When you contract to use the Services, you accept our rules and policies regarding your personal information and you expressly consent to us collecting, processing, using and storing your personal information, as described in this policy.
Mattel163 Limited is the data controller for the purposes of the EU General Data Protection Regulation.
If you have any comments, questions or complaints regarding the processing of your personal information, you can contact us at email@example.com.
The Types of Personal Information We Use
This section describes the different types of personal information we collect and how we collect it. We will collect and use the following information about you:
Information you give us. You give us information about you:
when you register for the Services (including your email, nominated nickname, and information we import from your third party account (Facebook, Apple Game Centre, Google Play) in order to set up your profile, including your name as it appears on your social media profile, your profile picture and your friend list);
when you set up your profile for the Services (including information you voluntarily elect to provide in order to customise gameplay, such as gender);
when you submit your contact details to us (including your name, email address and physical address) as part of promotional activities for the Services; and
when you make purchases in the Services (in which case we will process the information you provide to us to facilitate the payment).
Information we collect about you. We automatically collect certain data from you when you use the Services, including your IP address, physical location and device information (such as device type, network data, operating system (hereto referred as “OS”)) and information regarding your use of the Services, such as date and time stamps of actions. We also collect and store your data each time you interact with us, for example, when you use in-app support to communicate with us. We also collect your voice data after you authorize us to use your microphone.
We take many special precautions to protect the privacy of children. In general, we define “children” as users under 13, but adhere to local definitions of “children” where a different age applies. If you are located in the European Economic Area and under the age of 16, you must not use the Service for any purpose unless with your parental or legal guardian’s prior consent.
In our Services intended for children, we do not collect personal contact information (like full name, e-mail address, phone number, or home address) from children without the consent of a parent or legal guardian, except in limited circumstances authorized by law.
We may collect some information (like IP address, mobile device unique device identifier (hereto referred as “Device ID”), OS, etc.) automatically and use technology like cookies to provide functionality and support our operations.
We do not ask for more personal information than is necessary for a child to participate in an activity.
We take steps to prevent children from posting or publicly disclosing personal contact information. Parents can contact us if they have any question on the collection, use or sharing of their children’s information.
How We Use Your Personal Information
We will use the information in the following ways and in accordance with the following legal bases:
Registration Information (ID on social media accounts including Facebook, Google Play, iOS Game Center (collectively, “Social ID”), Open ID, email address, avatar): We use Registration Information to set-up user accounts, allow users to log-in to the Services and provide Services to users. We use this information pursuant to our contract with you to provide the Services.
Device Information (Device ID, Device Type, Operating System, CPU, RAM, IP address, MAC address, language, time zone, voice data collected by microphone): We use this information to provide and improve the Services such as: to allow users to download and install the Services on their devices; to enable user voice chat with each other; to record and keep track of requests from users of the Services; to detect the user network and device status when the user is using the Services; and to correct bugs or errors that occur when the user is using the Services. Use of Device Information is necessary to perform our contract with you to provide the Services.
Contact Information (Name, Email, Address, Phone Number, Instant Messaging Account): We use this information to send notifications to users to inform them of our promotional activities and any rewards they are entitled to. We use this information with your consent.
General Location Information: Such information including the information of country level, but no more specific address will be collect without your consent. We use this information to provide some Location Based Services such as knowing what language to use and providing applicable Services to your location. Moreover, another function is forming a team with people nearby to play a game, but we use this information with your consent.
Social ID: We use this information to enable users to share their game achievement or game-play video on social media or invite their friends to the Services. We use this information with your consent.
Game Data (Level, Score and game log): We use this information to provide Services to users as it is the basis of our Services. Use of Game Data is necessary to perform our contract with you to provide the Services.We have a feature that you have the option of saving your in-game performance and interactions through a replay video. You may completely choose whether or not to use this feature. You also have a access to the replay recordings in your profile setting page.
User-generated Content： You have an option to share or upload content, like game-play video or game achievement screenshot. If you choose to share or upload content (including your and other users’ personal information, like username, profile photo and game performance) via our Service to an online bulletin board, chat room, or other online social media platforms, it will be publicly accessible. Make sure you have the rights to share any content included in your video or screenshot. Likewise, other users may also use the feature to share information that may contain you. We are not responsible how you choose to share personal data with the public or third parties, or how third parties use the feature to share information.
How We Store and Share Your Personal Information
In order to perform our contract with you, your personal information will be accessible from and will be processed on our servers (depending upon your location and the game server you select). Our servers are located in the United States.
We may share your information we collect with our corporate affiliates for internal support, such as helping us to make our Services more available and functional; providing technical, customer, billing, administrative, event planning, marketing or operational assistance to us.
We share your personal information with selected third parties in and outside your country, including:
third parties that provide services in support of the Services, including:
Amazon Web Services (“AWS”), located in the United States, that processes download and instalment information, account set-up and log-in information, user log information, purchase information, notification push information, social sharing information, on the basis of US-EU Privacy-Shield, for the purpose of hosting the Services;
Appsflyer, whose data center is located in Ireland, that processes Device ID and some of in-app activities, on the basis of your consent, for the purpose of the evaluation of its marketing services;
Facebook, located in the United States, that processes Device ID and some of in-app activities, on the basis of US-EU Privacy-Shield, for the purpose of the evaluation of its marketing services;
Apple, located in the United States, that processes of purchase information, on the basis of the performance of our contract with you, for the purpose of providing in-app purchase;
Google, located in the United States. We use Google Play that processes of purchase information, on the basis of US-EU Privacy-Shield, for the purpose of providing in-app purchase. We also use other Google services such as Google Admob, Google Analytics and Google Tag Manager, that process of information related to devices and demographic data, such as IP address, unique identifier or log information on the basis of your consent, to assist in providing analytics or marketing;
OneSignal, Inc., located in the United States, that processes of device information, IP addresses, location data, usage information(e.g. total usage duration, session count, first and last session time), on the basis of your consent, for the purpose of pushing notifications to your device to host our internal operations. You may in most cases opt out of receiving push notifications by going to your device “Settings” and clicking on “Notifications” and then changing those settings for closing notification on your device. Now, we also are working on an in-game button that will allow the user to turn off the notification. If you reject notification, you may still use our Service;
PlayFab,Inc., located in United States, that processes of game data only in-game behavior analysis, on the basis of the performance of our contract with you, for the purpose of internal hosting and maintaining the Services;
Vungle,Inc., located in United States, that processes of IP addresses, Device ID for the purpose of providing targeted content and advertising to users, so that advertisers may measure the effectiveness of this marketing, on the basis of the performance of our contract with you. Vungle’s Ad Services do not collect any information that can identify Users personally (such as name, address, or email address), you may contact us to close tailored and personalized ads;
o AppLovin Corporation, located in United States, that processes of IP address, Device ID and identifier for advertisers for personalized ads, on the basis of your consent. You are able to change those private settings for closing ads tracking on your device. You can also make choices out about data collection for certain companies by visiting http://preferences-mgr.truste.com/;
Microsoft HockeyApp, located in United States, that processes of device information( e.g. device type, version of the operating system, bundle identifier, bundle version, time stamp when the crash happened), on the basis of US-EU Privacy-Shield, for the purpose of crash analytic and reports. HocKey SDK only collect non-personal device information on either iOS and Android, we use it for the purpose of hosting the Services;
Unity Technologies, located in United States, that processes of IP address, mobile advertising identifiers (e.g. iOS IDFAs, Android advertising IDs and Google advertising ID ) for personalized ads, on the basis of your consent. You may choose to opt-out via Apple or Google Ads Settings website link to close personalized function. You are also able to change those private settings for closing ads tracking on your device.
related group companies, with whom we share all of your personal information to operate the Services. The transfers contemplated above are made pursuant to our contract with you.
law enforcement agencies, public authorities or other judicial bodies and organizations. 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 organizations for the purposes of fraud protection); and
a third party that acquires all or substantially all of us or our business. We will disclose information to a third party in the event that we sell or buy any business or undergo a merger, in which case we will disclose your data to the prospective buyer of such business. We will also disclose information to a third party if we sell, buy, merge or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.
The Security of Your Personal Information
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of the information transmitted to our services; any transmission of your information is at your own risk.
We will retain most of your personal information for the lifetime of your use of the Services (i.e. until account deletion in accordance with your request) with the following exceptions: Audio voice files will be stored for up to 24 hours after you use it in the game, and then deleted from our servers. Contact Information that is obtained as a result of you participating in our promotional activities will be retained during the lifetime of such activities as expressly designated in the corresponding activities.Game-play video recordings will be uploaded to our servers and deleted within one month from the date of their creation.
When destroying personal information, measures will be taken to make the personal information irrecoverable or irreproducible, and electronic files which contain personal information will be deleted permanently using a technical method which makes the files irreproducible.
In the event that the processing and retention period have terminated, but personal information is required to be retained continuously for other reasons including for the purposes as prescribed under applicable laws, the relevant personal information will be stored and maintained separately from other types of personal information. If you require us to destroy your personal information before the end of its life cycle (as set out in the retention policy above), we will destroy your personal information in accordance with local laws).
This section (“Your Rights”) applies to users that are located in the European Economic Area only. For users located in other territories, please refer to the privacy clauses in our End-User License Agreement.
You have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). We must respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). To exercise any of your rights, please contact us at firstname.lastname@example.org.
You have the right to access personal information we hold about you, how we use it, and who we share it with. If you believe we hold any other personal information about you, please contact us as described above and complete the corresponding request form.
You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent (e.g., gender information) or pursuant to our contract with you (e.g., game play statistics), as described in the section “How We Use Your Personal Information”. You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party.
If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (e.g., where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).
You have the right to correct any personal information held about you that is inaccurate. If you believe we hold any other personal information about you and that information is inaccurate, please contact us as described above and complete the request form.
You can delete your account, or remove certain personal information. If there is any other personal information you believe we process that you would like us to erase, please contact us as described above and complete the request form.
You may request that we erase the personal information we hold about you in the following circumstances:
you believe that it is no longer necessary for us to hold such personal information; or
you believe the personal information we hold about you is being unlawfully processed by us.
You can also exercise your right to restrict our processing of your personal information (as described below) whilst we consider your request.
We may need to retain personal information if there are valid grounds under data protection laws for us to do so (e.g., for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Services and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.
Restriction of Processing to Storage Only
You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (e.g., for the defence of legal claims or for another’s protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.
You may request we stop processing and just store the personal information we hold about you where:
you believe the personal information is not accurate for the period it takes for us to verify whether it is accurate;
you wish to erase the personal information as the processing we are doing is unlawful but you want us to retain the personal information instead of deletion completely; or
you wish to erase the personal information as it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defence of legal claims.
You have the right to object to our processing of personal information about you. We will consider your request in other circumstances as detailed below by contact us as described above and completing the request form.
We may from time to time send you announcements when we consider it necessary to do so (such as when we temporarily suspend Services access for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature.
Promotional Material & Announcements
You have the right to ask us not to process your personal data for email or text promotional purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at email@example.com.
You are able to opt out of receiving targeted ads and analytics on our Services by limiting ad tracking in your device settings. Please note that you will still see ads, although they may be less relevant to you.
For ads in Apps, You can opt out of interest-based advertising on mobile applications by resetting the privacy settings of your Android or iOS device and selecting "limit ad tracking" (Apple iOS) or "opt-out of interest based ads" (Android).
For ads on the website, you can manage your cookie preferences using your own browser settings (for example, Chrome, Edge, Internet Explorer, Firefox, Safari, or Opera) to accept or block some or all cookies or receive notice so you can consent to cookies. In additional, some of third parties who provide tailor ads and analytic service are members of the Networking Advertising Initiative (“NAI”) and/or the Digital Advertising Alliance (“DAA”). If you wish to not have your information used for the purpose of serving you targeted ads, you may opt-out by visiting https://www.aboutads.info/choices and/or https://www.networkadvertising.org/choices/.
We may from time to time send you announcements when we consider it necessary to do so (such as when we temporarily suspend Game access for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature.
Contact & Complaints
For the purposes of European Data Protection Law, the Data Controller is Mattel163 Limited.
In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at firstname.lastname@example.org and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the country in which you live or work where you think we have infringed data protection laws.
For Data Subjects in the EU:
We appointed GDPR-Rep.eu as representative according to Art 27 GDPR. If you want to
make use of your GDPR data privacy rights, please visit: https://gdpr-rep.eu/q/18502255
Maetzler Rechtsanwalts GmbH & Co KG
Attorneys at Law
c/o Mattel163 Limited
Schellinggasse 3/10, 1010 Vienna, Austria
Please add the following subject to all correspondence:
GDPR-REP ID: 18502255
If we make any material changes to this policy, we will post the updated policy here and notify our users within the Services. Please check this page frequently to see any updates or changes to this policy.