Mobitale Limited Privacy Policy

Last Updated: January 12, 2021

 

Welcome! This Privacy Policy explains how Mobitale Limited (“Mobitale Limited" or "We") collects and uses your personal information while you play Mobitale Limited's games ("Games") and/or use Mobitale Limited's websites that link to this Privacy Policy ("Websites").

We may make changes to this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we will notify you via email if we have your email address on record, or via a notice on the Websites and/or Games prior to the change becoming effective.

Mobitale Limited is committed to making sure that kids’ privacy is safeguarded and we aim to comply with all (privacy) regulations worldwide, like the Children’s Online Privacy Protection Act (COPPA) in the US. If you want to know what data is collected by our apps and how this is handled, please review this policy. If you have any questions or concerns, send us an email via legal@mobitalegames.com, we are here to help.

When using the apps we produce for parents and children (the “Games”) our company and its subsidiaries (together “Mobitale Limited” or “We”) may collect information including usage data.  When adults or parents visit www.mobitalegames.com  (the “Website”), we may also collect information on the usage of our website for adults and parents.  This data collection is discussed in greater detail below.

If you are accessing the Games or Website from within the European Union (EU) or are an EU citizen, please review the Lawful Bases for Processing Personal Data and Individual Rights sections below for more information on your how your personal data will be processed and the rights you have regarding this processing.

Information collected through our Games

Information Collected Automatically By:

Mobitale Limited.  Most of our apps note your IP address and use this to determine the country the device is located. The IP address is not stored on our systems, but we keep track of the country our app is functioning in. This information cannot be connected to a unique device and is never shared with third parties.

For every device a Game is installed on, Mobitale Limited may collect some analytical information. We collect this information to improve the performance and reliability of our Games and to get a better understanding of what users prefer. We do not link any of this information in any way to individuals or any other information we might obtain. We do not share, sell or in any other way give other persons or companies outside Mobitale Limited access to this information, except to comply with a legal obligation to do so (e.g. court order) or in case the ownership of the information changes due to a merger, acquisition or restructuring involving Mobitale Limited.

Flurry Analytics. We use Flurry Analytics services in some apps to get a better understanding of the usage of our apps. To this end, our apps collect non-personal data which is sent to Flurry Analytics and only used to provide us with an overview of the usage of our apps. No information is shared or sold to any third party. The information collected by us is used solely to improve our service and we do not provide this information to any third party, unless in order to comply with a legal obligation to do so (e.g. court order) or in case the ownership of the information changes due to a merger, acquisition or restructuring involving Mobitale Limited.

For more information on Flurry Analytics please see their terms of service here: https://developer.yahoo.com/flurry/legal-privacy/terms-service/flurry-analytics-terms-service.html, and for more information on the exact data collected, you can refer to the appendix below.

Firebase Analytics. We use Firebase Analytics in some of our apps services to get a better understanding of the usage of our apps. To this end, our apps collect non-personal data which is sent to Firebase Analytics and only used to provide us with an overview of the usage of our apps. The information collected by us through Firebase Analytics is used solely to improve our service and we do not provide this information to any other third party, unless in order to comply with a legal obligation to do so (e.g. court order) or in case the ownership of the information changes due to a merger, acquisition or restructuring involving Mobitale Limited.

For more information on Firebase Analytics please see their terms of use here:  https://firebase.google.com/policies/analytics

Information you provide through the Games:

Child users do not have the ability to provide any personal information when using the Games beyond what has collected automatically (as noted above).  Adult users can use the Support link within the adult/parent area of the app to access the customer support features on the Website. If you submit a support ticket on our Website, you must provide an email address and may provide your name. We do not require you to provide your full name to contact us.

Information collected through our Websites:

Information collected automatically:

Our Websites are intended for use by parents and adults and use Google Analytics (third party scripts) that collect the following information and might (also) store such information as a cookie on the device you use to access our webpage:

  • Demographics (browser language, country, city);
  • System information (browser, OS, service provider);
  • Mobile (OS, service provider, screen resolution);
  • Acquisition channel (source from where the user clicked, most of it is not revealed by Google);
  • Site behavior (which pages users visit, duration of visit); and
  • Remarketing list (remembers user visit via cookie for future advertising).

In order for you to use any of our Websites, you should agree with the placement of the specific cookies and their use.

Information you provide:

In addition to the information automatically collected when you visit the Website, parents may provide their name and email address for this specific purposes:

  • Contacting us or our customer support team

If you submit a support ticket or reach out to us using the contact form on our Website, you must provide an email address and may provide your name. We do not require you to provide your full name to contact us.

How your information is used

We use the information collected through our Games and Websites for getting a better understanding of their use and the preferences of our visitors. We do not use this information for any other purpose or make it available to any other party (beyond those disclosed above), unless in order to comply with a legal obligation to do so (e.g. court order) or in case the ownership of the information changes due to a merger, acquisition or restructuring involving Mobitale Limited.

How your information is shared

Any personal information automatically collected by us is used solely to improve our service and we do not provide this information to any third party (beyond those disclosed above), unless in order to comply with a legal obligation to do so (e.g. court order) or in case the ownership of the information changes due to a merger, acquisition or restructuring involving Mobitale Limited.

Information that is collected on our Websites by scripts from Google will also be available to Google. Mobitale Limited has no control over the collection or usage of this information by Google and does not accept any liability for the same. However, we believe that the collection and usage of information by Google is compliant with relevant regulations. According to the disclosures of Google, they will use this information as follows:

According to the best of our knowledge, Google uses the information collected to provide us with a better understanding of the use of our Websites and of the preferences of our visitors. Google will also use the information collected to personalize advertisements that are shown to you while surfing the web or while using Google services. Please refer to http://www.google.com/policies/privacy/ and more specifically here: https://support.google.com/adwordspolicy/answer/143465?hl=en&rd=1 for more information. You can also opt-out using the following Google tool: Google Analytics opt-out browser add-on (https://tools.google.com/dlpage/gaoptout/). Click here to opt-out of Google Analytics.

Lawful bases for processing personal data

If you are an individual in the European Union (EU) or an EU citizen, we collect and process data about you only where we have legal bases for doing so under applicable EU laws. This means we collect and process your data only when:

  • It is necessary for a legitimate interest (which is not overridden by your individual privacy interests), such as preventing fraud, improving the Website, and increasing the security of the Website and network infrastructure;
  • You have consented to this collection and processing for a specific purpose;
  • It is necessary to fulfill our contractual obligations; or
  • It is necessary to comply with a legal obligation.

Where we rely on your consent to process your personal data, you have the right to withdraw or decline consent at any time. If you wish to withdraw your consent, please contact us using the information in the Contacts for the Individual Rights Requests section.  Some examples of our legitimate interests and the data being processed include:

  • Network and information security (IP address, Device ID)
  • Customer Support and fraud prevention (name, email address)
  • Improving our products and services (hardware information, activity logs)

Where we rely on our legitimate interests to process your personal data, you have the right to object.  More information on exercising this right can be found in the Individual Rights section below.

If you have any questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us at legal@mobitalegames.com.

We do not collect any other information

When you download and use our Games, or surf our Websites, we don’t require you to provide any information and we don’t collect any personal information, except general information explained above, including unique device identifiers and cookies (as specified above) to anonymously identify your computer or device so we can deliver a better experience. We do not share such information with third parties.

We do not knowingly contact or collect personal information from children under 16. If you believe we have inadvertently collected such information, please contact us so we can remove the information.

Individual Rights

Mobitale Limited makes certain choices available to you when it comes to your personal data.  Please review the below information outlining your choices and how to exercise them. We will respond to all requests within a reasonable timeframe.  If our full response will ever take more than a month due to complexity or scope, we will notify you of this and keep you updated.

Review and update your data: You have the right to access and update any personal data that we have collected.  To review the data that we have and update it as required, please submit a request using the contact information at the end of this section.  We may request more information to confirm your identity before releasing or modifying any personal data.

Delete your data: You also the right to have your personal data deleted. This is sometimes known as the ‘right to be forgotten’.  To request that we delete all personal data about you, please submit a request using the contact information at the end of this section.  We may request more information to confirm your identity before deleting any personal data.

After you delete your personal data from our services, we may not immediately delete residual copies from our active servers and may not immediately remove data from our backup systems for archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.  We may also decline to honor this request in certain specific situations, such as if the data is necessary to comply with a legal obligation or to exercise/defend a legal claim.

Restrict Processing: You have the right to restrict how we process your personal data in certain circumstances.  This is an alternative to requesting the deletion of your data. Rather than requesting we delete all your personal data, you may request that we limit our uses of your personal data to specific purposes.  You may wish to request we restrict our processing if you contest the accuracy of your personal data and we are working to verify this information, or if you want us to retain your personal data in connection to a legal claim but cease processing it.

Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or when our processing of your data is based on legitimate interests.  You may request that we stop processing your personal data for direct marketing purposes. This is an absolute right and we cannot refuse this request. Beyond direct marketing, if you wish to exercise this right, you must give specific reasons why you object to our processing of your data, based on your particular situation.  Even after receiving such a request, we may continue processing if it is necessary for the exercise/defense of a legal claim or if we can demonstrate a compelling legitimate ground for the processing.

If any request made under this section is clearly unfounded or excessive, we may reject the request or require a reasonable fee to honor the request.  If we decide to reject your request, we will inform you of the reasons for not taking action and provide information on other possible remedies. If we decide that a reasonable fee is necessary, we will promptly inform you and will comply with the request upon receipt of this fee.

Contact for Individual Rights Requests

Please use the below information when submitting a request to exercise any of the above rights.  Please do not submit requests across multiple communications channels. We will make all efforts to respond to your request within a reasonable timeframe.

E-mail: legal@mobitalegames.com

Data Retention

Mobitale Limited may retain users’ data for the following purposes:

  • To develop new features and improve the Games and Website;
  • To support subsequent customer service inquiries;
  • To improve the safety and security of the Games and Website; or
  • Comply with our legal obligations.

We will retain your information for as long as is reasonably necessary in relation to the purposes for which this data was collected.  In many instances, we will retain your data while it is necessary for your use of the Games or Website, which may include maintaining this information beyond when you cease using the Games or Website.

Updates to this Privacy Policy

This privacy policy was last updated on the date that appears at the top of this document.  Our privacy policy may change from time to time, and we explicitly reserve our right to do so. If we make any material changes to our policies, we will place a prominent notice on our website or application.  We will obtain prior parental consent if any changes we make to this Policy affect users under the age of 13 in a way that requires such consent under COPPA.

APPENDIX

Flurry Analytics  collects the following information through our Games:

  • IDFV – for generating Device ID that stored locally on the mobile device.
  • IP Address (the internet address the Game uses to connect to the Internet; this information is used to know in which country the device is and then deleted from Flurry Analytics’s systems);
  • Device type (e.g. iPad 2, Galaxy S3, etc.);
  • OS version (the type of operating system and the version thereof);
  • Game version (specific Game(s) and the versions thereof); and
  • Length of a play session.
  • Default language the device uses

Firebase Analytics collects the following information through our Games:

  • IDFA – (a unique ID used that lets us tell devices apart. If you have ‘limit ad tracking’ activated on your device, this ID will not be collected);
  • IP Address (the internet address the Game uses to connect to the Internet; this information is used to know in which country the device is and then deleted from Firebase Analytics’s systems);
  • Device type (e.g. iPad 2, Galaxy S3, etc.);
  • OS version (the type of operating system and the version thereof);
  • Game version (specific Game(s) and the versions thereof); and
  • Length of a play session.
  • Default language the device uses

CONTACT US.

    1. If you have any questions, please send your inquiries to Service support at support@mobitalegames.com. So we can deal with your enquiry effectively, please quote this Privacy Policy. We will aim to respond to you within 30 days from receipt of request.

    2. All correspondence received by us from you (written or electronic inquiries) is classified as restricted-access information and may not be disclosed without your written consent. The personal data and other information about you may not be used without your consent for any purpose other than for response to the inquiry, except as expressly provided by law.

    3. The e-mail address of our DPO is legal@mobitalegames.com