MIDAS GAMES – PRIVACY POLICY

INTRODUCTION

This Privacy Policy (“Privacy Policy”); MIDAS GAMES KFT; Registration number: 01-09-432808 Registered Seat: 1064 Budapest, Izabella utca 68/B A. lház. Fsz. 5. Ajtó Hungarian VAT Number: 32600207-2-42 EU VAT Number: HU32600207 (collectively "Midas Games”, "we", "us", "our") has been prepared to ensure that the personal data of our players or users within the scope of “Spark” are processed in accordance with the relevant legislation, in particular Regulations (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (“GDPR”), and to ensure that the relevant persons whose data are processed can effectively exercise their rights. All personal data shared with Midas Games will be processed in accordance with the law, in connection with our activities and service purposes and in a measured manner. This Privacy Policy applies to Spark. Before you access or use Spark, please be sure to read and understand how Midas Games collects, stores, uses and shares your personal information as described in this Disclaimer.

1) Definitions

The concepts of personal data and data processing used in this Privacy Policy are used in accordance with the definitions made in the GDPR. The concept of “personal data” stipulated in the GDPR refers to any information relating to an identified or identifiable natural person; the concept of “processing of personal data” refers to all kinds of operations performed on personal data such as obtaining, recording, storing, preserving, modifying, reorganizing, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data by fully or partially automated or non-automated means provided that it is part of any data recording system.

2) Personal Data Processing Principles

Pursuant to the GDPR, personal data belonging to the data subject shall be processed by the data controller Midas Games for the following purposes in accordance with the law and good faith, accurate and, where necessary, up-to-date, for specific, explicit and legitimate purposes, in connection with the purpose for which they are processed, limited and measured, in accordance with the rules of retention for the period stipulated in the relevant legislation or required for the purpose for which they are processed.

3) Processed Personal Data

Midas Games may collect your Identity Information (Name, Surname, Username, Date of Birth), Contact Information (E-Mail Address, Mobile Phone Number), Location Information (Precise and Imprecise Location Information, Country Information, Zip Code Information), IP Information (IP Address, VPN Usage Status, Internet Provider Information), User Data (User Tracking Data, Game Playing Data, Time Spent in the Application Data, Device Accessed Information, General Tracking Data, Wallet Account Movements, Application History), Security Data (Suspicious Activity Detection Data, Data Showing How Many Different Cards You Logged In With), Paypal Verification Data (Paypal Verification Data), Correspondence Data (Correspondence with Midas) are processed for the purposes specified below, with the explicit consent of the person concerned or if it meets any of the reasons for compliance with the law. Midas Games reserves the right to request additional information and/or documents in order to prevent all kinds of forgery and fraud due to its business model.

4) Purposes of Processing Personal Data

Midas Games processes your personal data for the purposes listed below:

  • Execution of emergency management processes,
  • Execution of information security processes,
  • Conducting audit/ethics activities,
  • Execution of access authorizations,
  • Execution of activities in accordance with the legislation,
  • Conducting finance and accounting affairs,
  • Conducting company/product/service engagement processes,
  • Follow-up and execution of legal affairs,
  • Conducting internal audit/investigation/intelligence activities,
  • Conducting communication activities,
  • Conduct/supervision of business activities,
  • Receiving and evaluating suggestions for improving business processes,
  • Carrying out activities to ensure business continuity,
  • Execution of service procurement, after-sales support, sales, production and operation processes,
  • Execution of customer relationship management processes,
  • Conducting activities for customer satisfaction,
  • Organization and event management,
  • Conducting marketing and analysis studies,
  • Execution of advertising, campaign and promotion processes,
  • Execution of risk management processes,
  • Carrying out storage and archive activities,
  • Execution of contract processes,
  • Execution of strategic marketing activities,
  • Follow-up of requests and complaints,
  • Execution of the remuneration policy,
  • Execution of marketing processes of services,
  • Ensuring the security of Midas Games' operations,
  • Informing authorized persons, institutions and organizations,
  • Registration and tracking of visitors,
  • Realization of user identification activity,
  • Performing age limit verification activity.

We use your information to operate, maintain and provide you with the features and purposes of our Service. The Data Processing process is important for the proper functioning of the contract we have established between the parties and the steps taken to create the contract. We may also use the information we process to send you marketing messages to keep you informed of things like innovations we are making and/or to ask for your feedback on our products and services. This data processing is based on Midas Games' legitimate interest. You may opt-out of such marketing communications by using the unsubscribe link included in each message or by contacting us. The execution of the processes will be carried out in accordance with the personal data processing conditions specified in the GDPR. In case of changes in the purposes of personal data processing, Midas Games reserves the right to make changes to this Privacy Policy at any time.

5) Transfer of Your Personal Data

Midas Games acts following the regulations stipulated in the GDPR regarding the transfer of personal data. Without prejudice to the legislation or the exceptional circumstances listed below, personal data are not transferred by us to other natural or legal persons without the Data Owner's explicit consent. In exceptional cases stipulated by the GDPR and other legislation, maximum care is taken to comply with the forms and limitations stipulated in the legislation during the transfer of personal data to authorized administrative or judicial institutions or private institutions. Your Personal Data may be shared with the following organizations as a result of our legitimate interest;

  • Adjust and Applovin and its affiliates to monitor and audit our acquisition marketing campaigns;
  • Google Analytics, Looker and Firebase detection and analysis of in-application behaviours;
  • Google, Paypal and Apple and their affiliates to manage authentication and fraud checking.

We may share your personal information with third party service providers and other service providers who perform services for us or on our behalf, which may include providing postal, email and chat services, payment services, identity verification services, fraud prevention, web hosting or providing analytics services. We may collect specific individual data through computer programs our accomplices provide, such as third-party analytics services, which we integrate into our service. This program may collect information related to following, installations, and downloads on your device by collecting mobile identifiers, such as the ID for Advertising for iOS (IDFA). These accomplices may have gotten to the individual information collected in this way to preserve this computer program and give us services, such as calculating utilization analytics about the Midas Games' Service. We may share your information with other companies owned by or under common ownership with Midas Games, including our affiliates (i.e., any entity we own or control), our ultimate holding company (i.e., any entity that owns or controls us), and its affiliates. These companies will process your personal information following our legitimate interests under this Privacy Policy. In connection with a business transaction, buyers and third parties may share your personal information with third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control, or acquisition of all or part of our business. We may share your Personal Information with law enforcement agencies, local authorities and governments as required by law or if we reasonably believe that such action is necessary to: comply with the law and reasonable requests by law enforcement; protect the security or integrity of our Service; protect ourselves, our users, or the public from harm or illegal activities; or prevent or stop any activity that we may consider to be, or that we reasonably believe is, illegal or unethical. In some cases, Midas Games may transfer personal data to countries outside the European Union. When transferring personal data to third countries outside the EU, we ensure that we comply with the rules of data transfer specified in the GDPR. The transfer of your personal data outside the EU will be carried out on the basis of adequate safeguards, such as standard contractual clauses that have been approved by the EU Commission and other mechanisms that comply with the regulations set forth by the GDPR. We will ensure the safety of your personal data through the measures we will take and that we will inform you of the risks arising from such transfer. If you would like more information about how we transfer your personal data outside of the EU, please contact us.

6) Your Rights as a Data Subject

As a data subject, you have the following rights under the GDPR:

  • The right to access your personal data;
  • The right to rectify your personal data;
  • The right to erase your personal data;
  • The right to restrict the processing of your personal data;
  • The right to data portability;
  • The right to withdraw consent;
  • The right to lodge a complaint with a supervisory authority.

You can exercise these rights by sending us a request using the contact information below. We will respond to your request in accordance with applicable law. Please note that we may need to verify your identity before responding to such requests. We will also provide the requested information without undue delay and in any event within one month of receipt of your request.

7) Security of Your Personal Data

Midas Games has implemented appropriate technical and organizational measures to protect personal data against unauthorized access, unlawful processing, accidental loss, destruction or damage. However, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee the absolute security of your personal data. We will notify you promptly in the event of a data breach where we are legally required to do so.

8) Changes to This Privacy Policy

Midas Games reserves the right to modify this Privacy Policy at any time. We will notify you of any changes by posting the new Privacy Policy on this page. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. We will also provide you with notice if we make any significant changes to this Privacy Policy that may impact your rights or your use of our Service.

9) Contact Us

If you have any questions about this Privacy Policy, please contact us: