MiniClick Studio GAMES PRIVACY POLICYThis is the Privacy & Cookies Policy (the ‘Policy’) of MiniClick Studio Games/MiniClick Studio Ltd. This Policy describes the ways in which MiniClick Studio collects and uses information about you when you visit MiniClick Studio games website at www.MiniClick Studiogames.com (the ‘Website’) or when you play one of MiniClick Studio games (each a ‘Game’ and together with the ‘Games’) on a browser, through a social networking site or as an app. It also details how MiniClick Studio collects and uses information about you when making a complaint to MiniClick Studio by e-mail, as well as if you choose to make a job application.
MiniClick Studio may change this Policy at any time and when this happens we will notify you of any changes to this Policy by noting this on our Website as well as within the Games. The changes will apply to your use of the Website and/or our Games after we have notified you. If you do not wish to accept the new Policy you should stop using the Website and/or playing our Games (as applicable). If you continue to use the Website and/or play our Games after the changes, your continued use of the Website and/or your continued playing of any of our Games show us your agreement to be bound by the new Policy.
1 WHAT PERSONAL DATA IS AND WHO THIS POLICY APPLIES TO
Personal Data means information that identifies, relates to, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or household, including identifiers such as a real name, alias, a device identification number, location data, an online identifier, commercial information (including products or services purchased), or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person, or as further defined under the General Data Protection Regulation (“GDPR”) (as applicable). We indicate in this Policy the information we collect from you.
By playing the Games or visiting the Website you are agreeing to be bound by this Policy in respect of the information collected about you. MiniClick Studio may change this Policy at any time. MiniClick Studio shall deem your continued use of the Games or access to the Website as indicating your consent to such changes. This Policy applies to the following people:
visitors to the Website (including those submitting a job application);
people who use the Games; and
people who make complaints to us by email.
2 VISITORS TO THE WEBSITE
The Website collects information from you in the following ways:
MiniClick Studio uses cookies for the limited purposes set out in TABLE ONE below to collect certain analytical/technical information. MiniClick Studio relies on consent to collect this information, such consent obtained via you clicking to agree to such cookies being placed when you first visit the Website or otherwise changing the cookie settings so that such cookies are not placed.
Should you choose to contact MiniClick Studio games via the Website, MiniClick Studio games will collect your e-mail address together with any other information that you submit in connection with such contact request. MiniClick Studio relies on consent to collect this information because you choose whether to contact MiniClick Studio or not and can choose how much personal information to provide to MiniClick Studio in doing so.
MiniClick Studio often advertises jobs on the Website. If you choose to respond to any such advertisement, or speculatively submit your CV and details for consideration through the recruitment inquiries section on the Website, any information provided by you to MiniClick Studio in connection with such response will be used to assess you as a candidate and undertake a criminal record and/or checks with references. Personal information about an unsuccessful candidate shall generally be held for twelve (12) months after the recruitment exercise has been completed after which it shall be destroyed or deleted without further notice unless MiniClick Studio reasonably considers that such candidate may be a good candidate for a future role in which case MiniClick Studio shall hold such personal information for so long as is reasonable in relation to such information. MiniClick Studio may retain anonymized statistical information about applicants to help inform MiniClick Studio’s recruitment activities in the future. MiniClick Studio relies on either: (i) compliance with a legal obligation; or (ii) the legitimate interests processing grounds in order to collect the information set out in this paragraph. Where legitimate interests are relied upon, it is in MiniClick Studio’s legitimate interests to collect such items of personal data because this is necessary in order to carry out certain specific employment-related duties relating to your application for employment with MiniClick Studio. The items of personal data collected are not of nature whereby your rights and freedoms as a data subject are outweighed by such data collection.
3 PEOPLE WHO CONTACT OR MAKE COMPLAINTS TO MiniClick Studio BY EMAIL
When MiniClick Studio receives complaints by email it shall file any relevant document and may retain details of the complainant, and other individuals identified in the complaint. MiniClick Studio will only use this information to process the complaint and to check on MiniClick Studio’s services and staff.
MiniClick Studio shall retain information in relation to a complaint for a maximum of six (6) years after its closure, in a secure environment, and access to it will be restricted on a ‘need to know basis. MiniClick Studio relies on the legitimate interests processing ground to collect the information set out in this paragraph.
It is in MiniClick Studio’s legitimate interests to collect such items of personal data listed here because this is necessary in order to analyze and respond to your complaint.
The items of personal data collected are not of nature whereby your rights and freedoms as a data subject are outweighed by such data collection.
4 PEOPLE WHO USE THE GAMES
Game Data:
MiniClick Studio will collect the following information from you when you use the Games:
MiniClick Studio may use certain information relating to your Game progress and/or Game spend and/or other Game activity to invite you to complete surveys in relation to its Games, including, for example, to join its “Player Council” and complete any other documents required for you to join (“Survey Data”).
What if Hutch cannot collect this information:
You can use your browser settings and privacy settings on your social networks to prevent us from collecting certain of the above information about you. If you still have concerns about the information we collect please contact us at any time by sending an e-mail to
HOW HUTCH USES COLLECTED INFORMATION FROM PEOPLE WHO PLAY THE GAMES
MiniClick Studio will use the information it collects:
in relation to the Game Data, offer the Games to the player in question;
in relation to the Analytics Data, to facilitate the improvement of the Games and your experience of the Games;
in relation to the Game, Data to provide technical support in relation to player enquires, resolving to troubleshoot;
in relation to the Game Data to prevent fraud or illegal activities;
in relation to providing newsletters/marketing information to you;
in relation to the Marketing Data, to provide information about the Games, applications, services and other digital goods which MiniClick Studio thinks may be of interest to you. You can tell us to stop this at any time by sending.
in relation to the Survey Data for MiniClick Studio to provide such survey to you; and
Share with third parties for the purposes as described in the paragraph below.
SHARING INFORMATION WITH THIRD PARTIES
MiniClick Studio will not pass your information to third parties other than as described in this paragraph. MiniClick Studio may, subject to its obligations to comply with applicable data protection legislation, share your information with third parties including:
it’s service providers which host and store the Game Data, such as Apple, Google, MiniClick Studiocloud.
the third parties who assist MiniClick Studio in collecting the Analytics Data (as listed below);
where MiniClick Studio carries out any e-mail marketing campaigns, your name and e-mail address will be transferred to send grid which carries out such campaigns on MiniClick Studio behalf.
as part of the Games, your information (for example your name, profile picture or user ID) may be posted on a Leaderboard of top scorers within the Game to be shared with other players and your social networks. You may also share elements of your performance or participation in the Games (e.g. your personal car design) with other players and your social networks;
with its group companies in order to assist and facilitate the services provided to you;
with law enforcement agencies in compliance with law enforcement.
THIRD-PARTY COOKIES
Third-Party Advertisers may place or read cookies and/or Technologies on your browser or device in the Games and/or on the Website.
This Policy is applicable only to the use of cookies or Technologies by MiniClick Studio and does not cover the use of cookies or Technologies by any third parties (including advertisers or Facebook). For example, Facebook will place cookies to maintain a secure login to the Facebook network, amongst other things.
More details of Facebook’s cookies are available on its website and further links to third-party cookies and Technologies are also set out in the tables below.
LINKS TO THIRD-PARTY WEBSITES AND THIRD-PARTY ADVERTS
MiniClick Studio cannot be responsible for the privacy policies and practices of other sites even if you access them using links from the Games/Website, adverts in the Games/Website, or from adverts on a webpage when you are playing the Game/are on the Website.
MiniClick Studio recommends that you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.
In addition, if you link to the Games from a third party site or via a social network (e.g. Twitter, Facebook), MiniClick Studio cannot be responsible for the privacy policies and practices of the owners or operators of that third party site and recommends that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.
SECURITY, STORAGE, AND DATA RETENTION
MiniClick Studio has implemented technology and policies to safeguard your privacy from unauthorized access and improper use.
Where you log in via a social network, you may also change your account settings on your social network to prevent both us and third parties from seeing certain information in relation to you, such as your Facebook profile.
MiniClick Studio’s physical servers are operated by MiniClick Studio cloud servers and are located worldwide including in the EEA, USA, and Asia. Where such information is transferred outside the EEA, MiniClick Studio has taken steps to ensure that its agreements with such third-party providers contain provisions ensuring the adequacy of such transfer.
MiniClick Studio has a retention policy in place with respect to the data it holds, ensuring that it does not retain such data for longer than is reasonable in line with the purposes for which it was originally collected.
8 MiniClick Studio’S POLICY TOWARDS CHILDREN
MiniClick Studio’s Games are intended for anyone who is legally entitled to own a device that accesses them and plays them.
However, MiniClick Studio does not knowingly collect personally identifiable information in relation to children under the age of 13. If MiniClick Studio discovers it has collected personal data in relation to any children under 13 Hutch shall take reasonable steps to delete such information.
You may also be required to obtain your parents’/guardians’ permission to play the Games if you are under 18, as indicated in our Terms of Service.
9.CONTACT DETAILS
If at any time you would like to contact MiniClick Studio about your views on this Policy or any inquiry relating to your personal information, including but not limited to your rights under the GDPR you can do so by sending an e-mail to us at. You also have the right to make a complaint to the ICO by contacting them at any time.
COOKIES AND OTHER SIMILAR TECHNOLOGIES
What are Cookies?
Cookies are small text files that are placed on your device when you visit a Website. Other similar technologies, defined in this policy as “Technologies”, are third-party technologies used in a Game.
MiniClick Studio’s use of cookies and Technologies is detailed below.
Session cookies enable you to move from page to page within websites, and any information you enter will be remembered but is deleted when you close your browser after a short time.
Persistent cookies allow us to remember your preferences and settings when you browse the Website in the future, in different browser sessions.
We may use your social login (if you access a Game via a social media platform) and/or Hutch User ID for saving protection so that you can restore your progress in a Game.
In our Games, we use Technologies that track or store your data for advertising, attribution, or analytics purposes.
Disabling Cookies:
The use of the cookies and Technologies described above improves the functionality of the Games and the Website and your experience using them.
If you do not want these cookies and/or Technologies to be served on your device, you are able to disable them by changing the settings on your browser, or on your device.
Please note that if you do decide to disable cookies and/or Technologies you may not be able to access some of the Games or the Website, some of the features of the Games or the Website, or the Games or Website may not function properly.
By continuing to use the Games, and/or the Website, including using social networking media functionality, you consent to the relevant cookies and/or Technologies being set on your device.
More information:
To find out more about how cookies work, how to manage and delete them, Information about the Technologies can be found in Table Two below.
Cookies used on the website:
Cookie Type
Purpose
Further Information
Google Analytics
MiniClick Studio uses Google Analytics cookies to collect information about how visitors use our Website, which Hutch uses to help improve it. These cookies collect information in an anonymous form, including the number of visitors to the Website, where visitors have come to the Website from, and the pages they visited.
Google Privacy Overview to opt-out of being tracked by Google Analytics visit https://tools.google.com/dlpage/gaoptout
MiniClick Studio may change this Policy at any time and when this happens we will notify you of any changes to this Policy by noting this on our Website as well as within the Games. The changes will apply to your use of the Website and/or our Games after we have notified you. If you do not wish to accept the new Policy you should stop using the Website and/or playing our Games (as applicable). If you continue to use the Website and/or play our Games after the changes, your continued use of the Website and/or your continued playing of any of our Games show us your agreement to be bound by the new Policy.
1 WHAT PERSONAL DATA IS AND WHO THIS POLICY APPLIES TO
Personal Data means information that identifies, relates to, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or household, including identifiers such as a real name, alias, a device identification number, location data, an online identifier, commercial information (including products or services purchased), or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person, or as further defined under the General Data Protection Regulation (“GDPR”) (as applicable). We indicate in this Policy the information we collect from you.
By playing the Games or visiting the Website you are agreeing to be bound by this Policy in respect of the information collected about you. MiniClick Studio may change this Policy at any time. MiniClick Studio shall deem your continued use of the Games or access to the Website as indicating your consent to such changes. This Policy applies to the following people:
visitors to the Website (including those submitting a job application);
people who use the Games; and
people who make complaints to us by email.
2 VISITORS TO THE WEBSITE
The Website collects information from you in the following ways:
MiniClick Studio uses cookies for the limited purposes set out in TABLE ONE below to collect certain analytical/technical information. MiniClick Studio relies on consent to collect this information, such consent obtained via you clicking to agree to such cookies being placed when you first visit the Website or otherwise changing the cookie settings so that such cookies are not placed.
Should you choose to contact MiniClick Studio games via the Website, MiniClick Studio games will collect your e-mail address together with any other information that you submit in connection with such contact request. MiniClick Studio relies on consent to collect this information because you choose whether to contact MiniClick Studio or not and can choose how much personal information to provide to MiniClick Studio in doing so.
MiniClick Studio often advertises jobs on the Website. If you choose to respond to any such advertisement, or speculatively submit your CV and details for consideration through the recruitment inquiries section on the Website, any information provided by you to MiniClick Studio in connection with such response will be used to assess you as a candidate and undertake a criminal record and/or checks with references. Personal information about an unsuccessful candidate shall generally be held for twelve (12) months after the recruitment exercise has been completed after which it shall be destroyed or deleted without further notice unless MiniClick Studio reasonably considers that such candidate may be a good candidate for a future role in which case MiniClick Studio shall hold such personal information for so long as is reasonable in relation to such information. MiniClick Studio may retain anonymized statistical information about applicants to help inform MiniClick Studio’s recruitment activities in the future. MiniClick Studio relies on either: (i) compliance with a legal obligation; or (ii) the legitimate interests processing grounds in order to collect the information set out in this paragraph. Where legitimate interests are relied upon, it is in MiniClick Studio’s legitimate interests to collect such items of personal data because this is necessary in order to carry out certain specific employment-related duties relating to your application for employment with MiniClick Studio. The items of personal data collected are not of nature whereby your rights and freedoms as a data subject are outweighed by such data collection.
3 PEOPLE WHO CONTACT OR MAKE COMPLAINTS TO MiniClick Studio BY EMAIL
When MiniClick Studio receives complaints by email it shall file any relevant document and may retain details of the complainant, and other individuals identified in the complaint. MiniClick Studio will only use this information to process the complaint and to check on MiniClick Studio’s services and staff.
MiniClick Studio shall retain information in relation to a complaint for a maximum of six (6) years after its closure, in a secure environment, and access to it will be restricted on a ‘need to know basis. MiniClick Studio relies on the legitimate interests processing ground to collect the information set out in this paragraph.
It is in MiniClick Studio’s legitimate interests to collect such items of personal data listed here because this is necessary in order to analyze and respond to your complaint.
The items of personal data collected are not of nature whereby your rights and freedoms as a data subject are outweighed by such data collection.
4 PEOPLE WHO USE THE GAMES
Game Data:
MiniClick Studio will collect the following information from you when you use the Games:
MiniClick Studio may use certain information relating to your Game progress and/or Game spend and/or other Game activity to invite you to complete surveys in relation to its Games, including, for example, to join its “Player Council” and complete any other documents required for you to join (“Survey Data”).
What if Hutch cannot collect this information:
You can use your browser settings and privacy settings on your social networks to prevent us from collecting certain of the above information about you. If you still have concerns about the information we collect please contact us at any time by sending an e-mail to
HOW HUTCH USES COLLECTED INFORMATION FROM PEOPLE WHO PLAY THE GAMES
MiniClick Studio will use the information it collects:
in relation to the Game Data, offer the Games to the player in question;
in relation to the Analytics Data, to facilitate the improvement of the Games and your experience of the Games;
in relation to the Game, Data to provide technical support in relation to player enquires, resolving to troubleshoot;
in relation to the Game Data to prevent fraud or illegal activities;
in relation to providing newsletters/marketing information to you;
in relation to the Marketing Data, to provide information about the Games, applications, services and other digital goods which MiniClick Studio thinks may be of interest to you. You can tell us to stop this at any time by sending.
in relation to the Survey Data for MiniClick Studio to provide such survey to you; and
Share with third parties for the purposes as described in the paragraph below.
SHARING INFORMATION WITH THIRD PARTIES
MiniClick Studio will not pass your information to third parties other than as described in this paragraph. MiniClick Studio may, subject to its obligations to comply with applicable data protection legislation, share your information with third parties including:
it’s service providers which host and store the Game Data, such as Apple, Google, MiniClick Studiocloud.
the third parties who assist MiniClick Studio in collecting the Analytics Data (as listed below);
where MiniClick Studio carries out any e-mail marketing campaigns, your name and e-mail address will be transferred to send grid which carries out such campaigns on MiniClick Studio behalf.
as part of the Games, your information (for example your name, profile picture or user ID) may be posted on a Leaderboard of top scorers within the Game to be shared with other players and your social networks. You may also share elements of your performance or participation in the Games (e.g. your personal car design) with other players and your social networks;
with its group companies in order to assist and facilitate the services provided to you;
with law enforcement agencies in compliance with law enforcement.
THIRD-PARTY COOKIES
Third-Party Advertisers may place or read cookies and/or Technologies on your browser or device in the Games and/or on the Website.
This Policy is applicable only to the use of cookies or Technologies by MiniClick Studio and does not cover the use of cookies or Technologies by any third parties (including advertisers or Facebook). For example, Facebook will place cookies to maintain a secure login to the Facebook network, amongst other things.
More details of Facebook’s cookies are available on its website and further links to third-party cookies and Technologies are also set out in the tables below.
LINKS TO THIRD-PARTY WEBSITES AND THIRD-PARTY ADVERTS
MiniClick Studio cannot be responsible for the privacy policies and practices of other sites even if you access them using links from the Games/Website, adverts in the Games/Website, or from adverts on a webpage when you are playing the Game/are on the Website.
MiniClick Studio recommends that you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.
In addition, if you link to the Games from a third party site or via a social network (e.g. Twitter, Facebook), MiniClick Studio cannot be responsible for the privacy policies and practices of the owners or operators of that third party site and recommends that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.
SECURITY, STORAGE, AND DATA RETENTION
MiniClick Studio has implemented technology and policies to safeguard your privacy from unauthorized access and improper use.
Where you log in via a social network, you may also change your account settings on your social network to prevent both us and third parties from seeing certain information in relation to you, such as your Facebook profile.
MiniClick Studio’s physical servers are operated by MiniClick Studio cloud servers and are located worldwide including in the EEA, USA, and Asia. Where such information is transferred outside the EEA, MiniClick Studio has taken steps to ensure that its agreements with such third-party providers contain provisions ensuring the adequacy of such transfer.
MiniClick Studio has a retention policy in place with respect to the data it holds, ensuring that it does not retain such data for longer than is reasonable in line with the purposes for which it was originally collected.
8 MiniClick Studio’S POLICY TOWARDS CHILDREN
MiniClick Studio’s Games are intended for anyone who is legally entitled to own a device that accesses them and plays them.
However, MiniClick Studio does not knowingly collect personally identifiable information in relation to children under the age of 13. If MiniClick Studio discovers it has collected personal data in relation to any children under 13 Hutch shall take reasonable steps to delete such information.
You may also be required to obtain your parents’/guardians’ permission to play the Games if you are under 18, as indicated in our Terms of Service.
9.CONTACT DETAILS
If at any time you would like to contact MiniClick Studio about your views on this Policy or any inquiry relating to your personal information, including but not limited to your rights under the GDPR you can do so by sending an e-mail to us at. You also have the right to make a complaint to the ICO by contacting them at any time.
COOKIES AND OTHER SIMILAR TECHNOLOGIES
What are Cookies?
Cookies are small text files that are placed on your device when you visit a Website. Other similar technologies, defined in this policy as “Technologies”, are third-party technologies used in a Game.
MiniClick Studio’s use of cookies and Technologies is detailed below.
Session cookies enable you to move from page to page within websites, and any information you enter will be remembered but is deleted when you close your browser after a short time.
Persistent cookies allow us to remember your preferences and settings when you browse the Website in the future, in different browser sessions.
We may use your social login (if you access a Game via a social media platform) and/or Hutch User ID for saving protection so that you can restore your progress in a Game.
In our Games, we use Technologies that track or store your data for advertising, attribution, or analytics purposes.
Disabling Cookies:
The use of the cookies and Technologies described above improves the functionality of the Games and the Website and your experience using them.
If you do not want these cookies and/or Technologies to be served on your device, you are able to disable them by changing the settings on your browser, or on your device.
Please note that if you do decide to disable cookies and/or Technologies you may not be able to access some of the Games or the Website, some of the features of the Games or the Website, or the Games or Website may not function properly.
By continuing to use the Games, and/or the Website, including using social networking media functionality, you consent to the relevant cookies and/or Technologies being set on your device.
More information:
To find out more about how cookies work, how to manage and delete them, Information about the Technologies can be found in Table Two below.
Cookies used on the website:
Cookie Type
Purpose
Further Information
Google Analytics
MiniClick Studio uses Google Analytics cookies to collect information about how visitors use our Website, which Hutch uses to help improve it. These cookies collect information in an anonymous form, including the number of visitors to the Website, where visitors have come to the Website from, and the pages they visited.
Google Privacy Overview to opt-out of being tracked by Google Analytics visit https://tools.google.com/dlpage/gaoptout