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Privacy Policy

2019-09-11

 

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SUMMARY

INTRODUCTION

What information do we collect about teenagers and adults?

What information do we collect and process from children?

How will we use the information about you?

What information you may choose to share?

How we store and share your personal information?

Where do we process your information?

How long do we keep hold of your information?

How can I exercise my rights over my information?

Contact Information

How will we notify you of changes?

INTRODUCTION


This Privacy Policy describes the data Mattel163 Limited (“Mattel163,” “we” or “us”) collects when you utilize our online services, including our websites, mobile applications, connected products, and other online services (collectively, the “Services”). It also describes how we use, share and protect your information; describes the collection and use of personal data by third parties; and tells you about your rights and choices.

If you do not agree with this Privacy Policy, you must not use the Services.

This Privacy Policy does not apply to any information collected by Mattel163 offline.  Nor does it apply to websites, apps, or other online services maintained by our affiliates, or other companies or organizations to which we link but are not subject to Mattel163’s control.

Mattel163 is a member in good standing of ESRB’s Privacy Certified Program.  To protect your privacy, we have voluntarily undertaken this privacy initiative. ESRB Privacy Certified seals appear on the Services that participate in the program. The ESRB has reviewed and certified that those Services meet established online information collection, use, and disclosure practices. The ESRB does not certify our Facebook platform games. As a licensee of this privacy program, we are subject to audits and other enforcement and accountability mechanisms administered independently by the ESRB.

We want you and your family to have fun using our Services, and urge you and your family to follow common sense whenever disclosing personal information - in our Services or anywhere else.

If you have any comments, questions or complaints regarding the processing of your personal information, you can contact us at privacy@mattel163.com.

The Types of Personal Information We Collect or Receive from Teenagers and Adults

Mattel163 makes Services that are fun and entertaining for a wide range of audiences. Some of our Services may target children under 16 years old or the age of consent as their primary audience. We call these child-directed Services. Other Services we offer (for example, our UNO!TM app) may target parents and/or the users above the age of consent as the primary audience, but they also target children. We call these mixed audience Services. Typically, when one of our Services is mixed audience, we collect the ages of our users to provide them with an age-appropriate experience. Finally, some of our Services (for example, our Phase10 app) do not target and/or are not intended for children. We call these general audience Services.

This section describes our collection of information from you (i) in our general audience Services, or (ii) in our mixed audience Services if you are above the age of consent (i.e., 13 years or older in the United States, and 16 years or older in the European Economic Area) . We will collect and receive the following information about you:

Information you give us.

When you register for any one of the Services, including to set up your profile, you provide us with information about yourself.  This includes your email address, gender, age, username, character name, password, and other information that help us confirm your access to your account. You may register utilizing a third-party account, such Facebook, Apple Game Center or Google Play, in which case you will provide us your username (or “Social ID”).

As part of promotional activities for the Services, you may submit your contact details to us (including your name, email address and physical address).

When you make purchases in the Services, you provide us with information to facilitate the payment.

Information we collect about you.

We automatically collect certain data when you use the Services, including your IP address and device information, such as device type, network data, operating system (hereto referred as “OS”), device ID, IMEI, MAC address, and advertising ID, language, and time zone. We also automatically collect information regarding how you use the Services, such as date and time stamps of actions and Game Data, which includes your game level, progress, scores, achievements, game log and interactions with other users. Some of this information will be stored on your device so we can remember it the next time you come back.

We automatically collect information about your general location (i.e., country), which is based on your IP address. In addition, we will collect information about your precise location, but only when you provide affirmative, opt-in consent within the Services (for example, if you choose to search for nearby friends to play a game).

In some of our Services, we have a record feature that gives you the option of recording your in-game performance and interactions through a video. You may choose whether or not to use this feature. Your mobile device might ask you for access to the “Gallery” as storage location. We do not collect or access any photos or videos stored on your device.

We also collect and store your data each time you interact with us, for example, when you use in-app support to communicate with us.

We also collect your voice data after you consent to use your microphone.

When you sign into our Services with a social media account, such as Facebook, Google Play, or Apple Game Center, we will collect information from your third party account, including your user ID, nickname, profile picture, and/or friend list with your prior consent. We only use the data received from these platforms for use with our Services.

We also collect information on your use of the Services via Cookies and related technologies (e.g., third-party SDKs). Additional information about our use of these technologies is provided below.

What information do we collect and process from children

The section describes our collection of information (i) in our child-directed Services, and (ii) from children in our mixed audience Services.

We take many special precautions to protect the privacy of children. In general, we define “children” as users under 13, but adhere to local definitions of “children” where a different age of consent applies, such as children under the age of 16 in the European Economic Area. Children must not use the Service for any purpose without the consent of their parent or legal guardian.

Except in limited circumstances authorized by law, we do not collect personal information (for example, full name, e-mail address, phone number, or precise location) from children without providing notice to and obtaining verifiable consent from a parent or legal guardian.

We collect some information (like IP address, device ID, OS, etc.) automatically and use technology like cookies exclusively to support the internal operations of our Services. We do not use these technologies to track user behavior or amass profiles of children. We use personal information from children located in the EEA exclusively to perform our contract with the child to provide the Services.

We do not ask for more personal information than is necessary for a child to participate in an activity.

We take steps to prevent children from posting or publicly disclosing personal information. If we become aware of any personal information posted publicly by a child, we will remove it. Parents can contact us if they have any questions about the collection, use or sharing of their children’s information.

If we collect an email address from a child in connection with a customer support inquiry, we delete the child’s email address immediately upon responding to the child’s request.

If you are a parent that has provided consent to the collection of your child’s personal information, you have the option to consent to the collection and use of your child’s personal information without consenting to our disclosure of that information to third parties, and to withdraw consent at any time.  Parents also have the right to review or have deleted their children’s personal information, and to refuse further collection or use of their children’s information. To exercise those rights, parents may contact us at privacy@mattel163.com.

How We Use Your Personal Information

This section applies to users at or above the age 16 or the age of consent. Age classification depends on local laws and regulations. We will use the information in the following ways and in accordance with the following legal bases:

Registration Information: We use Registration Information to set up user accounts, allow users to log-in to the Services and provide Services to users. We use this information pursuant to our contract with you to provide the Services and, with regard to information received from social networks, with your consent.

Device Information: We use this information to provide and improve the Services such as: to allow users to download and install the Services on their devices; to enable user voice chat with each other; to record and keep track of requests from users of the Services; to detect the user network and device status when the user is using the Services; and to correct bugs or errors that occur when the user is using the Services. Use of Device Information is necessary to perform our contract with you to provide the Services.

Contact Information: From time to time, we may host marketing events and/or user testing for which we will request this information so that we can send you notifications of any rewards to which you are entitled or coordinate playtest logistics. We will also use this information to respond to your customer service or technical support questions or issues. We use this information with your consent.

Location Information: We use country-level location information to provide some Location Based Services such as providing our Services in the appropriate language. We use this information to perform our contract with you to provide the Services.  We use more precise location information to provide Services for which you provide affirmative consent, such as to form a team with people nearby to play a game.

Social ID: We use this information to enable users to share their game achievement or game-play video on social media or invite their friends to the Services. We use this information with your consent.

User Profile:  We use this information to provide customized services to users such as a personal information page. We use this information with your consent by uploading your name and/or photo. For the protection of your information, we recommend you do not use your real name and personal photo in our Services.

Game Data: We use this information to provide the Services to our users. Use of Game Data is necessary to perform our contract with you to provide the Services.

Information Generated from Cookies and Tracking Technologies: Our Services use technologies, like cookies and web beacons, to manage registrations or access to certain features, store your settings and preferences, conduct age-screening, offer you personalized content, help us understand the features that appeal to visitors, and manage advertising, among other things. We may use your personal information for marketing and advertising, including by providing your personal information to other companies or organizations that offer products or services that may be of interest to you. If you want to know more about the cookies and third parties (i.e., SDK or advertisement providers) we use to collect your personal information for marketing and analyzing, including additional information on the third parties’ privacy policies and opt-out options, please click here for more details. You may also check the relevant sections “Your rights” and “Promotional Material & Announcements” for more opt-out information.

What Information You Choose to Share

You have the option of sharing your personal information with the public or with third parties. For example: (1) sharing gameplay video, screen shots or game achievements with third-party platforms or the public through a “share” button on your game system; (2) displaying your real name or photograph within games; and (3) sharing personal information with others through chat, text, or communications features.

If you choose to "share" content or to otherwise post information from or via our Services to a third-party platform, that information (which may include your and other users’ personal information, like username and profile photo) will become public and the third party platforms may have access to information about you and your use of our Services. Likewise, other users may use these same features to share information about you. For the protection of your information, we recommend you do not use your real name and personal photo in our Services. We are not responsible for how you choose to share personal data with the public or third parties, or how third parties use the feature to share information.

How We Store and Share Your Personal Information

To perform our contract with you, your personal information will be accessible from and will be processed on AWS servers, which are located in the United States. AWS is certified under the Privacy Shield Framework.

We share your personal information with selected third parties in and outside your country, including:

- third parties that provide services in support of the Services, please click here for more details.

- related group companies, with whom we share your personal information to the extent necessary to operate the Services. The transfers contemplated above are made pursuant to our contract with you.

- law enforcement agencies, public authorities or other judicial bodies and organizations. 

We disclose information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:

comply with a legal obligation, process or request;

enforce our terms of service and other agreements, policies, and standards, including investigation of any potential violation thereof;

detect, prevent or otherwise address security, fraud or technical issues; or

protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organizations for the purposes of fraud protection).

Some of the recipients of your personal data listed above are located in countries outside the EU/EEA that do not offer the same level of protection with regard to personal data as required in the EU/EEA and where there is no adequacy decision by the European Commission. In that case we will ensure an adequate level of data protection by appropriate safeguards, e.g. EU Model Clauses and Privacy Shield . If you would like to obtain a copy of the safeguard that we use, please contact us at the contact details indicated below.

The Security of Your Personal Information

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. Our group companies have information security and access policies that limit access to our systems and technology. We also protect data through the use of technological protection measures such as encryption. Your personal information will remain subject to our technical and organizational controls and our policies and procedures (including this Privacy Policy).

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of the information transmitted to our Services.

If we learn that your unencrypted personal information has been compromised by a data breach, we will notify you consistent with applicable laws.

Data Retention

As a general rule, we retain your personal information only as long as required to perform the Services or other purpose that was the reason for the collection of the information. We will retain most of your personal information as long as you use the Services (i.e., until account deletion in accordance with your request) with the following exceptions: Audio voice files will be stored for up to 24 hours after you use it in the game, and then deleted. Contact Information that is obtained as a result of you participating in our promotional activities will be retained during such activities as expressly designated in the corresponding activities. Game-play video recordings will be deleted within one month from the date of their creation.

When destroying personal information, measures will be taken to make the personal information irrecoverable or irreproducible, and electronic files which contain personal information will be deleted permanently using a technical method which makes the files irreproducible.

In the event that the processing and retention period have terminated, but personal information is required to be retained continuously for other reasons including for archiving purposes as prescribed under applicable laws, the relevant personal information will be stored and maintained separately from other types of personal information. If you require us to destroy your personal information before the end of its life cycle (as set out in the retention policy above), we will destroy your personal information in accordance with local laws).

Your Rights

You have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below) and in certain jurisdictions. To exercise any of your rights, please contact us at privacy@mattel163.com.

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. To assert this right, please contact us as described above.

Portability

You have the right to receive a copy of certain personal information that you have provided to us and that we process about you. This comprises any personal information we process on the basis of your consent (e.g., gender information) or pursuant to our contract with you (e.g., game play statistics), as described in the section “How We Use Your Personal Information”. You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party.

If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (e.g., where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).

Correction

You have the right to correct any personal information held about you that is inaccurate. To assert your right, please contact us as described above.

Erasure

You can delete your account, or remove certain personal information. If there is any other personal information you believe we process that you would like us to erase, please contact us as described above.

You may request that we erase the personal information we hold about you in the following circumstances:

you believe that it is no longer necessary for us to hold such personal information; or

you believe the personal information we hold about you is being unlawfully processed by us.

You can also exercise your right to restrict our processing of your personal information (as described below) while we consider your request.

We may need to retain personal information if there are valid grounds under data protection laws for us to do so (e.g., for the defense of legal claims or freedom of expression) but we will let you know if that is the case.  Where you have requested that we erase personal information that has been made available publicly on the Services and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.

Restriction of Processing to Storage Only

You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (e.g., for the defense of legal claims or for another’s protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

You may request we stop processing the personal information we hold about you where:

you believe the personal information is not accurate for the period it takes for us to verify whether it is accurate;

you believe the processing we are doing is unlawful and you want us to restrict its processing;

you believe the personal information is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defense of legal claims; or

you would like to verify whether our legitimate grounds for processing the information override your interests.

Objection

You have the right to object to our processing of personal information about you, which you may do by contacting us as described above.

California Privacy Rights

California Civil Code § 1798.83 permits our users who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not share our users' personal information with unaffiliated third parties for their direct marketing purposes without our users’ consent. However, if you are a California resident and you have any questions about our disclosure of your personal information to third parties, please contact us at:

Mattel163 Limited

Office of Privacy & Info Security

1/F Xiu Ping Commerical Building, 104 Jervois Street, Sheung Wan, Hong Kong

CHINA  +86(0)571-89852929

privacy@mattel163.com

If you are a California resident under the age of 18, you may also contact us to request the removal of content or information that you have posted publicly on one of our Services.

Links

Our Services may link to or use other content from the Internet, including content offered by third parties that we do not control and whose privacy and data collection practices may differ from ours. For example, we may link to social media sites or sites that sell our products.  We encourage you to carefully review the privacy policy and terms of use of such third parties, as they are not covered by this Privacy Policy, and Mattel163 is not responsible for them.

You may be able to alter settings on your browser, device, or other software to block or partially block those third parties.  Sometimes those settings may not be effective.

Promotional Material & Announcements

This section applies to users age 16 or older or above the age of consent. You have the right to ask us not to process your personal data for email or text promotional purposes. We will inform you and obtain your consent (before collecting your data) if we intend to use your data to send promotional text messages or emails, or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at privacy@mattel163.com.

You are able to opt out of receiving targeted ads and analytics on our Services by limiting ad tracking in your device settings. Please note that you will still see ads, although they may be less relevant to you.

For ads in Apps, you can opt out of interest-based advertising on mobile applications by resetting the privacy settings of your Android or iOS device and selecting "limit ad tracking" (Apple iOS) or "opt-out of interest based ads" (Android).

Some web browsers may transmit “do not track” signals. Web browsers may incorporate or activate these features differently, making it unclear if users have consciously activated them. As a result, at this time, we do not take steps to respond to such signals.

For ads on the website, you can manage your cookie preferences using your own browser settings (for example, Chrome, Edge, Internet Explorer, Firefox, Safari, or Opera) to accept or block some or all cookies or receive notice so you can consent to cookies. In addition, some of third parties who provide tailored ads and analytic services are members of the Networking Advertising Initiative (“NAI”) and/or the Digital Advertising Alliance (“DAA”). If you wish to not have your information used for the purpose of serving you targeted ads, you may opt-out by visiting https://www.aboutads.info/choices and/or https://www.networkadvertising.org/choices/.

We may from time to time send you announcements when we consider it necessary to do so (such as when we temporarily suspend Game access for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature.

Contact Complaints

In the event that you wish to make a complaint about how we process your personal information, please contact us and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the country in which you live or work where you think we have infringed data protection laws. Contact information:

Name: Mattel163 Limited -Office of Privacy & Info Security

Address: 1/F Xiu Ping Commerical Building, 104 Jervois Street, Sheung Wan, Hong Kong

Direct: +86(0)571-89852929

Mail:privacy@mattel163.com

Data Protection Officer and contact information:

privacy@mattel163.com

Designated EU representative and contact information:

GDPR-Rep.eu

Maetzler Rechtsanwalts GmbH & Co KG

Attorneys at Law

c/o Mattel163 Limited

Schellinggasse 3/10, 1010 Vienna, Austria

Please add the following subject to all correspondence:

GDPR-REP ID: 18502255

As previously stated, Mattel163 is a licensee of the ESRB’s Privacy Certified Program.  If you believe we have not responded to your inquiry or your inquiry has not been satisfactorily addressed, please contact the ESRB at:

ESRB

Attn:  Privacy Certified Program

420 Lexington Avenue, Suite 2240

New York, NY 10170

www.esrb.org/privacy/contact.aspx

Changes

If we make any material changes to this policy, we will post the updated policy here and notify our users within the Services. Please check this page frequently to see any updates or changes to this policy.

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