Privacy Policy
About
This Privacy Policy provides information on how we collect and process personal data when you use our apps and games, and what we do to ensure all data is protected and safe.
We are My Hill Studio – a publisher and developer of mobile apps and games. In the further text, My Hill Studio will be referred to as we, us, or our, depending on the context. The Policy applies to all our apps and games, as well as to our marketing and advertising activities on all platforms, or other services that we may provide at times. All our apps, games, websites, advertising and marketing activities, and other possible services in this text will be referred to as our Services.
The Privacy Policy can be changed – we will inform you about any changes made to the Policy by providing the dates of the changes on this page. Further, you might receive an additional notice or be asked for a renewed consent if the changes made require this. We recommend you stay informed on how we keep your privacy protected by checking this Policy page whenever you use our apps and games.
The Privacy Policy provides information on the relevancy of the collection of your data. It helps you understand how the collection of your data is adequate and limited only to the data necessary for the apps and games to function properly. Every user can decide if they want to give or not give consent to the processing of data relating to them.
If you have any further concerns and questions, feel free to contact us via the email address provided at the end of this document.
Security
The user needs to protect against unauthorized access to their password and their computer. We take commercially reasonable precautions to protect the personal information of our users and ensure the security of our systems.
Information Storage
We will store your personal data as long as it is necessary for providing the best experience for our apps and games or otherwise fulfill the purposes as described in this document - unless further storage is required to establish, exercise, or defend a legal claim or to comply with applicable law, including accounting rules. Any personal data is deleted or anonymized as soon as it is not relevant for the aforementioned purposes, and in any event, no later than three (3) years after the user's interaction with our app or game has ceased.
Push Notifications
We send push notifications or alerts to you that provide information about service updates, promotional communications, and other messages related to our apps and games - but only if you have allowed such notifications and alerts. You can deactivate these notifications and alerts can be deactivated at any time by accessing the settings on their devices.
The collected & processed data
The purpose of collecting information from you is to make sure our apps and games function properly. If and when personal data is collected, we always make sure it's protected.
AUTOMATICALLY COLLECTED DATA
When you access our apps and games, we collect general information automatically.
The automatically collected data is:
• Age - minor or not.
• Log Information - we collect log information about the use of our app or game, including the type of device used, and the features used;
• Device Information - we collect information about the device used to access our app or game, including the information about the device’s software and hardware, unique device identifiers (i.e. Device ID and advertising ID), device tokens for push-messages, mobile network information, and time zone;
• Usage Information - we collect information relating to the use of our app or game, including the user's game progress, scores, achievements, and interactions with other players;
• Consumption Information - we collect information about the user's consumption habits relating to his/her use of our apps and games, including which purchases they make with both virtual and real currencies and the reception of virtual goods in-game.
DATA COLLECTED ON REQUEST
Some apps and games require certain personal data to function properly. On these occasions, we might ask you for the following:
• Nickname – used in the app or game;
• E-mail address – your e-mail address.
DATA COLLECTED FROM OTHER SOURCES
If you log in to our app or game from a third-party website/platform including, but not limited to Facebook, Apple Game Center, and Google Sign-In, we access information about you from that website/platform such as screen name, profile information, friends lists - everything following the authorization procedures determined by the third-party in question, provided that you have given the consent to that third-party website/platform.
On these occasions, you warrant that:
- your access and use of such features in connection with app or game will comply with the applicable terms and policies of such site or platform;
- that you are over the minimum age limit that is prescribed for such third-party websites/platforms by the legislation in the individual jurisdictions.
WHY IS ALL THIS DATA COLLECTED AND PROCESSED?
We collect and process the data following the legal bases for each type of data in question. The following passages of this document will provide more info on the legal bases for each data type collection.
AGE is processed to identify whether the app user is a child or adult for data protection purposes and to determine the legal requirements for our processing of the user's data. To learn more about this purpose which is necessary for compliance purposes, see Article 6(1)(c) of the GDPR.
Log-, device-, usage-, and consumption information are processed to:
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provide and deliver the requested products/services, and send any related information to the user as requested by the user, and as agreed with the user;
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provide and maintain app or game experience;
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personalize and improve app or game, and provide tailored content and features to every user;
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monitor and analyze trends, usage, and activities in connection with the app or game;5
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provide children (as this term is construed under GDPR in EU, COPPA in the US and the relevant applicable legislation in other jurisdictions) with reasonable contextual advertisements in the app or game;
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provide non-child users that have given us consent to share their advertising IDs with our ad network partners (as further specified under Sharing of Information) to serve them with the personalized advertisement in the app or game (behavioral advertising).
We justify the processing of data for the above purposes with a legitimate interest in providing advertisements and content relevant to our users, as well as improving our Services in accordance with Article 6(1)(f) of the GDPR. The disclosure of our users' advertising ID to third parties for behavioral advertising is based on your consent in accordance with Article 6(1)(a) of the GDPR (see more below under Sharing of Information).
Nickname is processed to identify you among other users on leaderboards, ratings, and scores.
The processing for this purpose is necessary for the performance of a contract to which the user is a party to facilitate the delivery of requested products and services, see Section 6(1)(b) of the GDPR.
E-mail address is processed to identify the user's account for the purpose of synchronization of their data between different devices. The processing for this purpose is necessary for the performance of a contract to which the user is a party facilitate the delivery of requested products and services, see Section 6(1)(b) of the GDPR.
Information from other sources is processed to provide and deliver the products and services the user requests and send them related information. The processing for the above purpose is necessary for the performance of a contract the user is a party facilitate the delivery of requested products and services, see Section 6(1)(b) of the GDPR.
Information from other sources is processed to link or combine information we get from others to help understand the user's needs and provide them with a better service.
The processing for this purpose is justified by our legitimate interests in providing content of interest to our users and improving our services in accordance with Article 6(1)(f) of the GDPR.
The user's rights concerning their personal data
Any user of our app or game has certain rights concerning their personal data according to EU General Data Protection Regulation (GDPR). If a user wishes to use any of the rights described below, they may contact us at any time via the e-mail address found below.
The right to request access
The user of our apps and games has the right to request access to the data that we are processing on them, see Article 15 of the GDPR, including information about:
• the purposes of the processing
• the categories of personal data concerned
• the recipients or categories of recipient to whom the personal data have been or will be disclosed
• the envisaged period for which the personal data will be stored
Furthermore, the user has the right to obtain a copy of the personal data undergoing processing. Please note that the access may be restricted due to intellectual property or trade secrets.
Right to rectification and erasure
The user has the right to have inaccurate personal data rectified, see Article 16 of the GDPR.
Furthermore, the user has the right to have their personal data erased where one of the following grounds applies, see Article 17 of the GDPR:
• the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed,
• if the user has withdrawn their consent and there are no other legal grounds for the processing,
• if the user has objected to the processing and there are no overriding legitimate grounds for the processing,
• the personal data have to be erased for compliance with a legal obligation in Union or Member State law,
• the personal data have been unlawfully processed or
• the personal data have been collected in relation to the offer of information society services.
NB: Your right to erasure may be limited if the data are necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims.
The right to restriction of processing
The user has the right to obtain restriction of processing in certain circumstances, see Article 18 of the GDPR. If they have the right to restriction, we will only process their data with their consent or for the establishment, exercise or defense of a legal claim or to protect a person or important grounds of public interest
The right to withdraw consent
If we have asked for the user's consent to our processing of their data, they have the right to withdraw their consent at any time, see Article 7 of the GDPR.
If the user withdraws consent, we will cease processing of the data for which they have withdrawn consent, unless we have a legal obligation to keep some or parts of the data
NB: If the user withdraws consent, their user license to use our app or game will cease automatically.
The withdrawal of consent does not affect the lawfulness of processing based on your consent before its withdrawal.
The right to data portability
The user has the right to receive the personal data they have provided us with which we process in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller if the processing is based on consent or contract performance, see Article 20 of the GDPR.
The right to object
The user has the right to object to our processing of their personal data on grounds relating to their particular situation when the data are processed based on the balancing-of-interest rule in Section 6(1)(f) of the GDPR, see Article 21 of the GDPR. In this case, we will cease the processing unless there are compelling legitimate grounds for the processing which override the user's interests, rights and freedoms or if the processing is necessary for the establishment, exercise or defense of legal claims.
The user has the right to object to our processing of their personal data for direct marketing purposes at any time. We will cease the processing of their personal data for this purpose after the objection. If the user exercises this right, their user license to use the app or game will cease automatically.
The user has the right to make a complaint about the processing of their personal data by complaining to the relevant supervisory authority.
Information Sharing
We disclose information about our user to the following categories of recipients based on the legal bases in Sections 6(1)(b), 6(1)(c) and 6(1)(f) of the GDPR :
Social networks (further info under Social Sharing Features);
Third parties if we are required to disclose personal data by applicable law, rule, regulation, legal process or in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
The authorities if we believe the user's actions are inconsistent with the spirit or language of our policies or if the disclosure is necessary to protect the rights, property, and safety of the company or others;
Other players provide certain in-app features, such as leaderboards, if the user logs into the App using a third-party service, such as Facebook or Apple Game Center;
Advertising network companies serve contextual advertisements (the data include the user's IP address, Device ID, and advertising ID).
Furthermore, if the user has given their consent in accordance with Section 6(1)(a) of the GDPR, we share their advertising ID to advertising network companies for the purpose of them serving behavioral advertisements to the user within the App. We use or may use the following advertising network companies:
• Ad Mob - https://policies.google.com/privacy?hl=en
• Unity Ads - https://unity3d.com/legal/privacy-policy
• Facebook Ads - https://www.facebook.com/about/privacy/
• Adcolony - https://www.adcolony.com/privacy-policy/
• Chartboost - https://answers.chartboost.com/hc/en-us/articles/200780269
• AppLovin - https://www.applovin.com/privacy/
• IronSource - https://www.ironsrc.com/privacy-policy/
The recipients' use of the disclosed information will not be covered by this Privacy Policy. For questions regarding the processing carried out by such third parties, please consult their respective privacy policies.
In connection with our processing, we use data processors such as server hosting providers, technical service providers for supporting internal operations, user login services and analytics service providers.
Social Sharing Features
Our apps and games offer social sharing features and other integrated tools, which let users share actions they take in our app or game with other media. The user must be over the minimum age limit that is prescribed by the legislation in the individual jurisdictions to use any social sharing features integrated into the app or game. The use of such features enables the sharing of information with friends or the public, depending on the settings the user establishes with the entity that provides the social sharing feature.
Games and apps have social features from the following providers:
For more information about the processing carried out by the respective third parties in connection with social sharing features, please visit the privacy policies of the entities that provide these features, which can be found here:
• Facebook: https://www.facebook.com/about/privacy/
• Google: https://www.google.com/about/company/user-consent-policy.html
Children
Our apps and games are for a general audience. comply with the legislation, all users will be presented to an age screen, when launching our app or game. When presented with this age screen, the user must state the correct age.
Based on the user's age information and their device settings, we do not process the personal data of children under the minimum age limit that is prescribed by the legislation in the individual jurisdictions for behavioral advertisement. If such personal data have been processed without our knowledge, we will, after having become aware of the incident, immediately take reasonable measures to stop such processing and promptly delete any such data from our records.
For any additional questions about our privacy practices related to children under the applicable minimum age, please contact us via the e-mail address found below.
Data Controller
We are responsible for deciding how and why we collect and use the personal data of our users. The users can contact us at any time through the contact information provided below.
CONTACT INFORMATION
EMAIL: