PRIVACY POLICY - MADBOX

Last update: November, 18th 2021

Welcome to MadBox Privacy Policy!
This policy describes how and why MadBox, its group companies and its partners collect and process information (the “Data”), including personal information, we collect through our games and applications (the “Games”) or on our Madbox.io website (the “Website”). Hereinafter, we refer to both the Games and the Website as the “Services”.

It provides you with all important information regarding the principles that we apply to these information, and informs you about your “data subject rights” which are designed to protect your privacy.

Please note that this policy only applies to information collected and/or processed received by MadBox through your use of the Services.

If you have concerns about the information you make available to us or about our use of it under this privacy policy, we advise you not to use our Games or our Website.

If you have any questions, feel free to contact us at privacy@madboxgames.io.

Table of Contents

1. Our Games

Why do we collect or use your Data

When you install and play MadBox’s Games, we can collect and process some of your Data based on your express consent or for different purposes.

Under data protection law, where we are a data “controller” (meaning, when MadBox is the main decision-maker which exercises overall control over the purposes and means of the processing of personal information), we can only use your personal information if we have a proper legal basis for doing so, such as:

- for the performance of our contract with you;
- where you have given consent
- to comply with our legal and regulatory obligations;
- for our legitimate interests or those of a third party.

A legitimate interest is when we have a business or commercial reason to use your personal information and includes our own interests or the interests of third parties, and can cover commercial interests (e.g. sustain our free-to-play model), so long as this is not overridden by your own rights and interests.

Where under law or regulation we are required to obtain your consent to the processing of your personal information (for example, in countries that do not provide for legitimate interests as a legal basis), we will obtain your consent.

You will find below why MadBox may collect your personal information and the legal basis we rely on in each case :

For all data processing activities that rely on users’ consent, you can always change your preferences and withdraw your consent in the privacy settings of any of our applications. 

Note that, if you opt-out, you will still be able to see ads in our applications and some of our partners may still serve ads to you based on the non-personal information they have.

What Data do we collect 

When you use any of MadBox’s applications on a mobile platform and, for the above specific purposes, we may collect and process (store, share with our partners, process for analytics purposes) the following Data strictly in accordance with the lawful bases identified above:

- Your advertising ID, meaning, 
›› if you’re using an Apple device, the IDFA (Identifier For Advertising) / IDFV (Identifier For Vendors)
›› if you’re using an Android device, the GAID (Google Advertising ID)

- Your location at a city/region level (based on your Internet Protocol - “IP” - address),

- Technical information about the device you use and your connection (for instance, the operating system, device model, type of connection, language, timezone),

- Technical data pertaining to the app you’re using (for instance, the app version you’ve installed),

- Data pertaining to your activities in game and the way you interact with our apps (for instance, gameplay data, total play time, how and when you use our applications, your level in game, details of your in-app purchases excluding your payment/credit card information)

- Data pertaining to the advertising served in our applications (for instance, number of ads you’ve clicked on, purchase time, quantity of IAP you’ve purchased).

How is your Data collected

Most of the personal information we process via our Games comes directly from you.

In addition, we may also collect personal information:
- from our business partners SDK’s, as outlined below;
- from any other third party to whom you have given your consent.

With who may we share your Data

When you consent to the collection of Data for advertising and third party analytics purposes, we may share the data listed above with the following categories of recipients.

1. Advertising networks and Attribution

To provide users with free-to-play Games, we are working with third parties to (i) advertise our Games on different networks and other applications and (ii) monetize our Games via advertising revenue (we insert ads in our apps) and in-app purchases. 

These third parties generally collect user and device-related Data via their own SDKs (Software Development Kit), notably for attribution purposes. For example, you may see our Games advertised in other apps. After clicking on one of these advertisements and installing our Game, you will become a user of our Services. In order to verify the installs, a device identifier may be shared with our attribution partner to ‘match’ the advertisement with your install: this is what we call the “mobile attribution”. 

The privacy policies of our partners may include additional terms and disclosures regarding their data collection and tracking technologies. We encourage you to check those privacy policies to learn more about practices and exercise your rights directly towards them: 

2. Analytics partners

These partners provide us with tools and technologies that allow us to better understand how users interact with our Games and will help us improve it:

3. Storage / Servers

MadBox is relying on either AWS or GCP to store the Data we collect via our apps :

In addition to the other disclosures described in this Privacy Policy, we will also share your information:

- as is necessary to comply with any legal obligation;
- if there is a sale of the assets of MadBox or corporate restructuring, or as a result of a change of control of MadBox, or in preparation of any of these events. Any third party to which MadBox transfers or sells MadBox's assets will have the right to continue to use the Data that you provide to us in the manner set out in this Privacy Policy.

How long do we keep your Data

We keep the Data collected and processed for the purposes described in this policy only as long as necessary.

We will also retain and use your information for as long as is required in order to comply with our legal obligations.

Our policy regarding children

You must be over a certain age to play our Games and use our Services, depending on where you live. For the list of age restrictions by country, you can refer to this page published by the European Union Agency for Fundamental Rights.

We do not knowingly or willingly collect or solicit personal information from anyone under the applicable age, or knowingly allow such persons to use our Services. 

If you are under the legal age in your country, please do not play our Games or use our Services.

In the event that we learn that we have collected personal information from children under the legal age, we will delete that information as quickly as possible. If you believe that we might have any information from or about children under the legal age please contact us at privacy@madboxgames.io.

Data storage and International transfers

We store our Data on servers located in Europe via Amazon Web Services or Google Cloud Platform.

To deliver Services to you, it is sometimes necessary for us to share your Data outside of your country or region, e.g.:

- with our offices and group companies;
- with our service providers.

We may therefore transfer information that we collect about you to our third-party partners across borders, including outside of the European Economic Area (the “EEA”).

Please note that these countries outside of the EEA may not have the same data protection laws as your own jurisdiction. We take steps to ensure that there are adequate safeguards and mechanisms in place (including the use of EU Standard Contractual Clauses) to allow the transfer of your information outside of the EEA.

We also make sure any third parties we share information with have an adequate transfer mechanism in place, as well.

Security

We take appropriate security and technical measures to protect your information from unauthorised access, loss and misuse.

In addition, we request that our suppliers who process personal information on our behalf take a range of security measures designed to help protect your personal information and maintain an appropriate level of security.

2. Our Website

When you visit our madbox.io Website, here are the information that we may collect and process :

- browsing events and interactions with the Website’s contents and services (for instance, operating system, IP address access times, browser type and language);
- information that you provide us with when you fill in forms on our Website;
- if you contact us or respond to messages and communications that we send to you, we may keep a record of that correspondence;
- your interactions with us on our social media channels;
- information we collect via cookies and other similar technologies. For more information, see the “Cookies” section below.

We, or our partners may use these information:

- to operate and optimize the Website;
- to contact you, for example to send you updates about our Games or the Website;
- for the purposes of research, surveying, and engaging with you, for example by sending you communications (including by email) for these purposes.

If you no longer wish to receive these emails, you may opt-out from receiving them at any time by emailing us at privacy@madboxgames.io.

Cookies

Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are small text files stored on your browser that allow the collection of information related to your navigation on a website (e.g. interactive content or analytics).

MadBox uses Google Analytics to collect information related to the web traffic on our website. The following cookies have been set on our Website:

To opt-out from Google Analytics data collection: https://tools.google.com/dlpage/gaoptout

In accordance with our Data Protection Authority guidelines, cookies exempted of consent are valid for a maximum of 13 months, and cookies requiring consent are generally valid for 6 months.

In addition, the maximum data retention period of information collected via technical cookies is 25 months.

3. Your choices and rights

Under data protection law, you have certain rights in connection with your personal information and how we handle it. You can exercise these rights at any time by contacting us at privacy@madboxgames.io :

- Right of access. You have the right to know what information we hold about you and in some cases to have the information communicated to you. If you wish to exercise this right please contact us letting us know that you wish to exercise your right of access and what information in particular you would like to receive. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information.
- Right to rectification. You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Right to erasure. You have the right to ask us to erase your personal information in certain circumstances. 
You can contact us, as indicated in the “Contact” section below, in order to have the data previously collected by MadBox on you and/or your device permanently erased.
In addition, in order for your data not to be collected anymore (for the future), you can, in the following order: 

• Activate “Limit Ad Tracking” (LAT) in your device settings to opt-out of having an ID for Advertisers and don’t see specific ads targeted at you; and
• Desinstall our Games; and
• Reinstall our Games.

Where we delete personal information about you, we may still retain some or all of that information for other purposes such as maintaining financial records, protecting or enforcing legal rights. We may also retain your information in an anonymised form.
- Right to restrict processing. In some cases, you may have the right to request a restriction of the processing of your personal data, such as when you are disputing the accuracy of your data held by us.
- Right to data portability. When the processing of your personal data is based on consent or contract, you may have the right to request that personal data that you have provided to us is provided to another data controller of your choice in a portable format.
- Right to object to processing. You have the right to object to the processing of personal data about you which is processed on the grounds of legitimate interests.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. 
Please contact us at privacy@madboxgames.io. 

4. Contact Information

MADBOX SAS (RCS Paris 807 743 844)
19-21 rue Poissonnière – 75002 Paris, France

As a data subject, you have the right to lodge a complaint with the CNIL, our French data supervisory authority: www.cnil.fr

If you have any questions about this Privacy Policy, please contact us at privacy@madboxgames.io.