This Privacy Policy reflect our respect to your privacy. This policy will explain what information and how your personal data are processed by MNC Animation, including its subsidiary and affiliate companies under PT MNC Pictures. and/or PT Global Mediacom Tbk. (“MNC Animation”) when you are using our Animation, mobile applications, services, features, products, customer support, social media channels, websites, questionnaires, or competitions (collectively referred to as our "Services") wether on mobile devices, PCs, or other platforms.

  1. COLLECTION OF INFORMATION

We ensure a reasonable and transparent processing in accordance with the rules on processing of personal data. Generally, we will collect or receive information in 3 (three) ways:

  1. Information You Provide Us

We collect information you provide us, including:

  • Contact and Profile Information;
  • Age;
  • Information you provide when seeking help from us, such as your name, email address, contact information, payment related information, and records of the issues you experience;
  • Information you provide when completing a customer survey; and
  • Information you provide to enter a contest or competition. If you win, we may need your social identity number, postal address and/or national identification for eligibility, prizes delivery, and tax purposes.
  • When you participate in social features or log in through third-party’s platform or a social media site, i.e. Facebook, Twitter, Google, Game Center, or other platform providers, please acknowdledge the information you disclose is public information. We may store and access it, and it may be read, copied, collected, or used by other users without your consent. Please make sure your privacy setting through the third party’s platform reflect your preferences. You acknowledge that we are not liable when third party services use information you provide to them. We encourage you to be careful about the protection of your own personal information when using third party services such as social media platforms.

 

When you participate in online leaderboard components of our products, your in-game profile information, gameplay, and statistic may be visible to all.

  1. Information Collected Automatically When You Use Our Services

We collect information automatically when you visit or use our Services. If a combination of information we collect does identify you as an individual, we will treat the combined informations as personal information. We typically aggregate the data we collect automatically and use it in statistical form to determine trends among groups of users, rather than using it to identify individuals.

We may collect and store the information through technologies such as web browsers, cookies, log files, web beacons, and our back-end servers collect usage data transmitted from our Services, and other software. We use the information to modify or improve features, managing advertising, addressing technical issues, preventing fraud or misuses of our Services, and conduct data analytics.

We generally collect the information data as below:

  • Technical information about your computer, device, hardware, or software you use to accesss our Services, such as IP address, or other transactional or identifier information for your device (such as device make and model, information about device operating systems and browsers, or other devices or system related spesifications);
  • Usage information and statistics about your interaction with our Services, which may include the URLs of our website that you have visited, URLs of referring and existing pages, page views, time spent on a page, number of clicks, platform type, the application you used or the game you played, how long you used or played it and when, and other usage statistics;
  • Crash reports, which may be automatically generated when a game or application crashes and includes information about your system and crash;
  • Information that facilitate a safer and more personalized experience, such as your display name or other user identification provided in connection with your application use or game play, saved preferences, game progress, and device identifiers or usage information for authentication and fraud prevention purposes; and
  • Location information of your device, such as may be derived from your device’s IP address.

 

Please note that if certain features on our Services are provided by third parties, those third parties may also use automated means of data collection and may record information about your use of our Services or other’s Services over time. These features are subject to those third parties’s privacy policy.

What is Cookies?

Cookies is a website technology to provide information on usage of service. A cookie is a small data file that is transferred to your computer's hard disk. We may use both session cookies and persistent cookies to better understand how you interact with our Services or the advertising published outside of the Services and to monitor aggregate usage by our users and web traffic routing on the Services. This allow us to improve our Services. Also, we may create a unique device or user ID for you and store it in a cookie so we can recognize you and customize your experience based on your preferences. You can 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.

  1. Information Provided By Third Parties

Third parties may provide or allow us to collect information about you if you play or purchase our products or in-app purchases on your devices. We receive the information from the app store or other platform providers. This information may include your username and/or device identification number and the fact that you made a purchase, for instance, but does not include any sensitive or financial information. Some of services also may send information that you authorized them to provide, through systems such as Google Play Services or Apple Game Center.

We may also receive information from third-party social network, like Facebook, Twitter, Google+, Game Center, or other platform providers when you use these services in connections with our Services. We may also receive information about you when other players choose to share their contact lists with us. We also may receive information from third parties to supplement the information we receive from you. We use information from these companies primarily to help us deliver relevant advertising to you. A representative list of these types of third parties can be found below. We also may use information from third parties, for instance, to help us understand your approximate geolocation via your IP address for tax purposes, or to customize certain services to your location, and for fraud, and/or abuse prevention purposes.

  1. USAGE OF INFORMATION

In general, we use your information to provide you the Services, experiences, merchandise, or information you request.

We also use your information for the following purposes:

  1. For our legitimate interest, consistent with your rights and preferences, we use personal data:
    • to communicate with you, respond to your request, or provide you with updates and information
    • to better understand our users, their interests, and their preferences
    • to personalize your experience, save your preferences, authenticate our users, and provide similar user-experience features
    • to develop, deliver, and improve our Services and other offerings
    • to manage and customize advertisement or promotional offers
    • to facilitate sharing on social networks
    • to register your participation in a contest and contact you in case of prizes
    • for security purposes
    • for internal purposes such as auditing and data analysis.

 

  1. To provide Services that are subjected to the terms you have accepted and suitable to your age and compliant with the applicable laws of your country of residence.
  2. To the extent you give consent, such as when we would like to process your personal information for a purpose that would otherwise be incompatible with this policy.
  3. To comply with legal obligations and requirements, and answer any request from Data Protection Authorities or any law enforcement.

We will normally collect personal information from you only:

  • When we have your consent to do so;
  • When we need the personal information to fulfil a contract with you and provide you with the Services, such as customer services, bugs and service error detection, and fraud prevention;
  • When the processing is in our legitimate interest (when we serve and measure the effectiveness of advertising or marketing campaign, analyze your gaming activities, protect, and improve our Services) and not overridden by your rights; or
  • When we have a legal obligation to collect personal information from you.

 

We may use analytics services to understand how you engage with our Services. Our analysis relies on your consistent device identifier, or identifier for vendor (IDFV) on Apple devices, so that we can track your behavior over time and develop an understanding of how you prefer to interact with our products. If you have more than one MNC Animation product installed on your device, those products may share the same identifier value. This enables us to develop an understanding of how you engage with all of our products you have installed. The identifier value is provided to us through the operating system on your device.

In the course of processing your data, we may do any of the following:

  • Analyze your behavior in our products over time;
  • Analyze your behavior in aggregate;
  • Combine your information with the information of other players to create anonymized aggregate reports that allow us to understand large-scale behavior trends;
  • Analyze your information to understand how well our products perform on your device or to investigate bugs, crashes, and other technical issues;
  • Combine your information with the information of other players to create customer segments based on behavior in our products or location-based behavior;
  • Use analysis of your behavior in our products to provide you with customized gameplay experiences;
  • Use your device identifier to enroll you in an A/B test. An A/B test is a type of simple behavioral experiment wherein groups of users are provided with slightly different experiences in our products so that we can research and analyze which of the experiences is the most compelling to users of our products; and
  • Analyze your behavior in the context of an A/B test.

 

European Economic Area (EEA) Only:

Per requirements under the EU’s General Data Protection Regulation (GDPR), we log your consent state for compliance purposes. This information is stored on servers hosted in the EU and is used solely for GDPR compliance. Your device identifier is stored along with your consent status. If you consent to personalized advertising, your device advertising identifier also is stored in case we need to be able to access it to assist you with data portability or erasure requests. Your device advertising identifier is not stored in our consent logging database if you do not consent to personalized advertising.

Please note that your advertising consent status is only respected when you are playing the game from within an EEA member country

  1. STORAGE OF INFORMATION

We will store your personal data for as long as necessary in order to provide you with the Services or otherwise fulfil the purposes as described above, unless further storage is required in order to establish, exercise, or defend a legal claim or to comply with applicable law. We periodically review the personal information we retain to determine whether continued storage is proper.

Your personal data are deleted or anonymized as soon as it no longer serves one of the above mentioned purpose and in any event no later than 3 (three) years after your interaction with MNC Animation has ceased.

  1. SHARING INFORMATION

We may share, or provide you with opportunities to share, information about you with other users of our Services. We also provide services that allow our users to communicate with us and each other, in which case personal information may be shared and account IDs may be displayed.

We may share personal information we collect within our family of companies. We also will share information with service providers that perform services on our behalf and under our instructions. These service providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. We also may share certain limited information, such as device identifiers, with advertisers and other marketing partners for purposes of gauging the effectiveness of advertising and other marketing strategies. We use third-party services.

We may share information about you with your social network contacts when you and they use the same social features of our Services. If you decide, while using our Services, to use social sharing features such as “Share” or “Like” on Facebook or other third-party social network sites, this may allow the sharing and collection of personal and non-personal information both to and from such third-party social networks. You should visit the policies of such third parties for more information about their information-collection practices.

We may also disclose information about you: (i) if we are required to do so by law, legal process, or a reasonable request from law enforcement authorities or other government officials, (ii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity, or (iii) if necessary to protect the vital interests of another individual (such as to prevent death, bodily harm, or serious damage to property). We reserve the right to transfer information about our users in the event we sell or transfer all or substantially all our business or assets.

  1. CHILDREN’S PRIVACY

We encourage parents to instruct their children about privacy and the way they use their information on the Internet. Children should never disclose their name, address, phone number, or any personal information, without their parents’ prior permission.

Our Services are intended for general audiences and we do not knowingly collect any personal information from children under the age of 18. If you are under 18 years or a minor in your country of residence, please ask your legal guardian’s permission to use or access our Services. If you believe MNC Animation has inadvertently collected such information, please inform us in Contact section below, so we can promptly remove the information from our records.

  1. INTERNATIONAL OPERATIONS AND TRANSFERS OF YOUR INFORMATION

We may collect the personal information and processed for the purposes as set out above in Indonesia or any other country which MNC Animation, its bussiness partners, or third party agents operate. By using our Services, you consent that your personal information may be transferred to the recipients in the Indonesia and other countries that may not offer the same level of privacy protection as the laws in your country of residence or citizenship.

  1. PROTECTION

We take reasonable controls designed to help safeguard the personal information we collect through our Services. However, no security measures are perfect and we cannot assure you that personal information that we collect will never be accessed or used in an authorized way.

  1. LEGAL BASIS FOR PROCESSING (FOR EUROPEAN ECONOMIC AREA ONLY)

If you are a resident of the European Economic Area (EEA), our legal basis for collecting and using the personal information will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where:

  • we have your consent to do so;
  • where we need the personal information to perform a contract with you (e.g. to deliver a service you have requested); or
  • where the processing is in our legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms).

In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person. If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests which are not already described in this Privacy Policy, we will make clear to you at the relevant time what those legitimate interests are.

  1. Technical and Usage Information

We do not collect in-game technical or usage data or gameplay analytics for players in the European Economic Area. Note that Google Play Services, Apple Game Center, and other platform-level services may collect gameplay analytics if you are located within EEA. Please see your device-level settings for more information about how to disable those services. We considers any data specific to your use of our apps that is collected or processed through Google Play Services or Apple Game to be in our legitimate business interests.

  1. Advertising Networks

MNC Animation works with advertising partners that may collect information from you as part of their process of serving advertisements in our Services. This is described above in the section “Ad Serving Technologies.” In accordance with the General Data Protection Regulation (GDPR), our advertising partners in the European Economic Area all function as independent data controllers. Prior to showing you personalized advertisements, you will be asked whether you consent to share your information with the advertising company. If you are a resident of an EEA country and indicate that you are below the age of 16, you will be served non-personalized ads and the advertising companies will not collect personal information from you.

  1. Right to erasure

Under the GDPR, you have a right to have MNC Animation and our third party partners erase the personal information we have collected from you without undue delay.

  1. Right to Portability

Under the GDPR, you have a right to request a copy of the personal information MNC Animation and our third party partners have collected from you.

  1. Right to Withdraw Consent

Where we rely on your consent to process the personal information, you have the right to withdraw or decline your consent at any time. Please note that this does not affect the lawfulness of the processing based on consent before its withdrawal.

  1. Right to Object

Under the GDPR, you have the right to object to the processing of your data. If you wish to object to the processing of your data, please contact us

If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us.

  1. YOUR CHOICES

We provide you with choices about whether to provide us with personal information and whether it is shared. For example, we may seek your prior consent for certain processing. We are required to seek your consent before we use your personal information for any purpose incompatible with the purposes identified in this policy. You may withdraw your consent at any time by sending an email as specified in the Contact section below. Any withdrawal of consent is only effective on a going-forward basis and will not impact processing we undertook while relying on your consent.

We generally only ask you for personal information that is necessary to provide the services you request. You can choose not to give us the personal information we request, as described in the “Information You Provide Us” section of this policy. However, in some cases, if you decide not to provide the personal information we request, we will not be able to provide the Services you requested.

Other examples of your choices include:

  • You can browse our website without providing any personal information. We may collect some limited information automatically.
  • You may opt out of receiving our messages at any time by using the opt out mechanism provided in the message.
  • You can change your privacy settings on other parties’ websites, such as social networks, which will stop or limit our receipt of information from those other websites. You also may choose not to use social features we make available. If you choose to use these features, you should refrain from posting personal information that will be visible to others, such as including your email address in a forum or during a chat.
  • You may change your browser settings or take other steps to block, manage, or delete cookies. Not all of our websites and online services currently respond to browser “do not track” signals, so you will need to use your browser settings to effectively manage cookies. In some cases, blocking or disabling cookies may cause the Services not working as intended and some features may not be available.
  • If you are under the age of 18 and have an account for our Services, you may request that we remove certain content that you provided, such as deleting or editing comments you have posted. You also may ask us to assist you in removing or anonymizing content you have posted by contacting us as described in the Contact section of this policy. Please be aware that taking these steps may not ensure complete or comprehensive removal of the content or information posted on our Services. We also may not be able to remove content you post if applicable law requires us to maintain the posting or if another party has re-posted the content to a website, app, game or other online service that we do not own or control.

You may also exercise and amend your choices by sending an email to us as detailed in the Contact section below.

  1. ACCESS AND CORRECTION

We provide you with the ability to request access to and correction of your personal information. You can update your account information any time through our Services. If you would like to request access to or correction of your personal information, please submit your request by sending an email to the address specified in the Contact section below. Please include your name, email address, and postal address in your request and describe specifically the information that you would like to access or correct so that we may respond appropriately and promptly.

  1. THIRD PARTIES’ SERVICES

Our Services may link to external sites that are beyond our control. This Privacy Policy only covers the way we treat personal information and non-personal information we collect on the Services. By accessing any external sites, you agree to the privacy policies of those sites. Please understand that external sites may have different policies with respect to the collection, use, and disclosure of your personal information. We have no control over, and are not responsible for, the privacy practices of such third parties. Therefore, you are encouraged to review the privacy policies of all third parties' services. Without limiting anything in the following section, we are not liable in any way for the actions, inactions, or policies of any external services.

  1. UPDATES TO OUR PRIVACY POLICY

This policy may be updated periodically to reflect changes in our personal information practices or relevant laws. We will indicate at the top of this policy when this policy was last updated. Please review this policy every time you access or use our Services in order to stay informed about how we process your personal data and information.

  1. LEGAL DISCLAIMER

Our Services operate AS IS, and we do not represent or warrant that our Services will be available at all times, or that your use of the Services will be uninterrupted or error-free. We are not responsible for your ability to access the Services or for matters beyond our control. This Privacy Policy is governed by the laws of Indonesia. Any dispute arising from the use of the Services shall be submitted to the competent courts of Central Jakarta District Court. You agree to waive any and all objections to the exercise of jurisdiction over you by such courts and to venue in such courts.

  1. CONTACT

MNC Animation has the following contact information:

PT MNC PICTURES TBK. QQ. MNC ANIMATION
MNC Studios Tower 2, 7th Floor
Jalan Raya Pejuangan No. 1 Jakarta Barat 11530
Indonesia
E-mail: [email protected]