Privacy Policy for North American Users Only 

Last Updated on: 30.10.2023

Thank you for using our games, websites, marketing and advertising activities, and/or our related services ("Service" or "Services").

Mytona Ltd. ("Mytona", "we," "us," or "our") adopts this Privacy Policy (“Privacy Policy") , which sets out our privacy practices and explains how we handle the information we collect when you visit our websites and/or use our Services. This Privacy Policy applies to personal information relating to individuals who reside only in the United States of America ("consumers" or "you") and is governed by and incorporated by reference into the Terms of Use available here, and should be interpreted consistent therewith. Your use of the Services and your other interactions with us constitute your acceptance of this Privacy Policy and consent to the practices described herein. You also represent that you are a person of legal age in your jurisdiction and not a person barred from receiving services under the laws of the United States or other applicable jurisdictions. 

This Privacy Policy covers the following topics:

1. INFORMATION WE COLLECT

2. DISCLOSING PERSONAL INFORMATION

3. RETENTION

4. CHILDREN’S PRIVACY

5. YOUR RIGHTS 

6. HOW TO EXERCISE MY RIGHTS 

7. RESPONSE TIMING AND FORMAT

8. DO NOT TRACK SIGNALS. 

9. CHANGES TO THE PRIVACY POLICY

10. CONTACT INFORMATION

1. INFORMATION WE COLLECT

When you visit our website and/or use our Services, we may collect personal information about you. For the purposes of this Privacy Policy, "personal information" includes information that identifies, relates to, describes, references, is capable of being associated with, and could reasonably be linked, directly or indirectly, with a particular consumer or device.

We do not share your personal information for cross-context behavioral advertising. 

We do not sell or share the personal information of consumers under 16 years of age. 

We do not collect, sell, disclose or share sensitive personal information. 

In particular, we have collected the following categories of personal information from our consumers within the last twelve (12) months:

We obtain the personal information listed above directly from you when you submit it to us and indirectly from you (for example, through cookies or other tracking mechanisms). 

Information You Provide to Us

The information we collect on or through our website and/or Services may include:

• Information that you provide by filling in forms related to our Services. This includes information you provide at the time of setting up your account and/or making a purchase. 

• Records and copies of your correspondence (including e-mail addresses), if you contact us.

• Your responses to surveys that we might ask you to complete for research purposes.

• Details of transactions you carry out through our Services and of the fulfillment of your orders. 

• Your search queries on the Services. 

• You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Websites, such as “Comments”. You should exercise caution when deciding to disclose your personal details.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Websites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Services, including traffic data, location data, logs, and other communication data and the resources that you access and use with the Services.

• Information about your device and internet connection, including your IP address, operating system, and browser type.

• Gameplay data, meaning data on your interaction with any game. 

You may not find third-party website links on all of the pages of our Websites. However, where they are provided, this Privacy Policy does not cover the information privacy practices of any of those third-party websites or those you may otherwise be able to access from our Websites. We do not control, and are not responsible for, any such third-party websites' collection and/or use of your information. All users should timely refer to the Privacy Policy disclosures on those websites in order to obtain information regarding their personal information collection and use practices.

The information we collect automatically does not include personal information, but we may maintain or associate that information with personal information we collect in other ways. Doing so helps us to improve our Services and to deliver a better and more personalized Service, including by enabling us to estimate our audience size and usage patterns, store information about your preferences, allowing us to customize our Services according to your individual interests, speed up your searches, and recognize you when you return to our Services.

Cookies. Cookies are files with small amounts of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device's hard drive. Like many sites, we use “cookies”  to recognize your logged-in state on our website, to understand what Services you are interested in, to make our Services function for you, and to help your browsing experience and use of our Services feel more customized. You may be able to instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services. You can obtain more information about cookies at http://www.allaboutcookies.org/ and our Cookie Policy at https://mytona.com/cookie-policy.

We DO NOT use the Google Analytics Advertising Features or other similar technologies on our websites. 

Third-Party Use of Cookies and Other Tracking Technologies. Some content or applications, including advertisements, on the Services are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising and/or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

For more information about how we use your personal information, see Section 2 of the Privacy Policy.

2. DISCLOSING PERSONAL INFORMATION 

We do not sell your personal information. For purposes of this Privacy Policy, “sold,” “sell,” or “sale” means the disclosure of personal information for monetary or other valuable consideration but does not include, for example, the transfer of personal information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business. 

We do not share your personal information for cross-context behavioral advertising,  meaning we do not target advertising to you based on your personal information obtained from your activity across different third-party services, other than our Services. 

As a rule, we don’t disclose your personal information outside the company. However, we may disclose your personal information to third parties in limited circumstances, including: (1) with your consent; (2) to a vendor or partner who meets our data protection standards; and/or (3) when we have a good faith belief it is required by law, such as pursuant to a subpoena or other legal process.

We may disclose your personal information for business purposes to third parties such as Mytona affiliates, service providers such as data processors and/or aggregators, advertising networks, internet providers, data analytics providers, operating systems and platforms, social networks, and other third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you, etc. When we disclose personal information for business purposes, we enter into a contract that describes the purposes of such information collection and requires the recipient to both keep that personal information confidential and not use it for any purpose except as provided in the executed contract. 

3. RETENTION.

We will retain your personal information for as long as your account is active or as needed to provide you Services and as necessary to comply with our legal obligations, resolve disputes and/or enforce our agreements. If you wish to cancel your account or request that we no longer use your personal information to provide you Services, you may contact us as specified in Section 10 below. 

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. 

When you delete data, we follow a deletion policy to make sure that your data is safely and completely removed from our servers or retained only in anonymized form. However, please note even after you have closed your account or have stopped using our Services, we may continue to store your personal data if doing so is necessary for us to fulfill our legal obligations.  We may be required to keep your information for as long as necessary (i) to comply with our legal and regulatory obligations,(ii) to make or defend legal claims, (iii) to protect against the fraudulent activity of any account holder and/or others, (iv) to enforce our Terms of Service and this Privacy Policy, (v) to administer our Services and keep them safe and secure, and for internal operations (including, but not limited to, research, statistics, troubleshooting, data analysis, testing, survey and similar purposes); and (vi) to disclose as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to protect our operations and/or those of any of our affiliated parties; (c) to protect our rights, privacy, safety and/or property, and/or that of our affiliated parties, users or others; and/or (d) to allow us to pursue available remedies or limit the damages that we may sustain.

Please note that we may maintain and use de-identified data, as defined under applicable law, without attempting to re-identify the data.

4. CHILDREN’S PRIVACY 

By using our Services, you represent that you are at least 16 years old. The Websites are not directed toward children under 16 years of age nor do we knowingly collect information about children under age 16. If you are under 16 years of age, you are not permitted to submit any personally identifiable information to us, including, but not limited to, your name, address, telephone number, e-mail address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under age 13 without verification of parental consent, we will delete it immediately. If a parent or guardian becomes aware any of his/her/their children have submitted personal information to us, please immediately notify us at legal@mytona.com or otherwise as specified in Section 10 below.

5. YOUR RIGHTS. 

Some states have enacted privacy laws that provide consumers with specific rights regarding their personal information. The scope of your rights may vary depending in which state you reside. This section generally describes your rights and explains how to exercise those rights.

• Right To Know What Information We Collect, With Whom We Share Your Information, And The Right To Data Portability – You may request that we disclose to you the categories of personal information we collected about you, the categories of sources from which we collected that personal information, the categories of personal information we sold or disclosed, our business or commercial purposes for collecting and selling/disclosing such personal information, the categories of third parties with whom we sold/disclosed/shared such personal information, and the specific pieces of personal information we collected about you over the past 12 months. If we fulfill a request for a copy of the data we hold, we will provide it to any account you have with us. If you do not have an account with us, we will provide the data in a manner which allows for a good degree of data portability. 

• Right To Request Deletion Of Your Information – You may request we delete some or all of the personal information we maintain about you, subject to certain exceptions. If we cannot delete all of your personal information, we will give you a reason why we cannot do so. For security reasons, you or your authorized agent may be asked to verify your/their identity. Note that some personal data may be retained as permitted by law (e.g. to comply with legal obligations, to prevent fraud, etc.).  We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: 

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal or state law, or otherwise perform our contract with you.

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and/or prosecute those responsible for such activities.

• Debug products to identify and repair errors that impair existing intended functionality.

• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, and/or exercise another right provided by law.

• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

• Comply with the law, a court order or any other legal obligation(s).

• Make other internal and/or lawful use(s) of the information which are compatible with the context in which you provided the personal data.

• We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

• Opt-out of “Sale”/ “Sharing” of your personal information ––We do not currently consider the ways we shared consumer personal information in the past 12 months to comprise the “sale” of personal information. For purposes of this Privacy Policy, “sell” means the sale of your personal information to an outside party for monetary or other valuable consideration, subject to certain exceptions in applicable privacy laws. 

• Right to Correct Inaccurate Personal Information. Taking into account the nature of the personal information and the purposes of the intended processing, this right provides an individual with the ability to seek to correct or update personal data that individual considers we hold about that individual.

• Right to Limit Use of Sensitive Information. This right is limited to sensitive personal information used for the purpose of inferring characteristics about an individual. We do not collect sensitive personal information nor do we use sensitive personal information for the purpose of inferring characteristics about an individual, therefore we do not offer a path to exercise this right.

• Right of Non-Discrimination and Non Retaliation. This right prohibits (a) denying an individual access to or use of goods and services, (b) charging different prices or rates for those goods and services, and/or (c) providing a different level or quality of those goods or services, as a result of the individual exercising any right(s) under any data protection and/or privacy laws and/or regulations. We will not discriminate against you because you made any of these requests. We will not: (i) deny you goods or services; (ii) charge you different prices or rates for those goods or services, including through granting discounts or other benefits, or imposing penalties; (iii) provide you a different level or quality of our goods or services, or (iv) suggest that you may receive a different price or rate for our goods or services or a different level or quality of our goods or services. However, we may offer you certain financial incentives that can result in different prices, rates, or quality levels. Any permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

• Shine the Light. California's “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us as specified below in Section 10.

• Right to opt out of the processing of your personal data for the purposes of targeted advertising and for profiling in furtherance of decisions, including, solely automated decisions that produce legal or similarly significant effects.

• Right to appeal any decision or indecision related to the exercise of any right the consumer is granted under the applicable state law.

• Right to access. You have the right to confirm whether or not we are processing your personal information and access to such personal information. Please note that this right might be subject to certain limitations. 

6. HOW TO EXERCISE MY RIGHTS 

If you would like to exercise any of these rights (including the right to appeal), please contact us as specified below in Section 10.

We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain personal information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, to process transactions and/or facilitate customer requests, and/or to protect against fraud and other misuse of our Services.  We will take reasonable steps to verify your identity prior to responding to certain of your requests. The verification steps will vary depending on the sensitivity of the personal information. In some locations, you may designate an authorized agent to make a request on your behalf. When submitting such a request, please ensure you have adequately identified and authorized anyone acting on your behalf.

7. RESPONSE TIMING AND FORMAT. 

We will confirm receipt of your request to know, correct, delete and/or seek any request under the relevant U.S. state privacy law(s) within ten (10) business days. If you do not receive confirmation within that 10-day timeframe, please contact us at support@mytona.com     . We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of receipt. If we require more time (up to another 45 days), we will timely inform you of the reason(s) and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response electronically. 

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

8. DO NOT TRACK SIGNALS. 

Some browsers have a “do not track” feature that lets you tell those websites you do not want to have your online activities tracked. At this time, we do not respond to browser “do not track” signals as there is no agreed upon program for this limited purpose.

9. CHANGES TO THE PRIVACY POLICY. 

We reserve the right to make changes to this Privacy Policy depending on the circumstances and at any time. We will incorporate the changes into the  Privacy Policy, and will post the updated version. Your continued use of our application after the changes have been implemented leads to your acceptance of those changes..

10. CONTACT INFORMATION. 

If you have any questions or comments about this Privacy Policy, the ways in which we collect and/or use your personal information as described in this Privacy Policy, your choices and rights regarding such use, and/or wish to exercise your rights, please do not hesitate to contact us at: 

Website: www.mytona.com     

Email: legal@mytona.com     

Postal   address:

Level 5, 129 Hurstmere Road, Takapuna, Auckland 0622, New Zealand

Attn: Mytona Limited, Legal Department.      

If you need to access this Privacy Policy in an alternative format due to having a disability, please contact us at support@mytona.com or https://mytona.com/ccpa-request.