August 20, 2018
Thanks for using our games, websites, social media pages or related services (“Service” or “Services”).
1.1. This policy describes:
- what information MyTona and its other affiliated and related companies (“MyTona” or “we” or “us” or “our”), and its vendors and service providers collect through the Services, whether on your mobile device, computer, or any other device, platform or website, and why we collect it,
- how we use that information, and
- how you can exercise your privacy rights.
1.5. It is not our policy to allow anyone under the age of 16 to provide personal data and we do not knowingly collect or solicit personal data about to anyone under the age of 16 or knowingly allow such persons to use our Services.
No one under the relevant age may provide any personal data.
If we discover that we have collected personal data about a child under the relevant age, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under the relevant age, please contact us.
2. Information we collect and receive
We may collect and receive information which may be considered personal data according to applicable laws in a variety of ways. The types of information we collect depend on how you use our Services. More specifically:
2.1. When you use our social media pages:
2.1.1. Information that you and others provide voluntarily:
- Information and content you provide. We collect the content, communications and other information you provide when you use our Services, including when you sign up for an account, create or share content, and message or communicate with others through our Services. This can include information in or about the content you provide (like metadata), such as the location of a photo or the date a file was created.
- Networks and connections. We collect information about the people, pages, accounts, hashtags and groups you are connected to and how you interact with them across our Services.
- Your usage. We collect information about how you use our Services, such as the types of content you view or engage with; the actions you take; the people or accounts you interact with through our Services; and the time and frequency of your activities. For example, we log when you're using and have last used our Products, and what posts, videos and other content you view on our Services.
- Things others do and information they provide about you. We also receive and analyze content, communications and information that other people provide when they use our Services. This can include information about you, such as when others share or comment on a photo of you, send a message to you, or upload, sync or import your contact information.
2.1.2. Information that is collected and stored automatically from you and/or your device when you use our Services:
- We collect information about you automatically when you visit our website or use our Services. For example, we collect information about how often you use the Services, pages visited, links clicked, mouse movements, and other information about how you interact with the Services. We may also collect data about how you interact with messages we send to you, for example, whether you opened an email or read an in-app message.
- Device attributes and operations: we collect information about the device you use to access our Services, including your browser, operating system, and cookie information. We may also collect your location data (as indicated by the Internet Protocol [IP] address).
- Data from device settings: information you allow Facebook, Instagram, Twitter, Youtube to receive through device settings you turn on, such as access to your GPS location, camera or photos.
Whether we collect some or all of this information often depends on the type of device used and its settings. These technologies allow us and third parties to recognise your device when you use websites and applications. They are consistent across all pages and thus allow cross-app tracking.
2.1.3. Data we collect from our partners:
We may also obtain information from our third-party partners and service providers to analyze how users use our Services. We use this aggregated information to better understand and optimize our Services.
Some of this information may be collected using cookies, a small files that store information on your device to help us optimize the use of our Services and/or similar technologies (such as "SDKs" or software development kits). Some of the cookies are “1st party,” from the website itself, and others are “3rd party,” belonging to advertising and analytics entities or social networks. Cookies are typically used to quickly identify your device and to “remember” your device during subsequent visits for purposes of functionality, preferences, and website performance. You can disable cookies on your device or set your device to alert you when cookies are being sent to your device; however, disabling cookies may affect your ability to use the Services.
We only collect personal information that is reasonable or necessary to deliver information, or services that you have specifically requested or required by law. You may choose not to provide this information, but you need to understand that in some circumstances this may mean we are unable to provide you with a certain Service.
3. How do we use this information?
We use the information we have (subject to choices you make) as described below and to provide and support our Services. Here’s how:
To communicate with you: We communicate with you via our Services, or other means available on or through the Services (for example, via live chat or in-app notifications) about your use of our Services, product announcements, software updates, as well as transactional and service messages, such as welcoming you to our Services or informing you of issues with your account, for example if your social account has disconnected.
To enhance our Services and develop new features: We use the collected information to conduct research, develop new features, and enhance or improve the features, algorithms, and user experience of our Services.
To support you: We use the collected data about you to respond to your requests for information or assistance.
To conduct our contests: We use the collected data to determine the winners and send prizes (through our Services or to their addresses).
4. Your information will be shared with others in the following ways:
People and accounts you share and communicate with
When you share and communicate using our Services, you choose the audience for what you share. For example, when you post on Facebook, Instagram, Youtube, Twitter, you select the audience for the post, such as a group, all of your friends, the public, or a customized list of people. Those people and businesses can see the content you send. Your network can also see actions you have taken on our Services. We also let other accounts see who has viewed their Facebook or Instagram Stories.
Public information can be seen by anyone, on or off our Services, including if they don't have an account. This includes your Instagram, Twitter, Youtube username; any information you share with a public audience; information in your public profile on Facebook; and content you share on a Facebook Page, public Instagram account or any other public pages, such as our Services. You, other people using Facebook and Instagram, and we can provide access to or send public information to anyone on or off our Services, in search results, or through tools and APIs. Public information can also be seen, accessed, reshared or downloaded through third-party services such as search engines, APIs, and offline media such as TV, and by apps, websites and other services that integrate with our Services.
Content others share or reshare about you
You should consider who you choose to share with, because people who can see your activity on our Services can choose to share it with others on and off our Services, including people and businesses outside the audience you shared with. For example, when you share a post or send a message to specific friends or accounts, they can download, screenshot, or reshare that content to others across or off our Products, in person or in virtual reality experiences such as Facebook Spaces. Also, when you comment on someone else's post or react to their content, your comment or reaction is visible to anyone who can see the other person's content, and that person can change the audience later.
People can also use our Products to create and share content about you with the audience they choose. For example, people can share a photo of you in a Story, mention or tag you at a location in a post, or share information about you in their posts or messages.
Information about your active status or presence on our Services
People in your networks can see signals telling them whether you are active on our Services, including whether you are currently active on Instagram, Facebook, or when you last used our Services.
If the ownership or control of all or part of our Products or their assets changes, we may transfer your information to the new owner.
Vendors and service providers
We provide information and content to vendors and service providers that support our business by providing technical infrastructure services, analyzing how our Services are used, providing customer service, or conducting surveys.
5. Protection of Information
5.1. We take the security of your Personal Data very seriously. We implement the appropriate technical and physical safeguards to ensure that your Personal Data is protected against accidental or unlawful loss, destruction, alteration, unauthorized access or disclosure, or any other use or unlawful processing of Personal Data you have provided to us. Our security mechanisms for Personal Data are similar to those of other game developers. Please keep in mind, though, that the Internet is not 100% secure and any access, disclosure, alteration or destruction of the Personal Data you have provided through our games due to breach of our safeguards cannot be guaranteed.
6. Links to third parties in our Services
7. International data transfers
Our Service is global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Policy. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal data between our group companies and third party service providers and partners, which require all group companies to protect personal data they process from the EEA in accordance with European Union data protection law. It also includes transferring personal data to third party service providers and partners which are certified under the EU-US and Swiss-US Privacy Shield.
8. Legal Bases for Processing Personal Data
In each case where we process your Personal Data, we do so lawfully in accordance with one of the legal basis according to the applicable law. The legal bases which we rely upon are the following:
- Legal Obligation. This applies when data used by us to comply with a legal obligation, such as the preventing a crime or fraud;
- Legitimate Interests. This applies when data used for communication, conducting the contests, analytics, research and optimisation of the Services.
9. Personal Data Protection Rights
If you are in the European Union you have the following data protection rights:
- Right to access your Personal Data;
- Right to correct or update your Personal Data;
- Right to delete your Personal Data;
- Right to restriction of processing your personal data;
- Right to object at any time to processing of your personal data;
- Right to opt-out of direct or target interest advertising;
- Right to portability of your personal data;
- Right to withdraw your consent at any time.
- Right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
Please note we do not carry out any decision-making based solely on automated processing, including profiling unless we have your consent or we need to do so to perform a contract with you.
10. How to contact us
10.2. Joint Data Controller for the Facebook and Instagram pages: Facebook, Inc. you can contact them online or by mail at: ATTN: Privacy Operations 1601 Willow Road, Menlo Park, CA 94025
Joint Data Controller for the Twitter pages: Twitter International Company, you can contact them online or by mail at: ATTN: Data Protection Officer, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07 IRELAND
Joint Data Controller for the Youtube pages: Google LLC (“Google”), located at 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States. You can contact them online.
Joint Data Controller for all pages (on Facebook, Instagram, Twitter, Youtube): MyTona Pte. Ltd., a Singapore corporation with its registered office at 1 Fusionopolis Link #06-06 Nexus@One-North, North Lobby, Singapore 138542.
10.3. MyTona’s Representative Contact Information:
In the Czech Republic:
Matthew Joseph, Zahradníčkova 1220/20A, Prague 15000, Czech Republic, phone: +1-617-398-7067.
In the Republic of Ireland:
VeraSafe Ireland Ltd., Unit 3D North Point House, North Point Business Park, New Mallow Road, Cork T23AT2P, Ireland, phone: +1-617-398-7067.