PRIVACY POLICY
Valid from: September 16, 2021
MYRIDDLE SOFTWARE LIMITED (hereinafter referred to as “MYRIDDLE”), the company
acting and organized under the laws of the Republic of Cyprus, with address: Agias Zonis &
Thessalonikis, Nicolaou Pentadromos Center, 10th floor, Flat/Office 1001A, Block B,
3026, Limassol, Cyprus, care about personal data security and comply with all the laws and
regulations on the personal data protection, including European Union General Data Protection
Regulation (GDPR) and California Consumer Privacy Act (CCPA). Our users can be sure that
their privacy and protection of their personal information are the most significant values.
In order to demonstrate that MYRIDDLE is fully GDPR- and CCPA-compliant and provide
you with information on what personal data we collect from you, for which purposes, and with
the help of which companies, we establish and publish this Privacy Policy (hereinafter referred
to as “Policy”).
1. HOW WE USE YOUR INFORMATION
We use the information we collect about you/your device to deliver services and our Games to
you and to operate our business. We use it also for improving our services and Games, for
enhancing security and for analytics and research purposes to make sure we provide you with
the best experience. In addition, we use your information to promote our services and Games
in our Games and also in other publisher’s apps and to display third-party advertisements to
you. We use your information also for tracking and fraud prevention for advertising purposes
and for complying with our legal obligations.
We use your information for the following purposes:
Delivering and improving our services. We use your information for developing,
delivering and improving our Games and other products, services, and content, tailoring
our products and services, providing Game updates, technical troubleshooting,
understanding and analyzing trends in connection with usage of the Games, and
administering the Games.
Displaying advertisements. We use your information for showing advertisements for
our Games in other publisher’s apps and for displaying third-party advertisements in
our Games.
Cross-promotion. We use your information for cross-promoting our Games and
services, meaning to promote one of our Games while you are playing a different Game
of ours.
Tracking and fraud prevention for advertising purposes. We use your information for
tracking how our advertising campaigns perform and for identifying and preventing
fraud for our advertising campaigns.
Analytics and research. We use your information for understanding and analyzing
trends in connection with the usage of the Games, gathering demographic information
about our user base, data about where the Game was downloaded from. We may also
create reports and analysis for the purposes of research or business intelligence, for
example to track potential problems or trends with our Games and services, or to test
our new game features and content.
Security. We use your information for enhancing the safety and security of our Games,
products and services.
Customer Support. We use your information for providing customer support to you and
to respond to your inquiries.
Our legal obligations. We use your information when we are required to do so by law,
for example, we use your country or region for tax reporting purposes.
We do not process payments for in-app purchases nor have access to your credit card
information. Payment transactions for in-app purchases are completed through the app store
via your App Store account, Google Play account. Any post-purchase processes are controlled
by Apple, Google and are subject to specific terms of such Apple, Google. Please review the
privacy policy and terms of service of your Apple, Google and Amazon.com stores.
2. INFORMATION WE COLLECT FROM YOU
Most of the information that we collect about you comes directly from you when you visit our
website, play our Games or interact with third-party ads in our Games or with our ads in other
publisher’s Games. In general, the information we collect about you relates to the type of device
you are using, information that helps us identify your device, how you play our Games and
may include information that you submit to us when you voluntarily contact us. We may also
collect information from app store platforms and partners and other third parties such as
information about your interests and in-app purchases (provided that we never receive your
payment or credit card information).
In order to provide you with our Services, we can collect and further process the following
categories of your personal data:
Your name, email address or other details, necessary to process your inquiries;
Your Identifier for Advertisers (IDFA) or other kinds of Device ID that aggregate all
the tracking information on how you use our Services through your device (hereinafter
referred to as “Device ID”).
Your online identifier that directly or indirectly identifies you as a personal data subject,
including but not limited to Facebook ID, Google Play ID, Game Center ID etc. For the
purposes of this Policy, the term “online identifiers” also includes profile names that
you use in social networks for communication with other Users and MYRIDDLE.
Your login or in-game nickname and password that you can create by obtaining access
to Applications.
Mobile telephone number.
Country of residence
Age
Gender.
Besides, when you contact us through our web-site: https://myriddlesoftware.com/ or other
Sites, you may be required to provide us with the information about your Project that you would
like to publish and promote by use of our Services.
We do not request or intend to collect any “special categories of information” such as personal
data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or
trade union membership, genetic data, biometric data for the purpose of uniquely identifying a
natural person, data concerning health or data concerning a natural person’s sex life or sexual
orientation. Kindly be cautious when sharing this information about yourself (or others) in our
Services.
Storage of Your Personal Data:
While we and our Processors take all the reasonable and necessary measures aimed at
protection of your personal data against unauthorized access by third parties, we shall inform
you about the possible risks of such storage of your personal data in jurisdictions outside
European Union under Art.49(1)(a) GDPR. Such possible risks include:
Efforts of hacking attacks. We take all the necessary measures to prevent such attacks
and do not allow hackers to access your personal data.
Storage of personal data in the jurisdictions to which has no access. However,
Processors that store your personal data in such jurisdictions use all the necessary
security mechanisms for protecting your personal data in accordance with Section 9 of
this Policy. Furthermore, their storage authority is restricted and controlled by the
written contracts.
How We Secure Your Personal Data Against Unauthorized Use:
We employ reasonable security measures to protect your personal data from access by
unauthorized persons and against unlawful processing, accidental loss, destruction and damage.
We do not use vulnerability scanning and/or scanning to PCI standards. We use regular
Malware Scanning. Your personal information is contained behind secured networks and is
only accessible by a limited number of persons who have special access rights to such systems,
and are required to keep the information confidential. We implement a variety of security
measures when Users enter, submit, or access their information to maintain the safety of their
personal data. All transactions are processed through a gateway provider and are not stored or
processed on our servers.
Transfer of Personal Data to Third Parties:
We do not sell or otherwise transfer your personal data to any third parties. We have never sold
any personal data to any third parties, and have not done so within the last 12 (twelve) calendar
months. We are not planning to sell your personal data to any third parties in future. We can
only transfer your personal data to the Processors determined in this Policy for the purposes
specified in the Policy.
If we decide to change our policy on the sale of your personal data in future, we will provide
you with all necessary updates and notifications in accordance with CCPA.
3. CONSENT TO PROCESSING
When you download and open the Application or otherwise access the Services, you confirm
that you fully and freely agree to the Terms of Service and Privacy Policy. When you Download
and open the Applications, you give us your consent to the processing of your personal data in
accordance with the Privacy Policy.
You have a right to withdraw your consent to the processing of your personal data at any time.
If you would like to withdraw your consent, please send us the verifiable request via email:
lawyer@myriddlesoftware.com. In the verifiable request, please identify your online identifier
(such as Game Center ID) or other identifiers by which we can identify the personal data related
to your use of our Services. However, we cannot guarantee that after the withdrawal of your
consent you will be able to use all the features of the Services.
If you send us the request to withdraw your consent you also have the right to request the
erasure (deletion) of your personal data that we collected during your use of our Services.
Please send us the verifiable request via email: lawyer@myriddlesoftware.com. We will not be
able to erase your personal data if the processing of this personal data is necessary for the
performance of our Terms of Service that you agreed to, for the compliance with legal
obligations, when there are other legal grounds for processing your personal data established
by GDPR.
4. YOUR RIGHTS
You have certain rights in connection with your personal information and how we handle it.
Some of these rights may be subject to some exceptions or limitations. You can exercise these
rights at any time by following the instructions below or sending us relevant requests to
lawyer@myriddlesoftware.com
Your rights include:
Right to withdraw your consent in accordance with Art. 7 para. 3 GDPR (e.g. you may
withdraw your consent to show personalized ads to you, by loading Terms & Privacy
from your Game settings and following instructions in section Personalized Ads
Consent Withdrawal in Privacy Policy)
Right to access your data in accordance with Art. 15 GDPR (e.g. you may check what
data we store about you, for this purpose please load Terms & Privacy from your Game
settings and follow instructions in section Request a Summary of Personal Data in
Privacy Policy)
Right to correct your data in accordance with Art. 16 GDPR (e.g. you can contact us if
your email address has been changed and we should replace your old email 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, please load Terms
& Privacy from your Game settings and follow instructions in section request Personal
Data to be removed in Privacy Policy)
Right to restrict processing of your personal information in accordance with Art. 18
GDPR (e.g. you can contact us if you want to restrict processing). You have the right,
under certain circumstances, to restrict the processing of your Data. In this case, we will
not process your Data for any purpose other than storing it.
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). You have the right to object to the processing of your Data if the
processing is carried out on a legal basis other than consent. Where Personal Data is
processed for a public interest, in the exercise of an official authority vested in the
MYRIDDLE or for the purposes of the legitimate interests pursued by us, you may
object to such processing by providing a ground related to your particular situation to
justify the objection. You must know that, however, should their Personal Data be
processed for direct marketing purposes, they can object to that processing at any time
without providing any justification. To learn, whether we are processing Personal Data
for direct marketing purposes, you may refer to the relevant sections of this document
or contact us at lawyer@myriddlesoftware.com.
Right to send complaints to the supervisory authority in accordance with Art. 77 para.
1 of GDPR (e.g. you can contact the data protection supervisory authority directly).
5. CHILDREN’S PRIVACY
Our Service does not address anyone under the age of 16 (“Children”). When we collect
personal information, we do not know the age of our players. We do not knowingly collect
personally identifiable information from children under 16. If you are a parent or guardian and
you are aware that your Children have provided us with Personal Information, please contact
us. If we become aware that we have collected Personal Information from a child under age 16
without verification of parental consent, we will take steps to remove that information from
our servers.
6. COOKIES
Cookies are files with a small amount of data, which may include an anonymous unique
identifier. Cookies are sent to your browser from a website and stored on your computer’s hard
drive.
We use “cookies” to collect information. You can instruct your browser to refuse all cookies
or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not
be able to use some options of our Service. In order to receive more detailed information about
cookies, please review our Cookie Policy.
7. ADVERTISING
We use advertising to fund our Services and to make our games available for free. We offer
our Games for free or at low cost and in order to do that we need to share information we collect
from you with our third-party advertising partners. As a safeguard to protect your privacy, we
only store personal information temporarily. The information collected helps us to improve our
website and Games and at the same time keep our Games free for a wide player base.
As a European-based company, when you use our Games, we rely on our legitimate interest to
show advertisements to you. The legal basis to show ads 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.
Before sharing any information with our advertising partners for the purposes of personalized
advertising, we always ask for your consent, given when you press accept at relevant button at
loading of the Game. The purpose is to improve our Games and provide the player with more
relevant ads. We allow our advertising partners to show personalized ads to you only if you
have pressed ACCEPT in relevant pop-up window and so consented to the sharing of your
personal information for the purposes of personalized advertising. Our advertising partners use
different technologies for the purposes of personalized advertising that process your personal
information in different ways, so please review their data processing practices before you
ACCEPT to show you personalized ads at loading of the Game.
The legal basis to show personalized ads is consent in accordance with the European data
protection requirements under Art. 6 para. 1 lit. a GDPR. In addition, a data processing
agreements were concluded with external ad technology providers networks in accordance with
the requirements of Art. 28 GDPR. We also ensure that our external service providers are
committed to a high level of data protection by concluding data protection agreements.
You have an option to withdraw your consent to sharing your personal information for the
purposes of personalized advertising at all times. You can withdraw your consent by going to
the Game settings and clicking the terms & Privacy button therein, in section ‘Personalized
Ads Consent Withdrawal’ of the Privacy Policy you will be able to manage your preferences
by choosing to which advertising you would like to get. When you decide to withdraw your
consent or if you do not provide your consent, you may still see the same number of ads on
your mobile device; however, these ads may be less relevant because they won’t be based on
topics you like, your interest, behavior, demographics, etc. Our advertising partners may
continue to show you ads based on the content of the application you are using.
In-game advertising (i.e. when you view ads in Our Games)
To enable us to show in-game ads, we may send your advertising ID and IP-address to
advertisers (or ad networks) to enable them to find appropriate ads to serve to you in our games
and on third-party properties. You can control and limit our use of your advertising ID in your
device settings. We do not control which specific ads are shown in our games (it is controlled
by ad networks), but we do blacklist certain categories of ads.
Advertising IDs are used by the ad networks for a number of purposes (please refer to the
Privacy Notices of our advertising partners listed here) including:
limit the number of times you see the same ad;
ensure they are dealing with humans with real devices and not ‘automated’ bots;
serve you with advertisements likely to be relevant to you based on your advertising
ID engagement with other brands and ads, also recorded using your advertising ID
and using your general geographic area. Other brands buy advertisement placement
via an ad network or ad exchange to advertise their products in Our Games. The ad
network or ad exchange acts as intermediary between the other game companies and
Us. In order for an ad network to charge the company buying the ad, clicks from the
ad and potentially installs of other developers’ applications party apps are tracked.
Views, clicks, and installs from ads are measured using Advertiser ID;
keep track what games you have used to market you similar kind of games. IP-address
is typically used by advertisers to broadly see the general geographic area you are
coming from for example country, state, and sometimes at city level).
8. DEVELOPER INFORMATION
We may collect personal data related to developers who wish to submit their Games to
publishing. We do this in order to carry out the application process and to have a possibility to
contact the developers.
(A) Our purposes and legal bases for collection and using developer’s personal data. We may
collect personal data in the following purposes:
to communicate with the developer (or its representative) about your application for
publishing. In this case we have a legitimate interest to collect and process your
personal data to be able to enter a contract with you or to communicate with you;
(B) Types of personal data collected
We may collect personal information directly from the developer (or its representative) via
filing and submitting web-based application forms, such as:
full name and surname of the developer or its representative;
email address and phone number.
We do not transfer your personal data to third parties (except for affiliates, when such transfer
within a group of companies is legally permitted and to the extent necessary for the execution
of the application process).
9. INFORMATION FOR CALIFORNIA CONSUMERS
This part of the document integrates with and supplements the information contained in the rest
of the privacy policy and is provided by us and our subsidiaries and affiliates (for the purposes
of this section referred to collectively as “we”, “us”, “our”).
The provisions contained in this section apply to all users who are consumers residing in the
state of California, United States of America, according to "The California Consumer Privacy
Act of 2018" (Users are referred to below, simply as you”, “your”, “yours”), and, for such
consumers, these provisions supersede any other possibly divergent or conflicting provisions
contained in the privacy policy.
This part of the document uses the term “personal information“ as it is defined in The California
Consumer Privacy Act (CCPA).
How we collect information: what are the sources of the personal information we collect?
We collect the above mentioned categories of personal information, either directly or
indirectly, from you when you use our services and Games.
For example, you directly provide your personal information when you submit requests via any
forms on the services or Games. You also provide personal information indirectly when you
navigate the services and Games, as personal information about you is automatically observed
and collected. Finally, we may collect your personal information from third parties that work
with us in connection with the Service or with the functioning of the Games and features
thereof.
How we use the information we collect: sharing and disclosing of your personal information
with third parties for a business purpose
We may disclose the personal information we collect about you to a third party for business
purposes. In this case, we enter a written agreement with such third party that requires the
recipient to both keep the personal information confidential and not use it for any purpose(s)
other than those necessary for the performance of the agreement.
We may also disclose your personal information to third parties when you explicitly ask or
authorize us to do so, in order to provide you with our Service.
What are the purposes for which we use your personal information?
We may use your personal information to allow the operational functioning of the services or
Games and features thereof (“business purposes”). In such cases, your personal information
will be processed in a fashion necessary and proportionate to the business purpose for which it
was collected, and strictly within the limits of compatible operational purposes.
We may also use your personal information for other reasons such as for commercial purposes,
as well as for complying with the law and defending our rights before the competent authorities
where our rights and interests are threatened or we suffer an actual damage.
Your California privacy rights and how to exercise them
The right to know and to portability
You may submit once a year, free of charge, a verifiable request to disclose what personal
information we collect about you. The easiest way to submit a request is to use the in-app
support feature (“Contact Us”) in our Games (if possible).
You may also submit your request via e-mail at lawyer@myriddlesoftware.com.
The disclosure described above will be limited to the personal information collected or used
over the past 12 months.
If we deliver our response electronically, the information enclosed will be "portable", i.e.
delivered in an easily usable format to enable you to transmit the information to another entity
without hindrance provided that this is technically feasible.
The right to request the deletion of your personal information
You have the right to request that we delete any of your personal information, subject to
exceptions set forth by the law (such as, including but not limited to, where the information is
used to identify and repair errors on this Application, to detect security incidents and protect
against fraudulent or illegal activities, to exercise certain rights etc.).
If no legal exception applies, as a result of exercising your right, we will delete your personal
information and direct any of our service providers to do so. However, we may deny your
deletion request if retaining the information is necessary for us or our service providers under
certain circumstances, which will be explained to you at the time of the denial, if any.
Right to opt-out
You have the right to opt-out of “sale” of your personal information, as defined by the CCPA.
In certain circumstances we may share your information with our partners, who help us deliver
advertisements in our games tailored to your interests.
Right to be free from discrimination
We may not discriminate against you for exercising any of your CCPA rights. Unless permitted
by the CCPA, we will not: (i) deny your our Services; (ii) charge you different prices or rates
for our Services; (iii) provide you a different level or quality of Services; (iv) suggest that you
may receive a different price or rate for Services or a different level or quality of Services.
Authorized agents
You may exercise your CCPA rights by designating an authorized agent. If you would like to
designate an authorized agent to make a request on your behalf, please, be sure that the agent
can (i) demonstrate you have provided written permission for the agent to submit a request on
your behalf and (ii) provide proof of his or her own identity. We reserve the right to require
further reasonable information to verify the request. If the agent does not satisfy these
requirements, we may deny the request.
How to exercise your rights
To exercise the rights described above, you need to submit your verifiable request to us by
contacting us via the details provided in this document.
For us to respond to your request, it’s necessary that we know who you are. Therefore, you can
only exercise the above rights by making a verifiable request which must:
provide sufficient information that allows us to reasonably verify you are the person about
whom we collected personal information or an authorized representative;
describe your request with sufficient detail that allows us to properly understand, evaluate, and
respond to it.
We will not respond to any request if we are unable to verify your identity and therefore confirm
the personal information in our possession actually relates to you.
If you are an adult, you can make a verifiable request on behalf of a minor under your parental
authority.
You can submit a maximum number of 1 request over a period of 12 months.
How and when we are expected to handle your request?
We will respond to your request within 45 days of its receipt. Should we need more time, we
will explain to you the reasons why, and how much more time we need. In this regard, please
note that we may take up to 90 days to fulfill your request. Our disclosure(s) will cover the
preceding 12 months period.
Should we deny your request, we will explain to you the reasons behind our denial.
We do not charge a fee to process or respond to your verifiable request unless such request is
manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse
to act on the request. In either case, we will communicate our choices and explain the reasons
behind it.
10. SECURITY
Your information privacy and security are important to us and we always pay special attention
to ensure that we process your information lawfully in accordance with one of the legal bases
set out under EEA data protection laws that apply to our users. We have appointed data
protection officer to help us ensure compliance with EEA data protection laws. We store your
information for as long as needed to provide you with our services. We may store information
longer, but only in a way that it cannot be tracked back to you. We operate globally and we
share your information with our Partners, which may include a transfer of your personal
information outside of the European Economic Area (the “EEA”).
Please check regularly for changes to our Privacy Policy.
11.DATA PROTECTION OFFICER (DPO)
Because we regularly and systematically monitor personal data subjects on a large scale, we
have appointed the Data Protection Officer (DPO) in accordance with Art.37 GDPR.
Our DPO is Zinaida Kobzarenko.
Our DPO monitors the compliance with GDPR by and our Processors, and performs other tasks
provided by Art.39 GDPR.
Users may contact our DPO regarding their rights provided by GDPR and this Privacy Policy
via DPO’s e-mail: lawyer@myriddlesoftware.com.
Supervising authority of the EU Member State can also use this email to contact the DPO
12. CHANGES TO OUR PRIVACY POLICY
We will occasionally update this Privacy Policy as necessary to protect our users, furnish
current information, and respond to legal and technical changes.
For previous versions of this Privacy Policy, please contact us via
lawyer@myriddlesoftware.com.