Last updated: 20 April 2022
Mobile Card Games (“us”, “we”, or “our”) develops, publishes and operates mobile applications (hereinafter referred to as the “App”).
The App is a free to play game. This is provided by us at no cost and is intended for use as is.
This page informs you regarding our policies with the collection, use, and disclosure of personal data if anyone decided to use our App, and the choices you have associated with that data.
During installation of the App on your mobile device, entering into, connecting to, using and/or accessing any of the App, you confirm directly that you have read, understood and agree to the Privacy Policy regulation.
If you do not agree to the Privacy Policy, please do not use our App and promptly erase our App from your mobile device.
The personal data that we collect is used for providing and improving the App. We will not use or share your data with anyone except as described in this Privacy Policy.
Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Services.
When you access or use the App, we automatically collect general information about you, including:
Log Information: We log information about your use of the App, including but not limited to the type of device you use, the features you use, access times and your IP address.
Device Information: We collect information about the device you use to access the App, including but not limited to information about the device manufacture, device model, device's OS, time zone of device, language of device.
Device identifiers: We collect online identifiers of the device you use to access the App, including but not limited to Google Ads ID, Google Device ID and Amazon Advertiser ID.
Usage Information: We collect information relating to your use of the App, including but not limited to your game progress, scores and achievements.
We collect the following categories of your personal information and may sell it to third parties: identifiers, commercial information, internet or other electronic network activity information, geolocation data, and inferences drawn from these categories.
We use information about you for the following purposes in accordance with the legal bases for each type of personal data as described below:
Log-, device-, usage-, and device identifiers are being processed:
to provide and deliver the products and services you request and send you related information as requested by you / as agreed with you;
to provide and maintain the App and the game experience; and
to send you technical notices, updates, security alerts, and support and administrative messages;
Our processing for the above purposes is necessary for the performance of a contract to which you are party in order to support the operation of the App, facilitate the delivery of requested products and services and enable maintenance and update of the App, see Article 6(1)(b) of the GDPR.
to provide news and information about the App that we think will be of interest to you;
to personalize and improve the App and provide tailored content and features;
to monitor and analyze trends, usage and activities in connection with the App;
Our processing for the above 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 (also known as "the balancing-of-interest rule").
to provide users that have given us consent to share their advertising IDs with our ad network partners (as further specified under “Sharing of Information”) for the purpose of serving them with personalized advertisement in the App (behavioral advertising).
Our processing for the above purpose is justified by our legitimate interests in providing advertisements and content of interest to you in accordance with Article 6(1)(f) of the GDPR. The 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 (see more below under Sharing of Information).
We only process your information to the extent that is necessary to achieve the purposes for which the information has been collected.
We keep your personal information for no longer than necessary for the purposes for which the data is processed. The length of time for which we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.
We disclose information about you to the following categories of recipients based on the legal bases under Sections 6(1)(b), 6(1)(c) and 6(1)(f) of the GDPR (see a description of the legal bases above):
Third parties if we are required to disclose your personal data by applicable law, rule, regulation, legal process or in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
The authorities if we believe your actions are inconsistent with the spirit or language of our policies or if the disclosure is necessary to protect the rights, property and safety of Mobile Card Games or others;
Furthermore, if you have given your consent in accordance with Section 6(1)(a) of the GDPR, we share your Device identifiers to advertising network companies for the purpose of them serving behavioral advertisements to you within the App. We use or may use the following advertising network companies:
In connection with our processing, we use following data processors such as server hosting providers, technical service providers for supporting internal operations, user login services and analytics service providers:
The recipients' use of the disclosed information will not be covered by this Privacy Policy. If you have questions concerning the processing carried out by such third parties, you should review their privacy policy.
In connection with the processing, we will in certain circumstances transfer your personal data to recipients outside the EEU.
We only transfer personal data to entities in third countries that have provided appropriate safeguards to ensure that their level of data protection is in agreement with this Privacy Policy and applicable law.
Mobile Card Games does not, and will not, provide your personal data in direct exchange for money. Therefore, in the literal sense, Mobile Card Games does not sell your data. However, we have disclosed some categories of personal data we collect, explained under “Sharing of information”, to the third parties for business purpose as explained under “Use of information – purpose and legal basis”.
To the extent this practice is interpreted to constitute a “sale” under the CCPA, please contact us to exercise your right to withdraw your consent on sharing your personal data with third parties.
Cookies are files with small amount of data that is commonly used an anonymous unique identifier. These are sent to your browser from the website that you visit and are stored on your device internal memory.
This App does not use these “cookies” explicitly. However, the app may use third party code and libraries that use “cookies” to collection information and to improve their services. You have the option to either accept or refuse these cookies and know when a cookie is being sent to your device. If you choose to refuse our cookies, you may not be able to use some portions of this App.
We value your trust in providing us your Personal Information, thus we are striving to use commercially acceptable means of protecting it. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.
This App may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
Use of the App is limited to users aged 13 years and above, except in European Economic Area, where the App is limited to users aged 16 years and above. If you are accepting this Privacy Policy and using the App, you warrant you are 13 (or 16, depends what is applicable) or more years old.
In the case we discover that a child under 13 (or 16, depends what is applicable) has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions.
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.
We 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.
Right to request access
You have the right to request access into the data that we are processing on you, see Article 15 of the GDPR, including information about:
Furthermore, you have the right to obtain a copy of the personal data undergoing processing. 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 our processing of your personal data on grounds relating to your particular situation when the data are processed based on the balancing-of- interest rule in Section 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.
Right to rectification and erasure
You have the right to have inaccurate personal data rectified, see Article 16 of the GDPR.
Furthermore, you have the right to have your personal data erased where one of the following grounds applies, see Article 17 of the GDPR.
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, 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 asked for your consent to our processing of your data, you have the right to withdraw your consent at any time, see Article 7 of the GDPR.
If you withdraw your consent, we will cease processing of the data for which you have withdrawn consent, unless we have a legal obligation to keep some or parts of your data.
The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its 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.
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal data that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
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 can request us to disclose what personal data we have collected on you in the past 12 months.
We can assure you that our Privacy Policy is an relevant document where you can find information about what personal data we have collected about you over the past 12 months and intend to collect, sources of your personal data and how we use your personal data.
You also have a right to get a free copy of your personal information disclosed in a readily usable and readable format (right of access). You can make this request for free, twice per year.
When providing information under the right of access, we will provide you with the following information:
The categories of personal data we are collecting about you,
The categories of sources of the personal data,
The purpose for collecting your personal data,
The categories of any third parties with whom we share your personal data,
The specific pieces of personal data collected about you.
Right to deletion
You can request us to delete the personal data we have collected on you in the past 12 months.
We fully recognize you right to deletion, however, we would like to note that in some cases we are obliged to keep your personal data for certain period of time. For instance, if we need to provide services to you, detect or resolve issues security or functionality-related issues, comply with the law, conduct research in the public interest, safeguard the right to free speech or carry out any actions for internal purposes that you might reasonably expect. If we do not have obligations to perform any of the above actions, we can delete your personal information at your request.
Right to equal services and prices
California residents are protected against any discrimination that a business might subject them to based on the exercising of their CCPA rights.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Charge you different prices or rates for the App, including through granting discounts or other benefits, or imposing penalties,
Provide you a different level or quality of the App,
Suggest that you may receive a different price or rate for services or a different level or quality of the App.
If you wish to use any of the rights described below, you may contact us at any time by emailing us from within the App.
Mandatory verification: We will need to verify your identity before processing your request. However, because you cannot create an account with the App, and you do not provide us with any information directly, we only collect information automatically, we may use limited verification methods. To verify your identity, we will generally require the matching data in our systems to the information we can process when you are making a request. In certain circumstances, we may decline the request, mainly where we are unable to verify your identity, for example, if you disable cookies, changed the device you used to access the App or you already requested us to delete your personal data.
We may update our Privacy Policy from time to time. Thus, you are advised to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately after they are posted on this page.
If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact us from within the App.