Marsal Bermain is committed to making sure that kids' privacy is safeguarded and we aim to comply with all (privacy) regulations worldwide, like the Children's Online Privacy Protection Act (COPPA) in the US. If you want to know what data is collected by our apps and how this is handled, please review this policy. If you have any questions or concerns, send us an email via aspaltipis@gmail.com, we are here to help.
1. WHO IS RESPONSIBLE FOR PROCESSING YOUR DATA AND HOW TO CONTACT US
Your privacy is very important for us, and we will always use your personal information only for the purposes as described in this Privacy Policy.
This Privacy Policy applies to all of our games, applications, websites and related services, collectively referred here as our Service. It covers how we collect, use, disclose, transfer and store information received about users and/or information received about users' computing device through their use of the Service. Your continued use of the Service after the effective date will be subject to the new Privacy Policy.
We receive and/or you may be asked to provide your information (including personal information) any time you are in contact with us or use our Service. As described in greater detail below, we share your information (including personal information) with our affiliates and with third party partners (as defined below) and use it in ways consistent with this Privacy Policy. We may also use your information (including personal information) together with other information to provide and improve products.
Please read the following to learn more about how we use your personal information. By using our Service, you promise us that:
• You have read, understand and agree to this Privacy Policy;
• You are over 16 years of age (or have had your parent or guardian read and agree to this Privacy Policy for you);
• You are a parent, legal guardian, or an authorized school employee in compliance with applicable laws if you use our services on behalf of a child.
If you do not agree, or are unable to make this promise, you must not use our Service. In such case, if you are using our application you must:
1. Delete your/your child's account using the functionality found in "Settings" in the App, or contact us and request deletion of your/your child's data;
2. Cancel any subscriptions using the functionality provided by Apple (if you are using iOS) or Google (if you are using Android);
3. And (c) delete the application from your devices.
For the purpose of the General Data Protection Regulation 2016/679 and any implementing legislation (the "GDPR"), Marsal Bermain (referred to as "Marsal Bermain", "we", "us", "company" or "our") will be the data controller responsible for any personal data we process.
If you have any questions or concerns about Marsal Bermain's Privacy Policy, including those related to exercise any of your rights, please contact us through the game's Help & Support, so we can reply to you more quickly. Or contact us through one of the following ways:
• For privacy questions and exercising your rights via our privacy email: aspaltipis@gmail.com;
• For general information please feel free to contact us via our customer service by email: aspaltipis@gmail.com.
Marsal Bermain PRIVACY POLICY, v1.0, updated 29 October 2022
2. WHAT PERSONAL DATA WE COLLECT AND WHY
We may source, use and otherwise process your personal data in different ways. In all cases we are committed to protecting your personal data.
In each of the sections listed below, we describe how we obtain your personal data and how we handle it.
2.1 APPLICATIONS CUSTOMERS
We collect personal data related to users of our Applications.
A - SOURCES OF PERSONAL DATA
We may obtain your personal data from the following sources:
1. From you directly through the game; and/or
2. From third parties, service providers that are assisting us in providing you with an application (for example but not limited to, Google, Apple, Unity, etc).
B - PERSONAL DATA THAT WE COLLECT AND PROCESS
In general, the information we collect about you relates to the type of device you are using, information that helps us identify your device, how you play our applications and may include information that you submit to us when you voluntarily contact us. We may also collect information from app store platforms and partners and other third parties such as information about your interests and in-app purchases (provided that we never receive your payment or credit card information).
Technical Information We collect technical information about your device that is necessary for you to use our applications and additional technical data that enables us to maintain and analyse the functioning of the application and to personalize the content of the application. Such information includes amongst others the type of device(s) you are using to play our applications, persistent identifiers, such as IP address, device identifiers, ad identifiers, unique user ID specific for our applications, and the country or region that you are playing in.
Persistent identifiers (such as Device ID and IP address) are identifiers that do not identify you personally, but may uniquely identify your device. Such online identifiers provided by end user devices, applications, tools and protocols are considered as personal information according to data protection legislation. Please check the rights you have under data protection legislation in the Section "Your Rights".
We automatically collect certain information about your computing device, including:
• IP address; Country, city or region;
• Language; Locale (specific location where a given language is spoken);
• Time zone, session start/stop time,
• Network status (WiFi, etc.), browser plug-in types and versions;
• User agent string (UA), platform, SDK version, timestamp;
• UDID (Device ID)
• Technical device information (e.g. device model and name, operating system name and version, CPU information, screen size, firmware, software, mobile phone carrier, Internet service provider, API key identifier for application, Android ID, Android Serial No);
• Push notifications token (in order for us to be able to determine whether you are subscribed to push notifications).
Service Usage Information When you use our applications, we collect additional information from you by using persistent identifiers that permit identification of your device. We collect information about how you play our applications. Such information is used for delivering and improving our application, cross-promotion and analytics purposes.
We may ask you to submit, and we may process other non-personally identifiable information that may be personal to you such as your child's age category and gender, provided that age category and gender information is collected solely for users who have passed the parental gate in our applications.
For some of our applications we collect information about the nickname you choose for your child's account and your rating of the application (if any). Please do not use your or your child's real name.
C - WHY DO WE COLLECT YOUR PERSONAL DATA AND WHAT ARE OUR LAWFUL BASES FOR IT?
In General We use the information we collect about you/your device to deliver services and our applications to you and to operate our business. We use it also for improving our services and applications, for enhancing security and for analytics and research purposes to make sure we provide you with the best experience.
Personal Information that we obtain from Third Parties and our Service Providers
To help us provide you the best service, we work with third party analytics providers. Their respective Privacy Policies can be found at:
• Unity Technologies — https://unity3d.com/ru/legal/privacy-policy
These companies help us to understand your use of the applications. In association with them, we may collect some Personal Information mentioned above. This information is for internal operations only and cannot be shared.
Push Notifications We use push notifications to remind you about your activities within the applications. You will receive push notifications only if you have subscribed to push notifications in the application. You can always unsubscribe from push notifications. Please use the instructions provided below.
• For iOS: You will be asked to accept or refuse push notifications after an application is downloaded. If you do not accept, you will not receive push notifications. Please note that if you accept, some mobile phones will allow you to disable push notifications later on by using the settings on your mobile phone. To manage push notifications on your mobile phone please follow these instructions: Open your Settings menu and tap "Notifications"; Find the App; Tap on the icon of App; Manage the "Notifications" option by sliding it OFF or ON.
• For Android: After an application is downloaded, you will automatically receive push notifications. You can manage push notifications on your mobile phone by entering the "info screen" on the homepage of the App and choosing the "Settings" option. Here, push notifications can be disabled by unchecking the "Notification" option within the App.
When you decide to unsubscribe from push notifications, such push notification tokens will be deleted from our database.
For the restriction on the usage of information please see the 'Children's Privacy' Section of this Privacy Policy.
In-App Purchases
Our applications enable in-app purchases. We do not process payments for in-app purchases nor have access to your credit card information.
Payment transactions for in-app purchases are completed through the app store via your app store account. Any post-purchase processes are controlled by the app store and are subject to specific terms of such app store. Please review privacy policy and terms of service of your app store.
Location information
The Company does not collect, store or use information with which an individual’s location can be identified. However, certain advertisement banners operated by third parties, may collect, without storage, via location-recognition advertisements of advertising-service providers as such third parties, and temporarily use, location information with a device’s censor data, etc. that may provide actual location information (including GPS signals from mobile devices) or information on nearby Wi-Fi access points and base stations. However, such use of location information is unrelated to the Company.
INFORMATION ABOUT THIRD-PARTY DATA CONTROLLERS AND PROCESSORS
We are fully aware that the users of this application are children. Therefore, we will only show ads that are not targeted and contain completely neutral content or images. We as developers will do our best to:
Ensure ads displayed to users do not involve interest-based advertising (advertising targeted at individual users who have certain characteristics based on their online browsing behavior) or re-marketing (advertising targeted at individual users based on previous interaction with an app or website);
Ensure ads displayed to users present content that is appropriate for children;
Ensure ads displayed to users follow the Families ad format requirements; and
Ensure compliance with all applicable legal regulations and industry standards relating to advertising to children.
Review Ads Manually to Ensure Appropriateness for Kids
We as publisher have control of ads being display in our app (https://support.google.com/admob/answer/3150235).
For sensitive category ad serving requests (List of sensitive categories: https://support.google.com/admob/answer/3150953), we block them using the channels provided by Google Admob (https://support.google.com/admob/answer/3150176).
Apart from relying on blocking based on categorization by Google Admob, we as ad publishers also routinely block sensitive ad serving request manually and independently using the Ad review center channel provided by Google Admob to ensure appropriateness for kids (https://support.google.com/admob/answer/3480906).
Sensitive ad categories that will not be served (blocked)
1. Birth control
Includes birth control ads as well as ads for products, services & information relating to STDs including clinics and medication.
2. Astrology & Esoteric
Includes zodiac, horoscopes, love spells, potions, and psychic-related ads.
3. Cosmetic Procedures & Body Modification
Includes lifts, suctions, lasers, hair removal and restoration, tattoos, and body modification.
4. Dating
Includes dating services and online dating communities. Also includes chat sites and apps for meeting new people in general.
5. Downloadable Utilities
Software for download which is designed to enhance the functionality of an operating system or device, whether desktop or mobile. Typical examples include anti-virus software, file converters, driver updaters, system cleaners, download managers, disk defragmenters, codecs, browser toolbars, ringtones, screensavers, wallpapers, and so on.
6. Drugs & Supplements
Includes pharmaceuticals, vitamins, supplements, and related retailers; does not include resources providing information about drugs.
7. Get Rich Quick
Ads that offer to share lucrative business secrets with consumers, or which offer significant money or merchandise for little or nothing in return. Includes multi-level marketing, work from home offers, and so on; also includes online surveys.
8. Politics
Includes ads for political campaigns or candidates, ads addressing controversial social issues, ads referencing well-known politicians, and ads touching on events widely perceived to be political in nature, such as elections, protests, terrorist attacks, wars and conflicts.
9. References to Sex
Includes ads that are sexually suggestive or refer to sex.
10. Religion
Includes religious ads and ads advocating for or against religious views; does not include astrology or non-denominational spirituality.
11. Sensationalism
Ads that aim to induce users to click them by appealing to their curiosity, often using a teaser message with hyperbolic language or imagery. Includes ads that center around sensationalistic subjects (such as celebrity arrests, deaths, or divorces) or aim for shock value.
12. Sexual & Reproductive Health
Includes sexual function, fertility, and birth control ads, as well as ads for products, services, and information related to STDs and abortion including clinics and medication; does not include normal pregnancy resources.
13. Significant Skin Exposure
Ad images where any part of the human body from the sternum to the mid-thigh is not clothed; or the body is clothed in underwear, swimwear, lingerie, or other see-through clothes or non-clothing items such as a towel or bed sheet.
14. Social Casino Games
Includes simulated gambling games (including, without limitation, poker, slots, bingo, lotteries, sports betting, betting on races, as well as other card games and casino games) where there is no opportunity to win anything of value (such as money or prizes).
15. Video Games (Casual & Online)
Includes video games, online games and downloadable games; does not include video game consoles.
16. Weight Loss
Includes weight loss, dieting, and related products and programs; doesn't include healthy eating or general fitness ads.
17. Alcohol
Includes online sale of alcoholic beverages and brand or informational advertising for alcoholic beverages.
18. Gambling & Betting (18+)
Includes online gambling and location-based gambling.
In general, incoming ad serving requests have been systemically categorized by Google Admob. However, we will still manually review incoming ad serving requests to avoid incorrect categorization by the system. If in our judgment the ad is included in the above category, then we will block the ad.AdMob by Google (Google Inc.)
AdMob is a mobile advertising platform which allows developers to monetize their app(s) by displaying in-app ads from other advertisers. AdMob allows to set TFUA (Tag for Users under the Age of Consent in Europe) on ad requests. All ad requests that include TFUA disables ads personalization for users under the age of consent and collection of data by third party partners. Admob uses Personal and Non-Personal Data only for internal purposes.
Legal basis of processing: legitimate interests (support for internal operations).
Place of processing: US
Address: 1600 Amphitheatre Pkwy, Mountain View, California 94043, US
D – HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We will process your personal data only for as long as is necessary for the purposes for which it was collected in connection with the provision of service to you, unless we have a legal right or obligation to retain the data for a longer period, or the data is necessary for the establishment, exercise or defense of legal claims.
Some personal information that we collect is stored on your device (such as: Temporary age category hash; Temporary interest types hash; Temporary gender category hash; Audio setting for Parent account; Debug mask status). We do not process or have access to it, and it's stored until you delete our application or service from the device.
3. WHO WE SHARE YOUR PERSONAL DATA WITH
We do not sell your personal data to Third Parties, оur Partner Organizations or Service Providers.
We cannot provide all services necessary for the successful operation of our Services by ourselves. We must therefore share collected information with third parties, including analytics providers, tracking and fraud prevention providers and other third party service providers that develop and support our Services.
We do not share information that can be used to personally identify your device (e.g. persistent identifiers such as IDFA, IDFV, advertising ID and IP address). We also reserve the right to disclose your information (including personally identifiable information) when we are legally required to do so, to disclose your information in an anonymous and aggregated manner, meaning you could not be personally identified from it.
We may disclose information about you to organizations that provide a service to us, ensuring that they are contractually obligated to keep your personal data confidential and will comply with the GDPR and other relevant data protection laws.
We may share your information with the following types of service providers:
1. Technical support providers who assist with our website and IT infrastructure,
2. Third party software providers, including 'software as a service' solution providers, where the provider hosts the relevant personal data on our behalf;
3. Professional advisers such as solicitors, accountants, tax advisors, auditors and insurance brokers;
4. Providers that help us generate and collate reviews in relation to our goods and services;
5. Our advertising and promotional agencies and consultants and those organizations or online platforms selected by us to carry out marketing campaigns on our behalf and to advertise their own products or services that may be of interest to you; and/or
6. Service providers that assist us in providing our services.
7. Law enforcement or government bodies
We may disclose your personal data as permitted by law in order to investigate, prevent or take action regarding illegal activities, suspected fraud, violation of our intellectual property rights, situations involving potential threats to the physical safety of any person, violation of our Terms of Use or other agreements, or as required by law.
4. TRANSFERS OF PERSONAL DATA OUTSIDE THE EU/EUROPEAN ECONOMIC AREA
We operate globally, thus we may for the purposes described in this Privacy Policy transfer your information to our affiliated entities and/or to other third-party service providers across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note, that these countries and jurisdictions may not have the same data protection laws as your own jurisdiction, but wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information.
When we share your personal data with our affiliates in the EU and outside the EU. International transfers with Marsal Bermain affiliates outside the EEA, are governed by EU Commission-approved Standard Contractual Clauses for Controllers and, where relevant, for Processors.
We share personal data with external vendors or service providers or suppliers that we engage to perform services or functions on our behalf and under our instructions. Where these vendors are located within the EU, we ensure that they are contractually obligated to comply with the EU data protection rules. We also ensure in our contracts with these organizations that they only Process Personal Data in accordance with our instructions and in order to provide the agreed services and protect the integrity and confidentiality of your personal data entrusted to them.
We may also disclose personal data to our advisers, consultants, law enforcement and other public authorities (such as tax and social security bodies), the police, prosecutors, courts and tribunals. All these recipients are themselves responsible to comply with the EU data protection rules.
We will transfer your personal information to our Partner outside EEA, if we have entered into standard contractual clauses with such Partner, that are adopted by the Commission of European Union in accordance with EEA data protection legislation and are deemed to offer sufficient safeguards with respect to the protection of the privacy and fundamental rights and freedoms of individuals (you can obtain a copy of the clauses by contacting us via aspaltipis@gmail.com).
When we transfer your personal information to our Partner outside EEA, we ensure that our Partner is certified by an approved certification mechanism pursuant to EEA data protection legislation. For instance, to our partner that is certified to comply with the principles for data protection under the US-EU Privacy Shield Framework ("Privacy Shield") (you can view the entities certified under Privacy Shield at www.privacyshield.gov).
You may request a copy of these agreements by contacting us using the email address in section 1.
5. CHILDREN'S PRIVACY
Marsal Bermain adheres to the strict information collection, use and disclosure requirements. Marsal Bermain has established COPPA compliant privacy practices. If you have questions or concerns about our privacy practices, please contact us at aspaltipis@gmail.com.
We consider ourselves to be family oriented, however we have decided to voluntarily implement higher child protection standards even though our products and services are not directed toward, and we do not knowingly collect, maintain, or use personal information from children under the age of digital consent according to EEA data protection legislation without their parent's/legal guardian's permission, with the exception of persistent identifiers and age category as described below. If we learn that we have collected personal information other than persistent identifier or age category of a child under the age of digital consent according to EEA data protection legislation, we will take all reasonable steps to delete the information as soon as possible. If you become aware that your child has provided us with personal information without your consent, please contact us at aspaltipis@gmail.com.
The only personal information we collect from users who have identified themselves as below the age of digital consent according to EEA data protection legislation for the purposes of offering our services are persistent identifiers (such as User UDs, Device ID or IP address) and Child's age category.
We do not share such persistent identifiers with third parties. They are used only to authenticate users of applications, to maintain or analyse the functioning of the application, to personalize the content of the application (or send push notifications), to perform network communications to protect the security or integrity of the user or the application, or to ensure legal or regulatory compliance. Child's age category used to build a correct education plan (as we are required to do so by Contractual Necessity), its processed as a pseudonymized information (for example, 'category A' or 'B'), so the date of birth could not be identified from it.
When using the persistent identifiers we will not contact users under the age of digital consent according to EEA data protection legislation, nor do any user tracking or profiling. For the detailed information about disclosure to third parties please see section 3 of this Privacy Policy. For any additional questions about third party information disclosure please contact us at aspaltipis@gmail.com.
6. YOUR RIGHTS
You have certain rights in connection with your personal information and how we handle it, i.e. you have the right to obtain information about whether we hold personal information about you, to access personal information we hold about you, to obtain the correction, update, amendment or deletion of your personal information and to turn to supervisory authority. Some of these rights may be subject to some exceptions or limitations. You can exercise these rights at any time by sending your requests regarding your personal information to aspaltipis@gmail.com.
Your rights include:
• Right to object. You have the right to object to the processing of your personal information that is processed on the grounds of legitimate interests (see Legal Bases below). You are always free to opt out from the future collection of your personal information by us and our Partners by uninstalling all the Services from each of your computing devices.
• 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 by 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. Please note that we may not be able to provide all the information you ask for, for instance if the information includes personal information about another person. Where we are not able to provide you with information that you have asked for, we will explain to you why. We will try to respond to any request for the right of access as soon as possible, but we will always do so within 1 month of receipt of your request and verification of your identity.
• Right to correct personal information. We try to keep the information that we hold about you accurate and up to date. Should you realize that any of the information that we hold about you is incorrect, please contact us via email.
• Data deletion. You have the right to request deletion of the personal information that we hold about you. Should you wish to do so, please contact us via email. We reserve the right to ask to provide us additional information to verify your identity before we can start processing your request. Once we receive all information we need in order to be able to identify you, we will delete your personal information you requested us to delete as soon as possible, but we will always do so within 1 month of receipt of your request and verification of your identity. Please note that we may still retain some or all of that information, for example for complying with our legal obligations and protecting or enforcing legal rights. We may also retain your information in an anonymised form. In some instances, personal information about you that is visible through gameplay such as username, avatar, your high scores and any chat messages may be cached on other players' devices and we may not be able to remove or update that data from those devices, for example if that device is not connected to a wifi network.
• Data portability. In some circumstances, you have the right to request that we provide you with the personal information which you have provided to us, so you can transfer this information to another data controller. Should you wish to do so, please contact us via aspaltipis@gmail.com.
• Restriction of processing. In some cases, you may have the right to request a restriction of the processing of your personal information.
• Right to file a complaint. You have the right to file a complaint against us. To do so, contact the supervisory authority in your country of residence.
You can object to our use of your personal data where we stated we rely on our legitimate business interests to do so. We explained the legitimate interests we rely on in sections 'Why do we collect your personal data and what are our lawful bases for it?' above.
If you would like to exercise any of your above rights, contact us using the contact details in section 1 above.
B – LEGAL BASES
In each case where we process your information, we do so lawfully in accordance with one of the legal bases set out under EEA data protection law.
The legal bases that we rely upon are the following:
• Contractual Necessity. This covers information that is processed by us in order to provide you with service that you have requested - and that we have agreed - to provide to you, that is to deliver and improve our services, to provide customer support, to deliver special features in our Apps (such as in-app chat feature, multi-player feature, leader boards and other third party social network features), to deliver content of the in-app purchase you make.
• Legitimate Interests. This covers information that is processed by us for the purposes that can be reasonably expected within the context of your use of our services to pursue our legitimate interests in order to ensure you have the best experience when playing our apps, to make sure your information is secure and to provide to you our Apps free of charge or at a low cost. We pay special attention to your data protection rights making sure that your data protection rights are not overridden by our legitimate interests. We rely on our legitimate interests for data processing for analytics, tracking and fraud prevention, push-notifications, cross-promotion, and contextual advertising purposes.
• Consent. Where we ask for your consent to use your data for a particular purpose, we will make this clear at the point of collection and we will also make clear how you can withdraw your consent. We will ask for you consent before sharing any information with our advertising partners for the purposes of interest-based advertising and before conducting any surveys.
• Legal Obligation. This covers information that is processed by us to comply with a legal obligation, for instance is to maintain records for tax purposes.
C – SECURITY
We have implemented appropriate technical and organizational measures to protect the confidentiality, security and integrity of the collected information, and to prevent unauthorized access and the use of information contrary to this Privacy Policy. Although we use commercially reasonable efforts to assure that your information remains secure when maintained by us, please be aware that no security measures are perfect or impenetrable.
D – CALIFORNIA PRIVACY RIGHTS
California's "Shine the Light" law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties' and affiliates' own direct marketing purposes. Under the law, we will provide California customers certain information upon request ("Right to access") or permit California customers to opt out of, this type of sharing ("Right to opt-out of the sale of your personal information").
If you are a California resident and wish to obtain information about our compliance with this law, please contact us via aspaltipis@gmail.com. We may request information from you to verify your identity. Please note that Marsal Bermain is not required to respond to requests made by means other than through the provided email address or mail address.
E – CHANGES TO OUR PRIVACY POLICY
We will occasionally update this Privacy Policy as necessary to protect our users, furnish current information, and respond to legal and technical changes. The most current version of the Privacy Policy will govern our use of your information and will be available at https://marsalbermain.blogspot.com/2022/12/ads-policy.html.
