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MadOut2 Big City Online | Privacy Policy 

 

Effective date: March 20th, 2024

 

 

This Privacy Policy (the “Policy”) explains how and why Ivanchuk Vladislav as the copyright holder of the Game (“We” or derivatives) processes your personal data while you play the MadOut2 Big City Online mobile game (the “Game”). 

In addition to the Policy, please also review the Terms of Use.

 

 

About us 

 

  1. Copyright holder: Vladislav Ivanchuk

  2. Address: The Meydan Hotel, Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, United Arab Emirates

  3. E-mail: support@madoutgames.com

  4. We are the controller of your personal data, that is, We independently determine how and why We process your personal data (the “Controller”).

 

When We start to process your personal data

  1. You accept the terms of this Policy when downloading the Game. Please note that We process your personal data primarily with your consent. If you/your legal representative do not agree to the Policy, kindly uninstall the Game immediately.

 

  1. Some of the data that we collect and process are a contractual requirement and/or necessary to enter into a contract. Without this data, we will not be able to conclude and fulfill the contract with you.

 

  1. Conversely, some data are not a statutory or contractual requirement, nor are they necessary to enter into a contract. You are free to refuse the processing of this personal data.

 

  1. For more information, please see the section "Purposes and bases for collecting and processing data".

 

  1. However, if you refuse to consent to our processing of your personal data, We will be forced to limit available functionality and will not be liable if the missing personal data processing prevents the adequate work of the Game.

 

  1. If you wish to stop the processing of your personal data, you may withdraw your consent.

 

Personal data of minors

 

  1. Since access to the Game is provided remotely, We may inadvertently collect personal data from persons under the age of legal capacity.

  2. In this case, the Policy on behalf of the minor is accepted and confirmed by the legal representative of the minor.

  3. If you are a minor, please make sure that your parent or legal representative has read and understood the provisions of the Policy. 

  4. If you are a minor and cannot familiarize your legal representative with the provisions of this Policy, as well as if you (your legal representative) do not agree with the terms of this Policy, immediately stop further use of the Game.

  5. If a legal representative allows a minor to use the Game, it means that such a legal representative has read and understood the Policy, as well as accepted the Policy on behalf of the minor.

 

Amendment of the Policy

 

  1. We can change the Policy. 

  2. If We make significant changes to it, We will send you an in-Game notification before the changes take effect, but We ask you to regularly check for the latest version on this page. 

  3. The changes will take effect 15 days after publication. If you use the Game from the effective date of the changes, you agree to the new version of the Policy.

 

 

Principles of data processing

 

  1. In the processing of your personal data, We adhere to the following principles:

    1. Lawfulness. We process personal data only legally (with your consent, by virtue of the law, based on legitimate interest, on other legitimate grounds) and for specific purposes, as well as for the proper performance of the contract with you.

    2. Transparency. We strive to be as clear and open as possible about how We collect, use and share personal data. If you have any questions about any provisions of the Policy, We are open to communication.

    3. Fairness. We do not allow the processing of personal data in an unreasonably harmful, discriminatory, unexpected or misleading way.

    4. Specified, explicit and legitimate purposes. The purposes of processing your personal data can be found in the “Purposes and basis for collecting and processing data” section of the Policy. We do not process personal data for purposes not specified in this section.

    5. Data minimization. We process data only to the extent necessary to achieve the processing objectives.

    6. Accuracy. We keep your personal data up-to-date.

    7. Storage limitation. We do not store personal data for longer than is necessary for processing purposes.

    8. Integrity and confidentiality. We strive to ensure the security of your data by protecting it from unauthorized or illegal processing, as well as from accidental loss, destruction or damage, using appropriate technical and organizational measures.

 

 

Data We collect

 

  1. When you play the Game and share your personal data with Us, We act as the Controller of your personal data.

  2. We collect the following data, which may be considered personal data in some countries:

 

 

Data that you provide

 

  1. We collect the data that you provide yourself when using the Game. You have the right not to provide this data, but certain functions will not be available to you.

  2. These data include:

  1. “User's email” - your unique email address.

  2. “Username” is a set of characters and/or numbers that are not yet used by another player in our Game, and which you can change in your account yourself. You can specify the Username yourself, but this is optional. If you refuse to specify a Username, it will be assigned randomly in an automatic manner.

  3. “User’s Avatar" is an image or photo that you can, but are not required to upload to your account instead of the default avatar.

  4. “Information provided when contacting support” - information provided by you when contacting our support service, including the nature of your problem and information about your account.

  5. “Your data related to a third–party resource” - refers to information pertaining to your accounts (such as email address or login) on external platforms through which you access the Game (e.g., Facebook or Google), or link your Game profile. 

  6. “Information that you share in text chats” - information that is provided by you during personal communication (in personal chats) with other players through the messaging functionality in the Game.

 

 

Data that We collect automatically

 

  1. “Location Information”- general information about your location (without information about the exact geolocation) at the time when you are playing the Game (for example, IP address, country and city).

  2. “Device Information” - technical data about your device. For example, the device ID; the serial number of the device; the name of your Internet service Provider (ISP); the name of your browser and the plug-ins used; the operating system and its version; information about hacking the device (“jailbreak”); information about the network; the brand and manufacturer of your device; the language you selected for the device; the version of the Game installed on your device; the installation path of the Game; downloaded software libraries; your carrier.

  3. “Login information” - information about the time, location and IP when you log in to the Game.

  4. “User’s ID” is a unique number (code) automatically generated and assigned to your account to identify it in the Game.

  5. “Information about behavioral actions in the Game” - information about your gaming activities in the Game, including your achievements, time in the Game, rating, etc.

  6. “Purchase history” - information about your purchases in the Game including details of orders (amount spent, date, time, vouchers or offers used)

 

 

Data that We receive from third-party resources

 

  1. “Advertising ID” is a unique identifier that is associated with your mobile phone or tablet, used by advertisers to track ads.

 

Purposes and basis for collecting and processing data

 

Personal Data

Legal basis for collection and processing

Purpose(s)

When You Play the Game

Advertising IDs, Location information and Device Information

You consent

Analytics

 

For more information, see “Analytics” section

Advertising IDs, Location information and Device Information

Your consent

Advertising 

 

For more information, see “Advertising” section

Device Information

Your consent;

Also, in accordance with applicable legislation, the following legal bases may apply:

      • Legitimate interest (in preventing fraud in Games); 

      • Performance of the contract (by improving your gaming experience).

Prevention of fraud in the Game 

 

For more information, see “Fraud prevention” section

User's email

Your consent;

Also, in accordance with applicable legislation, the following legal bases may apply:

      • Performance of the contract (by maintaining the security of your account, preventing unauthorized use of your account);

      • Legitimate interest (in informing you about important issues, advertising campaigns and marketing offers, if We have your consent to such information).

Identification and verification of your account, sending important notifications, informing about potentially interesting marketing offers.

User’s ID, Username, User’s Avatar

Your consent;

Also, in accordance with applicable legislation, the following legal bases may apply:

      • Performance of the contract.

Identification and personalization of your account

Login information, Information about behavioral actions in the Game

Your consent;

Also, in accordance with applicable legislation, the following legal bases may apply:

Legitimate interest:

- analyzing your activity to ensure the proper functioning of the Game; 

- to fix problems; 

- to improve your future experience

Analytics 

 

For more information, see “Analytics” section

Your data related to a third–party resource

Your consent;

Also, in accordance with applicable legislation, the following legal bases may apply:

      • Performance of the contract.

Identification and authorization of you in the Game; personalization of your account

 

 

Information that you share in text chats

Your consent;

Also, in accordance with applicable legislation, the following legal bases may apply:

  • Legitimate interest in maintaining security and preventing the distribution of unlawful content or violations of our Terms of Use when receiving reports.

The implementation of the communication functionality in the Game

Purchase history

Your consent;

Also, in accordance with applicable legislation, the following legal bases may apply:

      • Performance of the contract.

 

      • Providing in-game objects that you have purchased;

      • Analytics

When you contact customer support

User's email, Username, User’s ID Information provided when contacting support

Your consent

Providing technical support in the Game

 

 

Data usage

 

Analytics

 

  1. It's crucial for us to understand how users engage with our Game to enhance your gaming experience. We gather your Location Information, Device Information, Advertising IDs, Purchase history and Login details for analytical purposes related to our Game. 

  2. This information is utilized for the following purposes:

  1. Assessing the difficulty level of the Game,

  2. Rectifying any errors present in the Game,

  3. Evaluating the demographics of our user base,

  4. Analysis of user interaction with advertising,

  5. Identifying the necessity to accommodate new types of devices for the Game,

  6. Providing technical support in the Game.

  1. We independently process your data for analytical purposes and do not transfer your data to third-party resources.

Advertising

  1. To keep our Game free, We use advertisements provided by third-party advertising partners (“Advertising Partners”).

  2. To provide you with targeted advertising tailored to your interests, our Advertising Partners collect and utilize your Advertising ID, Location Information, and Device Information. If location services are enabled on your device, Advertising Partners may also gather data regarding your geolocation.

  3. In some cases, Advertising Partners collect information about you on our behalf and act as a processor of your personal data, and in some cases, Advertising Partners independently decide to collect your personal data through the mechanisms built into our applications. In the latter case, Advertising Partners act as a controller in accordance with the EU General Data Protection Regulations (GDPR).

  4. Please review the following list of our Advertising Partners and their privacy policies:

Advertising Partners

Name

Privacy policy

Contacts

Appodeal

Privacy Policy

legal@appodeal.com

Adjust

Privacy Statement & Policy 

privacy@adjust.com

 

User’s Avatar, Username, User’s ID

  1. You are not required to provide us with your real name or image. You can freely use the Game without any limitations even if you choose not to provide this information.

  2. If you do not want to provide User’s Avatar and Username, they will be generated automatically. Also, to minimize the personal data We process, We assign a User’s ID to your account.

  3. If you wish to personalize your account, you have the option of providing us with a Username yourself, unless it is already used by another player in our Game. 

  4. If you do this, We will process your Username and User’s Avatar, but you can delete or change them at any time. 

Data related to a third–party resource

  1. We ask you to log in to the Game using your accounts on other resources such as Facebook and Gmail. 

  2. This is necessary to ensure the security of your account in the Game, as well as to prevent all types of illegal or unauthorized use of your account.

  3. We will also send you important notifications related to your use of our Game, as well as information about potentially interesting marketing offers, if you have agreed to receive such information.

  4. You can also, if you want, link accounts on third-party resources to your profile in the game in order to personalize your account. This is optional.

  5. If you prefer not to log into the Game using third-party resources, you have the option to use it without authorization.

  6. Please note that in this case, such third-party resources will provide us with some information about your account (in particular, your email address).

Third-party resources for authorization

Name

Privacy policy

Contacts

Facebook

Privacy Policy

Help contacts

Google

Privacy Policy – Privacy & Terms – Google

Privacy Help Center - Policies Help 

(google.com)

 

Fraud prevention

  1. Our Terms of Use strictly prohibit the utilization of third-party programs to gain an unfair gaming advantage. Such programs include mods, hacks, cheats, scripts, bots, simulators, and automation software.

  2. To prevent fraud in the Game, We analyze Device Information.

Data for making purchases in the Game

  1. In order for you to buy an in-game object, We cooperate with a payment acceptance partner XSolla.

  2. By making a purchase, you agree to the transfer of your personal data to XSolla. We recommend you to read the XSolla Privacy policy here.

  3. We do not act as the Controller or processor of your payment information. All payment information processing is carried out entirely and exclusively through XSolla. This means that any payment data you provide when making a purchase are processed directly by XSolla without our involvement. 

  4. We receive your Purchase history only in order to provide in-game objects and conduct analytics.

 

Automated decision-making

  1. We want to make it clear that We do not engage in any form of automated decision-making or profiling processes in the handling of personal data. This means that all decisions that might significantly affect you are made with human involvement, ensuring that your rights, freedoms, and legitimate interests are always respected.

 

 

Data storage location

  1. The data is stored by:

  1. G-Core Labs S.A. You can read Privacy Policy here;

  2. Selectel LLC. You can read Privacy Policy here

  1. All data is stored in countries that provide an adequate level of protection of personal data.

 

 

Data retention period

  1. If you withdraw your consent for the collection of personal data in cases where We rely solely on your consent as the basis for collecting and processing personal data, we will immediately delete it.

 

  1. In cases where We rely on grounds other than consent for collecting and processing your personal data, we reserve the right to retain your data for 1 year (or any period mandated by applicable law) after you cease to play the Game. This retention period allows us to save your progress and purchases should you decide to resume activity in our game. It also enables us to respond to requests for information about your transactions from government authorities.

 

  1. We do not retain data after the purposes for its processing have been achieved.

 

Data deleting 

  1. If you want to completely delete your account and personal data, which We are obliged to delete immediately upon your request, you can do it in the Game or contact us here

 

 

Children's personal data

  1. We do not process the data of persons under the age of 16 without the consent of their legal representatives.

  2. If you are the legal representative of a child under the age of 16 who plays our Game, you can request the deletion of your child's personal data and prohibit us from further collecting his personal data by writing to us at privacy@madoutgames.com.

 

 

Third-party services

  1. In our Game, you may encounter links to third-party websites or applications, such as social sites. 

  2. Please be aware that clicking on these links may result in the sharing of your personal data with those third-party websites or applications. 

  3. We are not controlling the collection of personal data by these third-party entities, so We advise you to review their privacy policies beforehand.

 

 

Security of your personal data

  1. We follow generally accepted industry standards to protect your information, both during transmission and once it is received. For example:

  1. Access Controls: implementing strict access controls ensures that only authorized individuals have access to personal data;

  2. Data anonymization methods that allow us to transform information and make it non-personal;

  3. Using data encryption to ensure data confidentiality during transmission.

 

 

Your rights 

 

For users in the European Union

  1. If you are a resident of the European Union, you have rights under applicable data protection laws. These include:

  1. The right of access. You have the right to request and receive a copy of your data available to us;

  2. The right to correction or deletion. You have the right to request the correction or deletion of your data available to us;

  3. The right to restrict processing. You have the right to restrict the processing of your data at our disposal;

  4. The right to data portability. You have the right to transfer your data at our disposal (transfer the data to another controller). At the same time, We are not responsible for the compatibility of data with a third-party service.

  5. The right to file a complaint with the local data protection supervisory authority. See more information in the “Contact the data protection authorities” section.

  1. In certain circumstances, you may also have the right to object to the processing of your data. To send such a request, please use the contact information provided in the "Contact us" section. We will review any such request and take action in accordance with applicable data protection laws.

  2. If We rely on your consent to the processing of your personal data, you have the right to withdraw your consent at any time. However, this will not affect the legality of processing until such consent is revoked. Please also note that in addition to your consent, We may have other legitimate grounds for processing certain categories of data, so if you disagree with their processing, you must delete your account in the Game.

For residents of the Russian Federation

  1. If you are a personal data subject from the Russian Federation, then you have the right to ensure the protection of your rights and freedoms when processing personal data, protection of the rights to privacy, personal and family secrets, in particular you have the right:

• require us, as an operator, to clarify your personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as take legal measures to protect your rights;

• to receive information related to the processing of your personal data;

• to protect your rights and legitimate interests, including compensation for damages and (or) compensation for moral damage in court.

For residents of USA

  1. We comply with the personal data legislation of all states, including, but not limited to, the California Online Privacy Protection Act (CalOPPA), the California Consumer Privacy Act (CCPA), Consumer Data Protection Act (Virginia) (CDPA), Colorado Privacy Act, Connecticut Act Concerning Personal Data Privacy and Online Monitoring (CTDPA), Consumer Privacy Act (Utah) (UCPA) and others.

  2. We will update this Policy at least once every 12 months in accordance with CCPA.

  3. You have the right to do the following:

  1. Be informed. We should notify you at or before the point of your personal information collection about the categories of personal information to be collected and the purposes for which the categories of personal information are collected or used, whether such information is sold or shared, the length of time we intend to retain each category of personal information or if that is not possible, the criteria used to determine such period, if we sell or share personal information, the link to the Notice of Right to Opt-out of sale/sharing or in the case of offline notices, where the webpage can be found online, a link to our privacy policy, etc.

  2. Access own personal information. You have the right to request access to the personal information we may have collected about you (the personal information collected, its sources, third parties to whom we disclose personal information, etc.). Such requests may be submitted up to two times in a rolling 12-month period. However, you may request us disclose the required information beyond the 12-month period and we will provide such information unless doing so proves impossible or would involve a disproportionate effort;

  3. Delete your personal information. You have the right to ask that We delete your personal information. Once we receive a request, we will delete the personal information We hold about you as of the date of your request from our records and direct our service providers to do the same. We should delete your personal information from our records and direct any service providers to delete your information from their records. Please note that choosing to delete your personal information may impact your ability to use our Game;

  4. Stop selling your personal information or sharing your personal information. You have the right to opt-out of the sale of your personal information or sharing of your personal information for cross-context behavioral advertising and can request that We stop. Please note that We have never sold your personal information to third parties and, therefore, there are no third parties to whom the information has been sold;

  5. Correct your personal information. You have the right to ask that We correct the personal information We may have collected about you if that information is inaccurate;

  6. Receive your personal data and have it transferred to another business. We should provide the specific pieces of personal information obtained from you in a format that is easily understandable to the average consumer, and to the extent technically feasible, in a structured, commonly used, machine-readable format, which also may be transmitted to another business at tour request without hindrance;

  7. Limit the use and disclosure of your sensitive personal information (SPI). You have the right to ask that We limit our use and disclosure of your SPI to certain purposes permitted by law;

  8. Not to be discriminated. You have the right to not be discriminated against because of the exercise of any of your rights.

  9. To opt out of the processing of the personal data for purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

  10. To file a complaint with your local data protection supervisory authority. See more information in the “Contact the data protection authorities” section.

  1. If you request access to, or the correction or deletion of, your personal information We will verify your identity before disclosing the requested information. To do so, we may ask that you log into your account or provide us with your:

  • Full name;

  • Email address.

  1. When you make a request, you will be asked to answer a few questions about yourself to help us verify your identity. In the event more documentation is necessary to verify your identity, We will notify you directly.

  2. If We cannot verify your identity, we will notify you, and your request(s) may not be processed. Any requests may be denied if We have reason to believe they are fraudulent.

  3. If you would like an authorized agent to exercise your rights for you, she / he may use the same order described above in this section. We require documentation demonstrating your agent’s authority to submit requests on your behalf.

  4. We maintain your records of requests and how we have responded to them for at least 24 months. We are not permitted to maintain this information for any other purpose than record-keeping purpose.

Contact the data protection authorities

 

  1. For residents of the European Union: If you live in the European Union and believe that We are illegally processing your personal data, you have the right to file a complaint with the local data protection supervisory authority. You can find contact information here: https://commission.europa.eu/about-european-commission/contact_en.

  2. For residents of the Russian Federation: if you believe that your rights are being violated, you can contact the Authorized Body for the Protection of the rights of personal data subjects – Federal Service for Supervision of Communications. You can find contact information at: https://rkn.gov.ru/contacts.

  3. For USA residents: If you are a USA subject, please contact the data protection authority in your state. You can find the relevant contacts on the official website of the authority in the "Contacts" section.

 

 

Contact us

 

  1. For any questions and requests, you can contact us:

 

privacy@madoutgames.com

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