1. Terms and definitions
This Online Privacy Policy (the “Policy”) is a document developed to help Users understand methods CIRCLES MAGIC LLC collects, processes, uses, discloses, and manages Personal Data.
Users are people using any digital products or services produced/provided by CIRCLES MAGIC LLC on the Platform (hereinafter the “User” / “Users” or “you”).
The Platform is an Internet platform that hosts applications, games or any other digital products produced by CIRCLES MAGIC LLC (hereinafter the “Platform”).
Personal Data is information relating to an identifiable person that can be obtained by CIRCLES MAGIC LLC when the user is using digital products or services produced/provided by the Company (hereinafter “Personal Data”). Aggregated and otherwise non-identifiable Personal Data is information that cannot be used to identify a User.
Personal Data Processing is an action performed by Controllers or Processors (under GDPR), including automatic and non-automatic operations with Personal Data of Users.
Data Processor is an organization that processes Personal Data on behalf of the Data Controller.
Application is software developed by CIRCLES MAGIC LLC that performs a specific function directly for a User.
Game is a game developed by CIRCLES MAGIC LLC
2. General Terms
CIRCLES MAGIC LLC is committed to protect and respect your privacy. This Policy has been developed to inform you about the ways we collect, process, use, and manage the information you provide in connection with any game or application or any other digital products or services produced/provided by CIRCLES MAGIC LLC (hereinafter referred to as “Products” or/and “Services”). Please note that the scope of this Policy is limited only to information collected by CIRCLES MAGIC LLC through use of the Products. This Policy shall not apply to any practices of third parties that CIRCLES MAGIC LLC will neither own nor control.
We process your personal Data subject to your consent. Any use of the Products shall be construed as your acknowledgement and agreement with this Policy and our terms of use specified below. If you do not agree to these terms, please do not use the Service.
3. Personal Data collected by our partners
Please note that this Personal Data is collected automatically by third parties (controllers or processors) due to the fact that you’re using our Products/Services:
- Data on your game progress.
- Data about your operating system and language.
- General location data.
- Information on your use of our application or game, such as gameplay data.
- Our software products include features from our partners, such as in-game advertising from Google AdMob.
All the data collected is anonymous, and no user id, device id, or any way to identify the user is collected or saved.
The list of third parties collecting Personal Data under this paragraph include Game Ever SA
4. Personal Data that we can obtain from other sources and/or share with third parties
We may also cooperate with third parties (including, e.g. partners, technical contractors, payment services, analytics providers, search information providers), and may receive Personal Data from them as part of the service we provide to you, or for legal reasons and share Personal Data with such third parties. We and the third parties will not collect Personal Data, and we and the third parties will never collect persistent identifiers (such as IDFA, IDFV, Advertising ID, or IP address).
By accepting the terms and conditions of this Policy you agree that we may disclose any aggregated and non-identifiable Personal Data to third parties without restriction for any purpose.
5. Why your Personal Data is collected and processed
Our Company collects Personal Data for some or all of the following reasons:
- To provide you with Products and Services under the terms and conditions specified herein.
- For legal reasons, e.g. if you have entered into a contract with us.
- To provide you with information on our Products and Services, if you have consented to receive them.
- To provide advertising and playing experience tailored to Users for the best quality of the Products or the Services.
Your Personal Data may be processed because:
- We have a contract with you.
- You have given us permission to do so.
- We should provide Services to you after you have purchased any Products from us.
- To comply with laws.
6. Rights and Options
Pursuant to GDPR you have certain data subject rights among other things changing or deleting your Personal Data, requesting access to your Personal Data and its rectification, obtaining restriction of processing your Personal Data, asking for a copy of your Personal Data, objection to processing of your Personal Data.
Please note that we do not collect and store your Personal Data. Pursuant to paragraph 3 of the Policy your Personal Data is collected automatically by third parties (controllers or processors under GDPR). If you wish to request access to your Personal Data, to rectify your Personal Data, if you want to remove your Personal Data just send us an e-mail request to: [email protected]. We will make every reasonable effort to help you and shall forward your request to our partners (controllers or processors under GDPR) which may access your Personal Data and operate under their own privacy policies. We will respond to all your requests within reasonable time.
We assure you that we will use your Personal Data in accordance with this Policy to the extent deemed to be reasonably necessary to serve our legitimate business purposes, and we will maintain appropriate safeguards to ensure security, integrity, accuracy and privacy of the information you have provided to us.
If you have any questions, comments, or concerns about this Policy, please contact our Company by email: [email protected]
7. Minors
We follow the principles of the Children’s Online Privacy Protection Act (“COPPA”), a U.S. law designed to protect the online privacy of children in Internet. If you would like to learn more about COPPA, you can refer to the “Children’s Privacy” section of the Federal Trade Commission’s website of the United States of America.
We don’t collect personal information from children under the age of 13, and if in the event that a user identifies himself or herself as a child under the age of 13 through a support request or through any feedback, we will not collect, store or use, and will delete in a secure manner, any personal information of such user.
If you believe that we may have unintentionally collected your child’s personal information without your prior consent, you may contact us by e-mail: [email protected]
We draw your attention that we do not collect any personal information. When you download and use our mobile Applications, we don’t require you to provide any information about you and we don’t collect any information about you or your device. We use only general information about you to analyze how users interact with our apps. It includes only technical characteristics of your device.
Our Games and Apps may contain advertisements about third party products and services but in any case, we did not permit behaviorally-targeted advertising to children in our Games and Apps.
8. Changes in the Policy
The Company may change this Policy from time to time. Any such changes will be posted here in the present Policy, and we advise you to check back frequently to look for any updates or changes. We shall reserve the right to make changes in this Policy at any time. Please check the Policy each time you use our Platforms to ensure you are aware of any changes in our privacy practices. Our Policy will indicate the data it was last updated. Your continued use of our Platforms will acknowledge your acceptance of changes in our Policy.
9. Company’s contact information
CIRCLES MAGIC LLC.
Registered address: 1201 N Orange St. Suite 700, Wilmington, Delaware, USA.
Email: [email protected]
If you contact us via e-mail, we will collect your name and e-mail address, as well as any other information included in the e-mail, in order to respond you. We may only use your Personal Data submitted in your communications to contact and respond to you.