
This Privacy Policy describes the measures that we
take to preserve and safeguard your privacy when you visit our website
located at https://mundfish.com/ (“Website”) or make use of our games,
Website, online shop, forums, social media channels, customer and
technical support and any other services we provide to you (“Services”) . It
also demonstrates how we may process data in accordance with the EU
General Data Protection Regulation ("GDPR"). Please read this Privacy
Policy carefully to understand our policies and practices regarding your
information and how we will treat it.
For the purpose of the GDPR, the data controller is Mundfish Limited,
registered office: Boumpoulinas, 1-3 BOUBOULINA BUILDING, Office 42,
CY-1060, Nicosia, Cyprus; registration number HE 385034 (“Mundfish”,“we”
or “us”) is committed to protecting the privacy of all individuals in respect
of whom we hold personal data. If you do not agree with our policies and
practices, your only recourse is not to use our Website or Services.
“Personal data” is information that identifies you or that can be used to
contact you (online or offline). Personal data can include but not limited to
your name, email address, physical address, Internet Protocol (IP) address,
telephone number, birthdate, etc.
All capitalized terms used but not defined herein shall have the meaning
given to them in the Terms of Use.
This Privacy Policy governs personal data and non-personal data, which we collect from you when you're using our Website and Services. We maintain reasonable and appropriate security safeguards designed to protect your information from loss, theft, misuse and unauthorised access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the information.
We rely on the following grounds to legally
collect and use your personal data:
● The data are necessary to provide our Services to you;
● We are using your personal information where it is in our legitimate
interests to do so;
● We have a legal obligation to process your personal information;
● You have consented to the use of your personal information by us.
We will use your personal information for the following purposes:
● to provide the Services to You;
● to improve the quality of our Website and Services and to offer new
features to you;
● to understand, improve, and research products, features, and
services;
● to comply with the legal requirements set by Regulation (EU)
2016/679 of the European Parliament and of the Council of 27 April
2016 on the protection of natural persons with regard to the
processing of personal data and on the free movement of such data,
and repealing Directive 95/46/EC (General Data Protection
Regulation).
Also, when we have your consent, we may process your personal data:
● to provide you with marketing information (including personalized
and targeted marketing emails) regarding goods and services you
request from us or which we feel may interest you and
● to target and personalize our marketing communications, offers and
advertisements that we display on our Website and websites of third
parties. To the extent that our processing of your personal data is
subject to the GDPR, we rely on its legitimate interests, described
above, to process your data.
We may collect the following data:
a. When setting up an Account, you may be asked to provide
personal data including, but not limited to, your username, password
and email address. You may also use your credentials from other
services such as Google, Facebook, Twitter, Apple iCloud to create an
account faster with us, in such case we will get information relating
to your account on social networking sites in order to allow you to
integrate or link your social network account with your Account or
our Services;
b. When you provide feedback about our Services. These data
include information that you post, comment, share content or like in
any of our forums, social networks, and on the Website and
information sent through the chat functionality;
c. We collect personal data whenever you contact us and provide
us with information that we are able to identify you by. This
includes information such as your name, email address, and phone
number, that you give us by filling out forms on this Website,
registering or by corresponding with us by phone, email or
otherwise;
d. In order to make a purchase on our Website, as well as for access
to the personalized services, if applicable, we collect your data, which
is necessary to fulfill obligations on the part of the Mundfish. This
information may include your username, full name and contact
details including your delivery address, email address and phone
number;
e. In order to fix crashes and other technical issues that may arise
while you are using our Services, as well as to make our Services
more suitable for you, we collect, store and use information about
the device you are using the Services on, including what type of
device it is, what hardware and operating system you are using, the
device settings, unique device identifiers, and crash data;
f. When you access our services using your credentials from a
social network or external platform we may process your social
network IDs, details about your use of social networking services and
our Services (if you link our services to a Social networking service
account or you interact with our profiles in Social networks). This
may potentially include certain data from Facebook or other social
networks (including access to your friends list as well as aggregated
non-personal analytics data about our users) strictly in accordance
with Facebook's and other networks' terms and conditions.
g. When you participate in a game contest or survey organized by
Mundfish. We collect, for example, your first and last name, date of
birth, postal address and email. We use this data to organize the
game contest or survey in question, send you promotional offers or
perform internal statistics.
h. In order to help us improve our Services and your experience,
including by monitoring aggregate metrics such as total number of
visitors, traffic, and demographic patterns;
i. In order to get in touch with you about features and offers relating
to the Service that we think you would be interested in and to make
sure that you get the most relevant offers and promotions based on
your Advertising ID, use of the Service, and your preferences. You can
opt-out of getting these electronic communications as described
below.
We indirectly collect a variety of information through your interaction with and use of our Website and Services. This information may include, but is not limited to, anonymized browser and device information (both software and hardware), data collected through automated electronic interactions, application usage data, demographic information, geographic, geo-location information, statistical and aggregated information. Statistical or aggregated information does not directly identify a specific person, but it may be derived from personal data.
In some cases, we receive your personal data as a data processor, which means that the data are controlled by our partners and we use them only in accordance with their instructions and applicable laws. We use this data in order to fulfil our obligation to you, improve the Services, and when processing is required in order to comply with a legal obligation to which we are subject.
We will not receive or store any of your payment details, this is fully handled by the relevant payment service provider. If/when you make any purchases in a Mundfish store, we are notified by the payment processor once the transaction takes place and then ensure you receive your purchase. We do not, however, receive any of your actual payment details or personal data related to the payment. We only keep the data concerning transaction dates, currencies, value and the subject of the transaction.
We do not collect or process any special categories of personal data. We do not undertake automated decision making or profiling on the data which are provided to us.
We use cookies and similar technologies like web beacons,
pixel tags, or local shared objects (“flash cookies”), to deliver, measure, and
improve our Services in various ways. A cookie is a small text file that
identifies your computer on our server. Cookies in themselves do not
identify the individual user, only the computer being used. Cookies are not
used to gather personal information.
Preferences and Features. Cookies or similar technologies can tell us
which language you prefer and what your communications preferences
are. They can help you fill out forms on our Websites more easily. They also
provide you with features, insights, and customized content.
Marketing. We may use cookies or similar technologies to help us deliver
marketing campaigns and track their performance. Similarly, our partners
may use cookies to provide us with information about your interactions
with their services and action tags to measure advertising effectiveness
and allow more effective targeted advertising, but use of those third-party
cookies would be subject to the service provider’s policies.
Performance, Analytics and Research. Cookies or similar technologies
help us learn how well our Websites and Services perform. We also use
cookies or similar technologies to understand, improve, and research
products, features, and services, also to create logs and record when you
access our Website from different devices, such as your computer or your
mobile device.
Third Party Analytics Providers. We may use third-party analytics
providers software to allow us to better understand the functionality of our
Website including but not limited to, Google Analytics, Yandex.Metrica.
This software may record information such as how often You use the
Website. The information about your use of our Website, may be
transmitted to and stored by Third-Party Analytics Providers’ servers,
which may also be located outside of the EEA.
We can use the cookies to help us develop and improve our Website. The
information gathered and statistics, however, do not include details that
can be used to identify you. By continuing to use our Website, you are
accepting our use of these cookies that make advertising and
communications more relevant to you and your interests, and further help
us to improve the Website.
Because we respect your right to privacy you may choose to decline all
cookies or to not allow some types of cookies. Click on the different
category headings in Cookies Banner to find out more and change our
default settings. However, blocking some types of cookies may impact
your experience of the Website and the services we are able to offer.
For the performance of a
contract with you, compliance with a legal obligation to which we are
subject, and based on our legitimate interests, we may share your personal
data with the following categories of third parties:
Our Affiliates. Our affiliates may access your personal data to help us
develop, maintain and provide our Services and help manage our
customer relationships.
Service Providers. Our service providers provide us support for our
Services, including, for example, Website and application development,
hosting, maintenance, backup, storage, payment processing, analysis and
other services for us, which may require them to access or use personal
data.
Advertising and Advertising Measurement Partners: we may share your
email, nickname, IP address and other information you provide to us in
order to facilitate targeting, delivery, and measurement of online
advertising on third-party services, or otherwise facilitate the transmission
of information that may be useful, relevant, or of interest to you.
Professional Advisers. Our lawyers, accountants, bankers, auditors and
insurers may need to review your personal data to provide consultancy,
compliance, banking, legal, insurance, accounting and similar services.
Legal Authorities. We may disclose your personal data if we believe it is
reasonably necessary to comply with a law, regulation, order, subpoena,
rule of a self-regulatory organization or audit or to protect the safety of any
person to address fraud, security or technical issues, or to protect our legal
rights, interests and the interests of others.
Business Partners. We may share certain information such as your
location, browser and cookie data and other data relating to your use of
our Services with our business partners to deliver personalized
advertisements that may be of interest to you. These third-party ad servers
or ad networks use technology to send, directly to your browser, computer
or mobile device, these personalized ads and ad links, and will
automatically receive your IP address when they do so.
Researchers. To enhance the public understanding of patterns and trends
in the markets served by our Service, we may provide personal data to
third parties under confidentiality obligations such as, for example,
academics or contractors for research purposes.
We may also share non-personal data (such as anonymous usage data,
platform types, number of clicks, etc.) with interested third parties to help
them understand the usage patterns for certain services or conduct
independent research based on such anonymous usage data.
Our Service is global by nature and your data can
therefore be transferred to anywhere in the world. We transfer, process
and store your information outside of your country of residence, to
wherever we or our third-party service providers operate for the purpose of
providing you the Services. Whenever we transfer your information, we
take steps to protect it.
International transfers to third-parties. In addition, data may be
transferred to our subsidiaries or processors in third countries or
subcontractors of our processors in third countries. Some of the third
parties described in this Privacy Policy that provide services to us under
contract, are based in other countries that may not have privacy and data
protection laws equivalent to those of the country in which you reside. In
the event your personal information is transferred, stored or processed
outside of the EEA, we will take all steps reasonably necessary to ensure
that your personal information is treated securely and in accordance with
this Privacy Policy and GDPR.
Depending on where you reside you may have rights to have access to
your personal information (upon your request, we will provide you with a
copy of your personal data in a structured, electronic format) and ask us to
rectify (you can edit some of your personal data through your account, you
can also ask us to change, update or fix your data in certain cases,
particularly if it’s inaccurate), erase (in certain territories you can ask us to
erase or delete all or some of your personal data) and have right to data
portability (if you ask us to do so, we will pass on your personal
information in a structured, usable format to provide it to another
administrator, as long as this is technically possible). You may also have
rights to object to your personal information being used (if you object, we
will no longer process your personal data unless there are compelling and
prevailing legitimate grounds for the processing, or the data is necessary
for the establishment, exercise or defence of legal claims), to ask for the
transfer of personal information you have made available to us and to
withdraw consent to the use of your personal information. You can
exercise these rights directly with us by submitting a request at
support@mundfish.com.
Subject to applicable law, you also have the right to restrict our use of
information that constitutes your personal data for marketing purposes
and lodge a complaint or direct questions to the data protection authority.
If you believe that we have not processed your personal data in
accordance with the applicable legislation, you may submit a complaint to
the data protection authority through the website
http://www.dataprotection.gov.cy/.
We may also process information that constitutes your personal data for
direct marketing purposes, provided that you have a right to object to our
use of your personal data for this purpose. You can withdraw your consent
at any time by following the ‘unsubscribe’ link that is provided in emails
from us or contacting us by emailing to
support@mundfish.com.
Please note that even if you unsubscribe from all our personalized
marketing emails, messages, or offers, we will still send you some
notifications, for example to confirm purchases or changes in your
Account, give warranty or security information, information about changes
to the Terms of Use and Privacy Policy, as well as will show to you non-
personalized marketing web offers. We will be able to stop all electronic
communications only after your Account is deleted.
We are obliged to respond to your requests without undue delay. In most instances, we will respond within one calendar month. If we are unable to deal with your request fully within a calendar month (due to the complexity or number of requests), we may extend this period by a further two calendar months. Should this be necessary, we will explain the reasons for such a delay. If you make your request electronically, we will, where possible, provide the relevant information electronically unless you request otherwise.
We keep most of your personal data collected and
processed for the purposes described in this Privacy Policy for as long as
you continue to use our Services, e.g.,you have an active Account. After the
retention period, your personal information will either be securely deleted
or anonymised and it may be used for analytical purposes. You must back
up your data if you wish to keep it for longer.
We will delete your personal data after you request to delete your Account
and the grace period of 90 (ninety) calendar days, during which we can
restore your Account, expires. The process of erasing your personal data
can take up to one month from expiry of the grace period and, considering
the complexity and number of requests, may be extended by a further two
months.
You may use the Services only if you are over the age of eighteen (18). We recognize the privacy interests of children and encourage parents and guardians to take an active role in their children’s online activities and interests. If we learn that we’ve collected personal data from a child under the age at which under the applicable law a child cannot give their own consent, we will take reasonable steps to delete it. Parents who believe that we may have collected personal data from a child can submit a request that it be removed, please contact us directly at support@mundfish.com.
We may change this Privacy Policy from time to time as laws, regulations and/or our business evolves. We will post the changes to this page and encourage you to review our Privacy Policy periodically to stay informed. If you have any questions about us, our Website, our Services or this Privacy Policy, please contact us by emailing to support@mundfish.com.
The California Consumer Privacy Act (“CCPA”) provides additional rights to know, delete and opt-out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise rights. We do not generally sell information as the term “sell” is traditionally understood. To the extent “sale” under the CCPA is interpreted to include the activities set out in this Privacy Policy, we will comply with applicable law as to such activity. We disclose the following categories of personal information for commercial purposes: identifiers, customer records, commercial or transactions information, internet activity, geolocation data, and inferences drawn. You have the right to know certain details about our data practices in the past 12 months. In addition, you have the right to delete the personal information we have collected from you. To exercise any of these rights please submit a request via email at support@mundfish.com. In the request, please specify which right you are seeking to exercise and the scope of the request. We may require specific information from you to help us verify your identity and process your request.