Thank you for playing our game!
Please carefully read this new Privacy Policy when you useMinigames’s services. This Privacy Policy will come into effect for all existing users on Feb 17th, 2020. Your use of the Service from that day will be subject to this Privacy Policy.
When this Policy mentions “Rulebreakers”, “We”, “us” or “our”, it refers toMinigames. and its affiliates.Minigames is Data Controller for your Data under this Privacy Policy. When this Policy mentions “Service”, “Rulebreakers’s Service”, “Rulebreakers’s Game”, it refers to services, applications, games provided byMinigames. and its affiliates.
Rulebreakers is dedicated to protecting users’ privacy rights. This Privacy Policy has been crafted to inform users as to howMinigames collects, stores, uses, manages, processes, transfers, and implements any other possible operation to the Data that users provided during the use ofMinigames’s services.
By using the service, users are agreeing to the collection, use and any other ways of operation of their Data as outlined in this Privacy Policy.Minigames may amend the Privacy Policy from time to time according to the relevant laws, users can find the updated Privacy Policy here.Minigames will notify users if any substantial change occurs. Unless specifically announced, users are deemed as agreeing to any amendment made byMinigames.
TABLE OF CONTENTS
1. Data and How we Collect them
2. How We Use and Share Data
3. Your Rights and Options
4. How We Protect Personal Data
5. Children’s Privacy
6. Updates to Our Privacy Policy
7. How to Contact Us
8. How to Contact the appropriate Authority
1. Data and How we Collect them
We collect or receive Data in three ways:
(1) you directly provide Data to us, such as by creating an account or signing up for email alerts.
(2) we collect Data automatically, such as through cookies and related technologies.
(3) we receive Data from third party, such as social media platforms.
1.1 Data You Provide to Us
You may provide your Data to us when you choose to useMinigames’s Service. As we change our offerings and features from time to time, the Data we collect from you may vary depending on the services you are using. You don’t have to provide Data when we ask you for it, but if you decline you might not to be able to access or enjoy certainMinigames’s Services, offering or features.
In general, we collect data when you:
• Register aMinigames Account——email, nationality, gender. If you are from certain areas, we will collect your username and password;
• Voluntarily complete a customer survey or provided feedback on any of our message boards or via email——your interests regarding certain promotion, offering and feature;
• Enjoy certain game features——profile pictures;
• Update information in yourMinigames account;
• Participate in online discussions or otherwise interact with us;
1.2 Data We Collect Automatically
We may also collect Data automatically through technologies such as log files, web beacons, from you when you use our Services. We use these Data for purposes such as modifying or improving features, managing advertising, addressing technical issues, preventing fraud, and conducting data analytics. The type of Data that we automatically collect may vary, but generally includes:
• Device Data: IP address, CPU, device type, operating system, language, Storage, device ID, MAC, IDFA;
• Transaction Data: If you choose to make a purchase, we will collect transaction-related Data such as number of transactions, object of transaction, payment channel, your name, address, card number;
• Data of Use of the Service: gameplay data (such as game setting), promotion clicks, in-game interactions (such as friends list), referral/exit pages.
• There are some dates we collected are inevitable and essential for us to provide service to you, such as device ID, MAC. We may need to identify who you are with your device ID, MAC when you need our help with the services. We also need to collect the date regarding to your profile figure, such as your battle date and promotion interests to improve and advance our Application and services. You can click the button‘Do Not Sell My Personal Information’on the loading page if don’t want us to provide your profile figure information to any third parties.
•
1.3 Data Received by Us through Third Party
We may also collect your Data through Third Party. Such as:
• Data you provided to Third Party Services. If you link, connect, or login to yourMinigames Account with a third party service (e.g. Facebook, Game Center, Vkontakte <“VK”>). Such third party may provide us with your registration Data, profile Data and contact lists. Please bear in mind that Third Party controls your Data and you may vary your authorization and revoke consent through privacy setting on Third party’s platform.
• We receive Data from iTunes or Google Play and other platforms if you downloadedMinigames’s services.
2. How We Use and Share Data
2.1 Using Your Data
• We collect, use, store, and process your Data based on:
• The principle of lawfulness, fairness and transparency;
• Your consent;
• Specified, explicit and legitimate purposes;
• The extent that is adequate, relevant and limited to what is necessary in relation to the purposes;
• The manner that ensures appropriate security of the personal data;Performing the Terms of Use and the providedMinigames Serivces;
• Your and our legitimate interests;
• Necessity for protecting the vital interests of you;
• Other legal reasons.
To operate our business and to enhance and personalize your game experience, such as:
• Software：identify, fix, and troubleshoot bugs and service errors; provide software updates.
• In-game Communications：In-game Chat, sharing.
• Account：set up and maintain your accounts; activate or authenticate your games and save game progress and stats; recover your account, locate your account when you receive rewards.
• Gaming Functions：facilitate your gameplay on multiple devices when available; populate online leaderboards; enable online matchmaking; enable purchasing related functions; monitor, analyze, test, improve, and developMinigames’s Service.
• Marketing/Advertising：serve and measure the effectiveness of advertising; adhere to your preferences and to deliver dynamic content.
• Solve In-game disputes：keep our services safe and fair, resolve disputes, investigate.
• Compliance: help identify fraud and illegal behavior, comply with the law and to enforce our agreements and policies
To provide you support, including to:
• Help identify and troubleshoot problems with your account or games;
• To survey your opinions through surveys or questionnaires;
• Communicate with you and respond to your specific requests or questions;
• Help you find your friends or share yourMinigames related gaming experience;
• Enable to streaming your game within the game;
• Manage and send you confirmations and important Data about your account, purchases, subscriptions, and warranties.
To personalize our communications with you, including to:
• Communicate you with special offers on otherMinigames products and services we think you might like. You can always managing notification from you IOS device, please see: https://support.apple.com/en-hk/HT201925#manage-alerts for more information. Android device, please see: https://support.google.com/android/answer/9079661?hl=en for more information.
2.2 Sharing Your Data
We do not share personal Data that directly identifies you (such as your name, e-mail) with independent third parties unless
(i) with your prior authorization or consent;
(ii) if we are required to do so by law, legal process, or a reasonable request from law enforcement authorities or other government officials;
(iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity; or
(iv) if necessary, to protect the vital interests ofMinigames and any of its users (such as to prevent death, bodily harm, or serious damage to property), public security and public interests; or
(v) It is absolutely necessary to fulfilMinigames’s obligation and performMinigames’s Services, such as enabling users to make in-game purchase, store data and make in-game communications.
We may share anonymous or aggregated Data, or other Data that does not directly identify you with:
(i) Other players and users. Social features are a core component of our games, other players and users may, for example, see your profile data, in-game activities and read the messages you have posted;
(ii) Other companies and public authorities in order to identify and/or prevent fraud and illegal activity, we may exchange data with other companies and public authorities in response to lawful requests;
(iii) Advertising Partners and Social Media Platform. The Service includes features from our partners, such as social media interaction tools and in-game advertising. These partners may access your data and operate under their own privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices:
n Advertising Partners:
u Topon (https://www.toponad.com/).
u Appsflyer (https://www.appsflyer.com/).
u AWS
u Google Play
u Bugly
n Social Media Platforms: Facebook, VK, YouTube
2.3 International data transfers
Our Service is global by nature and your data can therefore be transferred to somewhere that is not your domicile. Because different countries may have different Data Protection and Privacy laws, we take steps to ensure adequate safeguards are in place to protect your data. Adequate safeguards that our partners may use include standard contractual clauses approved by EU Commission or other jurisdictions.
3. Your Rights and Options
You may exercise any of the rights described in this section by adjusting it in the Service and/or sending an email toMinigames.game88@gmail.com, and we will respond within 30 days. Please note that we may ask you to verify your identity before taking further action on your request.
3.1 Managing Your Data
You may access and update some of your Data through your Account settings. If you have chosen to connect yourMinigames Account to a third-party application, such as Facebook or VK, you can do so within the Game. You are responsible for keeping your Data accurate and up-to-date.
We securely stores your data by using the Storage service provided by Amazon Web Services (https://aws.amazon.com/) and Appsflyer (https://www.appsflyer.com/). You can find more information regarding Amazon Web Services’ Security, Identity, & Compliance at https://docs.aws.amazon.com/, Appsflye’s Data Security and Privacy Principles for Services at: https://www.appsflyer.com/product/security-and-privacy/.
3.2 Rectification of Inaccurate or Incomplete Data
You have the right to ask us to correct inaccurate or incomplete personal Data concerning you, should you have such requirement, please email toMinigames.game88@gmail.com.
3.3 Data Access.
In some jurisdictions, applicable law may entitle you to request copies of your Data held by us. You may also be entitled to request copies of Data that you have provided to us in a structured, commonly used, and machine-readable format, should you have such requirement, please email toMinigames.game88@gmail.com. For providing such copies, we may charge a reasonable fee based on administrative costs incurred thereupon and your requests to such copies shall not adversely affect the rights and freedoms of others.
3.4 Withdrawing Consent and Restriction of Processing
Where you have provided your consent to the processing of your Data byMinigames you can always withdraw your consent at any time, for example by turning off GPS location sharing in your mobile device settings. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.
Additionally, in some jurisdictions, you have the right to object and/or limit the ways in which we use your Data, in particular where
(i) you contest the accuracy of your Data;
(ii) the processing is unlawful and you oppose the erasure of your Data;
(iii) we no longer need your Data for the purposes of the processing, but you require the Data for the establishment, exercise or defense of legal claims; or
Should you have any above requirements, please email toMinigames.game88@gmail.com.
4. How We Protect Personal Data
4.1 Security Safeguards
Security of our users' Data is a priority atMinigames, and we are continuously implementing and updating administrative, technical, and physical security measures such as Access Control, Compressed Encryption to help protect your Data against unauthorized access, loss, destruction, or alteration. However, please note that no security measure is 100% perfect. This means we cannot guarantee the security of your Data and do not assume any responsibility for the unauthorized use or access to your Data under our control.
If you know or have reason to believe that yourMinigames Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your account, please email toMinigames.game88@gmail.com, and we will proceed with it within 30 days and respond to you as soon as possible when we have any update.
Please keep in mind that whenever you voluntarily disclose personal Data online through certain channel (for example on message boards, through email, or in chat areas), that Data can be collected and used by others.Minigames will take no responsibility whatsoever caused by reasons said above. Since disclosure of personal Data through certain channel may lead to disclosure of your personal Data, we remind you to use caution before such disclosing. Ultimately, you are solely responsible for maintaining the secrecy of your passwords or any account Data. Please be careful and responsible whenever you're online.
4.2 Data Retention and Erasure
We generally retain your Data for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your Data to provideMinigames’s Service to you, you can request that we erase your personal Data and close yourMinigames Account.
Note that if you ask us to remove your personal Data, we may retain your Data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.
4.3 Additional Information for California Residents.
Below, we provide information, as required under California privacy laws, including the California Consumer Privacy Act ("CCPA"), which requires that we provide California residents certain specific information about how we handle their personal information, whether collected online or offline. This section does not address or apply to our handling of publicly available information made lawfully available by state or federal governments or other personal information that is subject to an exemption under Section 1798.145(c) – (f) of the CCPA.
Categories of Personal Information We Collect and Disclose
Our collection, use and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident. The table below sets out generally the categories of personal information (as defined by the CCPA) about California residents that we collect, sell, and disclose to others for a business purpose. We collect these categories of personal information from the sources described above, in Section 1. Data and How we Collect them, and for the purposes described above, in Section 2. How We Use and Share Data.
Categories of Personal Information We Collected
Data Usage and Disclosure
Device Data: IP address, CPU, device type, operating system, language, Storage, device ID, MAC, IDFA;
Identify, fix, and troubleshoot bugs and service errors; generate device code; provide software updates.
Transaction Data: If you choose to make a purchase, we will collect transaction-related Data such as number of transactions, object of transaction, payment channel, your name, address, card number;
Enable purchasing related functions; enhance your game experience
Data of Use of the Service: gameplay data (such as game setting), promotion clicks, in-game interactions (such as friends list), referral/exit pages, geolocation information.
Help you find your friends or share your related gaming experience;
serve and measure the effectiveness of advertising; adhere to your preferences and to deliver dynamic content.
Profile figure, such as your battle date
To improve and advance our Application and services.
Categories of Personal Information Sold. The CCPA defines a "sale" as disclosing or making available to a third party personal information in exchange for monetary or other valuable consideration. We do disclose or make available personal information to third parties, in order to receive certain services or benefits from them. For example, we may allow third party tags to collect information such as browsing history through our Sites and Apps in order to better reach Users with relevant ads and to improve and measure our ad campaigns, or to display third party ads in our Services.
California Residents' Rights.
California law grants California residents certain rights and imposes restrictions on particular business practices as set forth below.
Do-Not-Sell. California residents have the right to opt-out of our sale of their personal information. You can click the button‘Do Not Sell My Personal Information’on the screen if don’t want us to provide your personal information to any third parties. We do not sell personal information about residents who we know are younger than 16 years old.
Initial Notice. We are required to notify California residents, at or before the point of collection of their personal information, the categories of personal information collected and the purposes for which such information is used. We will make this Privacy Policy available to Users online, in order to satisfy this requirement.
Requests to Delete. Subject to certain exceptions, California residents have the right to, at no charge, request deletion of their personal information that we have collected about them and to have such personal information deleted, except where an exemption applies. To send the request, please email toMinigames.game88@gmail.com, and we will proceed with it within 30 days.
Request to Know. California residents have the right to request and subject to certain exemptions, receive a copy of the specific pieces of personal information that we have collected about them in the prior 12 months and to have this delivered, free of charge by email, readily useable format that allows the individual to transmit this information to another entity without hindrance. To send the request, please email toMinigames.game88@gmail.com and we will proceed with it within 30 days. California residents also have the right to request that we provide them certain information about how we have handled their personal information in the prior 12 months, including the:
· categories of personal information collected;
· categories of sources of personal information;
· business and/or commercial purposes for collecting and selling their personal information;
· categories of third parties/with whom we have disclosed or shared their personal information;
· categories of personal information that we have disclosed or shared with a third party for a business purpose; and
· categories of third parties to whom the residents' personal information has been sold and the specific categories of personal information sold to each category of third party.
· California residents may make a Request to Know up to twice every 12 months.
We will respond to verifiable requests received from California residents as required by law.
Right to Non-Discrimination. The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA. Discrimination may exist where a business denies or provides a different level or quality of goods or services, or charges (or suggests that it will charge) different prices, rates, or penalties on residents who exercise their CCPA rights, unless doing so is reasonably related to the value provided to the business by the residents' data.
Financial Incentives. A business may offer financial incentives for the collection, sale or deletion of California residents' personal information, provided it is not unjust, unreasonable, coercive or usurious, and is made available in compliance with applicable transparency, informed consent, and opt-out requirements. California residents have the right to be notified of any financial incentives offers and their material terms, the right to opt-out of such incentives at any time, and may not be included in such incentives without their prior informed opt-in consent; we do not offer any such incentives at this time.
You Rights Under California's Shine-the-Light Law. We do not share personal information collected online with unaffiliated third parties for their own direct marketing purposes and will not do so unless you agree to such disclosure. If you are a California resident and you still believe your information has been shared or you have general questions about how your information may have been shared, you may contact us by requesting a list of the third parties to which we have disclosed personally identifiable information about you for their own direct marketing purposes. You may make one request per year. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. You may request this information in writing by contacting us via the contact details set out in Section 7. How to Contact us
5. Children’s Privacy
Protecting children's privacy online is extremely important toMinigames. We do not directMinigames’s Service to children under age of 13. We also do not intentionally collect personal Data from children through ourMinigames’s Service. If you are the parent or guardian of a child and you believe that we have inadvertently received personal Data about that child, please email toMinigames.game88@gmail.com. We will delete the Data from our records as soon as possible If you believe that we might have any Data from or about a child under the age of 13, please contact us as well.
6. Updates to Our Privacy Policy
We may update this policy from time to time to reflect changes in technology, law, our operations, or any other reason we determine is necessary or appropriate, so please review it frequently. We will indicate at the top of this policy when this policy was last updated. Please review this policy every time you access or useMinigames’s Service to make sure that you have reviewed the most recent version. We will notify you if there is any substantial change occurs.
7. How to Contact us
If you have any questions about this Privacy Policy, the data we hold on you, or you would like to exercise any of your data protection rights, please do not hesitate to emailMinigames.game88@gmail.com.
8. How to Contact the appropriate Authority
Should you wish to report a complaint or if you feel that we are not addressed your concern in a satisfactory manner, you may contact your local Data Protection Authorities at: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm or any other authorities in your jurisdiction