PRIVACY POLICY FOR OUR GAMES
MVH Group Ltd, Bulgaria (or “we”), is a developer and publisher of games
and mobile game applications that are made available via app stores including
the Apple App Store, Google Play Store and Amazon Appstore,
and other platforms such as Facebook (our “Games”).
We are responsible for providing Games and related services (such as support
services, our website, competitions, newsletters, advertising etc.) (collectively, the “Services”) and for data processing.
In this data privacy policy, we will share what “personal data” or
“personally identifiable data” mean, how we collect and what we do with the
data, and why we do so. We will also let you know how we protect your data,
when data will be deleted and which rights you as a data subject have. Personal
data in this context are all individual information about personal or objective
circumstances of a specific or identifiable natural person, e.g. your name,
address or e-mail address, but also IP addresses and device-related
identifiers. When you use our Games or access our Services, personal data is
processed.
If you have specific questions about your personal data, deletion of your
personal data or similar things, you can contact us via e-mail at customers.mvh.group@gmail.com
Mobile app and app permissions
When downloading our Games as mobile apps or purchasing in-app items inside
the Games through an app platform (e.g. Apple App Store or Google Play Store),
you submit certain information to that platform, in particular your account
data, e.g. your name, device identifiers, e-mail address and payment
information. We have no influence on this data collection and are not
responsible for it.
Some features of our Games require the app to access certain functions and
services on your device. Depending on which mobile operating system you are
using, this may require you to accept certain app permissions. We will now
explain to you what those permissions are as follows:
iOS
Push notifications: If you select OK in the “Allow push notifications” pop
up, you allow the app to notify you of certain events inside the game, even if
the app is not currently open. You will then receive alerts as sounds, messages
and/or symbol indicators (an image or a number on the app icon).
Game Center: We also provide a connection to the Game Center service from
Apple, which is subject to Apple’s Privacy Policy, available at https://www.apple.com/privacy. When you
use the service, e.g. to receive notifications about achievements, the personal
information you share is visible to other users and can be read, collected, or
used by them. You need to consider which personal information you choose to
submit.
Android
External Storage (Change or delete the contents of your external storage,
read the contents of your external storage): These functions allow the app to
temporarily store content on your device. The app only uses its own memory
storage for this purpose. Other data on the external storage will not be erased,
modified or read.
Internet Connection (Get Internet data, view full network access, network
and Wi-Fi connections): These functions allow the app to obtain data from the
Internet and to determine whether a connection to the Internet exists via a
Wi-Fi network or via a mobile data connection. This is to prevent that larger
amounts of data may use too much of limited data volumes.
Deactivate hibernation: This function allows the app to deactivate the idle
state of the phone (e.g. to display videos without switching off the screen).
As a safeguard to protect your privacy, all app permissions are optional,
except for the technical permissions needed for the app to run. You can always
decline (by clicking “no” or “do not accept” in your device settings). You can
also revoke app permissions afterwards by changing the corresponding settings
on your device. The purpose of asking for those app permissions is to keep you
and the game updated on game updates, game related news and notifications. The
legal basis is your consent in accordance with the European data protection
requirements under Art. 6 para.
1 lit. a GDPR.
(Personalised) Advertising
We use advertising technologies in our Games and exchange ad identifiers
with external advertising networks to allow personalised
advertising within our Games. We and our trusted partners collect and process
the Apple Advertising ID (IDFA) on iOS devices and
the Google Advertising ID on Android devices to allow interest-based
advertising and measure the success of aforementioned advertising. Advertising
IDs are unique but at the same time non-personalised
and non-permanent identification numbers provided by your operating system and
device. We will now explain how to activate or deactivate the advertising
technologies within the mobile apps as follows:
iOS
Open the “Settings” application of iOS and select
the “Privacy” menu item and then the “Advertising” sub-item. If you activate
the “Limit ad tracking” option, we can only take limited measures such as
identifying unique users or combating fraud. In the same menu you can always
delete the IDFA (“Reset Ad-ID”), then a new ID is
created which is not merged with the data collected earlier.
Android
Open the “Settings” application and select the “Google” menu item.
Depending on your device, this option may not be visible on the main menu but
you may use the search function at the top of the Settings menu to find it.
From there, select the “Ads” sub-item and activate the option “Opt out of Ads Personalisation” to prevent the creation of profiles and
the display of interest-based advertising. You can delete the advertising ID in
the same menu at any time (“Reset advertising ID”), then
a new ID will be created which will not be merged with the previously collected
data.
As a safeguard to protect your privacy, we only store personal information
temporarily. Additionally, the user can deactivate interest-based advertising
in the device settings as described above. We also ensure that our external
service providers are committed to a high level of data protection by
concluding data protection agreements. The purpose is to improve our Games and
provide the player with more relevant ads. 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. The legal basis is the legitimate interest in
accordance with the European data protection requirements under Art. 6 para. 1 lit. f
GDPR, which we evaluated together with our data protection officer. In
addition, a data processing agreements were concluded
with external ad technology providers networks in accordance with the
requirements of Art. 28 GDPR.
Data collected in our Games
When you use our Services, we collect and store certain data about you to
provide our Games and Services, to improve your overall user experience and to
provide you with customised offers (e.g. certain
in-game offers that you might like based on your playing behaviour):
Temporary unique device identifiers (e.g. IDFA and Android ID) and random
device identification numbers (client IDs) and user identification numbers
(user IDs)
Progress in the game and playing behaviour (e.g.
how fast you reached a certain level)
In-app purchases (e.g. how many Coins you purchased for which price)
Game version (e.g. v1.0.1)
Language Settings (e.g. system language English)
IP address (e.g. 192.0.316.example or 2a02:7122:8337:1112:bdb2:651f:example)
Approximate location based on IP range (e.g. “London & surrounding
area”)
Internet connection speed (e.g. 120 Mbit)
Date and time of your game session (e.g. 12:45 on 27.07.2018)
Browser and version (e.g. Chrome v65 or Safari 11.1)
Operating system (e.g. MacOS, Android)
Hardware (e.g. Intel processor)
You may be aware that your IP address and other unique identifiers can
theoretically be traced back to you or to the device you are playing on. As a
safeguard to protect your privacy, we delete or anonymise
identifiers in our database and most of the technical data after your game
session. Any other data will only be used for statistical purposes to optimise the game, to serve interest-based ads (more
information can be found below under “(Personalised)
Advertising”) and to offer a more personalised gaming
experience to you as our players (e.g. automatically setting the difficulty
depending on your playing behaviour). The purpose of
temporarily storing this data is to establish a connection with our game
servers which is necessary for providing our Games and Services as well as to
provide a more personalised gaming experience to you.
The legal basis are the contract with you in
accordance with Art. 6 para.
1 lit. b GDPR and also the legitimate interest in
accordance with the European data protection requirements under Art. 6 para. 1 lit. f
GDPR. In addition, we apply the aforementioned safeguards to protect your data.
What are my rights?
You can contact us at any time if you have any questions about your rights
regarding data protection or if you wish to exercise any of the following
rights:
Right to withdraw your consent in accordance with Art. 7 para. 3 GDPR (e.g.
you can contact us if you wish to cancel a previously given consent to a
newsletter)
Right to access your data in accordance with Art. 15 GDPR (e.g. you can contact us if you would like to know what data we
have stored about you)
Right to correct your data in accordance with Art. 16 GDPR (e.g. you can contact us if your e-mail address has changed and we
should replace your old e-mail address)
Right to have your data deleted in accordance with Art. 17 GDPR (e.g. you can contact us if you want us to delete certain data
that we have stored about you)
Right to limit data collection in accordance with Art. 18 GDPR (e.g. you can contact us if you do not want us to use your e-mail
address for newsletters, but only to send absolutely necessary e-mails)
Right to take your data with you in accordance with Art. 20 GDPR (e.g. you can contact us to receive your data, if you want to
upload it to another service)
Right to object how your data is handled in accordance with Art. 21 GDPR (e.g. you can contact us if you do not
agree with any user analytics procedures as described within this privacy
policy)
Right to send complaints to the supervisory authority in accordance with Art. 77 para. 1 f GDPR (e.g. you can contact the data
protection supervisory authority directly)
Deletion of data and storage periods
Unless otherwise stated, we will delete or anonymise
your data as soon as it is no longer needed (e.g. your e-mail address after you
have unsubscribed from our newsletter). Your data will also be deleted or anonymised automatically, if and when the mandatory storage
period expires (e.g. those required by law for payment transactions). Such data
may be needed for longer periods of time for legal reasons. You can request information
about all personal data we have stored about you.
Last updated: August 2018