If you are a resident of the United States of America, this privacy notice refers to you.
Effective date: 05/25/2018
Last updated: 24/09/2025
Policy Overview:
1. Introduction
2. The Information We Collect and Receive
3. Controllership
4. How We Use Your Personal Data and on Which Legal Basis
5. Third-Party Recipients of Your Data
6. Social Network Integrations
7. Data Retention
8. Data Integrity & Security
9. International Data Transfers
10. General Privacy Rights
11. Children and Minors
12. Location-Specific Data Privacy Regulations
13. How to Contact Us
14. Changes to This Policy
Thank you for using our games, websites, social media pages, and for participating in our marketing and advertising activities.
1. Introduction
1.1. This policy describes:
what personal data Mytona Limited, its affiliates and third parties collect when you interact with us on your mobile device, computer, or any other device platform or website, and why we collect it;
how we use that information; and
how you can exercise your privacy rights.
1.2. By installing, using, or otherwise accessing the Services, you accept the provisions of this Privacy Policy.
1.3. If you have any concerns about how your personal data is used as described in this Privacy Policy, please contact us using the information provided in Section 12 before deciding whether to continue using our Services.
1.4. You may access our Services from various device types (e.g., mobile phones, tablets, computers). The categories of data collected and the purposes of processing remain consistent across devices, as described in Sections 2-4.
1.5. Definitions:
Personal data: any information relating to an identified or identifiable natural person.
Processing of personal data: any operation or set of operations that is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
Data controller: the natural or legal person, public authority, agency, or other body that, alone or jointly with others, determines the purposes and means of the processing of personal data.
Data processor: the natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller.
Data subject: the natural person to whom the personal data relates.
Consent: any freely given, specific, informed, and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
Services: refers to our games (Cooking Diary, Seekers Notes, OutFire, Ravenhill, Chef & Friends), Mytona's websites, the websites of our games, and any other services offered by Mytona.
Consent Management Platform (“CMP”): A software/service layer that presents privacy notices and choices and collects, stores (with timestamp and scope), and transmits users’ consent and preference signals to our apps/SDKs and partners using industry frameworks (e.g., IAB TCF in the EEA/UK and applicable U.S. state strings), where offered or required by law. The CMP enables users to review/withdraw choices at any time and, where required, honors recognized browser/app opt-out signals (e.g., Global Privacy Control). For minors, consent flows for targeted advertising are not shown (see Section 1.4).
App Tracking Transparency (“ATT”): Apple’s system-level framework on iOS/iPadOS/tvOS that requires an app to obtain the user’s permission before tracking activity across other companies’ apps and websites or accessing the Identifier for Advertisers (IDFA) for advertising or measurement. Permission is requested via Apple’s ATT prompt, and the app must respect the resulting tracking authorization status.
2. The Information We Collect and Receive
We may collect and receive information that may be considered personal data according to applicable laws in a variety of ways.
2.1. When you play our Services and interact with us, we may collect and store:
2.1.1. Personal data that you provide directly to us:
information when you sign up for an account in our Services or websites (e.g., usernames, passwords, information about logins via Google, Apple ID, Weibo, etc.);
information when you customize your profile (e.g., photo, name, personal settings);
email address, if you decide to provide it; If you choose to link/sync your account, we may use your email address for customer support and account recovery purposes (e.g., to help restore access)
content and messages that you create and share within our Services (e.g., chats, friend connections, support messages), on our social media pages (e.g., likes, comments, posts, chats, etc.), or in app stores reviews, or messages sent to us via other services (such as Helpshift or emails).
2.1.2. Personal data that is collected from you or created automatically:
usage information (such as gameplay data, game progress, levels, scores, session length, taps, in-game references, or game preferences);
information about in-game advertisements you may have viewed;
your IP address, Internet status, time zone, broad geographic location (e.g., country or city-level location), cookie identifiers. Note: We use IP addresses to derive coarse geolocation (country/city) for legal compliance (e.g., regional content and parental protections), security and fraud prevention, and to maintain service integrity;
device information, including type of device, device model, device operating system, device settings, language, or other technical data such as screen size or processor, or a combination of this data available from a device for a developer for checking device compatibility with a particular application, application IDs, device ID, Advertising ID (a unique identifier associated with your device that advertisers use for interest-based advertising), Vendor ID, Support ID;
information about how often you interact with us, pages visited, links clicked. We may also collect data about how you interact with messages we send to you, for example, whether you opened an email or read an in-app message.
The extent of the information collected may depend on your device type and settings. These technologies allow us and third parties (including marketers and advertisers) to recognize your device when you use websites and applications, enabling cross-app tracking. You can control the data collected by adjusting your device settings or opting out where applicable.
2.1.3 Minors - Advertising Identifiers (not collected): for minors (under 18, or any higher age required by local law), we do not collect, store, or share mobile advertising identifiers (e.g., IDFA, AAID) with third-party advertising or measurement partners, and we do not use such identifiers for profiling or cross-site/app tracking. We also do not show ATT prompts or CMP consent flows for targeted advertising to minors. See Sections 1.4 and 4.3.
2.1.4. Information we collect from our partners:
data we receive if you link a third-party application with a Service's social networking platforms, such as Facebook;
data to fight fraud (such as refund abuse in games or click fraud in advertising);
details of orders (such as items, date, amount, status, description, broad geographic location (e.g., the country or city where you live));
aggregated data for advertising and marketing purposes;
data for analytics purposes to provide you with better Services; and
data from other group companies or third-party companies who have obtained your consent or have other lawful bases on which to share your personal data with us (including publishing partners, platforms, advertising platforms, partners, and data aggregators). This may include attributes about you and your interests, as well as other games and services you use, demographic and general location information.
2.2. When you visit our websites or our social media pages, we may collect and store:
feedback and other information you provide through our websites;
information automatically collected and stored when you use our websites from your device or browser, including your device's model, operating system, screen size, browser type, information on how you use the website. For more information about our analytics and use of cookies, please click here.
Also included is information provided during your interview as a candidate for our company (such as your name, your past experience, and any other information provided in your CV). During the interview, we also use a text transcript of the conversation with you, which may contain personal information about you. We restrict access to this data and regulate its storage in accordance with our internal data retention policy.
2.3. If you are representatives of our Business Partners, Vendors, or Corporate Customers, we may collect and receive any information:
that you provide to us directly (such as your name, company name and position, signature); and
provided by your employer or other third parties (e.g., from publicly available sources or during networking events).
2.4. We do not collect or store any payment information from you when you purchase items via our mobile apps (such as those you can purchase in the Apple App Store, Google Play, Microsoft Store, Amazon Appstore, Facebook, or other marketplaces). All payments are processed by the respective platform's payment services, and we recommend reviewing their privacy policies for information on how they handle your data.
2.5. We use aggregated information to better understand and optimize our Services.
Some of this information may be collected using cookies, which are small files that store information on your device to help us optimize the use of our Services, and/or similar technologies (such as SDKs). Some of the cookies are "first-party cookies," set by our website, while others are "third-party cookies," set by advertising and analytics entities or social networks. Cookies are typically used to quickly identify your device and to "remember" your device during subsequent visits for purposes of functionality, preferences, and website performance. You can manage or disable cookies through your device settings or browser settings; however, disabling cookies may affect your ability to use certain features of the Services. You may read more about this in our Cookie Policy here.
2.6. Community surveys. We may conduct community surveys in-game and on our social media channels (e.g., via Google Forms). Survey participation is voluntary. We collect your survey responses and, where a prize is offered, we may collect your Support ID (internal support identifier) solely to verify eligibility and deliver the prize. After prize fulfillment, we delete the SUP ID and de-identify/anonymize the survey results for analysis.
2.7. We cannot guarantee the protection of any personal data you independently decide to make public on your account, or that you may post in comments or other social features in the Services, including but not limited to chats, forums, and blogs. We have no responsibility for how that information is used by other parties. So please be careful when you share sensitive information.
3. Controllership
3.1. In the context of this Privacy Policy, Mytona Limited (New Zealand) acts as a data controller (which means it determines means and purposes of processing your personal data), and our affiliated companies: Mytona ARM LLC, Mytona Georgia LLC, "Mytona KZ" LLP, Mytona RS, Mytona Pte. Ltd, and Mytona Thai Ltd act as data processors processing personal data on our behalf and under our instructions.
4. How We Use Your Personal Data and on Which Legal Basis
4.1. We process your personal data when it is necessary for the performance of a contract to which you are a party or to take steps prior to entering into a contract. Failure to provide the necessary personal data for the performance of a contract to which you are a party may result in an inability to use our Services.
Accordingly, we use your data for the following purposes:
providing you with the full functionality of our Services;
contacting you and interacting with you for customer service purposes or to send information about software updates, transactional messages, security alerts, and service messages, such as welcoming you to the Services or informing you of issues with your account, for example if your social account has disconnected, included but not limited to, via our Services, email, or other communication systems;
managing your account and improving your experience when using the Services;
customizing your experience with the Services;
providing you our offers in the Services as well as on other websites;
providing social features as part of the Services;
moderating chats either automatically or manually;
enabling you to communicate with other players; and
showing your score/progress in the leaderboards and rankings of our Services.
4.2. We also use your data to pursue our legitimate interests, provided that your interests and fundamental rights do not override those interests. Our legitimate interests include:
marketing our Services to current and potential users;
enhancing experiences through customer support services and product improvements;
conducting contests, analytics, research, and optimization;
keeping our contests transparent and publishing the game names of the winners on our websites and social media;
conducting internal game analytics to analyze, profile, and segment, except where our interests are overridden by your interests or fundamental rights and freedoms;
conducting research and surveys, communicating with you via email or other means;
developing new features and enhancing the Services, features, algorithms, and player experience of the Services; and
when it is necessary to do as you have requested for sending you related information, security alerts, and support messages.
4.3. With your prior consent, we may process your data for the following purposes:
Personalized Advertising:
Showing personalized advertisements in the Services and on other websites and services, including email.
Tracking the content you access in connection with the Services and your online behavior.
Delivering, targeting, and improving our advertising and the Services.
Location-Based Services:
Using your GPS location to show local events or offers.
Additional Purposes:
Processing your data for other purposes, which we will describe to you at the time of obtaining your consent.
Emailing newsletters about our Services as well as personalized offers.
You may withdraw your consent at any time through the means described in Sections 10 and 11 or by contacting us as described in Section 12. If we request additional information from you or your device, we will inform you about the information we wish to collect, why we need it, and how we will use it.
Personalized advertising is not available to minors; we only process data for personalized ads for users confirmed as 18+.
4.4. We may process your data when necessary to comply with the legal obligations to which Mytona is subject. We do so to keep our Services safe and fair, to fight fraud, prevent crime or cheating, and ensure acceptable use or otherwise take action against fraudulent or misbehaving players.
4.5. Privacy-enhancing practices. Where feasible, we apply privacy-enhancing techniques such as data minimization, on-device processing, aggregation/pseudonymization, limited retention, and differential access controls. We avoid using advertising identifiers for minors (see Section 1.4/5)
4.6. Personalized offers and pricing (non-ads). We analyze your in-game activity such as spending amounts and frequency, purchase history, progression/achievements, session patterns, and virtual currency balances to create user segments and show personalized in-game offers, which may differ in the composition of virtual items and/or in price. This constitutes profiling under applicable data protection laws. We rely on our legitimate interests (product improvement and relevant in-app marketing) as the legal basis.
We do not use special categories of personal data for this purpose, and we do not make decisions producing legal or similarly significant effects for you solely by automated means. We do not use third-party advertising identifiers for this feature and do not sell/share personal data for cross-context behavioral advertising in connection with these offers.
4.7. Minors. Personalized offers/pricing based on profiling are not applied to minors; see Section 1.4.
5. Third-Party Recipients of Your Data
5.1. We may share your information with third parties. Such third parties may include:
cloud computing service providers;
mobile attribution providers;
cloud storage providers;
app development platform providers;
analytics tool providers;
advertising partners;
marketing partners, such as social networking platforms like Facebook, Instagram, X, YouTube, Weibo, Naver, Discord, Reddit, TikTok, Douyin (抖音), and VK; and
professional advisers, including consultants, solicitors, accountants, tax advisors, auditors, and insurance brokers.
The current list of our third parties is available here.
5.2. We will require that these third parties maintain at least the same level of confidentiality and data protection that we maintain for such personal data.
5.3. We may also disclose your personal data:
to the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, or private parties, including but not limited to: in response to subpoenas, search warrants, or court orders;
to the people, networks, and accounts you share and communicate with when you share communications using our Services, in which case you choose the audience for what you share, for example, when you post on Facebook, Instagram, YouTube, or X, you select the audience for the post, such as a group, all of your friends, the public, or a customized list of people; or
if we sell or transfer all or a portion of our company's business interests, assets, or both, or in connection with a corporate merger, consolidation, restructuring, or other company change.
5.4. We reserve the right to use, transfer, sell, and share aggregated, anonymous data, which does not include any personal data, about users of the Services as a group for any legal business purpose, such as analyzing usage trends and seeking compatible advertisers, sponsors, clients, and customers.
5.5. We do not sell or rent your personal data to any third party unless it is related to one of the above reasons.
5.6. If we must disclose your personal data in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, we may not be able to ensure that such recipients of your personal data will maintain its privacy or security.
5.7. Please be aware that your public information can be seen by anyone, even those without an account. This includes your usernames on social media, any details you share publicly, information on your public profiles, and content posted on public social media pages. Both other players and people outside our community can access this information, and we may share it through search results and various tools. Additionally, third-party services like search engines and apps can also view and share your public information, meaning it could appear in places outside of our Services, such as TV or other media. Please think carefully about what you share publicly, as it may be accessed by anyone.
6. Social Network Integrations
6.1. If you choose to access our Services through a third-party social network or platform (like Facebook or X), they might share some of your personal data with us (like your profile picture, username, or connections) but only if you allow it. These platforms are not fully controlled by us, so we encourage you to review these platforms' privacy policies for a complete picture of how they process your data.
6.2. When you allow any interaction between the Services and any social network or platform that belongs to a third party, we also may share your personal data with that social network or platform, such as your name, your profile avatar, and your scores/progress in our games.
6.3. You should consider who you choose to share your activity with, because people who can see it on our Services can choose to share it with others on and outside of our Services, including people and businesses outside the audience you shared it with. For example, when you share a post or send a message to specific friends or accounts, they may download, screenshot, or reshare that content to others across or outside of our Services, in person, or in virtual reality experiences.
Also, when you comment on someone else's post or react to their content, your comment or reaction is visible to anyone who can see the other person's content, and that person may later change this audience. People can also use the Services and our products to create and share content about you with the audience they choose. For example, people can share a photo of you in a story, mention or tag you at a location in a post, or share information about you in their posts or messages. People in your networks can see signals telling them whether you are active on our Services, including whether you are currently active on Instagram or Facebook, or when you last used the Services.
6.4. You may, at any time, make changes to the data that these third-party social networks or platforms share with us by changing your settings for that provider, or stop allowing the Services to interact with that provider. In doing so, you may not experience our Services' special features to the fullest extent.
7. Data Retention
7.1. Your personal data will be stored for as long as necessary to provide you with the Services or to fulfill the purposes of processing. However, please note that even after you close your account or stop using our Services, we may continue to store your personal data. You can always request the deletion of your personal data, as described in Section 10.
7.2. Deletion of Inactive Profiles. If you have been inactive in the game for 5 years, your profile, including all associated data, will be deleted without the possibility of recovery. "Activity" refers to any action in the game, such as logging into your account, participating in game events, making purchases, etc.
7.3. Deletion of messages in game chats. Messages in guild chats are stored for 360 days. After this period, the message history is deleted. We delete player guilds where all members have been inactive for 36 months; associated content is deleted or anonymized unless retention is required by law.
7.4. Age-verification data is retained only as long as necessary to complete verification and comply with law. After a user reaches the age of majority, we retain only an “18+” flag and delete or anonymize original date-of-birth data unless retention is required by law.
7.5. Survey data. We retain the Support ID collected for prize delivery only until verification and fulfillment are completed and then delete it within 30 days. De-identified survey results may be retained for analytics.
8. Data Integrity & Security
8.1. We care about your privacy and have set up technical, administrative, and physical safeguards to protect your personal data from unauthorized access, disclosure, alteration, or destruction. This includes measures such as encryption, secure servers, and strict policies.
8.2. We strive to meet or exceed the security standards of the gaming industry. However, please keep in mind that no method of transmitting or storing data over the Internet is 100% secure. While we work hard to protect your information, we cannot guarantee that breaches will not happen.
9. International Data Transfers
9.1. Our Services are global by nature and your data may, therefore, be transferred anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this policy. These include implementing the European Commission's Standard Contractual Clauses for transfers of personal data between our group companies and third-party service providers and partners, which require all group companies to protect personal data they process from the EEA in accordance with European Union data protection law. These clauses can be found here.
9.2. Certain jurisdictions require consent before your data may be transferred to another country, particularly if the country to which the data is being transferred does not offer the same level of protection offered in the country from which your data originated. In such cases, you agree that this policy provides prior, informed, and express notice of the possibility of such transfers and you agree unequivocally to the transfer of your personal data.
10. General Privacy Rights
10.1. The right to access your personal data.
You have a right to know what personal data we hold about you and how and why we handle your personal data. You can ask us for a copy of your personal data and in some cases to have the information communicated to you. If you would like to exercise your right of access, please contact us as described below in Section 12 and let us know what information in particular you would like to receive. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information. Please note that we may not be able to provide all the information you ask for, for instance if the information includes personal information about another person. Where we are not able to provide you with the information that you have asked for, we will endeavor to tell you why.
10.2. The right to correct or update your personal data.
You have a right to request an update or correction to any of your personal data that is out of date, incomplete, or incorrect. Please contact us as described below in Section 12 to exercise your right to correct or update your personal data.
10.3. The right to delete your personal data.
In certain specific circumstances, you have the right to ask us to delete the personal data that we hold about you. We will pass on your request to other recipients of your personal information unless doing so is impossible or would involve disproportionate effort. If you would like to ask us for further information on the specific circumstances, who the other recipients are, and/or exercise your right to erasure, please contact us using the details described below in Section 12. Please note, some data can only be deleted when you delete our Services from your mobile devices and clear our cookies from any device that you have used for our Services. In that case, you will permanently lose all your game progress, virtual currency, and virtual goods without the right to data recovery or refund. We may retain your information in an anonymized form. In some instances, personal information about you that is visible through gameplay, such as your username, avatar, high scores, and any chat messages, may be cached on other players' devices and we may not be able to remove or update that data from those devices, for example if that device is not connected to a network. You can ask us for further information on the specific circumstances and who the other recipients are by using the contact details described in Section 12 below.
10.4. The right to restriction of the processing of your personal data.
In certain specific circumstances, you have the right to restrict the processing of your personal data. You can ask us for further information on the specific circumstances using the contact details described in Section 12 below.
10.5. The right to object at any time to the processing of your personal data.
You have the right to object at any time to the processing of your personal data when such processing is based solely on your consent. You have the right to object when processing is based on the legitimate interests pursued by us if, based upon new information, the interests or fundamental rights and freedoms of the data subject that require protection of personal data override the legitimate interests on which the processing is based, e.g. if we learn through new information that the data subject is a child. In some instances, our use of your personal data may result in automated decisions being taken (including profiling). Automated decisions mean that a decision concerning you is made automatically on the basis of a computer determination (using software algorithms), without our human review. For example, we use automated decisions to provide direct or targeted interest-based advertising on our Services. You may object to automated decisions being made in relation to direct or targeted interest-based advertising at any time by contacting us as described below in Section 12 or exercising your right to withdraw consent or opt out, as described below in Section 10.7. Please note that even if you use your right to opt out, you will still receive advertising, but not direct or target-interest advertising.
10.6. The right to portability of your personal data.
In some circumstances, you may have the right to request that data that you have provided to us be provided to another controller, where technically feasible, or to you in a common, machine-readable format, so you can transfer this to another data controller.
10.7. The right to withdraw your consent at any time if we are processing your personal data with your consent.
You have the right to withdraw your consent for any processing based on your consent at any time by contacting us as described below in Section 12. You may withdraw your consent for any information shared to us by third parties, such as social media platforms like Facebook, by changing the settings on the cookie banner. You may withdraw your consent to the use of your GPS location by changing the settings on your device. For example, on a device using iOS 14.6, you can stop sharing GPS location to us by going to Settings > [the Mytona App You Are Using] > Location and selecting "Never". You can withdraw your consent or opt out of direct or target-interest advertising on mobile applications by checking the privacy settings on your device's settings menu. On iOS, you can opt out of this by going to Settings > Privacy & Security > Apple Advertising, and tapping to disable "Personalized Ads". On Android, you can opt out by going to Settings > Privacy > Ads > Reset Advertising ID / Delete Advertising ID. Please note that even if you use your right to opt out, you will still receive advertising, but not direct or target-interest advertising.
10.8. The right to complain to a data protection authority about our collection and use of your personal information.
For example, in accordance with Article 77 of the GDPR, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or of the alleged infringement of the GDPR. For more information, please contact your local data protection authority.
11. Children and Minors
(a) Eligibility and parental consent. Our Services are intended for adults (users at or above the legal age of majority in their country of residence). Minors may use the Services only with parental or legal guardian consent where required by law.
(b) Age verification. We may ask you to provide your date of birth (full date or month/year) or complete additional verification at sign-up or later. If we detect that you may be under the applicable age or misrepresenting your age, we may temporarily restrict features or access until verification is completed. For adult users, after verification we retain only a flag that you are 18+.
(c) Limited features for minors. In-game chat is disabled for minors. Limited social features may remain (e.g., guild stickers, request/send help).
(d) Advertising (including rewarded ads).
Under 13: no ads, including rewarded ads.
Ages 13-17: non-personalized ads only (no profiling; no cross-site/app tracking; no sharing of advertising identifiers such as IDFA/AAID with third parties). Consent prompts for targeted advertising (Consent management platform) and iOS tracking prompts (AppTrackingTransparency) are not shown to minors.
18+: personalized ads are shown only with your consent (via Consent management platform and, on iOS, AppTrackingTransparency). Without consent, ads remain non-personalized.
(e) Data minimization and no sale/share. For minors we process only what is necessary to provide the Services and ensure safety (e.g., age/age-band, device/technical logs, anti-fraud/anti-cheat, moderation logs). We do not sell or share minors’ personal data for cross-context behavioral advertising and we do not pass advertising identifiers to third parties.
(f) Local rules. Where local law imposes additional measures (e.g., playtime limits, real-name/age checks), we comply. See Section 11 for location-specific provisions.
12. Local Data Protection Regulations
The regional provisions below supplement our global practices. If there is any difference between our 18+ baseline and local legal requirements for minors/children, we will apply the stricter standard.
12.1. European Economic Area (EEA), United Kingdom (UK), Switzerland
12.1.1. In accordance with the General Data Protection Regulation (GDPR), we have implemented a Consent Management Platform (CMP) that allows you to manage your preferences regarding the collection and processing of your personal data. When you first launch the game, you will be asked to provide consent for various types of data processing. You can choose which data you allow us to collect and use, and you may opt out of some or all types of processing.
12.1.2. You can change your consent settings at any time in the game's Settings menu.
12.1.3. Age of consent and Swiss FADP. In the European Economic Area, the digital age of consent is set by Member State law and ranges from 13 to 16. In the United Kingdom, it is 13. We apply the applicable threshold based on your country of residence. For Switzerland, we comply with the revised Federal Act on Data Protection (FADP). For minors, we do not show CMP prompts; consent flows for targeted advertising apply to adults only.
12.2. Brazil
If you use our services in Brazil, additional conditions apply, which take precedence over the main text of the Privacy Policy in case of any contradictions.
12.2.1. Brazilian law grants you certain rights regarding your personal data. We strive to be transparent and provide you with control over the exercise of these rights in accordance with applicable laws, including the Brazilian General Data Protection Law (LGPD). You have the right to:
Confirmation that we process your data;
Access your data;
Correct incomplete, inaccurate, or outdated data;
Anonymize, block, or delete your data;
Transfer your personal data to another service or product provider;
Object to the processing of your personal data;
Obtain information about public and private organizations with whom we have shared your data;
Be informed about the possibility of refusing to provide personal data and the consequences of such refusal, if applicable;
Withdraw your consent;
Request a review of automated decisions that may affect your interests, including data related to your personal, professional, consumer, or credit profile.
12.2.2. If you are not satisfied with our response to your rights requests, please contact us. You also have the right to file a complaint with the Brazilian Data Protection Authority (ANPD).
12.2.3. To protect your information and ensure that it is not disclosed to unauthorized persons, we may request additional information to verify your identity before fulfilling your data request. This information will be used solely to verify your identity and respond to your request.
12.2.4. In some cases, we may have legal grounds not to fulfill certain requests. For example, we may not disclose information that could harm our business, trade secrets, or intellectual property. We may also not delete your data if it is necessary to comply with legal obligations or to protect our rights and interests in the event of a dispute. We will explain our reasons if we cannot fulfill your request.
12.2.5. International data transfers are necessary for the provision of our services. If you are in Brazil, we will always rely on the lawful mechanisms provided by the applicable data protection laws for such transfers.
12.2.6. This policy is available in English and Portuguese. In case of contradictions, the English version prevails.
12.2.7. We retain your gaming account as specified in Section 7.
12.3. Republic of Korea
12.3.1. This section contains additional information required by the Personal Information Protection Act (PIPA) of the Republic of Korea. If you are in South Korea, the following terms apply to you in addition to the main text of our Privacy Policy.
12.3.2. From time to time, we may display personalized advertisements in our services.
12.3.3. We delete your personal data when the purpose of processing, as agreed by you, is fulfilled or the storage period you have agreed to has expired. Details regarding the deletion of personal data are described in Section 7. Minimum retention periods for personal data are established in accordance with the laws of the Republic of Korea and may vary depending on the data category. Once the storage period ends, we will destroy your personal data in a way that prevents its restoration.
12.3.4. Your rights. You have the right to:
Request access to your personal data;
Correct inaccurate or incomplete data;
Request deletion of your personal data;
Suspend the processing of your personal data;
Withdraw your consent to the processing of personal data where processing is based on consent. In cases where data transfer is necessary for contract execution or other legal grounds, processing may continue in accordance with PIPA.
You may exercise your rights by submitting a request as specified in our Privacy Policy. Contact details for exercising your rights are provided in Section 12. If you are dissatisfied with our response, you may file a complaint with the regulatory authority of the Republic of Korea.
12.3.5. Cross-border transfers of personal data. Cross-border transfers of personal data are carried out in accordance with PIPA and our internal procedures. We ensure that all recipients of personal data outside the Republic of Korea provide a level of protection comparable to the requirements of PIPA through appropriate agreements, security audits, or other established measures.
12.3.6. Security measures. We currently implement the following measures to ensure the security of personal data, including technical and administrative measures in accordance with PIPA:
Administrative measures include, but are not limited to, the establishment and implementation of an internal management plan and regular training on personal data protection.
Technical measures include, but are not limited to, access rights management for personal data processing systems, installation of access control systems, password encryption, and the implementation of security systems. Additionally, we have implemented monitoring and incident response mechanisms related to personal data protection, including procedures for detecting, investigating, and addressing potential violations. We also conduct regular security audits and inspections to ensure compliance with PIPA requirements.
12.4. United States
12.4.1. If you are a resident of the United States, the laws of your region may provide you with additional rights regarding our use of your personal data. More detailed information about your privacy rights in the United States can be found in our Privacy Notice for the United States .
12.5. China
Where local law imposes additional measures (e.g., real-name/age checks or time-of-day limits for minors), we implement them for the relevant users in that jurisdiction. We have included this section in Chinese in accordance with legal requirements.
未成年人保护 我们高度重视未成年人个人信息的保护问题，并持续探索加强未成年人个人信息保护的新方式。
我们响应国家防沉迷政策，落实防沉迷制度，保障未成年人合法权益。我们通过实名认证来验证账号是否属于未成年人，并相应限制未成年人的游戏时间。我们收集登录时间和游戏时长，采用自动干预措施限制游戏时间，并在出现疑似涉及未成年人交易的情况时尝试联系监护人以确认并处理情况。
此外，我们可能会根据国家法规实施更严格的防沉迷措施。我们也在不断研究与测试各种保护未成年人的新技术。为了进一步提高实名认证的准确性，防止未成年人冒用他人身份，我们实施了加强的身份验证方法。
若您是未成年人的法定监护人，请确保该未成年人在使用我们的游戏服务或提供个人信息前已获得您的授权同意。
为遵守相关法律法规及监管机构的要求，游戏用户必须完成实名认证才能继续使用和享受游戏。我们会在获得您同意或您主动提供的情况下收集您的实名身份信息（包括姓名、身份证号等信息），该信息属于敏感信息，拒绝提供实名认证可能会导致您无法访问游戏或某些游戏功能受到限制。
Minor protection. We attach great importance to the protection of minors' personal information and continuously explore new ways to enhance such protection.
We comply with national anti-addiction policies by implementing anti-addiction systems to protect the legitimate rights and interests of minors. We verify whether accounts belong to minors by using real-name authentication and limit their gaming time accordingly. We collect login times and gaming durations, apply automated interventions to restrict gaming time, and attempt to contact guardians in cases of suspected minor-related transactions to confirm and handle the situation.
Additionally, we may implement stricter anti-addiction measures based on national regulations. We continue to research and test various new technologies for protecting minors. To further improve the accuracy of real-name verification and prevent minors from misusing other individuals' identities, we implement enhanced authentication methods.
If you are the legal guardian of a minor, please ensure that the minor has obtained your authorization and consent before using our gaming services or providing personal information.
To comply with relevant laws, regulations, and regulatory authorities' requirements, game users must complete real-name authentication to continue using and enjoying the game. We collect your real-name identity information (including name, ID number, etc.) upon your consent or when voluntarily provided by you. This information is considered sensitive. Refusal to provide real-name authentication may result in restrictions on accessing the game or certain game features.
12.6. Japan
12.6.1. In accordance with the Act on the Protection of Personal Information (APPI) of Japan, we commit to processing personal data fairly, transparently, and securely. We ensure that the collection, use, and transfer of your personal data comply with the applicable laws and regulations of Japan.
12.6.2. Data storage. We will store your personal data only as long as necessary to fulfill the purposes for which it was collected. If you have registered an account with us, your data will be retained as long as your account remains active. After account deletion, your data will be either deleted or anonymized in accordance with our data retention policy described in Section 7.
12.6.3. Data transfers. If we transfer your personal data outside Japan, we will obtain your prior consent, unless the recipient is in a jurisdiction with an adequacy decision or we implement measures equivalent to APPI requirements. Upon request, we will provide information about the recipient’s country/region, the applicable protection regime, and the measures we take.
12.6.4. Your rights in Japan. Under APPI, you have the right to:
Request access to your personal data;
Correct inaccurate or incomplete data;
Request deletion of your personal data;
Request restriction of data processing;
Withdraw your consent to data processing where consent is the basis for processing.
12.6.5. Marketing preferences. You also have the right to request that we stop using or transferring your personal data for marketing purposes. We will process your request in accordance with APPI requirements and our internal procedures.
12.7. Canada
12.7.1. If you use our services in Canada, here are your rights under the Personal Information Protection and Electronic Documents Act (PIPEDA):
Access to your personal data. You have the right to know what personal data we hold about you and how and why we handle your personal data. You may request a copy of this information. To do so, please contact us with details of your request. We may need to verify your identity before providing the information. In some cases, we may not be able to provide all the requested data, especially if it contains information about other individuals. If so, we will explain why.
Correcting or updating your data. If you find that your data is outdated, incomplete, or inaccurate, you may request that we update or correct it. Contact us as specified in Section 12 to request changes.
Withdrawal of consent. You may withdraw your consent for data processing at any time. However, this may affect your experience using our services, as certain features rely on specific data. To withdraw consent, contact us as specified in Section 12.
Filing a complaint. If you have concerns about how we handle your personal data, you may file a complaint with the Office of the Privacy Commissioner of Canada. More information can be found at www.priv.gc.ca.
Provincial laws notice. Some provinces, such as Alberta, British Columbia, and Quebec, have their own privacy laws that may apply instead of PIPEDA. For more information, visit www.priv.gc.ca.
12.8. Turkey
We process the personal data of users from Turkey in accordance with Personal Data Protection Law No. 6698 (KVKK) and, where applicable, the General Data Protection Regulation (GDPR).
Additional KVKK requirements.
Legal basis for processing. In addition to the legal bases outlined in GDPR, data processing in Turkey requires explicit consent from the data subject, except in cases specified under Article 5 of KVKK, such as the necessity for contract performance, compliance with legal obligations, or protection of legal rights.
User rights. Users from Turkey have rights similar to those under GDPR, including access, correction, and deletion of their data. Additionally, under Article 13 of KVKK, users may submit a formal written request, which we are required to respond to within 10 days.
Contact information. To exercise your rights under KVKK, you may contact us using the details specified in Section 12.
12.9. Indonesia
12.9.1. If you are in Indonesia and use our services, please note the following additional terms. In case of any conflict between these terms and the main text of the Privacy Policy, the following terms shall prevail.
12.9.2. Age and parental/guardian consent. To use our services, you must be at least 16 years old. If you are under 21 but over 16 and are not married, you may need parental or guardian consent. If you are under 21, unmarried, and under guardianship, you must:
Obtain permission from your parents or legal guardians;
Remember that your parents or guardians are responsible for your actions on the platform;
Ensure that using our services does not violate child protection laws.
If you cannot obtain such permission, you must stop using our services.
12.9.3. Your rights. You may prevent your data from being shared with partners. Upon your request, we will stop displaying, publishing, and sharing your data with partners. However, this may limit the functionality of our services for you.
You may also:
Request information about what data we have collected about you;
Request the deletion of your data from our servers.
Deleting your data may limit your ability to use our services. To exercise your rights, please contact us as specified in Section 13.
13. How to Contact Us
13.1. If you have any questions regarding this Privacy Policy and would like to exercise your personal data protection rights described above, please contact us at dpo@mytona.com and at the following addresses:
Data Controller:
Mytona Limited
Level 5, 129 Hurstmere Road, Takapuna, Auckland 0622, New Zealand.
Contact Details for Mytona's UK Representative:
Rickert Services Ltd UK
PO Box 1487
Peterborough
PE1 9XX
United Kingdom
art-27-rep-mytona@rickert-services.uk
Contact Details for the EEA Representative:
Rickert Rechtsanwaltsgesellschaft mbH
- Mytona -
Colmantstraße 15
53115 Bonn
Germany
Contact Details for the Turkey Representative:
Att. Didem Kalaycioglu Birol
Sultan Selim District Humeyra Street. Nef 09 B Block No: 7 Inner Door No: 57 Kagithane/ Istanbul, Turkiye.
14. Changes to This Policy
14.1. This Privacy Policy may be updated from time to time to reflect current changes in Mytona's business processes and our privacy practices. Significant changes to the Privacy Policy will be communicated to you additionally (e.g., via email or in-game notifications).
14.2. We reserve the right to make any necessary changes to this policy at any time, so please view it often.
14.3. This Privacy Policy has been prepared in English. In the event of any conflict or discrepancy between the English version and any translated version of this Privacy Policy, the English version shall prevail and take precedence.