CSCMobi – Privacy Policy

Last Revised: June 2023

CSCMOBI VIET NAM TECHNOLOGY JSC and its subsidiaries and affiliates (collectively, “CSCMobi”, “we”, “our” or “us”) develops, publishes and operates social games for web and mobile environments (“Games”), as well as web and mobile applications (each, an “App”) for playing our Games across multiple devices and platforms (such as mobile devices and Facebook).

We also operate the website www.cscmobi.com, their subdomains, and related features, as well as an online store (collectively, “Sites”, and together with the Games and App, collectively – the “Services”).

CSCMobi respects your privacy and is committed to making our practices regarding your data more transparent and fair. This Privacy Policy describes how we collect, store, use and share your personal data, and it applies whenever you visit our Sites, install our App and play our Games, interact with us or otherwise access or use any of our Services.

We highly recommend that you carefully review and comprehend this Privacy Policy before proceeding. If you are not in agreement with the provisions stated in this Privacy Policy, we kindly ask you to refrain from using our Services. You retain the right to discontinue your use of our Services at any given time, as specified in this Privacy Policy.

CSCMobi responsible for deciding how we hold and use Personal Data about you. We are required under certain data protection legislation to notify you of the information contained in this Privacy Policy. You are not legally required to provide us with any Personal Data, but without it we will not be able to provide you with the full range or with the best experience of using our Services (for instance, you may still play our Games without connecting your Twitter account, Facebook account, but you will not be able to enjoy their social features).

1. Data Collection

We collect four main categories of data (and to the extent it may enable the identification of a specific person, or is linked to such potentially identifying data, we will deem it as “Personal Data”):

1. Data automatically collected or generated:
   When someone visits, interacts with or uses our Services, including any e-mail or text messages sent to them by us or via our Services, we may collect or generate technical data about them. We collect or generate such data either independently or with the help of third party services, including through the use of “cookies” and other tracking technologies (as further detailed below).
   
   Such data consists of connectivity, technical or aggregated usage data, such as IP address, in-game identifier, game statistics, game preferences, unique advertising ID (e.g. IDFA; you may reset such ID based on the operating system instructions ), non-identifying data regarding a device, operating system, browser or App version, mobile carrier, locale and language settings, user activity on our Services, in-App or Game activity (such as game play content/product interaction and advertising data); diagnostic data (i.e. crash data and game performance data). We do not use such data to learn a person’s true identity or contact details, but mostly to have a better understanding on how our users typically use and engage with our Services. The use of such technical and device data also helps us and our partners to deliver interest-based or otherwise more effective advertisements and content, to optimize our ad management and our users' viewing experience), and to improve the overall performance and your user experience of our Services. For more information about our advertising uses, please see Section 7 below.
2. Data received from you:
   You may provide us Personal Data voluntarily, such as when you set up an account with us, contact us (through Facebook, Messenger, e-mail, in-game chat or any other channel, including any support services), when you post on our public forums or groups, when you provide us your e-mail address (such as when you sign-up to receive e-mail updates or gifts), when you participate in competition, contest, tournaments and other promotions, when you place any purchases in any of our Games, when you interact with other users through the in-game chat or when you choose to connect your Facebook, Google, Apple or similar account to any of our Games.
3. Data received from Facebook and other channels:
   Once you connect the Games to your Facebook, Google, Apple or similar account, we will receive access to your public profile, including (to the extent you defined it as “public”), as applicable, your full name, e-mail address(es) provided to Facebook, Google or Apple, gender, profile picture or similar photo, location, time zone, and a list of your friends playing the Games (along with their photos and other public profile information). This will also allow us to present your and your friends’ public profile pictures inside the Games and to create your in-game friends list. In addition, we or our advertising partners may receive from Facebook and our other marketing channels general information concerning the performance of our advertising campaigns, such as the targeted age group or interests, and we or our partners may be able to link such general data to any other data in our possession. To learn more about our advertising practices, please refer to Section 8 below. If you access our Services through a third party such as Facebook, Google or Apple, or connect our Services to any third-party account, you should also read their terms and conditions and privacy policies. If you are unclear about what information a third-party application is sharing with us, please visit that third-party application's website in order to learn more about their privacy practices.
4. Transaction Data:
   In-Game purchases will typically be processed by the relevant platform provider (e.g. Apple, Google or Facebook), and we will not collect or store your financial data, e.g. your credit card numbers or bank account. We may still however receive your non-financial Personal Data related to the purchase, such as your name, billing address, e-mail address and the items purchased, in order to fulfil your purchase and for our accounting purposes.

2. Data Uses

Our legal basis for collecting and using your Personal Data will depend on the particular purpose for which your data is being processed, however, we generally use the following:

1. Performance of a contract. We will use this basis for processing necessary to make the Games, including social gaming when you choose to log in with Facebook, Google or Apple, and support services, available to you, and to send you service communications, gifts and awards.
2. Consent. In limited cases (where you choose to sign up to receive direct marketing emails, where you accept cookies on our Sites, we will process your Personal Data based on your consent. You can withdraw your consent at any time by contacting us using the details in Section 13.
3. Legitimate interests. We will process your Personal Data based on our legitimate interests in maintaining and improving our Services and offerings, understanding how our Services are used, serving effective advertisements within our Games and through other channels, matching users to create in-game friends lists, improving our customer service and support operations, fraud detection and protecting and securing our users, ourselves and our Services.
4. Compliance with a legal obligation. In limited cases we may process your Personal Data where we need to do so to comply with a legal obligation e.g. which is set out in an applicable law, or if we receive an order from a court or regulatory body.

The purposes for which we use Personal Data are described in more detail below:

1. To facilitate, operate, and provide our Services;
2. To authenticate the identity of our players, and allow them access to additional features;
3. To provide our users with customer care, assistance and technical support services;
4. To enable you to interact with other players in the game;
5. To further develop, customize and improve the Services and your user experience, based on common or personal preferences, experiences and difficulties, including by personalizing your profile and friends list;
6. To manage and deliver advertisements more effectively, including contextual, behavioral and interests-based advertising based on in-Games progress and activity, based on your preferences or other data available to us or to our Service Providers, including for re-targeting purposes;
7. To contact our users (via e-mail, Facebook, push notifications or any other available channels) with general or personalized service-related messages (such as purchase confirmations or system maintenance notices); to contact our users with promotional messages (such as Games updates, bonuses, new features, VIP services, etc.); and to facilitate, sponsor and offer certain events and promotions;
8. To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
9. To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our Service Providers may use to provide and improve our respective services; and
10. To comply with any applicable laws and regulations.

3. Storage and Retention

While privacy laws may vary between jurisdictions, CSCMobi has taken reasonable steps to ensure that your Personal Data is treated by its affiliates and Service Providers in a secure and lawful manner, and in accordance with common industry practices, regardless of any lesser legal requirements that may apply in their jurisdiction.  

We retain your Personal Data in order to maintain our relationship and to provide you with our Services. We will retain your Personal Data for only as long as necessary to fulfil the purposes for which we collected it. In other words, we will retain your Personal Data for as long as you remain our user and have not notified us otherwise. We will take reasonable measures to delete your Personal Data if you delete your account. We may also retain your Personal Data for legal and accounting purposes (i.e., as required by laws applicable to record and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), in accordance with our Data Retention Policy. If you have any questions about our Data Retention Policy, please mail to request@cscmobi.com

Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and are free to securely delete it for any reason and at any time, with or without notice to you.

In some circumstances, we may anonymize your Personal Data so that it can no longer be associated with you, in which case we may use such information without further notice to you and it is no longer considered Personal Data within the meaning of this Privacy Policy.

4. Personal Data Deletion and Closure of Accounts

1. In addition to any other rights set out in this Privacy Policy (except as set out in the Candidate Privacy Addendum), you at any time may direct that CSCMobi delete your Personal Data by accessing the “Account Deletion” button in the applicable Game and following the instructions.  Selection of this option will result in closure of your Account and deletion of all of your playing history, purchase information, social media log-in and other information associated with you in connection with the Game.  Deletion is irreversible. If you maintain Accounts with multiple Games, you should request closure of each.

   Upon receipt of your request, we will comply promptly but please allow some time for processing.  We also reserve the right to retain a copy of any Personal Data that we are required by applicable law to retain.

2. User data deletion

   The user of has the authority to manage, use and delete the data generated in the application. If the user no longer needs the account data in the app, the user can delete or remove it. Data range that can be deleted: 1) The basic information of the user's Facebook account obtained by the application; 2) User account login record; 3) All user operation records in the app, such as level records, purchase records, etc.

   There are notes users should be aware before deleting or removing users. Depending on users' account, deleting, or removing users may have the following effects: 1) The application will delete all user data; 2) Before deleting the user data, you may need to transfer some data; 3) The system will not delete certain data, such as application-related content shared by users on Facebook; 4) After user data is deleted, it cannot be recovered.

   Steps to delete the data in the app: 1) Go to your Facebook profile, and find Apps and Websites page at the Facebook Settings; 2) Remove our app; 3) Click the Removed sub-tab, find our app, and Send Request to delete data.

5. Data Sharing

We may share your data with certain third parties, including law enforcement agencies, our Service Providers and our affiliates. The circumstances in which we share data are summarised below:

1. Compliance with Laws, Legal Orders and Authorities: We may disclose or allow government and law enforcement officials access to certain Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations, including for national security purposes. Such disclosure or access may occur with or without notice to you, if we have a good faith belief that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
2. Service Providers: We may engage selected third party companies, contractors and individuals to perform services complementary to our own (e.g. hosting services, data analytics services, marketing agencies and advertising services and tools, data and cyber security services, fraud detection and prevention services, payment processing services, customer support partners, external moderators and testers, user engagement services, e-mail distribution and monitoring services, session recording, and our business, legal, financial and compliance advisors) (collectively, “Service Providers”). These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and complementing our Services, and may only process your Personal Data for the purposes for which we have instructed them. We may also share anonymous, statistical or aggregated information with our Service Providers for legitimate business purposes. 
3. Third Party Integrations: The Services allow you integrate with certain third party services, such as in order to connect your Facebook, Google or Apple account to a certain Game, Login with Google, Facebook or sign in with Apple or to place purchases, in which case you will be bound by the terms and conditions and privacy notices of said third parties (e.g., Apple, Google or Facebook) – so please make sure that you read and accept them in advance. We do not receive or store your passwords for any of these third party services.
4. Protecting Rights and Safety: We may share your Personal Data with others, with or without notice to you, if we believe in good faith that this will help protect the rights, property or personal safety of CSCMobi, any of our users or any members of the general public.
5. CSCMobi Subsidiaries and Affiliated Companies: We may share Personal Data internally within our family of companies, for the purposes described in this Privacy Policy. In addition, should CSCMobi or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Data may be shared with the parties involved in such event. If we believe that such change in control might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via e-mail and/or prominent notice on our Services.

For the removal of doubt, CSCMobi may share your Personal Data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data in our sole discretion and without the need for further approval.

6. Communications

1. Service Communications: We may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, billing issues, etc. You will not be able to opt-out of receiving such service communications.
2. Promotional Communications: If you have signed up to receive such communications from us, we may also notify you about new services, events and special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone, mobile or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.

You have the right to withdraw your consent to receiving such promotional communications at any time.  You can do this by contacting us at  request@cscmobi.com or by following the “unsubscribe”, “stop” or “change e-mail preferences” instructions in the promotional communications you receive.

7. Cookies and Tracking Technologies

Our Services and some of our Service Providers utilize “cookies”, anonymous identifiers and other tracking technologies (collectively, “Tracking Technologies”) which help us provide and improve our Services, personalize your experience and monitor the performance of our activities and campaigns, as well as the usage of our Apps, Games and Services as a whole. To learn more, please visit our Cookie Policy.

8. Data Security

In order to protect your Personal Data held with us and our Service Providers, we use appropriate physical, procedural and electronic security measures, including encryption where deemed appropriate.. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties. If you discover any security or vulnerability issues related to the Services you should send an email to: request@cscmobi.com

9. Advertising

Our Games include advertising for third party services and products. We and our advertising partners use certain data about you in order to improve our advertising practices and make the ads we deliver more effective, relevant and enjoyable, including by deploying interest-based advertising, as well as targeting and ad measurement and attribution systems.

Such data includes your device advertising identifiers (e.g. IDFA or Advertising ID), to the extent available), data related to your connected Facebook, Google or Apple profile (if any, such as your gender, region or country), gameplay content, user in-game ID, product interaction data and other demographic and interests-based information that we or our advertising partners may have received from or about you, based on your consent or another legal basis (i.e., as required in order to provide you with our respective services, or based on the legitimate interests that we described above).

The ads we or our advertising partners deliver may be shown within our Games, our Services, or through other channels, such as third party websites and applications.

This Privacy Policy does not apply to the practices of companies that we do not own or control, or to employees or Service Providers that we do not manage. Any information you provide to sites, applications or services advertised through our Services will be covered by the applicable privacy policies specified therein. Please be sure to read the privacy policies of any third-party applications, services and sites that you visit or provide permission to access your information. It is those third parties’ responsibility to protect any information you give them, so we will not be held liable for their use of your personally identifying information. To learn more, please visit our Cookie Policy.

1. How to adjust your preferences regarding interest-based advertising
   If you wish to prevent the use of your device’s advertising ID or other identifiers for interest-based advertising, you may change your device settings to reset such advertising ID or opt-out of such advertising (typically, this is available under the “Privacy” or “Ads” section in your device settings). If you live in the USA, Canada or Europe, you can also opt-out from the collection of your data by our advertising partners who participate in the Digital Advertising Alliance, by visiting www.aboutads.info/choices (for US users), www.youradchoices.ca/choices (for Canadian users), www.youronlinechoices.eu (for European users).
   
   Please note that if you reset your advertising ID or opt-out of interest based advertising, you may still see advertisements in our Games, or on any other channels, but those ads will not be targeted based on the above mentioned identifiers. For example, such ads may be instead based on context, such as your progress and actions in the Games, or your language preferences. Please note that such actions may result in a less enjoyable user experience.
2. Aggregated and analytical information
   We use the standard analytics tools of Google Analytics and may use other analytics tools from time to time. The privacy practices of these tools are subject to their own privacy policies. To learn more, please visit our Cookie Policy.
3. Google Products
   Google uses technologies such as cookies in order to track and analyse the use of our Site and/or an SDK to serve ads within our Games. To learn more about how Google processes data, we recommend you review Google’s policies located at:  https://policies.google.com/technologies/partner-sites. For additional information, please see Google Analytics’ opt-out web tool available at:  https://tools.google.com/dlpage/gaoptout. For additional information regarding the data which Google SDK processes and stores see: https://support.google.com/admob/answer/7665968

10. Data Subject Rights – European Economic Area, Switzerland and United Kingdom

If you are a resident of the European Economic Area (EEA), Switzerland or the United Kingdom (UK) about whom we process Personal Data, you have the right to:

1. Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
2. Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
3. Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
4. Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
5. Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
6. Request the transfer of your Personal Data to another party.
7. No fee usually required.
   You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
8. What we may need from you.
   We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.
9. Right to Withdraw Consent.
   Please see Section 14 below.

If you wish to exercise your rights under applicable law (e.g., the General Data Protection Regulation (GDPR) or the UK GDPR) please contact us here.

If you wish to manage the information we receive about you from a third-party application or platform where you play our Games, such as Facebook, Apple or Google, please follow the third-party application’s instructions for updating your information and changing your privacy settings.

11. Data Transfers

Your Personal Data may be maintained, processed, accessed and stored by CSCMobi and our authorized affiliates and Service Providers in and from the United States and other jurisdictions, as necessary for the proper delivery of our Services, or as may be required by law. CSCMobi is based in a jurisdiction which is considered by authorities of the UK, Switzerland and the European Commission to be offering an adequate level of protection for the Personal Data of residents of the EEA and UK.

We may transfer Personal Data we collect about you outside the EEA, Switzerland or UK,  in order to perform our contract with you. To ensure that your Personal Data receives an adequate level of protection, we have put in place the following measures to ensure that your Personal Data is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection: Standard Contractual Clauses and countries that are the subject of an EU adequacy determination. If you require further information about the protective measures, you may contact us using the details in Section 14.

12. Minors

Our games are intended for individuals aged 16 and above. We reserve the right to request proof of age or parental consent at any stage. We may block Users whom we suspect are under the applicable age. We do not knowingly collect Personal Data from minors and do not wish to do so. If we learn that a minor is using the Services or playing any of our Games, we may prohibit and block such use and will make all efforts to promptly delete any Personal Data stored with us with regard to such minor.

If you believe that we might have any such data, please contact us at request@cscmobi.com

13. Amendments and Controlling Version

We may amend this Privacy Policy from time to time by posting an amended version on our Services. The amended version will be effective as of the published effective date. We will provide an advance notice if any substantial changes are involved, via any of the communication means available to us, or on the Services. After this notice period, all amendments shall be deemed accepted by you. If you do not agree to be bound by the terms of the new or modified Privacy Policy, you are required to stop using the Services.

The Privacy Policy has been drafted in the English language, which is the original and controlling version of this Privacy Policy. All translations of this Privacy Policy into other languages shall be solely for convenience and shall not control the meaning or application of this Privacy Policy. In the event of any discrepancy between the meanings of any translated versions of the Privacy Policy and the English-language version, the meaning of the English language version shall prevail.

14. Right to Withdraw Consent.

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact info@moonactive.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

15. Contact Us

If you have any comments or questions about this Privacy Policy or if you have any concerns regarding your Privacy, or to contact CSCMobi’s Data Protection Manager, please contact us at info@cscmobi.com