Mystral SAS privacy policy

Introduction to our company:

We're known as Mystral SAS, a company specializing in creating games for mobile platforms. Our official company registration number is 87814088800016, and you can find our main office at 3 clos de Durand, 06330 Roquefort les Pins, France. At Mystral SAS, we take charge of managing and safeguarding your personal data. Throughout this policy, when we mention "Mystral", "we", "us", or "our", we're referring to Mystral SAS and, where relevant, our associated group companies. The term "apps" in this document denotes the mobile applications we offer for download called "Domino Puzzle".

Our commitment to Your privacy:

Your privacy is of utmost importance to us. We aim to be responsible, equitable, and transparent in how we handle your personal data. It's crucial for us that you understand your rights regarding your data, which are detailed within this document.

Our privacy policy is designed to clearly inform you about how we collect and use your personal data. We've organized this policy to be user-friendly, allowing you to easily find information pertinent to you and your interaction with us.

We continually strive to enhance the quality of information we provide. Should you have any suggestions or comments about our privacy policy, we welcome your feedback. Please reach out to us with your thoughts using the contact information provided in section 10.

Scope of the policy:

This policy applies to users of our apps and individuals who contact our customer service.

Your right to object:

You have various rights related to our use of your personal information, as outlined in section 5. Notably:

1. You may request us to stop using your personal information for direct marketing purposes. If you exercise this right, we will cease using your information for these purposes.
2. You may raise any valid objections to our use of your personal information, especially in cases where we process it based on our legitimate interest or that of a third party.For more information, please refer to section 5.

Your acknowledgement and confirmation:

We encourage you to read this privacy policy carefully to understand how we handle your personal information. By engaging with us, including downloading and using our apps, you acknowledge and confirm that you have read and understood the entirety of this privacy policy as it applies to you.

1. Collection and use of your personal information

1.1 Types of personal information we collect about you

(a) Our applications collect the following information about you (and we use this information as described below):

• (i) If you consent to receive personalized ads, we collect data about your general location and the Identifier for Advertisers (IDFA) of your device.
• (ii) If you participate in any chat activities on our apps, we collect your username and any information you share in your messages.
• (iii) If you utilize the Facebook connection functionality, depending on your Facebook privacy settings, we collect basic information from your Facebook profile.

(b) If you contact our customer support, we collect your email address along with any other information you provide in your correspondence with us, including any updates to that information.

1.2 How we use your personal information

We collect, use, and store the personal information mentioned above for the following reasons:

• (a) To manage advertising and provide you with advertising and marketing through our apps that are relevant to you, from us and our third-party partners, as detailed in the "Third-Party Advertising" section below.
• (b) To record your preferences regarding advertising and marketing communications.
• (c) To receive and respond to customer support inquiries from you.

1.3 Other uses of your personal information

(a) We also collect, use, and store your personal information for the following additional reasons:

• (i) To address any inquiries or issues you have regarding how we collect, store, and use your personal information, or any requests made by you for a copy of the information we hold about you. Even if we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interest to do so for customer service purposes.
• (ii) For internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies. We may process your personal information for these purposes where it is in our legitimate interest.
• (iii) To comply with any procedures, laws, and regulations applicable to us – this may include situations where we reasonably consider it in our legitimate interest or the legitimate interest of others to comply, as well as where we are legally required to do so.
• (iv) To establish, exercise, or defend our legal rights – this may include situations where we reasonably consider it in our legitimate interest or the legitimate interest of others, as well as where we are legally required to do so.

(b) We will not use your personal information in any way that is incompatible with the purposes outlined in this Section 1. Please contact us using the details in Section 10 if you want further information on the analysis we will undertake to determine if a new use of your personal information is compatible with these purposes.

2. Foundations for processing your personal data

The grounds for processing your personal data, as outlined in this privacy policy, are identified as follows:

• (a) Processing your personal data is essential for fulfilling our commitments under any agreement we have with you, such as adhering to our app's terms of service.
• (b) You have explicitly given us permission to process your data. This is particularly relevant for personalized advertising and marketing content we provide through our apps, designed according to your likes and preferences. Remember, you have the autonomy to revoke this consent at any moment while using our apps.
• (c) In situations where neither (a) nor (b) are applicable, processing your personal data is justified by our own legitimate interests or those of third parties. Such legitimate interests include:
• (i) The desire to expand, nurture, and evolve our enterprise and those of our affiliated entities, partially through advertising revenue.
• (ii) The necessity to manage, sustain, and enhance our apps and our strategies for marketing optimization.

Should our use of your personal data be based on legitimate interests (ours or someone else's), we commit to conducting an evaluation to ensure these interests are balanced against your rights and do not infringe upon your privacy or fundamental freedoms. For more details on how we perform this assessment, you're encouraged to reach out using the contact information provided in section 10.

3. Sharing your personal information with third parties

3.1 Our aim is to ensure that the advertising and marketing you encounter are both relevant and engaging for you and our other users. To accomplish this, we partner with third-party advertising and technology firms. These entities assist us in delivering ads and/or compiling aggregated data that help tailor the advertisements you encounter while using our apps. These third-party tech companies gather information about you to create a profile reflecting your preferences, which are inferred from your activity within our apps. We also rely on these services to automatically collect data about your app usage, aiding us in identifying the advertisements presented to you and understanding your interactions with them. Furthermore, we share your data with analytics tool providers, like Adjust, to analyze your app usage. Below is a list of the third-party advertising and technology companies we collaborate with:

• (a) Google Admob - https://policies.google.com/privacy?hl=en
• (b) AppLovin - https://www.applovin.com/privacy/
• (c) Meta Audience Network - https://www.facebook.com/privacy/policy/
• (d) Google Ad Manager - https://policies.google.com/privacy
• (e) Meta Ads - https://www.facebook.com/privacy/policy/
• (f) Google Ads - https://policies.google.com/privacy?hl=en
• (g) Game Analytics - https://gameanalytics.com/privacy/
• (h) Apple Search Ads - https://searchads.apple.com/privacy

3.2 Advertising partners and technology firms we work with employ cookies and tracking technologies within our apps to gather, store, and utilize data. The types of data collected include:

• Details about your device, its location, and how you use our apps, such as your IP address, a distinctive device identifier, geolocation specifics, and a User ID assigned by us;
• Information you provide while using our apps, which includes your interactions with ads and some technical data.

3.3 With your permission, these advertising entities use your information to deliver ads that match your interests and preferences. You have the option to revoke your consent to this personalized advertising at any point within our apps. Without your consent, ads will still be displayed, but they won't be customized to your interests and preferences.

3.4 Occasionally, these third parties may use the collected data for their own objectives, such as combining your information with other data they possess to enhance the advertising services they offer to other clients.

3.5 Additionally, we may share your information with social media platforms and our advertising partners to ensure the ads you and others see are relevant. For instance, by using services like Facebook Custom Audiences and sharing your IDFA with Facebook, we aim to display pertinent ads to you on Facebook or create a custom audience for targeted advertising, based on your Facebook profile information. You can opt out of Facebook Custom Audiences and similar services in your privacy settings on these platforms.

3.6 Your personal information will be shared with specific third parties, including:

• Amazon Web Services for data storage and access during support and maintenance;
• Your device's OS providers or the platforms from which you downloaded our apps, like Google, Amazon, and Apple, for verifying purchases and enabling in-app purchases;
• Google, Inc. (operating as Firebase), which helps us analyze and address app bugs and issues to improve app stability and performance.

3.7 We might share your personal information with our affiliate companies when it serves our legitimate interests, such as providing customer support or for internal administrative tasks including corporate strategy, compliance, and quality assurance.

3.8 We may also disclose your personal information to third parties:

• To support our business growth and development;
• In the event of a sale, purchase, or acquisition of business assets, where your personal information might be transferred as part of the deal;
• To comply with legal obligations, respond to government or law enforcement requests, or for national security purposes;
• To enforce or defend our terms of service or other agreements, protect the rights or safety of others, or prevent illegal activities.

3.9 For internal or external reporting purposes, we may use anonymized, aggregated data about our app users, which does not allow individual identification.

3.10 Except as specifically mentioned, we will not share, sell, or rent your personal information to any third party without informing you and, when necessary, obtaining your consent. If you decide to revoke previously given consent for a specific use of your personal information, contact us, and we will cease that specific use.

4. How long we store your personal information

We store your personal information only for as long as needed for the processing purposes. The retention period of your personal data varies based on the reasons for its collection and use, as well as legal obligations we must adhere to and the need to protect our legal rights.

5. Your entitlements regarding your data

5.1 You possess specific entitlements concerning your personal data. For more information about these rights or to exercise them, please reach out to us via email at admin@dominopuzzle.com at any point. Your entitlements include:

• (a) Access Right: You're entitled to access the personal data we have about you. You may request a copy of your data, verification of its use by us, insights into the purposes of its use, and information on protections in place for data transferred outside the EEA. Such requests can be made through the "Show my data" feature in our app settings.
• (b) Right to Update: You can request corrections or updates to any inaccurate or outdated personal data we hold about you.
• (c) Right to Erasure: Under specific conditions, you can request the deletion of your personal data from our records. For details on these conditions, contact us as outlined in section 10. Requests for data deletion can be submitted via the "Delete my data" option in our app settings.

We will forward your request to any other parties holding your personal data unless doing so is unfeasible or requires an unreasonable effort. You can inquire about these recipients by contacting us as mentioned in section 10.

• (d) Right to Restrict Processing: You have the right to request that we limit the processing of your personal data under certain conditions. For more information on these conditions, please contact us as specified in section 10.
• (e) Right to Data Portability: You can request that we transfer your personal data to another service provider.

This right is applicable only when processing is based on your consent or the execution of a contract and is carried out through automated means.

• (f) Right to Object: You are entitled to object to our processing of your personal data if it's based on our legitimate interests or those of a third party.

5.2 We will address all such requests and respond within a reasonable timeframe (always within one month of receiving your request, unless we inform you that we are entitled to an extension as per the law). However, it's important to note that in certain situations, specific personal data may be exempt from such requests, for example, if we must continue using the information to fulfill legal obligations or defend legal claims.

5.3 Should any exceptions apply, we will inform you when responding to your request. We may ask for information necessary to verify your identity before we proceed with any request you make.

6. About children

6.1 Individuals must be at least 16 years old to purchase our products or services. Our website and services do not target children under this age, and we do not intentionally collect personal information from children below this threshold.

6.2 If you are under the age of 16 and it comes to our attention that we have unintentionally gathered personal information from you via our website or any other means, we will promptly delete such information.

6.3 Please reach out to us at admin@dominopuzzle.com if you believe we might have inadvertently obtained personal information from a child under the age of 16.

7. Transferring your personal information

7.1 Your personal data may be utilized, stored, and/or accessed by our staff located outside the European Economic Area (EEA), including in the United States, whether on behalf of us, our affiliates, or our suppliers. More detailed information about the potential recipients of your data is provided in section 3.

7.2 When transferring your personal information to entities outside the EEA, we implement suitable safeguards to ensure your data is adequately protected. These measures can include, in accordance with Articles 45 and 46 of the General Data Protection Regulation (GDPR):

• (a) for entities in the United States, making European Commission-approved standard contractual arrangements with them, or ensuring they are enrolled in the EU-US Privacy Shield (see https://www.privacyshield.gov/welcome);
• (b) establishing European Commission-approved standard contractual arrangements with those entities.

7.3 For more details on how we protect your personal information under these circumstances, you can make a request by contacting us at the email address listed in section 10.

8. Managing risks and securing your personal data

8.1 The primary concern in processing your personal data is the potential for it to be lost, stolen, or exploited improperly. Such incidents could result in your personal information falling into the wrong hands, where it might be used for fraudulent activities or disclosed publicly against your wishes.

8.2 Consequently, safeguarding your personal information against loss, theft, and unauthorized use is a top priority for us. We implement robust safeguards, including organizational and technical measures, to protect the privacy of your personal data. Our security protocols, which include encryption, firewalls, and secure password protocols, adhere to industry standards. For instance, we encrypt your email address, making it significantly more challenging for unauthorized parties to access and misuse it. Additionally, we restrict data access to only those employees who need it to perform their job functions related to providing our apps. Our security measures are regularly reviewed and updated to incorporate new technologies and methods, ensuring ongoing protection of your data.

8.3 Despite our best efforts to secure your data, transmitting information over the internet inherently carries risks. Therefore, you must recognize and agree that we cannot fully guarantee the security of your personal data sent to our apps or customer service. Any transmission is at your risk. Upon receiving your personal data, we commit to stringent protocols and security features to deter unauthorized access.

9. Updating our privacy policy

Our privacy policy may undergo amendments periodically. Future modifications to our privacy policy will be communicated to you through the policy available within our app. We encourage you to regularly review our privacy policy for any new updates or changes.

10. Additional information and filing complaints

10.1 Should you have any questions or concerns regarding how we collect, utilize, or store your personal information, or if you'd like to enforce any of your data protection rights, please feel free to reach out to us at admin@dominopuzzle.com. Weare committed to thoroughly investigating and addressing any complaints or disputes related to the use or sharing of your personal information.

10.2 As per Article 77 of the General Data Protection Regulation (GDPR), you have the right to lodge a complaint with the Information Commissioner's Office or with the data protection authority in the country where you reside, work, or where you believe a violation of GDPR has occurred. Additionally, you have the option to pursue legal action in court should you feel that your data protection rights have been violated.