Privacy Policy for MindYourLogic Studios
by Logical Baniya February 9, 2019
MindYourLogic Studios Pvt. Ltd., an Indian corporation, with registered office at Nirmal Ganga Complex, Gittikhadan Chowk, Nagpur, India respects your privacy and provides you with this Privacy Policy (“Privacy Policy”) so that you may understand the ways in which we do and do not use the information you transmit when accessing and playing the MindYourLogic Game(s), accessing and using websites, platforms, software services and related services (hereinafter the “Game”). Please note that your access and/or playing of the Game constitutes your acceptance of this Privacy Policy as well as our Terms of Use.
IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY PLEASE DO NOT ACCESS AND/OR PLAY THE GAME.
Collection of information
Information collected through the Game
Where applicable, access and playing of certain basic Game versions, experience of certain basic content and games features may not require registering of an account with MindYourLogic and where applicable platform/service providers that are providing the Game etc. to you. However, in order to access and play the complete Game, access certain premium game functions, levels, content and features you must register an account with MindYourLogic and/or the platform/service providers that are providing the Game etc. to you. You must then create an account on the Game’s webpage or on the platform/service providers’ platforms that hosts the Game to access such premium game functions, levels, content and features etc. To create an account you are required to provide certain mandatory information such as your name, your email address, account login etc. which is mandatory in order to be able to establish an account. MindYourLogic and/or the platform/service providers (i.e. Apple App Store, Google Play Store, Xbox, Playstation etc.) collects financial information on the Terms and Conditions set out in this Privacy Policy. MindYourLogic does not use financial information for any purpose other than processing payments. Further you may, but may not be required to, provide certain voluntary information such as date of birth, screen name, your personal profile in the Game, interests in and use of various games, products and services, and any other personal or preference information which you may choose to voluntarily provide.
MindYourLogic will use information about you for the following purposes in accordance with applicable laws:
Age identification
To identify your age for data protection purposes, for example to determine the legal requirements for processing of Personal Data. We requests that anyone under the age of 18 not send any Personal Data about themselves over the Internet unless sent under the supervision of their parent or guardian. We do not knowingly collect Personal Data from children under 13 years old in the Game. We believe it is important to safeguard the privacy of children and encourage parents to regularly monitor their children’s use of online activities. If you are a parent and believe that your child under the age of 13 has accessed and/or played the Game and provided personally identifiable information to us, please contact us at privacy@mindyourlogic.com or the mailing address at the end of this Privacy Policy and we will work to delete that account and any such personally identifiable information. This in compliance with Article 6(1)(c) of the GDPR. Information you provide or is collected from you in or in relation to the Game and information from other sources Information is provided by you or collected in or in relation to the Game and/or collected from other sources in order to:
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provide, operate, improve and maintain the Game, game experience and services, your account(s);
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personalize the Game, content, loyalty programs and related services to you;
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send technical notices, updates, security alerts,
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for support and troubleshooting reasons;
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send support and administrative messages
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provide news and information about the Game about our games and products;
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monitor the end users playing of the Game and activities in the Game;
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facilitate sharing on social networks;
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provide adults with advertising in accordance with given consent and/or permissible laws;
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provide children reasonable contextual advertisements in the Game accordance with permissible laws;
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identify, fix, and troubleshoot bugs and service errors, provide software updates etc;
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resolve disputes, investigate and help curb fraud and illegal behavior, comply with the law, and to enforce our agreements and policies;
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survey end user's opinions about the game and related matters through surveys or questionnaires; communication reasons related to the Game and related matters;
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manage the Game and send you confirmations and important information about your account, products, purchases, subscriptions, and warranties;
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present offers and/or information relating to the Games and other games that you might like; make recommendations to you; and
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personalize advertising for you and deliver targeted marketing, service updates and promotional offers. Processing of this information is necessary for the purpose of performance of a contract to which you are party in order to support the operation of the Game facilitate the delivery of requested products and services and enable maintenance and update of the Game under Article 6(1)(b) of the GDPR and purposes is justified by our legitimate interests in providing advertisements and content of interest to you and improving our services in accordance with Article 6(1)(f) of the GDPR (“the balancing-of-interest rule”). Disclosure of your advertising ID to third parties for the purposes of behavioral advertising is based on your consent in accordance with Article 6(1)(a) of the GDPR. We only process your information to the extent that is necessary to achieve the purposes for which the information has been collected.
As a general rule we will not share Personal Data that directly identifies you (such as your name, e-mail or postal address) with independent third parties without your consent, unless it is either required by law or we determine that disclosure is reasonably necessary to enforce our rights, property or operations or to protect our players or third parties. We may share anonymous or aggregated information, or other data that does not directly identify you, with third parties, for instance your persona on leaderboards or to show trends about use of our products.
Notwithstanding the forgoing, we may share information about you with certain third parties based on the legal basis in Articles 6(1)(b), 6(1)(c) and 6(1)(f) of the GDPR as follows:
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Third-Party Agents and Contractors
We may share information about you with third-party agents and contractors in order to provide the Game to you, for ongoing development, for analytical purposes etc. We will only provide information to such third-party agents and contractors for their performances of their specific assignments for us and consistent with this Privacy Policy, and for no other purposes and provided that such third-party agents and contractors have ensured an adequate level of protection of the Personal Data in accordance with all Applicable Data Protection Legislation and/or though agreements with us.
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Social networks
Where the Game and related services is accessed and/or provided through social networks.
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Third parties
When required by applicable law, rule, regulation, legal process, in the process of negotiations of, any mergers and acquisitions, sale of company assets, financing or acquisition of all or a portion of our business by another company where personally identifiable information submitted to us may be transferred to the acquiring entity.
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Courts, law enforcement agencies, legal authorities etc.
When ordered or requested by courts, legal authorities etc. and required in order for us to abide by applicable laws, or to protect our rights, in defense in law suits, property or safety of MindYourLogic, the Game, end users etc.
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Other end users
In order to provide certain Game features.
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Advertising networks
For advertising purposes. We may share your advertising ID with advertisers in order to serve behavioral advertisements to you within the Game if you have given consent in accordance with Article 6(1)(a) of the GDPR.
Where applicable certain third parties’ use of Personal Data will not be covered by this Privacy Policy. In such instances you must review such third parties’ privacy policies.
We use or may use the following service providers in our services:
Ad Networks:
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https://developers.ironsrc.com/ironsource-mobile/ios/ironsource-mobile-privacy-policy/
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https://www.adcolony.com/privacy-policy/
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https://support.google.com/admob/answer/6128543?hl=en
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https://www.applovin.com/privacy
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https://answers.chartboost.com/en-us/articles/200780269
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https://developers.facebook.com/docs/audience-network/policy
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https://www.inmobi.com/privacy-policy/
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https://dev.tapjoy.com/faq/tapjoy-privacy-policy/
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https://unity3d.com/legal/privacy-policy
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https://vungle.com/privacy/
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https://tapcore.com/en/privacy-policy
Analytics:
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https://gameanalytics.com/privacy
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https://firebase.google.com/support/privacy/
Misc:
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https://aws.amazon.com/privacy/https://playfab.com/privacy/
In order to access the complete Game, certain premium game functions, levels, content and features etc. you are required to pay certain fees. When purchasing such features and functions etc. you may be asked by the platform/service providers to provide certain personally identifiable information, such as full name, billing address, email address, phone number and credit card number/expiration date etc. Please note that you must be the age of 18 or older to make purchases in the Game.
Once End Users have successfully entered valid credit card information etc. and completed the order process, a purchasing account will be created and maintained for them. The platform/service providers will use the information provided to process the End User’s order and to send order confirmations via email, as well as to make future purchases easier for the End User. MindYourLogic does not sell, transfer or share customer information with third parties, except where applicable the information is transferred, disclosed and shared with its third-party agent(s) who uses the information solely to handle and deliver certain online activities necessary to operate MindYourLogic’ business (e.g. processing orders and payments).
MindYourLogic has taken reasonable steps to ensure that the personally identifiable information it collects is secure and we have taken reasonable measures to protect the confidentiality, security, and integrity of the Personal Data collected from our Game’s End Users. Personal Data is stored in secure operating environments that are not available to the public and that are only accessible to authorized employees and contractors. We also have security measures in place to protect the loss, misuse, and alteration of the information under our control. However, there is no such thing as perfect security. As a result, although we strive to protect personally identifying information, we cannot ensure or warrant the security of any information transmitted to us through or in connection with the Game, that we store on our systems or that is stored on our service providers’ systems.
Please note that MindYourLogic may provide links to other games and websites that are operated and hosted by third parties who may have their own information collection practices. Those other games and websites are governed by their own privacy policies, which may be substantially different from MindYourLogic’ policies. Visitors to other games and websites are encouraged to review the privacy policies and information collection practices of those websites.
Any improper collection or misuse of User Content or information provided in the Game is a violation of the Terms of Use and should be reported to MindYourLogic at privacy@mindyourlogic.com.
You have the following rights regarding your Personal Data:
The right to request access
In accordance to Article 15 of the GDPR you may request access to processed Personal Data. This includes confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:
The purposes of the processing;
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The categories of Personal Data concerned;
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The recipients or categories of recipient to whom the Personal Data have been or will be disclosed, in particular recipients in third countries or international organizations;
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Where possible, the envisaged period for which the personal data will be stored or, if not possible, the criteria used to determine that period;
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The existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
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The right to lodge a complaint with a supervisory authority;
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Where the Personal Data are not collected from you, any available information as to the source;
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The existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
Where Personal Data are transferred to a third country or to an international organization, you have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.
You shall be provided a copy of the Personal Data undergoing processing. For any further copies requested, we may charge a reasonable fee based on administrative costs. Where you makes the request by electronic means, and unless otherwise requested by you, the information shall be provided in a commonly used electronic form. The right to obtain a copy shall not adversely affect the rights and freedoms of others. Please note that the access may be restricted due to intellectual property or trade secrets.
The right to object
You have the right to object to the Personal Data processing on grounds relating to your particular situation when the data are processed based on the balancing-of-interest rule in Article 6(1)(f) of the GDPR, see Article 21 of the GDPR. In this case, we will cease the processing unless there are compelling legitimate grounds for the processing which override your interests, rights and freedoms or if the processing is necessary for the establishment, exercise or defense of legal claims. You have the right to object to our processing of your Personal Data for direct marketing purposes at any time. We will cease the processing of your Personal Data for this purpose after the objection. Please note that if you exercise this right, your user license to use the Game and related services will cease automatically.
Right of correction and erasure
You have the right to have inaccurate Personal Data rectified, in accordance with Article 16 of the GDPR.
You have the right to have your Personal Data erased where one of the following grounds applies, see Article 17 of the GDPR:
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The Personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed,
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if you have withdrawn your consent and there are no other legal grounds for the processing,
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if you have objected to the processing and there are no overriding legitimate grounds for the processing,
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the personal data have to be erased for compliance with a legal obligation in Union or Member State law,
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the personal data have been unlawfully processed or
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the personal data have been collected in relation to the offer of information society services.
Please note that your right to erasure may be limited if the data are necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims.
The right to restriction
You have the right to obtain restriction of processing in certain circumstances, in accordance with Article 18 of the GDPR. If you have the right to restriction, we will only process your Personal Data with your consent or for the establishment, exercise or defense of a legal claim or to protect a person or important grounds of public interest.
The right to withdraw consent
If we have asked for your consent to our processing of your Personal Data, you have the right to withdraw your consent at any time, in accordance with Article 7 of the GDPR. If you withdraw your consent, we will cease processing of the Personal Data for which you have withdrawn consent, unless we have a legal obligation to keep some or parts of your data. Please note that if you withdraw your consent, your right to play the Game and related services will cease automatically. The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal.
You have the right to receive your Personal Data that you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hinderance if the processing is based on consent or contract performance, sin accordance with Article 20 of the GDPR.
Changing or Removing Account Information
Access and control over most Personal Data in the Game may readily available through the profile editing tools on the webpage or the gaming platforms. End Users
may modify or delete any or all of their profile information at any time by logging into their accounts. Information will be updated as soon as possible. End Users who wish to deactivate their Game account may do so in their accounts on the webpage or the gaming platforms. Removed information may persist in backup copies for a reasonable period of time but will not be generally available to other End Users or visitors of the Game. You cannot however remove communications made in any communication features in the Game, which might have been shared with other End Users (for example sending personal messages to another End Users).
If you wish to invoke any of the rights described above, you may contact us at any time by emailing us at privacy@mindyourlogic.com We will process and answer your requests without undue delay and in any event within one month of our receipt of the request unless a longer period is required due to the complexity of the request. In this case, our response time can be up to three months in total as permitted by Article 12 of the GDPR.
Disputes between you and MindYourLogic
OUR GOAL IS TO RESOLVE DISPUTES FAIRLY AND QUICKLY. FOR ALL DISPUTES AGAINST MINDYOURLOGIC, YOU AGREE TO FIRST CONTACT MINDYOURLOGIC AND TRY TO RESOLVE THE DISPUTE INFORMALLY BY SENDING A WRITTEN NOTICE OF THE CLAIM (“NOTICE”) TO MINDYOURLOGIC. THE NOTICE TO MINDYOURLOGIC MUST BE SENT VIA REGISTERED LETTER TO THE ADDRESS LISTED IN SECTION 17 BELOW OR BY EMAIL WITH CONFIRMATION OF RECEIPT. THE NOTICE MUST (A) INCLUDE YOUR NAME, YOUR RESIDENTIAL ADDRESS AND E-MAIL ADDRESS AND / OR MOBILE PHONE NUMBER ASSOCIATED WITH YOUR ACCOUNT REGISTERED WITH MINDYOURLOGIC AND/OR THE PLATFORM/SERVICE PROVIDER; (B) DESCRIBE THE TYPE AND REASON FOR THE CLAIM; AND (C) SPECIFY THE SPECIFIC COMPENSATION SOUGHT, IF ANY. IF YOU AND MINDYOURLOGIC CANNOT AGREE ON A SOLUTION TO THE DISPUTE WITHIN 60 DAYS OF RECEIVING SUCH A NOTICE, EITHER PARTY MAY INITIATE LEGAL PROCEEDINGS IN ACCORDANCE WITH SECTIONS 12-15 BELOW.
User disputes
You are solely responsible for your interactions with other users of the Game. We reserve the right, but have no obligation, to monitor disputes between you and other users.
If you are located within the United States of America, the following applies to you: Any claim (excluding claims for injunctive or other equitable relief) where the total amount of the award sought by either party is less than $10,000 shall be resolved via binding non-appearance-based arbitration initiated through the American Arbitration Association (“AAA”). The AAA Rules are available online at www.adr.org or by calling the AAA at 1-800-778-7879. In any such arbitration, the parties and AAA must comply with the following rules: (a) the arbitration shall be conducted by telephone, online and/or be solely based on written submissions, the specific manner shall be chosen by the party initiating the arbitration; (b) the arbitration shall not involve any personal appearance by the parties or witnesses unless otherwise mutually agreed by the parties; (c) the arbitrator may award injunctive or declaratory relief only in favor of the individual party seeking relief and only to the extent necessary to provide relief warranted by that party’s individual claim; and (d) any judgment on the award rendered by the arbitrator may be entered in any court of competent jurisdiction. Nothing in this Agreement shall prevent either party from seeking remedies in small claims court of competent jurisdiction.
The right to refrain from arbitration. You may choose to waive this arbitration term. Then neither you nor MindYourLogic can demand that the other party take part in arbitration proceedings. In order to refrain, you must inform MindYourLogic in writing about this within 30 days of obtaining notice of this Arbitration section. You must provide the name and address, the e-mail address associated with your Game account (if you have one) and a clear wording that you want to waive the arbitration terms. All requests to refrain from arbitration must be sent to: MindYourLogic Studios Pvt. Ltd., Nirmal Ganga Complex, Gittikhadan Chowk, Nagpur, India and marked “Waiver of Arbitration”. If you do not waive this arbitration section it will continue to apply to you.
YOU AGREE THAT ANY AND ALL CLAIMS MUST BE MADE IN YOUR INDIVIDUAL CAPACITY, AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE PROCEEDING.
YOU AND MINDYOURLOGIC AGREE THAT ANY CAUSE OF ACTION ARISING OUT OF OR RELATED TO THE TERMS OF USE OR THIS PRIVACY POLICY MUST COMMENCE WITHIN ONE (1) YEAR AFTER THE CAUSE OF ACTION ACCRUES. OTHERWISE, SUCH CAUSE OF ACTION IS PERMANENTLY BARRED.
This Privacy Policy applies to all information collected by us or provided to us on and after the Effective Date. This Privacy Policy is subject to change and we may make any changes to this Privacy Policy as we see fit. MindYourLogic will notify you of material changes by posting them in the Game, or on the websites etc. You are encouraged to check back and review this Privacy Policy from time to time so that you will always know what information is collected how it is used and to whom it is disclosed. Your continued use of our services and playing of the Game subject to this Privacy Policy will signify your acceptance of Privacy Policy changes.
If you have any questions, complaints or comments regarding our Privacy Policy,
Please contact MindYourLogic at:
MindYourLogic Studios Pvt. Ltd.
Gittikhadan Chowk,
Nagpur
India
email: privacy@mindyourlogic.com