🔒Privacy Policy

Effective Date: August 13, 2023

At MiniTon (“MiniTon”, “we”, “us” or “our”), we take your privacy and the security of your information very seriously.MiniTon operates a platform, which we make available through our Telegram bot (our “Site”), through which we provide technology services and access to our SDK to allow independent game developers to host tournaments and provide competitive gaming functionalities to end-users (collectively, the “Services”).This Privacy Policy (“Privacy Policy”) sets out how we collect and process information that identifies or is associated with you (your “personal information”) when you access our Site or play a game (a “Developer Game”) published by an independent game developer that uses our Services (a “Developer”).If you have any questions regarding this Privacy Policy, please contact us at [e-mail]

1. REGION-SPECIFIC DISCLOSURES

We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain countries, regions or states.If you are resident in the State of California in the United States, please refer to California-specific privacy disclosures.If you are resident in the State of Nevada in the United States, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at [e-mail] you are resident in the European Economic Area or the United Kingdom, please refer to European and UK Privacy Disclosures for additional EEA-specific privacy disclosures.

1. SPECIAL NOTICE REGARDING MINORS UNDER 18 YEARS OF AGE

MiniTon respects the privacy of children. The Services are not intended or directed towards children or minors under the age of 18. Please do not use the Services if you are under the age of 18. MiniTon is intent on complying with applicable laws and regulations regarding minors, including the United States’ Children’s Online Privacy Protection Act. Specifically, MiniTon does not knowingly solicit or collect personal information from individuals under 18.If we learn that any personal information has been collected inadvertently from a child, we will delete the information as soon as possible. If you believe that we might have collected information from a child, please send an email to [e-mail].

1. NFORMATION WE COLLECT WHEN YOU USE OUR SITE AND OUR SERVICES AS A GAME DEVELOPER

3.1 Personal Information you provide directly to us, which may include: We collect the following personal information you provide when you use our Site and our Services:

• Login and contact information, such as your name, phone number, email address and password.

• Your employment information, such as the name of your employer and job title.

• The Services you use.

• The Developer Game for which you use our Services, and the website at which you promote it or make it available for download.

• Chat, comments and opinions. When you contact us directly, e.g. by email or phone we will record your comments and opinions.

• Marketing and Communications Preferences, such as your preferences in receiving marketing from us and your communication preferences, such as the language in which you choose to communicate with us.

• The country from which you access our Services.

3.2 Personal Information that is passively collected when you use the Sites or Services: We collect certain personal information automatically when you use our Services, including:

• Log File Data, including your internet protocol (IP) address, operating system, browser type, browser ID, date/time of visit, and pages visited.

• Analytics Data, including the electronic path you take to our Services, through our Services and when exiting our Services, as well as your usage and activity on our Services, such as the links and objects you view, click or otherwise interact with (also known as “clickstream data”).

• Approximate Location Data, including your general geographic location based on your IP address.

3.3 How we use this information: We use personal information we collect to:

• Register and authenticate you: we use your personal information to allow you to register for and access our Services and update your profile information.

• Provide our Services: we use your personal information to provide you with our Services, including providing support services and allowing you to incorporate our SDK into your Developer Game, and to customize the user experience (such as the language in which our Services are provided to you and the time zone in which you record your activities using our Services).

• Monitor the performance of and improve our Services: we use your personal information to measure the performance of our Services, fix issues, improve and otherwise develop the features and functionalities of our Services. We also use your personal information to test and develop new products and services.

• Inform our product roadmapping and marketing: we use your personal information to gauge market interest to assist in product roadmapping, positioning and inform and tailor our marketing.

• Communicate with you and deal with complaints: we use your personal information to send you communications relating to our Services and to address any comments or complaints you submit to us.

• Send you marketing materials, including emails, newsletters, and other marketing communications in accordance with your preferences.

• Maintain the safety and security of our Services: we use your personal information to detect and prevent fraud, cheating, abuse or other harmful activities, diagnose and fix technology problems, conduct security investigations and risk assessments, and improve and enforce our security measures.

• Legal and regulatory requirements and proceedings: we use your personal information in connection with legal and regulatory proceedings and requirements, including the defense of legal claims, compliance with corporate reporting obligations, and compliance with applicable laws.

• Enforce our rights: we may use your personal information to monitor, investigate, prevent and/or mitigate violations of our terms of use as well as enforce our agreements with third parties and business partners.

• For any other lawful purpose, or other purpose that you consent to.

1. INFORMATION WE COLLECT WHEN YOU PLAY A DEVELOPER GAME AS A USER

4.1 Personal Information you provide directly in the Developer Game: We may collect the following personal information that you input when you play a Developer Game:

• Contact information, such as your name, username, phone number, email address and physical address.

• Your date of birth.

• Payment information, such as the form of payment you use, payment method details (such as credit or debit card number).

• Demographic data, such as your income and other financial information.

• Identification documents, such as passport or driving license.

• Your precise location and the contacts saved on your device, when you agree, through your device settings, to allow the Developer Game to access this information.

• Any photos that you upload to your profile.

• Chat, comments and opinions that you send through any in-app messaging features, or when you submit requests for in-app technical support.

• In-app searches that you carry out within the Developer Game.

• Transaction and purchase information, such as any cash top-ups that you make in the Developer Game and the frequency with which you top-up your account in the Developer Game.

4.2 Personal Information that is passively collected when you play a Developer Game:

• Phone contacts that you have stored on the mobile device from which you access a Developer Game.

• Approximate Location Data, including your general geographic location based on your IP address.

• Gameplay content, including recordings of your gameplay and performance records.

• User ID that you are automatically assigned in connection with your access to a Developer Game.

• Device IDs, such as IDFA and Android ID.

• Usage Data, including the time you launched the Developer Game, the pages and content viewed, any adverts that you viewed and clicked on, the objects and links you clicked on and interacted with, and scrolling information.

• Diagnostics Data, including any crash logs and usage and performance statistics.

4.3 How we use this information: We use personal information we collect to:

• Register and authenticate you: we use your personal information to allow you to register for and access Developer Games and update your profile information.

• Ensure you are able to play a Developer Game: we use your personal information to ensure that you are legally able to access and play a Developer Game, or use certain features and functionalities of a Developer Game, in your country or state.

• Deliver physical prizes: we use your personal information to provide you with any physical prizes that you win when playing Developer Games. In some cases, we may provide your email address or physical address to prize fulfillment partners for the purpose of fulfilling the prize.

• Help you find other players on Developer Games, such as people whose details are saved in your phone contacts.

• Process your payments and purchases, such as updating your account to reflect any purchases that you make in a Developer Game.

• Provide features and functionalities of the Developer Game, such as in-app messaging, chat, gameplay performance records and profile customization features.

• Provide support in relation to Developer Games.

• Monitor the performance of and improve our Services: we use your personal information to measure the performance of our Services, fix issues, improve and otherwise develop the features and functionalities of our Services. We also use your personal information to test and develop new products and services.

• Identify how you learned about a Developer Game in order to understand the effectiveness of any advertising of Developer Games.

• Communicate with you and deal with complaints: we use your personal information to send you communications relating to our Services and to address any comments or complaints you submit to us.

• Send you service related communications, such as purchase confirmations.

• Send you marketing materials, including emails, newsletters, and other marketing communications in accordance with your preferences.

• Inform and support our marketing, including helping us determine products and services that may be of interest to you and contacting individuals about our Services.

• Maintain the safety and security of our Services: we use your personal information to detect and prevent fraud, abuse or other harmful activities, diagnose and fix technology problems, conduct security investigations and risk assessments, and improve and enforce our security measures.

• Legal and regulatory requirements and proceedings: we use your personal information in connection with legal and regulatory proceedings and requirements, including the defense of legal claims, compliance with corporate reporting obligations, and compliance with applicable laws.

• Enforce our rights: we may use your personal information to monitor, investigate, prevent and/or mitigate violations of our terms of use as well as enforce our agreements with third parties and business partners.

• For any other lawful purpose, or other purpose that you consent to.

1. SHARING OF PERSONAL INFORMATION COLLECTED FROM YOU

5.1 MiniTon may transfer personal information to third parties for the purpose of providing the Services. We may disclose personal information to our appropriate affiliates, including third-party service providers, to provide you with the Services. These third-party service providers are not authorized to retain, share, store or use the personal information for any purposes other than to provide the services they have been hired to provide.The service providers we may share your information with include:

• Marketing and Attribution Partners – our marketing service providers help us with campaign support, attribution and analytics to help us identify and attribute user referrals between Developer Games.

• Customer relationship, service and support partners – these service providers help support our customer relationships, from our developers to end users of our developer’s applications.

• Billing and payment providers – these service providers offer billing and financial administration, as well as payment support.

• Analytics providers – these service providers help generate statistics about our Site usage, game play and other data that helps us provide the best services to our customers.

• Cloud Hosting Service Provider – Amazon Web Services Inc., is our cloud hosting service provider.

5.2 Certain personal information is transmitted to a third-party service provider for the purpose of processing any payments. The transmission of your payment information is automatic, and at no point do we, or any of our agents or employees, have the ability to review, access or retain such payment information.5.3 MiniTon may also elect to transfer your personal information to third parties under special circumstances: (i) to comply with a legal requirement, judicial proceeding, court order, or legal process served on MiniTon; (ii) to investigate a possible crime, such as fraud or identity theft; (iii) in connection with the sale, purchase, merger, reorganization, liquidation or dissolution of MiniTon; (iv) when we believe it is necessary to protect the rights, property, or safety of MiniTon or other persons; (v) as otherwise required or permitted by law, including any contractual obligations of MiniTon; or (vi) with your prior authorization.

1. ACCOUNT SECURITY

The security of your account relies on your protection of your password and mobile device. You are responsible for maintaining the security of your password and mobile device. You are solely responsible for any and all activities that occur under your account. You may not share your password with anyone. We will never ask you to send your password or other sensitive information to us in an email, though we may ask you to enter this type of information on the MiniTon SDK interface.Any email or other communication requesting your password or asking you to provide sensitive account information via email should be treated as unauthorized and suspicious and should be reported to us immediately at [e-mail]. If you do share your password or your mobile device with a third party for any reason, the third party will have access to your account and your personal information, and you may be responsible for actions taken using your password. If you believe someone else has obtained access to your password, please change it immediately. If you believe that an unauthorized access has already occurred please report it immediately at [e-mail].

1. POSTINGS TO PUBLIC FORUMS

All postings in MiniTon public forums will generally be available to, and freely accessible by, other users of the MiniTon public forums as well as the internet’s general public. Therefore, users should not expect that any information they post will be kept private or confidential and are encouraged to exercise discretion when using the public forums. Additionally, your username, which you can change, will always be included in conjunction with your postings in the public forums. MiniTon is not responsible for events arising from the distribution of any information you choose to publicly post or share through the forums. All information or materials uploaded by you while utilizing the Services is subject to our Terms of Service.

1. MARKETING

From time to time, we may contact you with relevant information about our Services. Most messages we send will be by email. For some messages, we may use personal information we collect about you to help us determine the most relevant information to share with you.You can change your marketing preferences by clicking on the unsubscribe link at the bottom of our emails.

1. THIRD PARTY DATA COLLECTION AND ONLINE ADVERTISING

We participate in interest-based advertising and use third-party advertising companies to serve you targeted advertisements based on your browsing history. We permit third-party online advertising networks, social media companies and other third-party services, to collect information about your use of our online services over time so that they may play or display ads on our Services, on other websites or services you may use, and on other devices you may use.Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the site, AdID, precise geolocation and other information. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices.We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. We may do this by providing a hashed version of your email address or other information to the platform provider. Please see “Your Choices About Online Ads” below, to learn more about interest-based advertising.9.1 Your Choices About CookiesIf you would prefer not to accept cookies, most browsers will allow you to change the setting of cookies by adjusting the settings on your browser to: (i) notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Be aware that disabling cookies may negatively affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionalities and features of the Services.Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.If you are accessing the Site from the UK or EEA, we will only use cookies (other than cookies that are strictly necessary for the provision of the Services) to the extent you give us your consent to do so. Please see our cookie policy for more information about the cookies we use on our Site.9.2 Your Choices About Online AdsTo learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Digital Advertising Alliance’s (DAA) and/or the Network Advertising Initiative’s (NAI) online resources, at www.aboutads.info/choices or http://www.networkadvertising.org/choices/ and you can opt-out of receiving some interest-based advertisements on mobile apps by visiting http://www.aboutads.info/appchoices. You may also be able to limit interest-based advertising through the settings menu on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android). You may also be able to opt-out of some — but not all — interest-based advertising served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online services. It means that the online ads that you do see from DAA program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s principles.

1. MAINTAINING AND UPDATING YOUR ACCOUNT INFORMATION

As part of your use of the Services, you are responsible for maintaining and updating, as applicable, your account information with current and complete information. You may edit and delete portions of your account information. To do this, select “My Account” in the main menu and choose which information to edit or delete. You can also delete your MiniTon account entirely. To do this, select “Help Center” in the main menu. Further select “Contact Us” and select “Disable Account” to request for your account to be deleted.After receiving any requested changes to your account information or personal information, we will make reasonable efforts to ensure that all of your personal information stored in databases we actively use to operate the Services will be updated, corrected, changed, or deleted as appropriate, as soon as reasonably practicable. However, we reserve the right to retain in our archival files any information we remove from or change in our active databases, subject to any obligations under any applicable law. Where permissible, we may retain such information to resolve disputes, troubleshoot problems, and enforce our Terms of Service. In addition, it may not be technologically possible to remove every record of the information you have previously provided us, as a copy may exist in a non-erasable form that will be difficult or impossible for us to locate.

1. EFFECTIVE DATE; POLICY CHANGES

Our business changes frequently and this Privacy Policy is subject to change from time to time. If we make any material changes to this Privacy Policy, we will notify individuals by email to their registered email address, by prominent posting on our Service, or through other appropriate communication channels. We will also update the “Effective Date” at the beginning of this Privacy Policy.

1. CONTACT US

To contact us with your questions or comments regarding this Privacy Policy or the information collection and dissemination practices of the MiniTon SDK, please email us at [e-mail].