Privacy Policy
Last updated: 13 May 2023
This Privacy Policy explains how your personal data is collected and processed by MindYourLogic Studios Pvt Ltd ("MYL Games") when you use our mobile applications (the "App").
The App is free to play game (with optional in-game-purchases), and in order to maintain the high quality and a great game experience we process information from and about you in particular to improve the entire experience in the App and to support internal operations.
We update this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, depending on the specific changes, we will provide you with additional notice or require a renewed consent.
Collection of information
When you use the App, certain information about you is collected automatically, including general information such as the type of device you use, the features you access, the times you access them, and your IP address. We also gather information about your device, such as its manufacturer, model, operating system, time zone, and language. Additionally, we collect online identifiers of your device, such as IDFA, Google Ads ID, Google Device ID, Game Center ID, and Google Play Account ID.
We also collect data on how you use the App, such as your progress, scores, achievements, and interactions with other players. Furthermore, we track information about your consumption habits, such as purchases made with virtual or real currencies and the virtual goods you receive in-game.
Information we collect from other sources
When you log into the App using a third-party site or platform such as Facebook, Apple Game Center, or Google Sign-In, we may access certain information about you in accordance with the authorization procedures determined by the third-party site or platform. This information may include your screen name, profile information, and friend lists, provided that you have given such third-party site or platform your consent.
To learn more about how these third-party sites or platforms process your personal data, you can refer to their relevant privacy policies, which are available at the following links:
- Facebook: https://www.facebook.com/about/privacy/
- Game Center: https://www.apple.com/legal/internet-services/itunes/gamecenter/
- Google Play Games: https://policies.google.com/privacy
If you choose to log into the App using a third-party site or platform, you represent and warrant that you will comply with the applicable terms and policies of that site or platform, and that you meet the minimum age requirement prescribed by the legislation in your jurisdiction for using such third-party site or platform.
Use of information – purpose and legal basis
We use your personal data for the following purposes, which are based on the legal bases described below:
- We process log, device, usage, and consumption information, as well as device identifiers, to provide and deliver the products and services you requested, maintain the App and the game experience, and send you related technical notices, updates, security alerts, and support and administrative messages. We process this information because it is necessary for the performance of the contract to which you are a party, as it supports the operation of the App and facilitates the delivery of requested products and services.
- We also process this data to provide news and information about the App that we think will be of interest to you, to personalize and improve the App, and to monitor and analyze trends, usage, and activities in connection with the App. We process this information based on our legitimate interests in providing advertisements and content that are relevant to you and improving our services.
- If you have given us consent to share your advertising IDs with our ad network partners, we process this data to provide personalized advertisements to you in the App (behavioral advertising). We process this information based on our legitimate interests in providing advertisements and content that are relevant to you, and on your consent to share your advertising ID with third parties for the purposes of behavioral advertising.
- We process information from other sources to provide and deliver the products and services you requested, to link or combine information we get from others to help understand your needs and provide you with better service, and to provide news and information about the App that we think will be of interest to you. We process this data based on our legitimate interests in providing content that is relevant to you and improving our services. We only process your personal data to the extent necessary to achieve the purposes for which the data was collected.
Storage of information
MYL Games will retain your personal information for the duration necessary to provide you with the App and fulfill the purposes stated above. If required to establish, exercise, or defend a legal claim or comply with applicable laws, including accounting rules, further storage may be necessary. Once your personal data is no longer needed for the above-mentioned purposes, it will be deleted or anonymized. This will occur no later than three years after your last interaction with MYL Games.
Sharing of information
We may share your information with different categories of recipients based on the legal bases provided under Sections 6(1)(b), 6(1)(c), and 6(1)(f) of the GDPR, as explained above. These categories of recipients include:
- Social networks, as described in the "Social Sharing features" section;
- Third parties, if required to disclose your information by applicable law or in connection with a merger, sale of company assets, financing, or acquisition of our business by another company;
- Authorities, if necessary to protect MYL Games or others' rights, property, or safety or to address inconsistent actions with our policies;
- Other players, if necessary to provide certain in-app features, such as leaderboards, when you log into the App using a third-party service.
Additionally, if you have provided consent according to Section 6(1)(a) of the GDPR, we may share your Device identifiers with advertising network companies for serving behavioral advertisements within the App. We use or may use different advertising network companies, such as Facebook, Google LLC, Unity Technologies, IronSource, and Applovin Corporation, whose processing of your data will be governed by their respective privacy policies.
• Facebook, Inc. https://www.facebook.com/about/privacy/
• Google LLC https://policies.google.com/privacy
• Unity Technologies https://unity3d.com/legal/privacy-policy
• IronSource http://www.ironsrc.com/wp-content/uploads/2019/03/ironSource-Privacy-Policy.pdf
• Applovin Corporation https://www.applovin.com/privacy
We also use data processors for our processing, such as server hosting providers, technical service providers for supporting internal operations, user login services, and analytics service providers, including Facebook Analytics (Facebook, Inc.) and Firebase (Google LLC). If you have any questions regarding these third-party processors, please review their privacy policies.
Social sharing features
The App includes social sharing features and integrated tools (such as the Facebook "Like" button) that allow users to share their actions within the App with other media. To use these features, users must be above the minimum age limit set by the relevant legislation in their jurisdiction. Sharing information through these features is subject to the user's established settings with the entity providing the social sharing feature.
Children
The App is intended for users aged 13 or older, with the exception of users in the European Economic Area who must be aged 16 or older. By accepting this Privacy Policy and using the App, users confirm that they meet the required age threshold.
For inquiries regarding MYL Games’ privacy practices related to children under the applicable minimum age, please contact us at info@mindyourlogic.com.
Transfer to third countries
Under certain circumstances, we may transfer your personal data to recipients outside of the European Economic Area (EEA). However, we will only transfer your personal data to third countries that provide appropriate safeguards to ensure that their level of data protection complies with this Privacy Policy and applicable law. We will only make such transfers based on the following safeguards: • The entity is certified to comply with the principles for data protection under the US-EU Privacy Shield Framework ("Privacy Shield") (you can view the certified entities at https://www.privacyshield.gov/), or • We have entered into standard data protection clauses adopted by the European Commission with the entity, which is considered to offer sufficient safeguards with respect to the protection of the privacy and fundamental rights and freedoms of individuals.
Security
MYL Games takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.
Push notifications
We send push notifications or alerts to your mobile device to provide game-related information, service updates, promotional communications and other related messages, if you have agreed to such notifications. You can deactivate these notifications by changing your notification settings on your device.
Does MYL Games actually "sell" personal data?
MYL Games does not engage in the direct exchange of your personal data for monetary compensation, and therefore does not sell your data. However, we do share certain categories of personal data with third parties for business purposes, as outlined in the "Sharing of information" section. If this practice is considered a "sale" under the CCPA, you can exercise your right to withdraw your consent by contacting us at info@mindyourlogic.com.
YOUR RIGHTS
Rights of EEU residents
As a resident of the EEU, you have certain rights related to your personal data. We will respond to your requests in a timely and efficient manner, within one month of receiving the request, unless the request is complex and requires more time, in which case we may take up to three months to respond, as allowed under Article 12 of the GDPR.
Right to request access
One of these rights is the right to request access to the personal data we hold about you, as outlined in Article 15 of the GDPR. This includes information about the purposes of the processing, the categories of personal data involved, the recipients or categories of recipients to whom the data has been or will be disclosed, and the expected duration for which the data will be stored. You also have the right to obtain a copy of the personal data being processed. However, please note that access to this data may be restricted if it involves intellectual property or trade secrets.
The right to object
Under Article 21 of the GDPR, you have the right to object to the processing of your personal data if it is being processed based on the balancing-of-interest rule in Section 6(1)(f) of the GDPR and if the objection is related to your particular situation. In such cases, we will stop the processing of your data unless we have compelling legitimate reasons that override your interests, rights, and freedoms or if the processing is necessary for the establishment, exercise or defense of legal claims. You also have the right to object to the processing of your personal data for direct marketing purposes at any time. Once you object, we will no longer process your data for such purposes.
Right to rectification
You have the right to have inaccurate personal data rectified, see Article 16 of the GDPR.
The right to restriction
You have the right to obtain restriction of processing in certain circumstances, see Article 18 of the GDPR. If you have the right to restriction, we will only process your 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 obtained your consent to process your personal data, you have the right to withdraw your consent at any time, as stated in Article 7 of the GDPR. If you withdraw your consent, we will stop processing your data, except for cases where we have a legal obligation to retain certain parts of your data. Please note that withdrawing your consent does not affect the lawfulness of any processing that occurred prior to the withdrawal.
The right to data portability
You have the right to receive the personal data you have provided us with which we process in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller if the processing is based on consent or contract performance, see Article 20 of the GDPR.
Rights of California residents
We aim to respond to a verified request from a consumer within 45 days of receiving it. If we require more time (up to 90 days) to respond, we will inform you of the reason and the extension period in writing. Our written response will be delivered via mail. Please note that any information we disclose will only cover the 12-month period before we received the verified request. If we are unable to comply with the request, we will explain the reasons why. For requests related to data portability, we will provide your personal data in a format that is easily accessible and can be transmitted from one entity to another without any obstacles.
Right to opt out
Under CCPA each California resident can request any business stops selling personal information to third parties.
Right to be informed
You have a right to be informed about what categories of personal data we are collecting, including the purpose of the collection. You can freely find this information in our Privacy Policy. We update our Privacy Policy at least once every 12 months.
Right to disclosure
You have the right to request disclosure of the personal data we have collected about you within the past 12 months. Our Privacy Policy contains relevant information regarding the personal data we have collected about you and our intended collection practices, sources of your personal data, and how we use your personal data. You are also entitled to receive a free copy of your personal information disclosed in a readily usable and readable format (right of access), which can be requested twice per year at no charge. In response to a right of access request, we will provide information about the categories of personal data we collect, sources of the personal data, the purpose for collecting your personal data, any third parties with whom we share your personal data, and the specific pieces of personal data collected about you.
Right to deletion
You have the right to request the deletion of your personal data that we have collected in the past 12 months. While we respect your right to deletion, it is important to note that we may be required to retain your personal data in certain circumstances. For example, we may need to retain your personal data to provide you with our services, to detect or resolve security or functionality-related issues, to comply with legal obligations, to conduct research in the public interest, to protect the right to free speech, or to carry out internal actions that you might reasonably expect. If we do not have any obligations to retain your personal data for the above reasons, we can delete your personal information upon your request.
Data Deletion Request
You may request MYL Games to erase without undue delay your personal data when it is no longer necessary for MYL Games to retain such data.
In order for your data to be erased you can contact MYL Games by info@mindyourlogic.com.
Right to equal services and prices
As a California resident, you have the right to exercise your CCPA rights without any fear of discrimination by us. We will not deny you access to our App or provide you with a different level or quality of service because you have exercised your CCPA rights. Additionally, we will not charge you different prices or rates for our App or suggest that you might receive different pricing or quality of service due to exercising your CCPA rights. We are committed to protecting your CCPA rights and ensuring that you receive fair treatment and equal access to our services.
How to exercise my rights
If you would like to exercise any of the rights outlined below, please feel free to contact us by sending an email to info@mindyourlogic.com. Please note that before we can process your request, we will need to verify your identity to protect your privacy and security. As you do not provide us with any personal information directly and we only collect information automatically, we may need to use limited verification methods. Typically, we will require the matching data in our systems to the information you provide when making the request. However, in some cases, we may not be able to verify your identity, for example, if you have disabled cookies, changed the device used to access the App, or previously requested that we delete your personal data. If we are unable to verify your identity, we may decline your request.
Contact
MYL Games has the following contact information:
MindYourLogic Studios Pvt Ltd
Address: 5th Floor Park Avenue, New colony road, Sadar, Nagpur, Maharashtra, India
Email: info@mindyourlogic.com.