advertising ID or Facebook ID) to them so they can determine whether you are a registered account holder with them. Our ads may then appear when you access their websites.
  • Advertising partners. We are an ad-supported service. Subject to your settings, we provide certain Information to advertisers who will use them to serve you with ads in our Games, and we measure who sees and clicks on their ads. We also share advertising identifiers, along with the interests or other characteristics of a device or the person using it, to help partners decide whether to serve an ad to that device or to enable them to conduct marketing, brand analysis, personalise advertising, or similar activities.
  • Payment processors: For Mobile Games, we may use payment processors such as Google (if you run Android on your mobile device), Apple App Store payments (if you run IOS on your mobile device), etc.
  • Law enforcement agencies, public authorities or other judicial bodies and organisations. We disclose Information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to comply with a legal obligation, process or request; enforce our terms of service and other agreements, policies, and standards, including investigation of any potential violation thereof; detect, prevent or otherwise address security, fraud or technical issues; or protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organisations for the purposes of fraud protection).
  • Change of corporate ownership. If we are involved in a merger, acquisition, bankruptcy, reorganisation, partnership, asset sale or other transaction, we may disclose your Information as part of that transaction. 

Third Party Privacy Practices

If you access any Games through a third-party platform such as Facebook or Google (“Third Party Services”), you must understand that those Third Party Services may collect other information about you (including information you share with them directly or about your use of the Games) in accordance with their own terms and privacy policies.  The privacy practices described in this Policy do not apply to Third Party Services. Any links in the Games to Third Party Services do not imply that we endorse or have reviewed the Third Party Services.

Security 

Although we have in place security measures to maintain the privacy and integrity of your Information, unfortunately, the transmission of Information via the internet is not completely secure. We may also take extra steps to protect your Information and minimise the Information we process. For example, when you provide us with your password as part of the registration process, we apply a one-way hash.

4. WHERE WE PROCESS YOUR PERSONAL INFORMATION

Your Information will be processed by our employees and service providers in the European Economic Area (“EEA”), and in Switzerland and Israel, which are both countries which the European Commission has decided offer an adequate level of data protection.  Because countries outside of the EEA may have different data protection laws, we take steps to ensure all transfers are protected by adequate safeguards, including the use of standard contractual clauses approved by the European Commission, such as the transfers to our partners in the USA and South Korea.

5. HOW LONG WE STORE YOUR INFORMATION

Your Information is kept for as long as you are registered or using our games, and then for up to three years from the date you stop interacting with the games. When deleting Information, we will take measures to make the Information irrecoverable or irreproducible, and electronic files which contain Information will be deleted permanently.

6. YOUR RIGHTS

  • Access. You have the right to access Information, and to receive an explanation of how we use it and who we share it with. This right is not absolute. For example, we cannot reveal trade secrets, or give you Information about other individuals.
  • Erasure. You have the right to request deletion of your Information. We may need to retain some of your Information where there are valid grounds for us to do so under data protection laws. For example, for the defence of legal claims, respect freedom of expression, or where we have an overriding legitimate interest to do so, but we will let you know when this is the case.

Note that where the Information is held by a third party data controller, such as an advertising partner or a payment processor, we will use reasonable steps to inform them of your request, but we recommend you contact them directly in accordance with their own privacy policies to ensure your personal data is erased.

  • Objection and withdrawal of consent. You have the right to (i) withdraw your consent where you previously provided such consent; or (ii) object to our processing of your Information where we process such Information on the basis of our legitimate interests.
  • Portability. You have the right to receive a copy of Information we process on the basis of consent or contract in a structured, commonly used and machine-readable format, or to request that such Information is transferred to a third party.
  • Correction. You have the right to correct any Information held about you that is inaccurate.
  • Restriction. You have a right in certain circumstances to stop us processing Information other than for storage purposes.

7. CONTACT & COMPLAINTS

We welcome questions, comments, requests and complaints. These should be addressed to info@mrm-programming.art.

8. CHANGES

Any updates or changes to this Policy will be published here. If there are any significant changes, we will notify you through the website and in-Game.

Last updated: Jun. 4. 2021