Effective Date: 18th August, 2018
Mobile) collect, process, use and share information about you, why we do so, and how you can ensure your privacy is protected at all times.
Our goal is to be a reliable partner that treats your personal data in a respectful manner, in compliance with all applicable regulations, and leads the way when it comes to transparency and fairness.
1.1 Data Subject is a natural person about whom
Mobile has got information or data enabling to identify the natural person. Data Subjects are, for example, the Clients, Visitors and cooperation partners, as well as the employees who are natural persons and whose personal data are held by
1.3 Personal Data is any information concerning an identified or identifiable natural person.
1.4 Personal Data Processing is any operation or set of operations which is performed on the Personal Data of a Data Subject, such as collection, recording, organisation, structuring, storage, alteration and disclosure, enabling an access to, retrieval, consultation, use, transmission, cross-checks, alignment or combination, restriction, erasure or destruction of Personal Data, irrespective of the manner of performing these operations or the means exploited.
1.5 Client is any natural or legal person that uses or has expressed a desire to use the Services of
1.6 Agreement is the Service Agreement or any other agreement entered into between
1. 8 Website means the websites of MSY Mobile, the list whereof is available here: www. msymobile.com .
1.9 Visitor is any person using the Services or Website of
1.10 Child’s Consent Age in the context of Personal Data Processing is at least 16 years in relation to the offer of information society services directly to a child.
1.11 Services are any services and products offered by
1.12 Cookies are the data files of the Website sometimes recorded in the device of a Visitor.
1.13 Data Protection Officer of
1.14 Product Portfolio means the business entities, various products and Services of
2. GENERAL PROVISIONS
Room 639,C Block,E-plaza Fortune Center,
No.11 Zhongguancun Street, Haidian District, Beijing
(1) a controller, while determining the purposes and means of processing;
(2) a processor in accordance with the instructions from the controller; and
(3) a recipient to the extent to whom the Pe rsonal Data are transferred.
3.1 The objective of
3.2 All the processes, guidelines, operations and activities of
(1) Lawfulness. There is always a legal basis for the Processing of Personal Data, i.e. consent;
(2) Fairness. Personal Data Processing shall be fair, while providing a Data Subject with sufficient information and communication on how the Personal Data are Processed;
(4) Purposefulness. Personal Data shall be collected for legitimate purposes which have been established precisely, clearly and shall not later be processed in any manner which is in conflict with these purposes;
(5) Minimisation. Personal Data shall be adequate, relevant and limited to what is necessary for the purpose of Processing the given Personal Data.
(6) Accuracy. Personal Data shall be correct and shall be updated as necessary, and all reasonable measures shall be taken to ensure that Personal Data which are incorrect in the light of the purpose of Personal Data Processing shall be deleted or corrected without delay;
(7) Accuracy. Personal Data shall be correct and shall be updated whenever necessary. All reasonable measures will be taken in order to ensure that Personal Data, which in light of the purpose for Personal Data Processing is found to be incorrect, shall be deleted or corrected without delay;
(8) Limit of storage. Personal Data shall be stored in the format enabling the identification of Data Subjects only as long as it is necessary to achieve the purpose for which the Personal Data are processed. It means that in case
(9) Reliability and confidentiality. Personal Data Processing shall be carried out in the manner ensuring the adequate security of Personal Data, including their protection against unauthorised or unlawful Processing and against accidental loss, destruction or damage, by taking reasonable technical or organisational measures.
(10) Data protection by design and by default.
3.3 Upon Personal Data Processing,
4. COMPOSITION OF PERSONAL DATA
(1) the Personal Data disclosed to
a) contact information such as nickname and e-mail address; in some cases postal address, telephone number;
b) information on job applicant such as resume, name, e-mail address, telephone number;
c) information provided as an answer to a survey;
d) information provided when creating an account, such as e-mail, nickname, country, age, gender;
e) information provided when inviting others to use
f) content of the messages sent through
(2) the Personal Data generated as a result of the day-to-day communication between the Data Subject and
(3) the Personal Data manifestly made public by the Data Subject e.g.:
a) Personal Data received from Facebook. If Data Subject logs in the game using its Facebook account, then
b) Personal Data received from Google. If Data Subject logs in a
(4) the Personal Data generated upon consumption of Services and visiting, using the Website e.g.:
a) username, password;
b) profile information such as gender, photo, age, date of birth;
c) links to Data Subject’s profiles on social networks;
d) mobile device identifiers such as unique mobile device ID, hardware type, media access control (“MAC”) address, international mobile equipment identity (“IMEI”), name of the device;
e) general information about Data Subjects location, as well as accurate information about the geographical position of the device (only when there is consent);
f) game data such as interactions with the game itself and with other users in the game through server log files;
g) player ID;
h) the time spent on the Website and on the consumption of Services; IP address; the operating system of a device, browser type, language info, access times, addresses of the websites from which Data Subject transferred to
i) information about interaction with our Services such as when and how games are played, details about the game activity.
(5) information collected using cookies or other similar technologies;
(6) the Personal Data received from third persons e.g.:
a) Data Subject’s characteristics and interests;
b) information about other games and services used.
(7) the Personal Data created and combined by
a) electronic correspondence;
b) information about Data Subject’s interactions with
5. COMPOSITION, PURPOSES AND BASES FOR PROCESSING OF PERSONAL DATA
5.3 Upon entry into and performance of an Agreement, Personal Data Processing may be additionally provided for in the specific Agreement, but
(1) in order to take steps at the request of the Data Subject prior to entering into the Agreement;
(2) to identify the Client to the extent required by due diligence, this might include identification for account recovery;
(3) to perform the obligations to the Client regarding the provision of its Services this includes providing appropriate device versions of
(4) to communicate with the Client this includes sending confirmations, invoices, technical notifications, updates, security alters, support and administrative messages;
(5) to ensure the performance of the payment obligation of the Client;
(6) to submit, realise and defend claims.
5.4 For the entry into an employment agreement, the Processing of the Personal Data of a job applicant by
(1) Processing of the data submitted by the job applicant to
(2) Processing of the Personal Data received from the person indicated as the referee by the job applicant;
(3) Processing of the Personal Data collected from state databases and registers and public (social) media.
In case a job applicant is not selected,
5.5 Legitimate interest means the interest of
(1) for ensuring a trust-based relationship with a client, for example Personal Data Processing that is strictly necessary to determine the ultimate beneficiaries or to prevent fraud;
(2) for the administration and analysing the client base to improve the availability, selection and quality of Services and products, and to make the best and more personalised offers to the Client upon the Client’s consent;
(3) for the identifiers and Personal Data collected upon the use of websites, mobile applications and other Services.
(4) for the organisation of campaigns, including organisation of personalised and targeted campaigns, carrying out Client and Visitor satisfaction surveys, and measuring the effectiveness of the performed marketing activities;
(5) for monitoring of the service.
(6) for ensuring integrity of
(7) for corporate purposes, in particular for the financial management and for the Processing of the Clients’ or employees’ Personal Data;
(8) for receiving feedback;
(9) for targeted advertising online (also on third party websites) from which Data Subject can opt out (see section 12: Important Guidelines);
(10) for providing Data Subject’s with third party online advertising from which Data Subject can opt out (see section 12: Important Guidelines);
(11) for the establishment, exercise or defence of legal claims.
5.6 For performing a legal obligation,
5.7 In case Personal Data Processing is carried out for a new purpose, different from those for which the Personal Data were originally collected or is not based on the consent given by the Data Subject,
(1) any link between the purposes for which the Personal Data were collected and the intended further purposes Processing;
(2) the context of collecting the Personal Data, in particular, regarding the relationship between the Data Subject and
(3) the nature of the Personal Data, in particular, whether any special categories of Personal Data, or Personal Data related to criminal convictions and offences are processed;
(4) possible consequences of the intended further processing for the Data Subjects;
(5) existence of appropriate protection measures which may consist in, for example, encryption and pseudonymisation.
6. DISCLOSURE AND/OR TRANSFER OF CLIENT DATA TO THIRD PERSONS
6.2 Such third persons may be the persons within the same group with
(1) the respective purpose and the Processing are lawful;
(2) the Personal Data Processing is carried out in accordance with the guidelines of
(3) the data regarding the respective processors are disclosed to the Data Subjects (see section 12: Important Guidelines).
7. SECURITY OF PERSONAL DATA PROCESSING
7.3 In case of an incident related to Personal Data,
8. PROCESSING OF THE PERSONAL DATA OF CHILDREN
8.1 The Services of
8.3 In case
9. RIGHTS OF DATA SUBJECTS
9.1 Rights related to consent:
(1) A Data Subject will always be entitled to inform
(2) You will be able to change and withdraw your consents given to
9.2 A Data Subject has also the following rights upon Personal Data Processing:
(1) Right to receive information i.e. the right of a Data Subject to receive information regarding the Personal Data collected about him or her.
(2) Right of access to data i.e. the right to obtain confirmation as to whether or not Personal Data concerning him or her are being processed. It also includes the right of a Data Subject to a copy of the Processed Personal Data.
(3) Right to rectification of inaccurate Personal Data. A Data Subject will be able to request the correction of inaccurate data.
(4) Right to erasure of data i.e. in certain cases a Data Subject will be entitled to demand the deletion of Personal Data, for example if the Processing is carried out only on the basis of a consent. In some cases Personal Data displayed during the game, such as user name, avatar, scores and chat messages can be stored on other player’s devices, and this data cannot be erased by
(5) Right to demand restriction of Personal Data Processing. This right is created, inter alia, in case the Personal Data Processing is not permitted under law or if the Data Subject challenges the accuracy of the Personal Data. A Data Subject will be entitled to demand the restriction of the Personal Data Processing for a period enabling the processor to check the accuracy of the Personal Data or if the Personal Data Processing is unlawful but the Data Subject does not request the deletion of the Personal Data.
(6) Right to data portability i.e. a Data Subject shall have, in certain cases, the right to receive the Personal Data in a machine-readable format, and to take these data along or transfer them to another controller.
(7) Right to object in some cases the Data Subject shall have the right to object, on grounds relating to his or her particular situation, at any time to Processing of Personal Data concerning him or her.
(8) Rights related to automated Processing mean, inter alia, that a Data Subject will have the right to object, on grounds relating to his or her particular situation, at any time to Processing of Personal Data concerning him or her, based on automated decision-making. For the avoidance of doubt –
(9) Right to the assessment of a supervisory authority on whether the Processing of the Personal Data of the Data Subject is lawful;
(10) Compensation for damage when there has been a violation of Data Subject’s rights for which
10. EXERCISING OF RIGHTS AND FILING OF COMPLAINTS
10.1 Exercising of rights. A Data Subject will be entitled to address
11. COOKIES AND OTHER WEB TECHNOLOGIES
11.5 Most of the web browsers allow Cookies. Without fully allowing Cookies, the functions of the Website are not available to a Visitor. The allowing or prohibiting Cookies and other similar technologies shall be under the control of a Visitor via the settings of the Visitor’s own web browser, settings of the information society service and platforms for making such privacy more efficient (see section 12: Important Guidelines).
12. IMPORTANT GUIDELINES
(1) All About Cookies: Descriptions of cookies and other web technologies used by
(2) Your Online Choices; About Ads; Network Advertising: the platform of controlling and monitoring of cookies and other web technologies, where Data Subjects themselves can change and control how their Personal Data are used and collected.
(3) Data regarding processors can be found here.
13. CONTACT DETAILS AND INFORMATION
13.1 The contact details of
(1) Regarding Personal Data issues,
14. OTHER TERMS AND CONDITIONS