Introductions
This Privacy Policy has been updated on September 20, 2023
MATRYOSHKA GAMES PRIVACY POLICY
WE RESPECT YOUR PRIVACY
If you have any privacy related concerns, please contact us at:
support@matryoshka.com
MATRYOSHKA GAMES LTD is a company registered in Cyprus, with registration number
HE 408160 and address at this date at GRIVA DIGENI 4, OROKLINI SHOPPING CENTER,
OFFICE 104, 7040, LARNACA, Cyprus (‘’MATRYOSHKA’’, ‘’We’’ “Us”), who offers
entertaining mobile applications (“App(s)’’). This privacy statement describes how
MATRYOSHKA GAMES collects and uses the information and/or data (the terms are used
interchangeably) you provide. It also describes the choices available to you regarding
our use of your information and how you can access the information. We respect your
privacy and we take protecting it seriously.
Reading Privacy Policy is important so we hope you will give it time and
attention.
This Policy applies to the following people:
● visitors to the websites (“Visitor”, “you”, "your", "yours") (including those
submitting a job application).
● people who use the Games (For the purposes of this policy, we define the term
“User”, “you”, "your", "yours" as a person which has concluded the installation of
any App(s) provided by MATRYOSHKA GAMES).
● people who make complaints to us by email.
In this Policy we refer to the Sites, the App(s) and the Ancillary Services together as the
“Services”.
MATRYOSHKA GAMES do not sell your personal information to third parties. A “sale” of
Personal Information under the CCPA is defined broadly to include the “selling, renting,
releasing, disclosing, disseminating, making available, transferring, or otherwise
communicating orally, in writing, or by electronic or other means” the Personal
Information of a Consumer to another business or third party “for monetary or other
valuable consideration.” If we decide to sell our App(s) (our business), we will inform you
about this, so you can forbid us to transfer your personal data together with our
business. If so, we will delete your data from the databases prior to a business transfer.
We adhere to the following principles in order to protect your privacy:
● principle of purposefulness - we process personal data fairly and in a transparent
manner only for the achievement of determined and lawful objectives, and they shall
not be processed in a manner not conforming to the objectives of data processing;
● principle of minimalism - we collect personal data only to the extent necessary for
the achievement of determined purposes and do not keep personal data if it is no
longer needed;
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● principle of restricted use - we use personal data for other purposes only with the
consent of the data subject or with the permission of a competent authority;
● principle of data quality - we update personal data shall be up-to-date, complete and
necessary for the achievement of the purpose of data processing;
● principle of security - security measures shall be applied in order to protect personal
data from unauthorised or unlawful processing and against accidental loss,
destruction or damage, using appropriate technical and organisational measures;
● principle of individual participation - the persons shall be notified of data collected
concerning him or her, the persons shall be granted access to the data concerning
him or her and the persons have the right to demand the correction of inaccurate or
misleading data.
1. DEFINITIONS
● “Analytical data” means any data that is derived from the data mentioned herein
that is used for internal analytics purposes via Our analytic system (e.g., for statistics
analysis, marketing, enhancing the in-game experience, enhancing the Games, the
Services, etc.).
Analytical data may as well include the following data: separate ID of the User in
Analytical data, User ID in BrainCloud service by bitHeads Inc., Apps language, Paying
information (whether the User spent any money while using the Apps), Platform
information (where the Apps were installed), Store information (via which the Apps
were installed), Session ID, Start version of the Apps, Version of the Apps, First Seen
(time and date of the first launch of the Apps), Last Seen (time and date of the last
in-App action of the User), Total Spent (the amount that was spent by the User within
the Apps in USD), total amount of all Purchases made by the User, Client Event Time,
Client Upload Time, Server Upload Time, Server Received Time.
Analytical data is generated by Us. We securely store Analytical data for the
above-mentioned internal purposes without sharing it with any third party.
● “Device information” means data about your device from which you use our Games
and/or Sites that may include: your IP address and unique mobile device identification
numbers (e.g., your device ID, advertising ID), device family, device type, RAM
information, CPU information, Designated Market Area information, Operating system;
● “Games” means Our Apps including "Rescue Dash", "Tribe Dash", "Farming Fever",
"Cooking Live", "Idle Mars Colony", "Mega Farm", "Royal Cooking" ;
● “Location information” means data about your location, namely broad location data
(e.g. country, region or city-level location);
● “Sites” means Our websites, including https://matryoshka.com/ and any other
MATRYOSHKA GAMES sites on which this Policy is posted;
● “User information” means data that we collect about you (such as your nickname,
profile picture) that we receive if you link a third-party tool with the Service (for
example, Facebook, Google Play), data about your age or other data provided by you
regarding yourself.
2. PERSONAL DATA THAT WE COLLECT AND PROCESS
We may source, use and otherwise process your personal data in different ways. In all
cases we are committed to protecting your personal data.
We may use the information collected from you for a variety of purposes, primarily,
relating to providing our Services and information about our Services. We may also use
the information for such other purposes as otherwise allowed by law. For example, we
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(or a supplier or our affiliate company acting on our behalf and only under our
instructions) may use your personal information, including personally identifiable
information, for such purposes, including but not limited to the purpose examples listed
below.
2.1. VISITORS TO THE SITES
The Website is essentially a brochure for MATRYOSHKA/s business, its Apps and
opportunities to work with and for MATRYOSHKA GAMES. The Website collects personal
data from you for the following purposes and on the following legal bases:
Categories of
Personal Data
Purpose examples
Legal basis
● Email;
● Any other data that
you submit in
connection with a
contact request
To collect this information
because you choose whether to
contact us or not and can choose
how much personal data to
provide to us in doing so
Legitimate interest in
provision with the most
detailed information
regarding Our
business, Apps and
opportunities to work
with and for
MATRYOSHKA GAMES
● Your data in CV;
● Any other data that
you submit in
connection with a
job request
To be able to receive your
requests via the recruitment
enquiries section and reply to
them
Legitimate interest in
assessing you as a
potential candidate
● Information about the candidate is stored indefinitely, until we receive a written
notification with the requirement to delete the information;
● Source of the above-mentioned personal data: we collect it directly from you.
2.2. USERS
We may collect the following categories of personal data relating to our Users for the
purposes and on legal basis mentioned below:
Categories of
Personal Data
Purpose examples
Legal basis
Data about your
progress of the game,
using connected your
social networks, if you
link a third-party tool
with the Service (for
example, Facebook,
Google Play)
● To provide you with the access
to the Apps;
● To track and analyze your
in-game experience in order to
improve Our Services and
Games.
Legitimate interest in
statistics analysis of the
use of our Apps and
Services
Data about in-app
purchases that you
make in any App(s)
provided by
MATRYOSHKA GAMES
(details of orders,
amount spent, date,
time, used vouchers or
offers)
● To track purchases and usage
information;
● To prevent cheating, crime or
fraud;
● To obtain statistical data.
Legitimate interest in
preventing fraud and
other illegal actions,
research and statistic
analysis.
Data from platforms
that the games run on
● To verify payments;
● To prevent cheating, crime or
fraud.
Legitimate interest in
preventing fraud and
other illegal actions
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Device information
● To monitor the Services,
including the Website, App(s)
and operation thereof;
● To prevent cheating, crime or
fraud.
Legitimate interest in
preventing fraud and
other illegal actions
Location information
● For marketing and promotion of
our Services or related
products;
● To obtain statistical data.
Legitimate interest in
marketing and statistic
analysis
User information
● To provide the tech support;
● To obtain statistical data on the
target audience App(s).
Legitimate interest in
provision of User
support, research and
statistic analysis.
Other data that you
choose to provide to us
For analytics, tech support or
other purposes depends on the
provided data
Consent
● Source of the above-mentioned personal data: we collect it directly from you and
from Our partners;
● We also process Analytical data based on the combination of the collected data.
Source of the Analytical data: it is generated by Us.
2.3. PEOPLE WHO CONTACT OR MAKE COMPLAINTS TO MATRYOSHKA GAMES
BY EMAIL
We may collect personal data from you for the following purposes and on the following
legal bases:
Categories of
Personal Data
Purpose examples
Legal basis
● Email;
● Any other relevant
data that you
submit in
connection with a
complaint,
including data of
other individuals
identified therein.
To analyze and respond to your
complaint
Legitimate interest in
processing a complaint
● We shall retain information in relation to a complaint for a maximum of six (6) years
after its closure, in a secure environment and access to it will be restricted on a
‘need to know’ basis;
● The items of personal data collected are not of a nature whereby your rights and
freedoms as a data subject are outweighed by such data collection;
● Source of the above-mentioned personal data: we collect it directly from you.
3. USE OF COLLECTED PERSONAL DATA
Based on you consent and our legitimate interest to fulfill our obligation for
providing you with Apps, replying to your requests, enhancing your experience and
Our Services and Games, we may use any of the collected Personal data in order
and in relation to:
● contacting you (for example as part of customer service or to send you updates
about our Services) or receiving request from you (for example as part of Our
User support);
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● managing your account and improving your experience when you use our
Services;
● marketing and promotion of our Services or related products, including those of
a third party’s products which are related to our Services (If you do not want
us to use your data in this way, please let us know by contacting us at:
support@matryoshka.com
● creating reports, analysis or similar services for use by us for the purposes of
research or business intelligence, for example to track potential problems or
trends with our Services;
● delivering relevant advertising to you and measuring and analyzing the
effectiveness of advertising, including advertising of third parties placed within
the Services;
● resolving disputes or issues;
● tracking purchases and usage information;
● enforcing the legal terms governing your use of our Services; and
● any other purpose as we determine, in our sole discretion, to be necessary or
required to ensure the safety and/or integrity of our users, employees, third
parties, public, and/or our Services, or to comply with requirements of any
applicable law.
4. СOMPLIANCE WITH GENERAL DATA PROTECTION REGULATION (GDPR),
CALIFORNIA CONSUMER PRIVACY ACT (CCPA) AND BRAZIL'S GENERAL
DATA PROTECTION LAW (LGPD (LEI GERAL DE PROTEÇÃO DE DADOS))
4.1. If you are located in the European Economic Area (EEA) privacy rights are
granted and all processing of Personal Data is performed in accordance
with regulations and rules following the Regulation (EU) 2016/679 of the
European Parliament and of the Council of 27 April 2016 on the protection
of natural persons with regard to the processing of Personal Data and on
the free movement of such data, known as the General Data Protection
Regulation (“GDPR”).
4.2. If you are located in California, all processing of Personal Data is performed
in accordance with regulations and rules following the California Consumer
Privacy Act, Cal. Civ. Code § 1798.100 et seq. (“CCPA”).
4.3. If you are located in Brazilia, all processing of Personal Data is performed
in accordance with regulations and rules following the Lei Geral de
Proteção de Dados (“LGPD”).
4.4. The Child Online Privacy and Protection Act (“COPPA”) regulates online
collection of information from persons under the age of 13 (covered
person). Covered persons are required to obtain parental consent before
providing personal information via this App(s). If you are a parent of a
COPPA covered person, you have the option to agree to the collection and
use of your COPPA covered person’s information. You may revoke your
consent, review your COPPA covered person’s personal information, ask to
have it deleted, and/or refuse to allow any further collection or use of your
COPPA covered person’s information at any time, contact us at
support@matryoshka.com.
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5. DATA ACCESS, DATA CORRECTION, DATA DELETION, DATA PORTABILITY
AND WITHDRAWAL OF THE CONSENT
5.1. You can review, correct, update, delete or transfer their personally
identifiable information. For that, contact us directly at
support@matryoshka.com or via the "Support" button inside our games.
We will acknowledge your request within seventy-two (72) hours and
handle it promptly and as required by law.
5.1.1. Right to access. You may contact us to get confirmation as to
whether or not we are processing your personal data. When we
process your personal data, we will inform You of what categories
of personal data we process regarding You, the processing
purposes, the categories of recipients to whom personal data have
been or will be disclosed and the envisaged storage period or
criteria to determine that period.
5.1.2. Right to withdraw consent. In case our processing is based on
consent granted, You may withdraw the consent at any time by
contacting us or by using the functionalities of our Services. You
can withdraw your consents at any time by replying to the email
with your withdrawal and your Personal Data will be deleted in 48
hours. Withdrawing consent may lead to fewer possibilities to use
our Services.
5.1.3. Right to object. In case our processing is based on our legitimate
interest to run, maintain and develop our business, You have the
right to object at any time to our processing. We shall then no
longer process your personal data unless for the provision of our
Services or if we demonstrate other compelling legitimate grounds
for our processing that override your interests, rights and freedoms
or for legal claims. Notwithstanding any consent granted
beforehand for direct marketing purposes, You have the right to
prohibit us from using personal data for direct marketing purposes,
by contacting us or by using the functionalities of the Services or
unsubscribe possibilities in connection with our direct marketing
messages.
5.1.4. Right to restriction of the processing. You have the right to obtain
from us restriction of processing of your personal data, as foreseen
by applicable data protection law, e.g. to allow our verification of
accuracy of personal data after your contesting of accuracy or to
prevent us from erasing personal data when personal data are no
longer necessary for the purposes but still required for your legal
claims or when our processing is unlawful. Restriction of processing
may lead to fewer possibilities to use our Services.
5.1.5. Right to data portability. You have the right to receive your
personal data from us in a structured, commonly used and
machine-readable format and to independently transmit those data
to a third party, in case our processing is based on your consent
and carried out by automated means.
5.1.6. How to use these rights. To exercise any of the above-mentioned
rights, You should primarily use the functions offered by our
Services. If such functions are however not sufficient for exercising
such rights, You shall send us a letter or email to the address set
out below under Contact, including the following information:
name, address, phone number, email address, and a copy of a valid
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proof of identity. We may request additional information necessary
to confirm your identity. We may reject requests that are
unreasonably repetitive, excessive or manifestly unfounded.
5.2. You have the right to lodge a complaint with a supervisory authority if you
think that we violate your rights. You could contact The Data Protection
Inspectorate in Cyprus via their email
commissioner@dataprotection.gov.cy.
5.3. If you are from California and dissatisfied with how we have used your
personal information you could contact The California Department of
Justice (Department) via their website
(https://www.oag.ca.gov/privacy/caloppa/complaint-form/privacy-notice).
5.4. If you are from Brazil, you can also file a complaint with Brazil’s National
Data Protection Authority (ANPD) through its official channels.
6. STORING OF INFORMATION AND DELETION
6.1. We store your Information for as long as needed to provide you with our
services unless the specific time period for storing some of your
Information is additionally defined herein. We may store Information
longer, but only in a way that it cannot be tracked back to you. When
Information is no longer needed, we delete it using reasonable measures
to protect the Information from unauthorized access or use.
6.2. We may store your Information both by using the services of Our partners
(please see Section 8 hereof) and by using Our own servers without
sharing any of your data to the third parties. Amid personal data that is
stored solely by Us is Analytical data and Device information.
6.3. We implement and maintain appropriate technical, security and
organizational measures to protect Personal Data against unauthorized or
unlawful processing and use, and against accidental loss, destruction,
damage, theft or disclosure (please see Section 7 hereof for more details).
6.4. EU Territory. We store Personal Information as long as it is needed for the
provision of our services. Traffic information is erased or made anonymous
when it is no longer needed for the purpose of the transmission or, in the
case of payable services, up to the end of the period during which the bill
may lawfully be challenged or payment pursued. Direct marketing and
provision of value-added services information (including traffic information
used for these purposes) is stored as long as the same is necessary for the
provision of these activities, or up to the time when a user opts out from
such use in accordance with this Privacy Policy. Other information is stored
for as long as we consider it to be necessary for the provision of our
services. This Section shall not prevent any technical storage or access to
information for the sole purpose of carrying out the transmission of a
communication or as strictly necessary in order for us to provide the
service you requested.
6.5. As explained in the GDPR statement, we strive to anonymize the data
when possible. Our technical logs will be automatically deleted within one
(1) month and backup logs within two (2) months. If you decide to
exercise your right to erasure we will also inform our Providers to delete all
your data.
6.6. US Territory. We will retain collected information for the period necessary
to fulfill the purposes outlined in this Privacy Policy unless a longer
retention period is required or permitted by applicable legislation.
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6.7. Storing might be different depending on the territory of collecting the
information and the applicable legislation, but we always strive to store the
information only as long as it is needed for the purposes of providing,
improving or personalizing our services.
6.8. We do not use our App(s) to knowingly solicit information from or market
to children under the age of 13. In the event that we learn that we have
collected personal information from a child under 13 years of age we will
delete that information as quickly as possible. If you believe that we might
have any information from or about a child under 13 years of age please
contact us at support@matryoshka.com.
7. INFORMATION SECURITY
7.1. We care to ensure the security of personal data. We follow generally
accepted industry standards to protect the information submitted to us,
both during transmission and once we receive it. We maintain technical,
physical, and administrative security measures to provide reasonable
protection for your Personal Data. When we or our contractors process Your
information, we also make sure that your information is protected from
unauthorized access, loss, manipulation, falsification, destruction or
unauthorized disclosure. This is done through appropriate administrative,
technical and physical measures.
7.2. There is no 100% secure method of transmission over the Internet or
method of electronic storage. Therefore, we cannot guarantee its absolute
security.
7.3. We never process any kind of sensitive data and criminal offence data. Also
we never undertake profiling of personal data.
8. CONTRACTORS
Please note that We may transfer some of your personal data to Our partners and
third parties indicated below as well as receive your personal data from the third
parties (for example, from social networks).
We strongly encourage you to read carefully the privacy documents of all
mentioned partners as We are not liable for the services of third parties and do not
control their data usage processes.
8.1. We work with third party service providers who provide website,
application development, hosting, maintenance, and other services for us.
They may be located outside of the EEA. These contractors may have
access to, or process Personal Data on behalf of us as part of providing
those services for us on the basis of the respective Data Processing
Agreements and Partners’ Privacy Policy. We limit the information provided
to these service providers to that which is reasonably necessary for them
to perform their functions.
8.2. All data transfers are performed in accordance with the highest security
regulations. Transfer of Personal Data to countries outside of the European
Economic Area may be possible only in the case, when we have obtained
your consent for it.
8.3. All processed data that is not stored by Us is stored exclusively in secure
hosting facilities provided by Vultr and Amazon CloudFront.
8.4. In order to make a purchase from us, you must use our third party
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checkout options to finalize and pay for your order. In-app purchases may
be made only upon entering the app store password and you are
responsible for maintaining the security of such password. Your
authentication and security maintaining is subject to specific terms of the
app store and the OS of your mobile device. You should be aware of iOS'
15-minute and Android’s 30-minute window after the downloading of an
Application, during which in-app purchases may be made without inserting
an in-app store password. You should also take into account that OS 2.1 or
older versions of Android mobile phones do not require entering of the app
store account password to carry out in-app purchases.
8.4.1. Google Wallet: If you choose to use Google Checkout to finalize and
pay for your order, you will provide your credit card number directly
to Google Checkout. Google's Privacy Policy will apply to the
information you provide to the Google Checkout web site.
8.4.2. Apple AppStore: If you choose to use AppStore to finalize and pay
for your order, you will provide your credit card number directly to
Apple. Apple's Privacy Policy will apply to the information you
provide to Apple.
8.5. We use Google Analytics for Firebase allows us to collect data on the usage
of our Apps. We use your data only for the purposes of our internal
analytics to improve our Apps and we do not allow sharing of your data
with other parties and their products or services. Google Analytics for
Firebase collects these data: Online Identifiers, browser type and settings,
operating system, mobile network information, cookie identifiers, IP
Address (which is anonymised before any storage takes place), crash
reports, device identifiers as well as App-Instance Identifier (a randomly
generated number that identifies a unique installation of an App for the
first time). This data is collected by Google Firebase when the Users
installs the App from Google Play or App Store. We use Firebase Analytics'
own unique user ID (app.instance id), which separates one mobile phone
from another, but does not personally identify you. We are using the
following Google Analytics for Firebase features: Remote Config., Crash
Reporting, Events (about usage of our App in a pseudonymized way),
Analytics in general, Firebase Cloud Functions and Firebase Communication
Manager.
8.6. We use Google and Facebook login so you can save your progress in our
App(s). Third-party social networks/platforms may provide your publicly
available data to us if you so allow.
8.7. We use Google Analytics to collect the Information in order to analyze and
improve our App(s). If you are using one of our child directed App(s) or
mixed audience App(s) and you identified yourself as under the age of 13,
the collected Information will only be used for support for internal
operations.
8.8. We use AppsFlyer in purpose marketing analytics that enables us to
measure and analyze the effectiveness of our marketing campaigns by
understanding which marketing campaigns contributed to the
download/installation of mobile applications or such other conversion
metric (e.g. relaunch of Application) and measure and analyze certain
events and actions within Application or websites, such as in-app
purchases made by Users.
8.9. We use Amplitude Analytics for analytic user behavior and understand how
users are navigating through App(s) and which features engage the most.
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8.10. We use Unity Ads, Google Ads, Facebook Ads and Apple Search Ads as a
video ad networks for iOS and Android Apps to attract new Users.
8.11. We use ironSource for advertising purposes, to analyze ads statistics and
to attract new Users.
8.12. We use BrainCloud to maintain and enhance our Apps.
9. OPT-OUT
9.1. You can deactivate local notifications by changing the notification settings
in accordance with the instructions of the operating system running on the
Users’ device.
10. APPLICATION OF THIS PRIVACY POLICY
10.1. This Privacy Policy is applicable to our website and our App(s). Our website
contains links to other websites. Once redirected to another website, this
Policy is no longer applicable.
11. ACCEPTANCE OF THESE CONDITIONS
11.1. We assume that all Users have carefully read this document and agree to
its content. If one does not agree with this privacy policy, they should
refrain from using our website and App(s).
12. CHANGES AND UPDATES TO OUR PRIVACY POLICY
12.1. We may update this Privacy Policy to reflect changes in our Information
processing practices. We encourage you to periodically review this page
for the latest information on our privacy practices. You will be informed
about material changes to our data processing practices with local in-app
notification and you can get acquainted with the changes by reviewing the
Privacy Policy link available within the App(s).
13. CONTACT US!
13.1. If you have any questions please contact us at support@matryoshka.com.
MATRYOSHKA GAMES (CY) LTD
GRIVA DIGENI 4, OROKLINI SHOPPING CENTER, OFFICE 104, 7040, LARNACA,
Cyprus
HE 408160
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