PLAY MAGNUS AS PRIVACY POLICY

Applicable from May 25, 2018.

Play Magnus AS (Tordenskioldsgate 2, 0160 Oslo, Norway), including its affiliates (“Play Magnus”), collects and uses personal data concerning you in connection with and in order to provide and develop Play Magnus’ products, mobile applications, services and websites (together “Services”) according to this privacy policy (“Privacy Policy”). Play Magnus is the data controller of such collection and use of the data.

For questions and information about Privacy Policy and data subject's rights, please contact us via email at privacy@playmagnus.com. For information about our privacy practices related to data from children, please see “Special Note About Children’s Privacy” below.

All Play Magnus Services are governed by this Privacy Policy. Please do not install or use the Services if you do not agree to this Privacy Policy.

Play Magnus reserves the right to modify this Privacy Policy. The Privacy Policy as amended from time to time is available in the Play Magnus app and Magnus Trainer app (under "Privacy Policy") and on Play Magnus' website www.playmagnus.com/privacy

We encourage you to familiarize yourself with the latest updates of the Privacy Policy.

 

TABLE OF CONTENTS

1. When we collect personal data

2. Why we collect and use personal data

3. How we use personal data

4. How we share personal data

5. How your information is secured

6. What are your rights?

7. How you can contact us

 

1. WHEN WE COLLECT PERSONAL DATA

We collect personal data concerning you when you use our Services. This includes when you:

(i) Use Play Magnus’ mobile apps or visit our websites.
(ii) Register for Services, contests and special events;
(iii) Access Services using a third party ID, such as social networking sites or gaming services;
(iv) Subscribe to email communication;
(v) Purchase a product or services through Play Magnus’ online stores or within the apps (or "in-app purchase");
(vi) Use “share the app”, "email this page", or other similar features;
(vii) Request technical support.

We generally process the following categories of personal data about the users of our service:

  • Username / nickname.
    Nickname is used to differentiate users in competitive context within our service.

  • Birth year, our service does not collect the month or day, and therefore does not know the exact birthday of our users.
    Birth year is used to present users with personalized statistics within our service.

  • Gender.
    Gender is used to present users with personalized statistics within our service.

  • Country code, following the ISO 3166-1 alpha-3 convention.
    Country code is also used to present users with personalized statistics within our service.

  • Email address.
    Email address is used make sure we can contact the registered users, either in case of subscribing to our email services, or to contact winners of our in-app events and competitions.

  • Device ID. (given by an Android device or iOS when the user accepts push notifications)
    Device ID is used to make sure we can push notifications to users of our service.

  • IP-address.
    IP-address is used by third party services. Our services don’t collect it explicitly, but our third party services use IP-addresses data to collect statistics.

  • Password.

For more information about which types of personal data we collect, please see "How we use personal data" below.

 

2. WHY WE COLLECT AND USE PERSONAL DATA

Play Magnus collects and uses your personal data for the following purposes:

Providing you the requested Services: To be able to provide you with the requested Services, including to register and administer your use of the Services, we process personal data about you. The legal basis for such processing is the service contract for the Service in question.

Registration and administration related to your participation in Services, contests and special events: The personal data processed for this purpose will vary according to the contest or special event in question. The legal basis for such processing is your consent to participate in the contest or special event. These may include: the Play Live Challenge - in-app contest and physical, live events, Facebook contests, and in-app competitions sponsored by other companies.

Access management when using a third party ID: Play Magnus allows for accessing the Services by using a third party ID. In such instances, we process personal data concerning your third party ID username(s) and password(s). The legal basis for such processing is your consent to utilize a third party ID to log in to the Services.

Administration of email subscriptions: You can subscribe to receive updates from us via email. If you do so, we will send you information regarding our Services. We will only send you emails with your consent, and you can unsubscribe to such emails by clicking on the unsubscribe link in the email. We will only contact you with direct marketing from third parties with your consent.

Providing you products and services related to in-app purchases: You can make purchases in our Services. We will process personal data necessary to provide you with the purchased products and services if you make such purchases. Such personal data include payment details and billing address, and the contract for the provision of the products and/or services is our legal basis for processing such personal data.

Providing "share the app", "email this page" or other similar features: Our Services allow for features such as "share the app" and "email this page". It is voluntary to use the features, and if you do so, we will use personal data concerning you, such as your username and device ID to analyze how well the features work. The legal basis for using the personal data is our legitimate interests in improving our Services.

Feedback and technical support: We appreciate your feedback and want to resolve any issues you might have with the Services. Contacting us for giving feedback or requesting technical support is voluntary, and you can provide us with specific information regarding your feedback or issue. If you want a reply to your request, you can provide your email address. We store the information you provide based on our legitimate interest in improving our Services.

Providing you information and advertisements: We collect and use personal data to be able to provide you with relevant information and advertisements. The basis for this is our legitimate interests in earning revenue by ad serving through the Services. For more information, please see the sections on "ADVERTISING AND AD SERVING TECHNOLOGY" and "LOCATION DATA" under "How we use personal data".

General analysis of the use of the Services to improve the Services: We collect and use personal data, such as user activity, to analyze how our Services work. The legal basis for this is our legitimate interests in improving our Services. For more information, please see the sections on "TECHNOLOGIES FOR PERSONALIZATION, ADVERTISING AND ANALYTICS" and "ANALYTICS" under "How we use personal data".

When our collection and use of your personal data is based on your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of the processing prior to the withdrawal. You can contact us at privacy@playmagnus.com to withdraw your consent to some or all of our uses of personal data that require your consent.

 

3. HOW WE USE PERSONAL DATA

TECHNOLOGIES FOR PERSONALIZATION, ADVERTISING AND ANALYTICS

We will retain and evaluate information on your recent visits to and use of our Services and how you move around different sections of our Services. This is for analytics purposes, which helps us understand how people use our website, so that we can make our Services more intuitive. Data collected for these purposes will generally not contain any personal data.

The Services use various techniques to be able to remember your settings and preferences, to personalize the look and feel of the Services and for advertising and analytics. Such techniques involve use of technologies such as:

  • Pixel tags

  • Local shared objects

  • Hardware-based device identifiers

  • Operating System-based identifiers

  • Clear GIFs

  • Web beacons

A “web beacon” or a “pixel tag” is an electronic image (often not visible to the end-user) that allows Play Magnus to count users who have visited certain pages or viewed certain advertisements.

Additionally, e-mails and other electronic communications Play Magnus sends to you may contain pixel tags that enable Play Magnus to track your usage of the communication, including whether the communication was opened and/or what links were followed, if any. This information enables Play Magnus to recognize how many users have accessed particular pages and the path they took, and will not contain any personal identifiable information.

 

ADVERTISING AND AD SERVING TECHNOLOGY

Play Magnus employ third party ad serving technologies, that use certain methods to collect information as a result of ad serving through Services. Information collected will as a main rule not be personal data.

Play Magnus reserves the right to use and disclose the collected data for purposes of advertising though Services by Play Magnus or Play Magnus’ partners and contractors.

Play Magnus or third parties operating the ad serving technology collect and use information such as:

  • Demographic and geo-location information. For more information regarding use of Location Data, see the section "LOCATION DATA" below.

  • Information logged from your hardware or device to ensure that relevant advertising is presented within the Service.

  • IP address

  • Email address

  • Device ID

  • MAC address

  • Installed software

  • Application usage data

  • Hardware type

  • Operating System information

  • Browser information

  • Unique identifiers in browser cookies, Flash cookies, and HTML5 local storage

  • Internet and on-line usage information and in-game information

Please note that you may adjust the settings in your device to accept or not accept cookies. Rejection of cookies may affect functionality in the Services. For more information, please see our Cookie Policy.

The foregoing data may be used and disclosed in accordance with this Privacy Policy and the privacy policy of the company providing the ad serving technology.

 

LOCATION DATA

Some of Play Magnus Services enable you to share your location data. If you allow the sharing of location data, Play Magnus will collect and use your location data to provide you with location related Services and advertisements. For example, some add-ons or offers may be available at dedicated locations.

Your fine, GPS-based geo-location will only be accessed with your prior consent. The location data is used and stored only for the duration that is required for the provision of the location related Services.

Depending on the Service, Play Magnus uses the following location data:

  • IP-based location based on the IP address presented by the end-user

  • Fine geo-location data based on coordinates obtained from a mobile device’s GPS radio

  • Coarse, network-based geo-location data based on proximity of network towers or the location of WiFi networks

 

ANALYTICS

Play Magnus collects and uses personal data to perform its own analytics and to enable analytics provided by third parties, such as Appsflyer, Apple and Google. We use analytical information for supporting business analysis and operations, business intelligence, product development, improving products and services, personalizing content, providing advertising, and making recommendations.

Google Analytics processes data on Play Magnus' behalf and will only receive general web statistics such as:

  • Browser type

  • Time

  • Language

  • Which website the user arrived from

Play Magnus uses a script which removes the last digits of the user's IP-address before it is provided to Google Analytics. This information allows Google Analytics to determine your location without receiving any personal data. Information provided to Google Analytics is subject to Google's Privacy Policy: policies.google.com/privacy?hl=en.

 

4. HOW WE SHARE PERSONAL DATA

CONNECTING TO SOCIAL NETWORKING SITES

Certain features of the Services may be able to connect to your social networking sites to obtain additional information about you. When your social networking site permits such connection and when you consent to allow your social networking site to disclose certain data to Play Magnus, Play Magnus will collect this information from your social networking profile. Depending on your settings, such data includes, for instance, your name, profile picture, gender, user ID, email address, your country, your language, your time zone, the organizations and links on your profile page. Play Magnus associate and/or combine as well as use information collected by Play Magnus and/or obtained through such social networking sites. The data processed in this matter is done for delivering a social media-powered experience within our Services, which makes it easier to find friends, compete with them and invite friends into our Services.

 

SHARING USER-GENERATED CONTENT

You may choose to disclose data about yourself in the course of contributing user-generated content to the Services. Please be aware that any data that you disclose in any of these forums, blogs, chats or the like is public.
The purpose of disclosing such self-generated content would be to make the Service provide a personalized experience for yourself.

 

DISCLOSURE AND TRANSFER OF PERSONAL DATA TO THIRD PARTIES

Certain Services that Play Magnus offers, such as multiplayer gaming, social networking and gaming console services, use third party services to provide authentication for the Services with a gaming console ID, social networking ID, or gaming network account. In connection with such use, certain personal data regarding the user and/or membership data may beis transferred automatically to and from Play Magnus. The purpose of this processing is to provide you the Services you have required.

In addition, Play Magnus may use third parties (domestic and/or foreign) to collect and process personal data on Play Magnus’ behalf and in according to Play Magnus’ instructions. The purpose of the processing is i) to improve or develop our website and mobile application or any equipment related to specific services and ii) for the proper functioning of our Services. Play Magnus requires that companies comply with Play Magnus’ Privacy Policy before Play Magnus allows those companies to access our sites and Services.

Play Magnus also transfers your personal data to its affiliates, partners and contractors outside the European Economic Area (EEA). Such transfer will only take place if appropriate safeguards are provided, e.g., by entering into EU Standard Contractual Clauses or ensuring that the receiving party is certified under the EU-US Privacy Shield. If you have any questions relating to this, please contact us at the contact point provided below.

Please note that your access to and use of the Services may be subject to certain third party terms and conditions and Play Magnus is not liable for any such third parties’ use of your personal data, except as provided by mandatory law.

Play Magnus may disclose your personal data to third parties in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of Play Magnus’ stock and/or assets or other corporate change, including, without limitation, during the course of any due diligence process provide. Under these circumstances, this Privacy Policy shall continue to govern such personal data.

 

LIST OF THIRD PARTY PROVIDERS

Play Magnus uses several third party providers who process personal data on Play Magnus' behalf for the purposes of providing the Services. Use of third party providers includes, but may not be limited to:

  • Server: SendGrid (email)

  • Server: New Relic (server monitoring)

  • Server: Cloudinary (picture app)

  • Play Magnus: Google+ (login)

  • Server: Microsoft Windows Azure (platform)

  • Play Magnus: Chartboost (ad serving)

  • Play Magnus / Magnus Trainer: AppsFlyer (analytics)

  • Play Magnus: Xamarin Insights (analytics)

  • Play Magnus / Magnus Trainer: Google Analytics (analytics)

  • Play Magnus / Magnus Trainer: Firebase (analytics)

  • Play Magnus / Magnus Trainer: Twitter (login, sharing, analytics, advertising) sharing)

  • Play Magnus / Magnus Trainer: Facebook (login, sharing, analytics, advertising)

  • Play Magnus / Magnus Trainer: Instagram (login, sharing, analytics, advertising)

  • Play Magnus / Magnus Trainer: Google Storage (content)

  • Magnus Trainer: Fyber (ad related analytics)

  • Magnus Trainer: Branch (analytics)

  • Play Magnus / Magnus Trainer: Google Play (analytics)

  • Play Magnus / Magnus Trainer: iTunes Connect (analytics)

 

5. HOW YOUR INFORMATION IS SECURED

INFORMATION SECURITY

Play Magnus processes personal data in accordance with Norwegian data protection law and follows generally accepted industry standards to maintain appropriate technical and organizational security measures.

 

DATA RETENTION

Play Magnus retains the collected data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Thereafter Play Magnus deletes all aforementioned data in its possession within a reasonable timeframe.

Please note that some data may be further retained if necessary to resolve disputes, enforce Play Magnus user agreements and comply with technical and legal requirements and constraints related to the security, integrity and operation of Services.

 

6. WHAT ARE YOUR RIGHTS?  

We think it is important that you are able to control your personal data.

 

DATA SUBJECT'S RIGHTS

Play Magnus makes good faith efforts to enable you to review, update, delete or correct your personal data in Play Magnus’ possession.

Based on certain conditions, you have the right to request access, rectification, restriction and deletion of your personal data held by us, and to receive a copy of your personal data in a structured machine-readable format. If you have a registered profile, you may at all times request to update, correct or delete information you have provided to us. Inquiries regarding processing of personal data and access request shall be directed to the point of contact provided below.

You also have rights to object to some types of processing and, where we have asked for your consent to process your data, to withdraw your consent. Where Play Magnus process your data because Play Magnus have a legitimate interest in doing so (as explained above), you also have a right to object to this.

Our rights may be limited in some situations – for example, where Play Magnus can demonstrate that Play Magnus have a legal requirement to process your data.

Where Play Magnus require personal data to comply with legal or contractual obligations, then provision of such data is mandatory. If such data is not provided, then we will not be able to manage our contractual relationship, or to meet obligations placed on us. In other cases, provision of requested personal data is optional.

Your personal data will be retained in accordance with the provisions of the various subsections of section 2.

For questions and information about the Privacy Policy and your rights, please contact us via email at privacy@playmagnus.com. Play Magnus will need sufficient information from you to establish your identity and to verify your request to exercise your rights.

You also have a right to make a complaint to the competent data protection authorities. If you want to complain about the processing of your personal data by Play Magnus, we encourage you to contact us first.

 

SPECIAL NOTE ABOUT CHILDREN’S PRIVACY

Play Magnus does not knowingly collect personal information from children under 13 years of age. If Play Magnus learns that Play Magnus has inadvertently gathered personal data from children under 13 years of age, Play Magnus will take reasonable measures to promptly delete such personal data from Play Magnus’ records.

Play Magnus understands the need to provide extra privacy protections to users who are children.

Play Magnus requires that companies comply with Play Magnus’ Privacy Policy before Play Magnus allows those companies to access our sites and Services. However, please note that Play Magnus’ partners may have their own policies related to tracking technologies for analytics and ad-serving purposes. Play Magnus therefore encourages parents to review the list of operators below and to become familiar with those parties' policies and practices.

If you have additional questions about Play Magnus’ Privacy practices related to children under the age of 13, please contact us at privacy@playmagnus.com.

 

7. HOW YOU CAN CONTACT US

If you want to exercise rights in personal data concerning you or if you have additional questions about Play Magnus’ Privacy practices, please contact us at privacy@playmagnus.com.