Last revised: [March 2021]
At MANAGENE GAMES, we collect personal data to support our products and services, while respecting all applicable laws, including but not limited to the Personal Information Protection and Electronic Documents Act (PIPEDA), regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, directly applicable from May, 25th, 2018 (hereinafter, "General Data Protection Regulation", or "GDPR"), UK GDPR, Children's Online Privacy Protection Act of 1998(COPPA) in USA, or other applicable laws or regulations in your country. As defined in the GDPR, "personal data" means any information relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
According to the GDPR, COPPA and other applicable laws and regulations, the minimum age for you to play our game services unsupervised is 13 (in US，JAPAN )/ 14(in UK、KOREA )/16(in Europe)/18(in most countries) years old. We will not knowingly collect personal data from children under this age without prior consent from their parents or legal representative. If you are a child under the age abovementioned, we will require parental consent before an account is created for you and personal data associated with it collected and use all reasonable efforts to verify that the consent was given by the child’s parents or legal representative, considering available technologies. We encourage parents to instruct their children to never give out personal data when online.
In the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, we will make an announcement in advance, disclose the details of the event and information about the successor, and with the express consent of you or your guardian in advance, your personal data may transfer to the successor of MANAGENE GAMES.
1. WHAT PERSONAL INFORMATION DOES MANAGENE GAMES COLLECT?
1.1 When you use MANAGENE GAMES services
1.1.1 While Browsing MANAGENE GAMES websites
IP addresses. MANAGENE GAMES also collects Internet Protocol (IP) addresses for safety and security reasons. An IP address is a number that is used by computers on the network to identify your computer every time you log on to the Internet.
Other passively collected information. While browsing our sites, MANAGENE GAMES may, on its own, or with the help of third-party tools, collect non-personally identifiable information concerning your gaming hardware, habits, behaviors and use of our Services. MANAGENE GAMES collects such information to better adapt our Services to users’ interests, and for a better quality of our Services. The information collected may contain the following, without limitation: device unique identity, including MAC address, mobile, unique identifier or other device identifiers and settings, internet provider, carrier, operating system, hardware information, localization information, date and time spent on the Services, game scores, game metrics, achievements, rankings, time played and statistics, feature usage, advertising conversion rates, monetization rate, purchase history and other similar information.
1.1.2 Registering on a MANAGENE GAMES service
When you use our Services, you may give us information directly (like when you’re setting up your account). Some games or parts of our Services may also let you create a registration or account where you may be asked to give us information like: your username, password, email address, date of birth (or age) and country of origin.
1.1.3 Contacting MANAGENE GAMES
1.1.4 Participating to contests and sweepstakes
MANAGENE GAMES may offer you the opportunity to participate in online surveys, questionnaires. To participate, you may need to provide your first name, your family name, e-mail address, date of birth, your address and country of residence. If you choose to participate in surveys and questionnaires, your personal data may be processed to allow you to participate, and for internal statistical use.
1.1.5 Interacting on forums
Whenever you participate or interact with other users on a forum, MANAGENE GAMES collects the content of your communications, the time and the location of your activities, as well as your online ID and your IP address.
You have the right to withdraw your consent to the processing of your personal information for advertising purposes at any time by contacting us in the manner set out in section 8, or by turning off the corresponding permission in the privacy settings of your personal devices. We undertake not to process personal information of children or minors under the age of 13 (or the age of a minor or child as defined by law or other regulation in your country or region) for advertising purposes.
1.1.7 Social media and other third parties’ platforms
We collect the Data that you have agreed to share via the social media site or third-party platform in question when you sign into our Services with a social login or your credentials from a third-party platform (for example, Facebook, Google).
If you become aware that a third party application provider is processing personal information about you or your child in a manner that causes you concern or anxiety, you may also contact us and we will do our best to assist you with the situation.
1.2 Whenever you play games of MANAGENE GAMES
1.2.1 Creation of user generated content
Some Services give you access to tools in order to allow you to create and/or share unique content. This User-Generated Content may be collected by MANAGENE GAMES; this content may also contain your personal information or the personal information of others (for instance, your name, or a picture of you). Please exercise caution: MANAGENE GAMES is not liable for any negative consequences linked to your disclosure of User-generated content.
1.2.2 In-game data collection
1.3 Online payment
For some Services, you may make purchases, whether you shop on MANAGENE GAMES websites or directly in-game.
When you do this, you agree that MANAGENE GAMES may share your personal data with third parties, companies, or organizations, which may collect and process your personal data in order to effectuate online transactions, delivery, discounts, and promotional gifts.
2. HOW DOES MANAGENE GAMES USE YOUR PERSONAL DATA?
a. you use a Service,
b. you create an Account,
c. you make a purchase within our Services,
d. you create user generated content,
e. you watch advertisements within our Services,
f. you sign up for a newsletter,
g. you contact MANAGENE GAMES customer service and during technical support sessions,
h. you chat with other users of the Services,
i. you participate in a beta or otherwise download a patch or a demo, or
j. you share or otherwise contribute to our social media channels or other community websites.
In addition, MANAGENE GAMES may use the submitted information to answer your demands, to send your order confirmations and other information regarding your MANAGENE GAMES Account, to send you (non-child or minors only) advertising or promotional materials, including information about special rebates, promotional offers and other events of interest, based on your preferences.
We also may use your personal information for our internal marketing and demographic studies, so we can constantly improve the Services we provide you and to better meet your needs.
MANAGENE GAMES processes your personal data, wherever necessary:
- To provide you with the Services (creation of your MANAGENE GAMES account, bug detection, fighting fraud, online payment, etc.)
- To offer the best possible experience to users, and improve the Services (in-game data analytics, etc). It is in MANAGENE GAMES’s legitimate interest to process your data for these purposes.
- To provide you with supplementary services (custom content, etc.). In such case, MANAGENE GAMES will ask for your consent before processing your personal data for this purpose.
Whatever the activity may be, we will only collect personal information to the extent necessary to provide you with the Services and fulfil your requests.
3.Security of Your DATA
We take your privacy and the security of your personal information very seriously. To protect your personal information, MANAGENE GAMES maintains appropriate safeguards to ensure the security, integrity and privacy of the information you have provided. We use robust security measures to protect personal information from loss, misuse and alteration. We use industry-standard practices such as encrypted communications, physically secured rooms, firewalls and password protection systems to safeguard the confidentiality of your personal information. In addition, we take reasonable steps to assure that third parties who collect personal information on our behalf provide sufficient protection of personal information. Please note, we will make every effort to protect your personal information to the maximum extent possible using the security solutions allowed by available technology and notify Users of a data breach pursuant to applicable law.
4. FOR HOW LONG DOES MANAGENE GAMES KEEP YOUR PERSONAL DATA?
5. WITH WHOM DOES MANAGENE GAMES SHARE YOUR PERSONAL DATA?
MANAGENE GAMES does not disclose your personal data to any third party other than our affiliates and partner suppliers without your prior consent, except in cases where disclosure is expressly required by applicable laws or regulations.
5.1 Sharing your personal data with MANAGENE GAMES affiliated companies
5.2 Sharing your personal data with third parties
the list of the third parties collecting your information on our behalf is as followed:
Name of the SDK provider: [Facebook]
purpose of data collection: [Login, analytics]
Name of the SDK provider: [AppsFlyer]
purpose of data collection: [Configuring media sources]
Name of the SDK provider: [Firebase]
purpose of data collection: [Configuring media sources, analytics, push notification]
5.3 Sharing your personal data with government authorities
In accordance with relevant laws, MANAGENE GAMES may have to disclose your personal data to a judiciary or administrative entity, whenever such disclosure is deemed necessary for protecting or enforcing the legal rights of MANAGENE GAMES, its Users, or third parties. Unless required by law, MANAGENE GAMES will not be required to notify you of any such disclosure.
5.4 Transfers of personal data to third countries or outside the European Union
The user data we collected above is stored and encrypted in our servers located in East Virginia, United States of America (“USA”). And you are aware and agree that your personal information may be transferred to, stored in, and processed by affiliated companies, subcontractors and/or MANAGENE GAMES partners, located in third countries/outside the country where you live or work. Because different countries may have different data protection laws than your own country and they may not provide you with protection of the same level to your personal information as the data protection law in the country where you live or work, in which case, we will take steps according to applicable laws and regulations in your country to ensure that your personal information is adequately protected within the data process location.
5.5 Friends and Other MANAGENE GAMES Players
MANAGENE GAMES Services may offer a public profile feature ("Public Profile") that allows you to publish information, including personal information, to the public Internet. Those aspects of the Public Profile that are designated as "public" will be visible to everyone, potentially including people not registered within the MANAGENE GAMES environment, and may be indexed and displayed through public search engines when someone searches for you. If you post your personal information to a Public Profile, including a video, image or photo, you should be aware that these may be viewed, collected, copied and/or used by other users without your consent.
We are not responsible for disclosure by other users of your Personal Information, including without limitation, videos, images or photos that you choose to make public on the MANAGENE GAMES Services. Also, please remember that the Personal Information you provide to us as part of your Public Profile may reveal or allow others to identify aspects of your life that you may not choose to state on your Public Profile directly (for example, your picture may reveal your gender).
6. WHAT ARE YOUR RIGHTS AS DATA SUBJECT?
You can access and update the contact information you gave us during registration (that is, your e-mail address or any other information that would directly enable us to contact you), by logging in and clicking the Edit Profile section. Additionally, according to the applicable laws and regulations in the country or region where you live or work, you may have a right to access, rectify, erase, object, or restrict processing for all your personal data processed by MANAGENE GAMES, as well as the right of data portability. You can exercise these rights or terminate your MANAGENE GAMES account by writing to MANAGENE GAMES customer support, via the following website: [www.managames.hk] or send an e-mail to [firstname.lastname@example.org]. MANAGENE GAMES will answer your request within a month following the receipt of your demand and the completion of the verification process. MANAGENE GAMES reserves the right to extend this delay up to three months if it necessary regarding the complexity of your demand, or based on the number of demands we receive. In such case, we will inform you of this extension within a month following the receipt of your demand. For any data processing activity requiring your consent (cookies, behavioral advertising, etc), you may withdraw your consent at any time. This withdrawal does not affect the lawfulness of any previous processing. You can also adjust your browser settings to understand when these Cookies are stored on your device or to disable the Cookies by consulting your browser’s “Help” menu. Please note that these settings may affect your ability to access certain features of our Services whenever these Cookies are needed for the operation of our Services.
Opting Out of Third-Party Behavioral Advertising
If you are interested in more information about behavioral advertising and your choices to prevent behavioral web and mobile web advertising from third parties, you may visit the following websites:
• Network Advertising Initiative Consumer Opt-Out Page or the Digital Advertising Alliance Opt-Out Page for U.S.-based advertising
• If you do not want to receive behavioral in-application advertisements from third parties that relate to your interests on your mobile device, you may adjust the ad tracking settings on your device (such as turning on “Limit Ad Tracking”). You can also reset the “Advertising Identifier” (such as an IDFA) from your mobile device’s settings page, which will prevent continued use of existing behavioral data tied to your previous “Advertising Identifier.”
All of the opt-out tools described in this subsection are provided by third parties, not by MANAGENE GAMES. MANAGENE GAMES does not control or operate these tools or the choices that advertisers and others provide through these tools.
Please note that you may still receive third-party advertisements in MANAGENE GAMES’s Services after using these opt-out tools, but the advertising you see may be less relevant to your interests.
Opting Out of Promotional Communications from MANAGENE GAMES
You can unsubscribe from promotional emails by by following the unsubscribe instructions included in these emails. You can opt out of mobile push notifications in your device’s settings page. You can opt out of SMS text communications by texting STOP. You also may contact us at [email@example.com].
* If there are special provisions provided by applicable laws (including but not limited to GDPR, UK GDPR, CCPA, COPPA, PIPEDA etc.) and regulations in the country where you live or work, we will process your personal data in accordance with applicable laws.
You can also write to us at the following address: [Rm 2701 27/F CENTRAL PLZ，18 HARBOUR RD，WANCHAI，HONG KONG]
Please be assured that any Personal Information that you provide in communications to the above email and postal mail addresses will not be used to send you promotional materials, unless you request it.
According to applicable laws, you may also have the right to lodge a complaint to data protection authorities in the country where you live or work.