Privacy Policy of <Trip Master><Real Screw Master>
MONOTAR SOFTWARE ENTERTAINMENT LIMITED and its subsidiaries and affiliates (collectively, “MONOTAR SOFTWARE”, “we”, “our” or “us”) develops, publishes and operates social games for web and mobile environments (“Games”), as well as web and mobile applications (each, an “App”) for playing our Games across multiple devices and platforms (such as mobile devices and Facebook).
MONOTAR SOFTWARE respects your privacy and is committed to making our practices regarding your data more transparent and fair. This Privacy Policy describes how we collect, store, use and share your personal data, and it applies whenever you visit our Sites, install our App and play our Games, interact with us or otherwise access or use any of our Services.
We strongly urge you to read this Privacy Policy and make sure that you fully understand and agree to it. If you do not agree to this Privacy Policy, please discontinue and avoid using our Services. You have the right to cease using our Services, pursuant to this Privacy Policy at any time.
MONOTAR SOFTWARE is a “data controller”. This means that we are responsible for deciding how we hold and use Personal Data about you. We are required under certain data protection legislation to notify you of the information contained in this Privacy Policy. You are not legally required to provide us with any Personal Data, but without it we will not be able to provide you with the full range or with the best experience of using our Services (for instance, you may still play our Games without connecting your Facebook account, but you will not be able to enjoy their social features).
1. Data Collection
We collect four main categories of data (and to the extent it may enable the identification of a specific person, or is linked to such potentially identifying data, we will deem it as “Personal Data”):
a.Data automatically collected or generated:
When someone visits, interacts with or uses our Services, including any e-mail or text messages sent to them by us or via our Services, we may collect or generate technical data about them. We collect or generate such data either independently or with the help of third party services, including through the use of “cookies” and other tracking technologies (as further detailed below).
Such data consists of connectivity, technical or aggregated usage data, such as IP address, in-game identifier, game statistics, game preferences, unique advertising ID (e.g. IDFA; you may reset such ID based on the operating system instructions ), non-identifying data regarding a device, operating system, browser or App version, mobile carrier, locale and language settings, user activity on our Services, in-App or Game activity (such as game play content/product interaction and advertising data); diagnostic data (i.e. crash data and game performance data). We do not use such data to learn a person’s true identity or contact details, but mostly to have a better understanding on how our users typically use and engage with our Services. The use of such technical and device data also helps us and our partners to deliver interest-based or otherwise more effective advertisements and content, to optimize our ad management and our users' viewing experience), and to improve the overall performance and your user experience of our Services. For more information about our advertising uses, please see Section 8 below.
b.Data received from you:
You may provide us Personal Data voluntarily, such as when you set up an account with us, contact us (through Facebook, Messenger, e-mail, in-game chat or any other channel, including any support services), when you post on our public forums or groups, when you provide us your e-mail address (such as when you sign-up to receive e-mail updates or gifts), when you participate in competition, contest, tournaments and other promotions, when you place any purchases in any of our Games, when you interact with other users through the in-game chat or when you choose to connect your Facebook, Google, Apple or similar account to any of our Games.
c.Data received from Facebook and other channels:
Once you connect the Games to your Facebook, Google, Apple or similar account, we will receive access to your public profile, including (to the extent you defined it as “public”), as applicable, your full name, e-mail address(es) provided to Facebook, Google or Apple, gender, profile picture or similar photo, location, time zone, and a list of your friends playing the Games (along with their photos and other public profile information). This will also allow us to present your and your friends’ public profile pictures inside the Games and to create your in-game friends list. In addition, we or our advertising partners may receive from Facebook and our other marketing channels general information concerning the performance of our advertising campaigns, such as the targeted age group or interests, and we or our partners may be able to link such general data to any other data in our possession. To learn more about our advertising practices, please refer to Section 8 below. If you access our Services through a third party such as Facebook, Google or Apple, or connect our Services to any third-party account, you should also read their terms and conditions and privacy policies. If you are unclear about what information a third-party application is sharing with us, please visit that third-party application's website in order to learn more about their privacy practices.
d.Transaction Data:
In-Game purchases will typically be processed by the relevant platform provider (e.g. Apple, Google or Facebook), and we will not collect or store your financial data, e.g. your credit card numbers or bank account. We may still however receive your non-financial Personal Data related to the purchase, such as your name, billing address, e-mail address and the items purchased, in order to fulfil your purchase and for our accounting purposes.
2. Data Uses
Our legal basis for collecting and using your Personal Data will depend on the particular purpose for which your data is being processed, however, we generally use the following:
a.Performance of a contract. We will use this basis for processing necessary to make the Games, including social gaming when you choose to log in with Facebook, Google or Apple, and support services, available to you, and to send you service communications, gifts and awards.
b.Consent. In limited cases (where you choose to sign up to receive direct marketing emails, where you accept cookies on our Sites, we will process your Personal Data based on your consent. You can withdraw your consent at any time by contacting us using the details in Section 13.
c.Legitimate interests. We will process your Personal Data based on our legitimate interests in maintaining and improving our Services and offerings, understanding how our Services are used, serving effective advertisements within our Games and through other channels, matching users to create in-game friends lists, improving our customer service and support operations, fraud detection and protecting and securing our users, ourselves and our Services.
d.Compliance with a legal obligation. In limited cases we may process your Personal Data where we need to do so to comply with a legal obligation e.g. which is set out in an applicable law, or if we receive an order from a court or regulatory body.
The purposes for which we use Personal Data are described in more detail below:
a.To facilitate, operate, and provide our Services;
b.To authenticate the identity of our players, and allow them access to additional features;
c.To provide our users with customer care, assistance and technical support services;
d.To enable you to interact with other players in the game;
e.To further develop, customize and improve the Services and your user experience, based on common or personal preferences, experiences and difficulties, including by personalizing your profile and friends list;
f.To manage and deliver advertisements more effectively, including contextual, behavioral and interests-based advertising based on in-Games progress and activity, based on your preferences or other data available to us or to our Service Providers, including for re-targeting purposes;
g.To contact our users (via e-mail, Facebook, push notifications or any other available channels) with general or personalized service-related messages (such as purchase confirmations or system maintenance notices); to contact our users with promotional messages (such as Games updates, bonuses, new features, VIP services, etc.); and to facilitate, sponsor and offer certain events and promotions;
h.To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
i.To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our Service Providers may use to provide and improve our respective services;
j.To comply with any applicable laws and regulations.
3. Storage and Retention
While privacy laws may vary between jurisdictions, MONOTAR SOFTWARE has taken reasonable steps to ensure that your Personal Data is treated by its affiliates and Service Providers in a secure and lawful manner, and in accordance with common industry practices, regardless of any lesser legal requirements that may apply in their jurisdiction.
Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and are free to securely delete it for any reason and at any time, with or without notice to you.
In some circumstances, we may anonymize your Personal Data so that it can no longer be associated with you, in which case we may use such information without further notice to you and it is no longer considered Personal Data within the meaning of this Privacy Policy.
4. Personal Data Deletion and Closure of Accounts
In addition to any other rights set out in this Privacy Policy, you at any time may direct that MONOTAR SOFTWARE delete your Personal Data by accessing the “Account Deletion” button in the applicable Game and following the instructions. Selection of this option will result in closure of your Account and deletion of all of your playing history, purchase information, social media log-in and other information associated with you in connection with the Game. Deletion is irreversible. If you maintain Accounts with multiple Games, you should request closure of each.
Upon receipt of your request, we will comply promptly but please allow some time for processing. We also reserve the right to retain a copy of any Personal Data that we are required by applicable law to retain.