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Privacy Policy for Developers

PRIVACY NOTICE – DEVELOPERS

This privacy policy was last modified on 27 September 2024

Introduction

This privacy policy (“Policy”) informs you of your choices and our practices in relation to your Information (as defined below). In this Policy, (“Miniclip”), “we” or “us” refers to Miniclip SA, a company registered in Switzerland with its office located at Rue des Beaux-Arts 8, 2000 Neuchatel, Switzerland. We choose why we need to use your Information and how it is used, which means we are considered the data controller in certain countries.

For the purpose of this Policy, “Information” means any information relating to an identified or identifiable individual. If you do not agree with this Policy, you must not contact us.

1. PERSONAL INFORMATION WE COLLECT

We will process and use the following Information about you:

Information you provide to us: name, surname, email address, studio, location, language and other information that you may want to share with us as a result of our business relationship.

Information we collect: IP Address and country.

2. HOW WE USE YOUR PERSONAL INFORMATION

We use your Information to:

  • Conduct business: engage with you to discuss business opportunities.

  • Prevent fraud, defend Miniclip against legal claims or disputes, enforce our terms and to comply with our legal obligations. It is in our legitimate interests to protect our staff against online abuse and other anti-social or illegal activity. Furthermore, it is also in our legitimate interest to protect our interests by (1) detecting fraud or any other behaviour which prejudices the integrity of our business, (2) taking steps to remedy fraud and concerning behaviour, (3) defending ourselves against legal claims or disputes, and (4) enforcing our contracts, terms and policies. When doing so, we will process the Information relevant in such a case, including Information you provide us and Information which is provided to us by third parties.

3. WHO WE SHARE YOUR PERSONAL INFORMATION WITH

We share your Information with selected third parties, including:

  • Vendors and service providers we rely on, for example:

    • Cloud service providers that we rely on for data storage;

    • Customer support solution providers, who help us manage and respond to our customer questions and complaints;

    • Vendors that help us manage deal flow.

  • Companies who belong to the same group as Miniclip. We share your Information with different entities which are part of our group of companies.

  • Other companies that we may do or explore business with.

  • Law enforcement agencies, public authorities or other judicial bodies and organisations. 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 organisations for the purposes of fraud protection).

Change of corporate ownership. If we are involved in a merger, acquisition, bankruptcy, reorganisation, partnership, asset sale or other transaction, we may disclose your Information as part of that transaction.

SECURITY

Although we have in place security measures to maintain the privacy and integrity of your Information, unfortunately, the transmission of Information via the internet is not completely secure. We may also take extra steps to protect your Information and minimise the Information we process.

4. WHERE WE PROCESS YOUR PERSONAL INFORMATION

We process your Information in several countries, including countries within the European Economic Area (“EEA”), the United Kingdom (“UK”), the United States of America and others.

When we transfer your Information outside the UK or the EEA, we may transfer it to countries that have been recognised as offering an adequate protection by the EEA or the UK. When this adequacy status has not been offered, we use standard contracts that can be used in the EEA or the UK to safeguard your Information while transferring it outside the EEA or the UK.

5. HOW LONG WE STORE YOUR INFORMATION

Your Information is kept for as long as needed for the relevant purpose.

When deleting Information, we will take measures to make the Information irrecoverable or irreproducible, and electronic files which contain Information will be deleted permanently.

6. YOUR RIGHTS

If you are based in the EEA, the United Kingdom, Switzerland or other territories, you may have certain rights.

To exercise your rights, please open a ticket here or send an email to dataprotection@miniclip.com.

  • Access. You have the right to access Information, and to receive an explanation of how we use it and who we share it with. This right is not absolute. For example, we cannot reveal trade secrets, or give you Information about other individuals.

  • Erasure. You have the right to request deletion of your Information. We may need to retain some of your Information where there are valid grounds for us to do so under data protection laws. For example, for the defence of legal claims, respect freedom of expression, or where we have an overriding legitimate interest to do so, but we will let you know when this is the case. Note that where the Information is held by a third-party data controller, such as an advertising partner or a payment processor, we will use reasonable steps to inform them of your request, but we recommend you contact them directly in accordance with their own privacy policies to ensure your personal data is erased.

  • Objection and withdrawal of consent: You have the right to (i) withdraw your consent where you previously provided such consent; or (ii) object to our processing of your Information where we process such Information on the basis of our legitimate interests (see above under How we use your personal information). You may exercise this right as follows:

To stop receiving marketing emails: please follow the unsubscribe mechanism at the bottom of each email communication.

To stop our cookies being placed: please refer to our Cookie Policy.

To stop receiving push notifications: please change your device or browser settings.

  • Portability. You have the right to receive a copy of Information we process on the basis of consent or contract in a structured, commonly used and machine-readable format, or to request that such Information is transferred to a third party.

  • Correction. You have the right to correct any Information held about you that is inaccurate.

  • Restriction. You have a right in certain circumstances to stop us processing Information other than for storage purposes.

7. CONTACT & COMPLAINTS

We welcome questions, comments, and requests regarding this Policy. These should be addressed to dataprotection@miniclip.com. You can also send a letter to Data Protection at Miniclip SA, Rue des Beaux-Arts 8, 2000 Neuchatel, Switzerland. Alternatively, if you are based in the EEA or the United Kingdom, you can send a letter to Miniclip (UK) Limited at Legal Department at Miniclip, 2nd Floor, Bureau, 90 Fetter Ln, London EC4A 1EN, United Kingdom.

If you wish to make a complaint about how we process your Information, please contact us at dataprotection@miniclip.com and we will endeavour to deal with your complaint as soon as possible. This is without prejudice to your right to start a complaint with a data protection authority.

8. CHANGES

Any updates or changes to this Policy will be published here.