1. PURPOSE & SCOPE
What are Internet Protocol addresses?
An Internet Protocol (“IP”) address is the unique number assigned to your server or Internet Service Provider (“ISP”).
What does Platform mean?
As used herein, the term “Platform” refers collectively, and at times individually, to
· The Mini Panda App software,
· The Mini Panda gaming services,
· Each of the Games,
· Each of the account services provided by Mini Panda(including but not limited to forums, wikis, blogs, social media accounts, customer and technical support and any other services we provide to you)
· Authorized Mobile Apps relating to the Games and the Mini Panda service,
· All features and components of each of them, whether installed or used on a computer or mobile device.
In order for you to play our games or use our services we need to process some of your data. Should we need to process your data for any other purpose than offering you our games and services, we will always ask you for your consent in advance.
Please note that Mini Panda is not responsible for the actions of Third Parties, the content of their sites, the use of information you provide to them or any services they may offer. Sometimes we work with partners to help us in developing our games and services and If we share data with them we will always ask you for your consent in advance.
By using Services in any way, you represent that you are older than 13 or your parent or guardian has reviewed and accepted this Agreement. You acknowledge that the Platform is not intended for minors under age 13 and services will not be provided to those under age 13.
Mini Panda collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, and guests (collectively “Individuals”).
Subject to the laws of your country of residence, minor children may utilize an Account established by their parent or legal guardian. In the event that you permit your minor child or legal ward to use an Account on the Platform, You are responsible for all the provisions they have agreed on your behalf, and you understand and agree that you will be responsible for all uses of the Account whether or not such uses were authorized by you. You acknowledge, and further agree that you are legally responsible for all actions of that minor, including but not limited to any payments, damages and/or liabilities related to the actions of that minor.
We recognize we have a special obligation to protect personal data obtained from children. We do not and will not knowingly collect personal data from any child under 16 without consent from their parent or guardian.
For more information about the responsibility of minors, their parents and/or legal guardian, please read our User Agreement.
If you are a parent or guardian and are concerned about the transfer of personal data about your child, please contact email@example.com
2. TYPES OF PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT
The types of Personal Information we collect (directly from you or from Third-party sources) and our privacy practices depend on the nature of the relationship you have with Mini Panda and the requirements of applicable law. We respect your right to privacy and will only process personal data in accordance with applicable legislations.
As explained in detail under this section, we collect information of:
· Personal Information directly to company through interacting with the Services, participate in Services feedback, questionnaires, surveys, or contests or participating in forums discussions, and requesting Services, or information; and
· As you navigate the Services, certain passive information is collected about your visit, including through Cookies and similar technologies as described in detail below.
· Primary goals in collecting information are to provide and improve our Services, to administer your use of the Services and to enable you to enjoy and easily navigate our Services. We endeavor to collect information that is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.
· If you play any of the games or use any of the Services on connected Third-party applications or connect the Services to any Third-party applications, like Apple, Google, Amazon and/or from Social Networking Sites (“SNS”) such as Facebook, Mini Panda may receive certain information about you from the provider of the Third-party application. The information received depends the Third-party application, your privacy settings and, if applicable, your friends’ privacy settings on that Third-party application.
· When you connect with the Services through an SNS, the information that Mini Panda collects may include your first and last name, your SNS user identification number and/or user name, your profile picture or its URL, location, sex, the login e-mail you provided to that Third-party application when you registered with the SNS, age-range (e.g. min 21), locale, language of your application, time zone and the SNS user identification numbers for your friends who are also connected to the Services.
2.1. INFORMATION WE COLLECT(Directly, Third Parties and Voluntarily Given):
a. Your name and surname,
b. Your email address,
c. Any username (such as a forum username) used to identify yourself in any of our services,
d. “Platform” Details of your digital distribution account regarding our games (such as a Google Play account), but not any financial details,
e. Technical details about any device which you use to access our services, Internet and/or network connection (including IP address); any mobile device identifier; your operating system, browser type or other software; or your hardware or other technical details.(See section “ i ” about providing support)
f. Information regarding your use of our services, metrics data about when and how you use the services; traffic data; and your geographical location data. This is technical data about our users and their actions and patterns which does not contain personal data,
g. Information collected from third party apps:
We receive personal information about you from third party sources. You can log in to our Services using sign-in services such as Facebook Connect, Apple Game Center or Google account. These services will authenticate your identity and provide you the option to share personal information as we mentioned in detail in this section with us. These services give you the option to post information about your activities on our Services to your profile page to share with others within your network Mini Panda merges the personal information collected at a website with data from third parties in order to update your contact information, perform market analysis, or improve our products, services, or systems.
if you link our services to a social networking service account or you interact with our profiles in social networks we collect via third party apps:
· Details about your use of social networking services and our services.
· Data from Facebook or other social networks
· Your first and last name and other information made publicly available by you
· Your user identification number and/or user name,
· Your friends list,
· The user identification numbers for your friends that are also connected to our Games,
· Locale, city, state and country,
· Birth date,
· E-mail address associated with your account,
· Profile picture or its URL.
Your friends list information as well as aggregated non-personal analytics data about our users strictly in accordance with Facebook’s and other networks’ terms and conditions – in the extent necessary to provide you with all functions of our Platform;
If you want us to delete the data we receive from Facebook or other sign-in services please contact us via our in-game customer support portal.
Furthermore, we offer you the opportunity to invite your contacts from social networking services so that those contacts can be located in our Games and/or you can invite them to join you in our Games. Such contact information will be used only for the purpose of sending communications to the addressee.
h. As part of the payment processing through Third Parties, Mini Panda does not collect, store and use personally identifiable information (your name, address, credit card number, phone number, and your e-mail address etc.). Mini Panda does not have access to your credit card or bank account data. However, Third Party payment processors share non-financial information with us related to your purchases, like the items purchased to fulfill your order. This is a data about our users which does not contain personal data.
i. Information that you provide voluntarily; Any other data which you supply us via our services as described below.
The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you when your personal information is requested.
The personal information that you are asked to provide is limited to the queries or support matters you may need assistance with via our forums or customer support service.
· Your contact details;
In order to contact our player support (although you can also contact directly through the Games without providing additional personal information),
In order to subscribe to marketing communications (like newsletters) from us.
In order to help you with any queries or support matters you may need assistance with via our forums or customer support service.
· Your System Information and Technical details about any device that you need our support with.(Please see the number “5.” in this section.)
j. Automatically Collected Information as described below.
· Data and analytics about your use of our Services;
· Your IP address and mobile device identifiers (your device ID, advertising ID, MAC address, IMEI);
· Data about your device, such as device name and operating system, browser type and language;
· Fabric Analytics and Google Analytics, may store log files and use tracking technologies such as Cookies, web beacons and/or tracking pixels.
· Geographic information or information regarding your computer (from web browser or client software; to transmit capabilities, game data processing) which Mini Panda uses this information to generate aggregate statistics about our user community. In addition Mini Panda uses this information for security, system integrity (the prevention of hacking, cheats), or enforcement purposes. (see section “2.3” for more detailed explanation about our purpose to collect information).
ALFA and BETA ACCESS NOTICE:
The specific game or service (the Platform chosen for Alfa or Beta) may have specific legal rules of its own for its Test. Users will be notified beforehand.
· Mini Panda may monitor and record any and all communications, electronic or otherwise, pertaining to the Beta,
· Mini Panda may delete or modify the information stored by the Platform being Tested for any reason at any time during the duration of the Tests,
· Mini Panda may transfer software program files to the Test System, including a program that will collect and send us CPU, RAM, operating system, video card, and sound card information from the Test System,
Confidentiality: Mini Panda may choose to make some of the Alfa and Beta releases as confidential. During a confidential Alfa and Beta Test, the existence of the Beta Test and all elements thereof is to be kept confidential. Therefore user agrees to keep everything related to the Tests secret from everyone who is not participating in the Test until Mini Panda informs them that the Test is no longer confidential.
2.2. Additionally, communications made using a product or service should not be considered private. By using the speech to text feature in voice chat, you understand that your communications may be used for transcription of speech to text, including for accessibility purposes. We do not retain the chat transcription after you end the session and close the chat window. By using voice or text chat, you understand that your communications may be monitored and/or recorded;
· for accessibility,
· toxicity analysis (toxic player behavior),
· to prevent cheating and fraud,
You acknowledge and agree that you have no expectation of privacy concerning the transmission of any user generated content or communications, chat texts, voice communications, or speech to text for transcription purposes.
You hereby provide your irrevocable, express consent to such monitoring and recording. Because voice chat and other communications may be viewed and/or heard by other users, users should avoid revealing any personally identifiable information in those communications.
2.3. PURPOSES FOR PROCESSING OF YOUR PERSONAL DATA
We collect and use your personal data for the following purposes:
· To enable us to provide our games, to ensure that your purchases are activated (for in correct numbers and for correct items) in our Platforms,
· To provide you with better player support if you need it;
· To enable us to optimize our Platforms for you and for the device that you are using,
· To deliver customized in game events, offers and promotions;
· For marketing and advertising purposes;
· To operate, improve and optimize our Platforms;
· For toxicity analysis (toxic player behavior),
· To prevent cheating and fraud,
· To personalize our Services, understand our users and their preferences to enhance user experience and enjoyment using our Services and improve our users’ experience
· To provide access to certain areas, functionalities and features of our Services;
· To notify you about in-game updates, new products or promotional offers;
· To send related information, including confirmations, technical notices, updates, and security alerts and support and administrative messages;
· To enable players to communicate with each other in games or on our social media accounts;
· To respond to your comments and inquiries and provide customer support services;
· To prevent potentially prohibited or illegal activities and protect of our players;
· To measure interest in our Services;
· To ensure internal quality control;
· To enable us to comply with laws that apply to us,
· To ensure compliance with our terms of service or where necessary to defend, exercise or establish our legal rights including our rights under our Terms of Service and/or our EULA, and other legal documents
· To contact you as a part of our recruitment processes; and
3. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
4. CHANGING OR ERASING YOUR PERSONAL INFORMATION
Information that has been provided by registered users in their records or in their account profile can be evaluated; this information can be updated, altered or erased by changing “account settings”. If you wish to alter information that could be determined as personal, you can update or erase by making changes with respect to account settings.
· You can disconnect your Facebook or other social network account from our games or delete our games from your mobile device.
· You can also reset your mobile advertising identifier or limit ad tracking altogether using the settings in your phone.
· We will occasionally send you push notifications through our mobile applications with game updates, high scores and other notices that may be of interest to you.
· You can at any time opt out from receiving these types of communications by changing the settings on your mobile device.
5. YOUR RIGHTS
You have certain rights in connection with your personal data and how we handle it. You can exercise these rights at any time by contacting us via any of the methods set out in the Contact Us section below.
· Access to personal data: You have the right to access your personal data
· Correction or deletion of personal data: You have the right to ask to correct or complete your personal data if it is wrong or incomplete. You have the right to ask to delete your personal data. Contact us via mail.
· Account deactivation: Should you wish to completely deactivate your account include disassociating your Facebook account from our mobile games and deleting our games from your mobile devices. Please note that if you completely deactivate your account all your progress in our games and any unspent virtual items will be lost and we may not be able to restore them in the future.
· Restriction on processing of personal data: You have the right to ask to restrict the use of your personal data, when certain conditions apply.
· Object to processing of personal data: You have the right to object to the use of your personal data by, when certain conditions apply.
· Portability of personal data: You have the right to receive your personal data in a structured and commonly used format so you can use this data with another company.
7. INTERNATIONAL TRANSFER
· If Mini Panda decides to change base of operation.
· If Mini Panda decides to change their server base, separate servers, merge servers.
· If user wants to carry their information to a different server.
If Mini Panda has to carry your information for further reasons, users will be notified about the reason and users’ permission will be taken beforehand.
When we transfer your personal data internationally, we will take reasonable steps to ensure that it is treated securely, lawfully and in the manner, we described here.
The personal data that you provide is stored on servers that are located in secured facilities and protected by protocols and procedures designed to ensure industry-standard security of such data such as firewalls and data encryption. However, no server, computer or communications network or system or data transmission over the internet can be guaranteed to be 100% secure. As a result, we cannot ensure or warrant the security of any personal data you transmit. By using the Services or providing personal data to us, you agree that we may communicate with you electronically regarding security privacy, and administrative issues related to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services or sending an e-mail to you.
9. LEGAL BASES (For European Economic Area Users)
If you are an individual in the European Economic Area (EEA), we collect and process personal data about you only where we have legal bases for doing so under applicable EU laws. The legal bases which we rely upon are the following:
· Contractual Necessity. This covers data used by us in order to provide you with Services that you have requested – and that we have agreed – to provide to you, on our customer services, chat functionality and third-party social network connectivity and our Platform;
· Legal Obligation. This covers data used by us to comply with a legal obligation, to maintain records relating to tax or to respond to a valid legal request for certain data;
· Legitimate Interests. This covers data used by us for purposes that are not harmful to your privacy and can be reasonably expected within the context of your use of our Services, marketing, advertising, analytics, research and optimization of our games and other Services and use of our Platform; and
· Consent. This is used as a legal basis in the following contexts: the collection of data stored on your device by us and our advertising partners, your device information, ad identifiers, IP address, country and region. You consent to this collection when you agree to install our game and you can withdraw your consent to this by uninstalling our games.
We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we will notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we protect your information.
11. Governing Law and Venue: Any legal questions/complaints/claims regarding this Agreement are under Turkish law and jurisdiction for users all around the world. Turkish law will govern all disputes, including but not limited to, arising out of or relating to violation of our content, products, intellectual rights and related terms, service-specific additional terms, or any related services, regardless of conflict of laws rules and choice of law principles. These disputes will be resolved exclusively in the courts of Ankara, TURKEY, and you consent to personal jurisdiction in those courts.
BINDING DATE: Once we change the Agreement, it will become legally binding on you after we post it online.
If you don’t agree to those changes (regardless of whether you email us), then unfortunately we must ask you to cease using Mini Panda’s Platforms. We hope you’ll appreciate that for our Platforms to work properly we need to have everyone using them under the same rules. We encourage you to get in contact if you have queries or concerns.
If you have questions or comments about this notice, you may email us at firstname.lastname@example.org