If you object to us using your personal data for the above purposes, please let us know using the email address provided in section 1.
D – HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We keep your personal data for as long as necessary to ensure security of visitors to our premises and as soon as it is no longer necessary, usually after 90 days, we delete it.
3. WHO WE SHARE YOUR PERSONAL DATA WITH
We do not sell your personal data to Third Parties, оur Partner Organizations or Service Providers.
We cannot provide all services necessary for the successful operation of our Services by ourselves. We must therefore share collected information with third parties, including analytics providers, tracking and fraud prevention providers and other third party service providers that develop and support our Services.
We do not share information that can be used to personally identify your device (e.g. persistent identifiers such as IDFA, IDFV, advertising ID and IP address). We also reserve the right to disclose your information (including personally identifiable information) when we are legally required to do so, to disclose your information in an anonymous and aggregated manner, meaning you could not be personally identified from it.
We may disclose information about you to organizations that provide a service to us, ensuring that they are contractually obligated to keep your personal data confidential and will comply with the GDPR and other relevant data protection laws.
We may share your information with the following types of service providers:
- Technical support providers who assist with our website and IT infrastructure,
- Third party software providers, including 'software as a service' solution providers, where the provider hosts the relevant personal data on our behalf;
- Professional advisers such as solicitors, accountants, tax advisors, auditors and insurance brokers;
- Providers that help us generate and collate reviews in relation to our goods and services;
- Our advertising and promotional agencies and consultants and those organizations or online platforms selected by us to carry out marketing campaigns on our behalf and to advertise their own products or services that may be of interest to you; and/or
- Service providers that assist us in providing our services.
- Law enforcement or government bodies
We may disclose your personal data as permitted by law in order to investigate, prevent or take action regarding illegal activities, suspected fraud, violation of our intellectual property rights, situations involving potential threats to the physical safety of any person, violation of our Terms of Use or other agreements, or as required by law.
For any additional questions about third party information collection please refer to
privacy@magickids.me;
4. TRANSFERS OF PERSONAL DATA OUTSIDE THE EU/EUROPEAN ECONOMIC AREA
We operate globally, thus we may for the purposes described in this Privacy Policy transfer your information to our affiliated entities and/or to other third-party service providers across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note, that these countries and jurisdictions may not have the same data protection laws as your own jurisdiction, but wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information.
When we share your personal data with our affiliates in the EU and outside the EU. International transfers with Magic Kids Inc affiliates outside the EEA, are governed by EU Commission-approved Standard Contractual Clauses for Controllers and, where relevant, for Processors.
We share personal data with external vendors or service providers or suppliers that we engage to perform services or functions on our behalf and under our instructions. Where these vendors are located within the EU, we ensure that they are contractually obligated to comply with the EU data protection rules. We also ensure in our contracts with these organizations that they only Process Personal Data in accordance with our instructions and in order to provide the agreed services and protect the integrity and confidentiality of your personal data entrusted to them.
We may also disclose personal data to our advisers, consultants, law enforcement and other public authorities (such as tax and social security bodies), the police, prosecutors, courts and tribunals. All these recipients are themselves responsible to comply with the EU data protection rules.
We will transfer your personal information to our Partner outside EEA, if we have entered into standard contractual clauses with such Partner, that are adopted by the Commission of European Union in accordance with EEA data protection legislation and are deemed to offer sufficient safeguards with respect to the protection of the privacy and fundamental rights and freedoms of individuals (you can obtain a copy of the clauses by contacting us via
privacy@magickids.me).
When we transfer your personal information to our Partner outside EEA, we ensure that our Partner is certified by an approved certification mechanism pursuant to EEA data protection legislation. For instance, to our partner that is certified to comply with the principles for data protection under the US-EU Privacy Shield Framework ("Privacy Shield") (you can view the entities certified under Privacy Shield at
www.privacyshield.gov).
You may request a copy of these agreements by contacting us using the email address in section 1.
5. CHILDREN'S PRIVACY
Magic Kids Inc adheres to the strict information collection, use and disclosure requirements. Magic Kids has established COPPA compliant privacy practices. If you have questions or concerns about our privacy practices, please contact us at
privacy@magickids.me.
We consider ourselves to be family oriented, however we have decided to voluntarily implement higher child protection standards even though our products and services are not directed toward, and we do not knowingly collect, maintain, or use personal information from children under the age of digital consent according to EEA data protection legislation without their parent's/legal guardian's permission, with the exception of persistent identifiers and age category as described below. If we learn that we have collected personal information other than persistent identifier or age category of a child under the age of digital consent according to EEA data protection legislation, we will take all reasonable steps to delete the information as soon as possible. If you become aware that your child has provided us with personal information without your consent, please contact us at
privacy@magickids.me.
The only personal information we collect from users who have identified themselves as below the age of digital consent according to EEA data protection legislation for the purposes of offering our services are persistent identifiers (such as User UDs, Device ID or IP address) and Child's age category.
We do not share such persistent identifiers with third parties. They are used only to authenticate users of applications, to maintain or analyze the functioning of the application, to personalize the content of the application (or send push notifications), to perform network communications to protect the security or integrity of the user or the application, or to ensure legal or regulatory compliance. Child's age category used to build a correct education plan (as we are required to do so by Contractual Necessity), its processed as a pseudonymized information (for example, 'category A' or 'B'), so the date of birth could not be identified from it.
When using the persistent identifiers we will not contact users under the age of digital consent according to EEA data protection legislation, nor do any user tracking or profiling. For the detailed information about disclosure to third parties please see section 3 of this Privacy Policy. For any additional questions about third party information disclosure please contact us at
privacy@magickids.me.
6. YOUR RIGHTS
You have certain rights in connection with your personal information and how we handle it, i.e. you have the right to obtain information about whether we hold personal information about you, to access personal information we hold about you, to obtain the correction, update, amendment or deletion of your personal information and to turn to supervisory authority. Some of these rights may be subject to some exceptions or limitations. You can exercise these rights at any time by sending your requests regarding your personal information to
privacy@magickids.me.
Your rights include:
- Right to object. You have the right to object to the processing of your personal information that is processed on the grounds of legitimate interests (see Legal Bases below). You are always free to opt out from the future collection of your personal information by us and our Partners by uninstalling all the Services from each of your computing devices.
- Right of access. You have the right to know what information we hold about you and in some cases to have the information communicated to you. If you wish to exercise this right please contact us by letting us know that you wish to exercise your right of access and what information in particular you would like to receive. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information. Please note that we may not be able to provide all the information you ask for, for instance if the information includes personal information about another person. Where we are not able to provide you with information that you have asked for, we will explain to you why. We will try to respond to any request for the right of access as soon as possible, but we will always do so within 1 month of receipt of your request and verification of your identity.
- Right to correct personal information. We try to keep the information that we hold about you accurate and up to date. Should you realize that any of the information that we hold about you is incorrect, please contact us via privacy@magickids.me and we will correct it as soon as we can.
- Data deletion. You have the right to request deletion of the personal information that we hold about you. Should you wish to do so, please contact us via privacy@magickids.me. We reserve the right to ask to provide us additional information to verify your identity before we can start processing your request. Once we receive all information we need in order to be able to identify you, we will delete your personal information you requested us to delete as soon as possible, but we will always do so within 1 month of receipt of your request and verification of your identity. Please note that we may still retain some or all of that information, for example for complying with our legal obligations and protecting or enforcing legal rights. We may also retain your information in an anonymised form. In some instances, personal information about you that is visible through gameplay such as username, avatar, your high scores and any chat messages may be cached on other players' devices and we may not be able to remove or update that data from those devices, for example if that device is not connected to a wifi network.
- Data portability. In some circumstances, you have the right to request that we provide you with the personal information which you have provided to us, so you can transfer this information to another data controller. Should you wish to do so, please contact us via privacy@magickids.me.
- Restriction of processing. In some cases, you may have the right to request a restriction of the processing of your personal information.
- Right to file a complaint. You have the right to file a complaint against us. To do so, contact the supervisory authority in your country of residence.
You can object to our use of your personal data where we stated we rely on our legitimate business interests to do so. We explained the legitimate interests we rely on in sections 'Why do we collect your personal data and what are our lawful bases for it?' above.
If you would like to exercise any of your above rights, contact us using the contact details in section 1 above.
B – LEGAL BASES
In each case where we process your information, we do so lawfully in accordance with one of the legal bases set out under EEA data protection law.
The legal bases that we rely upon are the following:
- Contractual Necessity. This covers information that is processed by us in order to provide you with service that you have requested - and that we have agreed - to provide to you, that is to deliver and improve our services, to provide customer support, to deliver special features in our Apps (such as in-app chat feature, multi-player feature, leaderboards and other third party social network features), to deliver content of the in-app purchase you make.
- Legitimate Interests. This covers information that is processed by us for the purposes that can be reasonably expected within the context of your use of our services to pursue our legitimate interests in order to ensure you have the best experience when playing our apps, to make sure your information is secure and to provide to you our Apps free of charge or at a low cost. We pay special attention to your data protection rights making sure that your data protection rights are not overridden by our legitimate interests. We rely on our legitimate interests for data processing for analytics, tracking and fraud prevention, push-notifications, cross-promotion, and contextual advertising purposes.
- Consent. Where we ask for your consent to use your data for a particular purpose, we will make this clear at the point of collection and we will also make clear how you can withdraw your consent. We will ask for you consent before sharing any information with our advertising partners for the purposes of interest-based advertising and before conducting any surveys.
- Legal Obligation. This covers information that is processed by us to comply with a legal obligation, for instance is to maintain records for tax purposes.
C – SECURITY
We have implemented appropriate technical and organizational measures to protect the confidentiality, security and integrity of the collected information, and to prevent unauthorized access and the use of information contrary to this Privacy Policy. Although we use commercially reasonable efforts to assure that your information remains secure when maintained by us, please be aware that no security measures are perfect or impenetrable.
D – CALIFORNIA PRIVACY RIGHTS
California's "Shine the Light" law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties' and affiliates' own direct marketing purposes. Under the law, we will provide California customers certain information upon request ("Right to access") or permit California customers to opt out of, this type of sharing ("Right to opt-out of the sale of your personal information").
If you are a California resident and wish to obtain information about our compliance with this law, please contact us via privacy@magickids.me. We may request information from you to verify your identity. Please note that Magic Kids Inc is not required to respond to requests made by means other than through the provided email address or mail address.
E – CHANGES TO OUR PRIVACY POLICY
We will occasionally update this Privacy Policy as necessary to protect our users, furnish current information, and respond to legal and technical changes. The most current version of the Privacy Policy will govern our use of your information and will be available at
https://magickids.me/privacy.
For previous versions of this Privacy Policy please contact us via privacy@magickids.me