Privacy Policy – Miralet

Effective Date: November 20, 2020

By installing and launching Miralet Inc. mobile applications or games, you agree and consent to all terms and conditions specified in this Privacy Policy.

This Miralet Privacy Policy (“Privacy Policy”) describes how we may collect, use, and share information about you when you access or use Miralet games, mobile apps, websites, content, products, and any related services (collectively the “Services”), and your choices regarding that information. For purposes of this Privacy Policy, “Miralet” (or “we”, “our”, or “us”) refers to Miralet Inc. and its parents, subsidiaries, agents, representatives, affiliates, officers, and directors.

Information We Collect and How We Collect It

We’ll collect and store any information that you provide to us, including when you create your account or a player profile.

When you use our Services, you may give us information directly (for example if you setup an account), and we’ll store that information on our systems and use it for the purposes described in this Privacy Policy.

Some games or parts of our Services may use a traditional registration or account setup process where you may be asked to give us information such as:

your first and last name;
your username;
your gender;
your age or birthday;
your e-mail address;
a password; and/or
other information that helps us to provide or improve our services.
We may also let you create a player profile that other Miralet players can see. Your player profile may include information like:
your profile photo;
your first and last name;
your game username (“Gamer Tag”);
your gender;
your biographic details (like your age or age range);
the approximate physical location information that you provide;
links to your profiles on various social networks; and/or
details about the games you play.

Information Collected or Generated When You Use our Services

When you use our Services, we’ll collect information about the ways in which you use and interact with our Services, such as when and for how long you play our games, game features and other players you interact with, purchases you make, progress you achieve, and other gameplay activities.

We may access in real-time, record, and/or store archives of these interactions, and other user-generated content on Miralet’s servers to make use of them to protect the safety and well-being of our players; to protect Miralet’s rights and property in connection with our Services; to conduct research; to operate, improve, personalize, and optimize our Services and our players’ experiences, including through the use of analytics; and to manage and deliver advertising. Where required by law, we will seek your consent for this.

Customer Support Correspondence

When you ask for help from our Customer Support team, we will collect and store the contact information you give them (generally, your name and e-mail address), information about your game play or activity on our Services, and your Miralet Gamer Tag. We will also store the communications you have with our Customer Service team and any additional information in those communications in order to provide support and improve the Services.

Information Collected Using Cookies and Similar Technologies

We and our affiliates and partners may use cookies, beacons, software development kits, mobile analytics software, and/or similar technologies for a number of purposes, including to authenticate users, prevent fraud, remember preferences and settings, analyze advertising and messaging campaigns, analyze traffic and trends, personalize content (including ads), and otherwise provide the Services. These technologies may collect information about your use of our Services, pages you view, links you tap, messages you open, and other actions taken in connection with our Services.

Depending on the choices and settings available for the browser(s) you use, you may be able to disable cookies in your browser settings, but this could affect the availability and functionality of our Services. For information on interest-based advertising and how to opt out, see the Interest-Based Advertising section below.

We, our service providers, and our business partners use these cookies and other similar technologies to collect and analyze certain kinds of technical information, including:

IP address;
the type of computer or mobile device you are using;
platform type (for example Apple iOS or Android);
your operating system version;
your mobile device’s identifiers, like your MAC Address, Apple Identifier For Advertising (IDFA), and/or Android Advertising ID (AAID);
application performance and debugging information;
your browser type and language;
referring and exit pages, and URLs;
the number of clicks on an app feature or web page;
the amount of time spent on an app feature or web page;
domain names;
landing pages;
pages viewed and the order of those pages; and/or
game state and the date and time of activity on our Services.

If you want to adjust your privacy preferences on your device, please see Internet-Based Advertising.

Information Collected From Other Sources

We may collect information about you from other sources, including from our third-party partners or service providers, publicly available sources, or feedback from other players. We may combine this information with other information in our possession, which helps us to update, enhance, and analyze our Services, and provide tailored experiences for you.

How We Use Information We Collect

We use your information to provide, personalize, maintain the security of, and improve the Services you use; to maintain our business operations; to communicate with you; to protect you and others; to carry out marketing and advertising; and to exercise, defend or establish our rights.

We mainly use the information we collect and store to provide you with the Services you request from us and to improve your experience. The uses for which we collect and store your information include:

to improve and optimize our Services and our players’ experiences;
to create your game accounts and allow you to play our games;
to identify and suggest connections with other Miralet players and personalize our Services to you;
to communicate with you about the Services you’re using, including in-game updates, new Services, and promotional offers that we think might be of interest to you;
to enable players to communicate with each other;
to provide technical support and respond to player inquiries;
to protect the safety and well-being of our players;
to protect Miralet’s rights and property in connection with our Services;
to prevent fraud or potentially illegal activities, and to enforce our Terms of Service;
to manage and deliver contextual and behavioral advertising;
to administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our business partners;
to comply with our legal obligations, resolve any disputes we may have with you or other players, and to enforce our agreements with third parties; and/or
to conduct research.

Legal Basis for Processing Personal Data

If you are from the EEA, the United Kingdom, or Switzerland, our legal basis for collecting and using your personal data will depend on the type of information and the context in which we collect it. In general, we collect personal data from you only where we have your consent to do so, where we need it to perform a contract with you, or where it is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal data from you or may otherwise need it to protect your vital interests or those of another person. If you have questions about the legal basis on which we collect and use your personal data, please contact us.

How We Share Information

We may share the information we collect about you, and may enable you to share this information, with a variety of third parties in various ways, including:

With vendors, consultants, business partners, payment processors, and other third-party service providers as necessary to carry out work on our behalf and otherwise provide the Services;

With other players, to enable you to interact with them and to share gameplay-related data such as history, high scores and other leaderboard information;

With the general public, if you choose to share information when contributing content to our Services through a forum, blogs, social features, or the like;

With others who share your device, if you make your Account available to them through that device;

With specific third parties if we believe disclosure is required by applicable law, regulation, or legal process;

With law enforcement officials, government authorities, or other third parties if we believe your actions are inconsistent with our terms or other policies, and/or are fraudulent or in violation of applicable law, or as we determine necessary to protect the rights, property, or safety of Miralet or others;

In connection with a merger, consolidation, restructuring, sale of company stock and/or assets or other corporate change, including during the course of any due diligence process; and/or

In an aggregated form or otherwise in a form that cannot reasonably be used to identify you.

In some cases, we may enable you to access third-party products or services through our Services. Please note that those products or services are offered by people or companies not affiliated with or controlled by us, and we are not responsible for their actions, their terms, their use of information, or their products or services. If you submit your information to a third party, that third party’s treatment of your information is governed by their privacy policy, which may differ from this Privacy Policy and which we encourage you to review.

We may share information with your consent or at your direction. For example, we may share your personal data if you opt in to receiving information from Miralet’s business partners.

Interest-Based Advertising

We work with third-party advertising partners such as Google, Unity, and their partners. We may share certain of your information with these partners to make advertising more relevant, measure its effectiveness, and help recognize your devices and serve ads. We or they may also employ cookies or similar technologies, as described above, to ensure appropriate advertising and personalized experiences.

If you prefer to opt out of having your web viewing behavior used for interest-based advertising, you can learn how to do so by visiting www.aboutads.info/choices. If you are located in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, you can visit youronlinechoices.eu. If you would prefer to opt out of having information about your mobile app usage used for interest-based advertising, you may do so through your device settings (“Limit Ad Tracking” on iOS and “Opt Out of Ads Personalization” on Android). Please note that you may continue to receive generic ads that are not based on your preferences.

Your Rights and Choices

You can access and modify any personal and other information that is made available to you in your Account or in-app. You can manage your information as described below, and you may have additional rights related to that information as described elsewhere in this Privacy Policy.

Deleting Your Data

We offer you the ability to request deletion of personal information we have collected and stored about you, subject to our Data Retention policy described below. If you would like to have your personal information deleted with respect to any games you’ve played, contact privacy@miralet.com for help. Please also note that if you request deletion of your personal information, you may no longer be able to use or access the Services, and if you share devices with someone else who uses the Services, that person may lose game progress or related account information and access. If you decide to use or access the Services again, Miralet may consider this a new Account and may collect personal information associated with that Account in accordance with this Privacy Policy.

Communication Preferences

Push: In connection with certain Services, you may choose to opt in to receiving push notifications. If you no longer want to receive them, you can turn them off at the device level.

Cookies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

Other Rights

In some cases, particularly if you are a resident of the EEA, the United Kingdom, or Switzerland, or if you are a resident of the State of California, you may have additional rights with respect to your personal data or personal information as defined under applicable laws. For more information on these rights, please refer to the additional disclosures below.

Data Retention

We may retain personal information where required by law or where we have an ongoing legitimate business need to do so. For example, we may retain such information to provide you a service you have requested, to comply with applicable legal, tax or accounting requirements, or where necessary for fraud prevention, dispute resolution, enforcement of our contracts and terms, or for safety reasons (e.g., we may retain certain information about an Account to prevent that user from opening a new Account).

Security

We follow generally accepted industry standards and maintain reasonable safeguards designed to secure the information in our possession, and only those at Miralet with a legitimate business need to access your personal information are permitted to do so. We also take reasonable steps to assure that third parties to whom we transfer information will provide protections appropriate to that type of information. If you have reason to believe that your interaction with us is no longer secure, please immediately contact us.

Use by Minors

We do not knowingly collect or process personal information from or about, or direct or target interest-based advertising to, anyone under the age of 13 (or under the age of 16 for those in the EEA, United Kingdom, or Switzerland), nor do we knowingly allow such individuals to use our Services. If you believe we might have any information from or about a child under this age, please contact us. If we learn that we have inadvertently gathered such information, we will take reasonable measures to promptly remove that information from our records.

Additional Information for Residents of California

Information We Collect, Use, and Disclose

California law requires us to disclose information about the categories of personal information we collect and how we use them, the categories of sources from which we collect personal information, and the third parties with whom we share personal information. We have provided detailed descriptions of this information above in this Privacy Policy.

Generally, we collect the following categories of personal information, as defined by applicable California law:

Identifiers and contact information, including first and last name, username or Gamer Tag, third party service ID, IP address, unique device identifier, advertising identifier, device serial number, email address, and your friends’ usernames;

Internet or other electronic network activity information, such as hardware model, device software platform/OS and firmware, mobile carrier, preferred languages, device motion information, and mobile network information, and in some cases, browser type, Internet service provider, referring/exit pages and URLs, and clickstream data;

Commercial information, including in-game purchase information;

Demographic information, including your gender, age, date of birth, and language;

Non-precise geolocation information, such as approximate location as inferred from IP address; and

Visual information, such as your profile picture.

In the past 12 months, we have disclosed (or have enabled you to disclose) the following categories of personal information to third parties for business or commercial purposes:

Identifiers and Non-precise location information (e.g., estimated location based on your IP address) with: cloud service providers (such as our email service providers and cloud-based survey and customer service tools we use); payment processors; analytics providers; and advertising networks.
Internet and electronic network activity information with: cloud service providers (such as our email service providers and cloud-based survey and customer service tools we use); and analytics providers.
Commercial information and Demographic information (e.g., gender, age, date of birth, and language) with: cloud service providers (such as cloud-based customer service and survey tools we use).
Visual information (such as your profile picture) with: service providers that enable photograph functionality on our behalf.

Miralet does not sell player personal information for money or for other consideration. If the Miralet games you play are supported by ads, we do allow our advertising partners to collect certain device identifiers and electronic network activity via our Services to show ads that are targeted to your interests. To opt out of having your personal information used for targeted advertising purposes, please see the Interest-Based Advertising section above.

Rights and Choices Available to California Residents

If you are a California resident, you may have the following rights with respect to any information about you that constitutes “personal information” under California law:

Access your personal information: You may have the right to obtain a copy of the specific pieces of personal information we have collected about you. (Note that this right only applies to personal information relating to you, and not to any other player.)

Request deletion of your personal information: You may have the right to request that Miralet delete your personal information. This right may be limited to the extent that Miralet is permitted or required by applicable law to retain information. (Note that if you request deletion of your personal information, you may no longer be able to use or access the Services, and that if you share devices with someone else who uses the Services, that person may lose game progress or related account information and access. If you decide to use or access the Services again, Miralet may consider this a new Account and may collect personal information associated with that Account in accordance with this Privacy Policy.)

Obtain additional details regarding Miralet’s information practices: You may have the right to request disclosures regarding Miralet’s information practices. (Note that this information is generally available in this Privacy Policy.)

If you wish to exercise any of the rights described above, please follow the instructions below:

Email privacy@miralet.com with the subject line “California Rights Request”.

In the body of the email, please clearly state which right(s) you wish to exercise. For example, you can say “I want to delete my personal information,” or “please provide me with access to my personal information.” We cannot begin processing your request until you have clearly stated which right(s) you wish to exercise.

Include your username, city and country of residence in your request. We cannot begin processing your request until you have confirmed your identity and residence. We will only use this information in order to fulfill and document your request.

We will need to verify your identity before processing your request. In order to verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. We try to minimize the personal information collected in connection with a request to exercise the right to know and the right to deletion to what is necessary for verification. Certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the right to know and right to deletion, particularly where we are unable to verify your identity.

We will never discriminate against you for exercising any of your rights under California law. However, please note that if the exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products or services or engage with you in the same manner.

Additional Information for Residents of the EEA, United Kingdom, and Switzerland

If you are a resident of a member country of the European Economic Area (“EEA”), the United Kingdom, or Switzerland, you may have the following rights with respect to any information about you that constitutes “personal data” under EEA law:

You can access or request deletion of your personal information.

You can correct or update your personal information, object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.

If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

You have the 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.

If you wish to exercise any of the rights described above, please follow the instructions below:

Email privacy@miralet.com with the subject line “European Rights Request”.

We will need to verify your identity before processing your request. In order to verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. We try to minimize the personal information collected in connection with your request to exercise your rights to what is necessary for verification. Certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the right to know and right to deletion, particularly where we are unable to verify your identity.

In some cases, you may have the right to file a complaint with a data protection authority about our collection and use of your personal data. For more information, contact your local data protection authority. We will cooperate with the appropriate governmental authorities to resolve any privacy-related complaints that cannot be amicably resolved between you and us.

Changes to the Privacy Policy

Miralet may change this Privacy Policy at any time. If we make a change, we will notify you by revising the “Effective Date” date above, and in some cases, we may provide you with more prominent notice. We encourage you to review this Privacy Policy frequently to stay informed about our information practices and your privacy choices.

Contact Us

If you have questions or concerns about our Privacy Policy or our data practices, you can contact us by email at privacy@miralet.com.