Collins Mwai, its subsidiaries and affiliates (“Company” or “we””) respects the privacy of the users (“User” or “you”) of the mobile applications we distribute (“Apps”) and are committed to protect Users’ information. We believe you have a right to know our practices regarding information we may collect and use when you use our Apps.
Note that the “Children Privacy Policy” (Chapter A below) and the “Collins Mwai Privacy Policy” (Chapter B below), and each together with Chapter C detailed below, shall be referred to collectively as “this Privacy Policy”.
1. Your consent (important, please read carefully!)
BY INSTALLING THE APPS ON YOUR MOBILE DEVICE, ENTERING INTO,
CONNECTING TO, ACCESSING AND/OR USING THE APPS, YOU AGREE TO THE
TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY, INCLUDING TO
THE POSSIBLE COLLECTION AND PROCESSING OF YOUR PERSONAL
INFORMATION.
PLEASE NOTE: IF YOU OR, AS APPLICABLE, YOUR LEGAL
GUARDIAN, DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MUST NOT
INSTALL, ACCESS AND/OR USE THE APPS AND YOU ARE REQUESTED TO
PROMPTLY ERASE ALL OUR APPS FROM YOUR MOBILE DEVICE.
If you are under the age of eighteen (18), please ensure that your legal guardian has
reviewed and agreed to this Privacy Policy.
2. Online Use
These are the types of data and information which may be collected from Users of our Children Apps:2.1 Non-personal Information:
We and our Third Parties may passively collect non-identifiable and anonymous information as detailed below (“Non-personal Information”). To put it simply, with respect to such children Non-personal Information, we and our Third Parties are not aware of the identity of the User from whom children Non-personal Information has been collected. Children Non-personal Information collected by us or our Third Parties may include technical information such as: type and version of operating system (e.g. Android, iOS, etc.), User session ID, time zone, session start / stop time, source of traffic (e.g. which ads, sites, applications and campaigns a User came from and associated revenue), App version, language (e.g. English), device type/model (e.g. Galaxy, iPhone, etc.), data regarding User behavior within Children Apps (e.g. ad impressions, User’s response to ads, including ads viewed or clicked), User’s in-app purchases including data regarding receipt validation, User’s gameplay (e.g. level reached, frequency and time spent in the Children App and in each level, game progress, fail rate, mini game(s) played, virtual currency (if any) collected or earned, virtual inventory items (if any), tools and in-app functionalities used, screens accessed, User retention, performance errors and problems (e.g. Children Apps’ stability, crashes, functioning, etc.), and other predefined events and behavior relating thereto (e.g. if User viewed a specific ad and other game play events, time of the event, internet connectivity (Wi-Fi, 3G), device time zone, etc.), our other installed Apps, User age-related information (if a User passes an age-gate i.e. if the User is below or above the age of 13 or the minimum age of majority), and geo-location – only at a country and city level. It is hereby clarified that no street name is collected.2.2 Children’ Persistent Device Identifier and No Other children personal identifiable information:
We and Third Parties may passively collect a persistent device identifier from children, such as advertising identifier (IDFA, Advertising ID). We do not collect and do not permit Third Parties to collect from children any information that may personally identify an individual (e.g. name, address, e-mail) or any other personally identifiable information of a private and/or sensitive nature about children. We note that we may collect, use and provide access to the User’s advertising identifier in accordance with the applicable platform provider’s policies.2.3 Purpose of the collection:
The information described above is collected and processed solely for the purpose of supporting our internal operations. This means the following:How is the Information about our Users of Children Apps being collected?
The
Non-personal Information and Children Persistent Device Identifier are collected either
by us or our Third Parties through the Users’ use of Children Apps, including through
Third Parties’ SDKs embedded in our Children Apps. Non-personal Information and
Children Persistent Device Identifier may also be stored locally on the Users’ device via
generally accepted industry technologies used within Children Apps, such as
“cookies-like technology” and local storage.
If Third Parties collect Non-personal Information, Children Persistent Device Identifier
and/or any other information directly from children, such collection and processing is
governed by such Third Parties’ privacy policies. However, all Third Parties are carefully
selected to ensure compliance with applicable privacy laws, and we confirm that they
are compliant with COPPA, this Privacy Policy and the rules, policies and guidelines of
the applicable Platform Provider in performance of their services.
3. Sharing children information with third parties
We may share the Children Persistent Device Identifier only in limited cases, including the following:4. Advertising
We accept ads from Third Party ad networks which may be displayed in Children Apps.
These Third Parties ad networks are carefully selected to ensure compliance with
applicable privacy laws, and we confirm that they are compliant with COPPA, this
Privacy Policy and the rules, policies and guidelines of the applicable Platform Provider.
Note that if the User of Children Apps clicks on any of these ads, the User will leave our
Children Apps and go to the advertisers’ site which the User selected, and the
advertisers may use cookies and other tracking technologies to collect Non-personal
Information and/or children personally identifiable information. We recommend that
children and their legal guardians review the terms of use and privacy policies of these
advertisers. Their privacy policy, not ours, will apply to any of those interactions. We
may also promote Children Apps in Third Parties’ applications and platforms.
In addition, we may advertise our other Apps within Children Apps. Such ads are not
directed towards specific Users but are rather broadly posted onto random Apps.
5. Additional Terms and Conditions
See further terms and conditions which also apply to Users of Children Apps in Chapter C below: “Terms and Conditions Common to Both Children Privacy Policy and Collins Mwai Privacy Policy”.
6. Which information may be processed from Users of our Collins Mwai Apps?
There are two types of information which may be processed about Users of our Collins Mwai Apps:6.1 Non-personal Information:
Non-identifiable and anonymous information (“Non-personal Information”).may be collected, stored and/or processed by us and/or third party providers of certain products and services, such as ad networks, analytics, etc. (“Third Party(ies)”). We and our Third Parties do not know the identity of the User from whom Non-personal Information has been collected. Non-personal Information is any information which is available to us and/or our Third Parties through use by Users of the Collins Mwai Apps. For details of the categories of data constituting Non-personal Information please refer to Section 3.1 above. Some jurisdictions consider this information to be personal information. Game Center Features: If a User enables Game Center Features in Collins Mwai Apps, then we will be provided with access to the identifier number of the User’s Game Center account (i.e. access token).7. How is the Information about Our Users collected?
7.1 Non-personal Information may be collected through your use of the Collins Mwai Apps.
In other words, when you are using a Collins Mwai App, we and our Third Parties are aware of it and may gather information relating to such usage, through the Collins Mwai Apps, APIs or SDKs embedded in our Collins Mwai Apps. In addition, local Non-personal Information may also be stored on your device via generally accepted industry technologies used within the Collins Mwai Apps, such as “cookies” and local storage7.2 Personal Information which you provide us directly and/or through Third Parties via your installation and/or use of the Collins Mwai Apps or your behavior to ads inside such Apps.
This information is collected via the Collins Mwai Apps or such Third Parties’ APIs or SDKs embedded in our Collins Mwai Apps. In addition, local Personal Information may also be stored on your device via generally accepted industry technologies used within the Collins Mwai Apps, such as “cookies” and local storage.8. What are the Purposes of the Collection of Information?
Non-personal Information is collected in order to:9. Sharing Information with other third parties
In addition to the sharing of Personal Information with Third Parties described above, we may share Personal Information in the following cases:10. Advertisements
We accept ads in various formats (such as banners, interstitial, rewarded videos, etc.) from Third Party ad networks which may be displayed in our Collins Mwai Apps. These Third Party ad networks may collect and use: (i) information about your visits to Collins Mwai Apps in connection with such marketing, sales and advertising activities; and (ii) geographic tracking and carrier network preferences; (iii) information, such as age, gender and other information logged from your device to ensure that appropriate advertising is presented within the App, to calculate or control the number of views of an ad, to deliver ads relating to User’s interests and to measure the effectiveness of ad campaigns. The delivery of ads to you may be based on IP address, device identifiers and other Personal Information gathered during your use of the Collins Mwai Apps. You may also be presented with contextual or non-targeted ads, i.e. ads which are not directed towards specific Users but are rather broadly posted onto random Apps. If you chose to receive contextual or non-targeted ads only within our Apps, please be aware that you may still see some targeted ads served by third parties if you have separately (e.g. on that third party’s website or app) agreed to personalized advertising directly to those third parties. You can find the list of Third Parties Ad Networks providing services in relation to Collins Mwai Apps at: Note that if you click on any of these ads, the advertisers may use cookies and other tracking technologies (such as tracking pixel agent or visitor identification technology, etc.) on your device to collect data regarding ad performance, your interaction with such ads and our Collins Mwai Apps and your interests (which may include, non-personal and/or personal information such as, device and network information, unique identifiers, gender, age and geo-location about you) in order to serve you ads, including targeted ads, and for the legitimate business interests of such Third Parties ad networks. We recommend that you review the terms of use and privacy policy of any third party advertisers with whom you are interacting before doing so. Their privacy policy, not ours, will apply to any of those interactions.11. Using Game Center Features and Social Features
Our Collins Mwai Apps may enable using certain Game Center Features and may include Social Features. The Game Center Features and the Social Features are operated or allow for social integration with certain third party social networks or third party platforms (“Social Network” or “Platform”) .12. Additional Terms and Conditions
See further terms and conditions which also apply to Users of the Collins Mwai Apps in Chapter C below: “Terms and Conditions Common to both Children Privacy Policy and Collins MwaiApps Privacy Policy”.13. Third Party Providers
When you use the Apps Third Parties may collect, store and/or process the information detailed in this Privacy Policy. You may find the list of Third Parties Ad Networks These Third Parties are carefully selected to ensure that they, and their related entities who may access Your information, provide Your information with equal protection to that stated in this Privacy Policy and required by applicable privacy laws and the Platform Providers’ rules, policies and guidelines. We use commercially reasonable efforts to engage with Third Parties that post a privacy policy governing their collection, retention, processing and use of non-personal and personal information. For further information regarding the collection, processing and usage of your information by the Third Parties, please review their privacy policy practices.14. The User’s compliance with Certain Additional Terms and Conditions
A User’s access to and use of the Apps (including use of Promotional Codes defined in TOS) may be subject to certain third party terms and conditions and privacy policies, including but not limited to those of application stores, mobile software platforms, Third Parties and payment providers. We do not exercise control of such third parties and are not responsible for their privacy practices and their use of the Users’ personal information. You should review the privacy policies of these third parties to learn how they may collect and use your Personal Information.15. Links to third party sites
Certain links provided in the Apps through ads or otherwise permit Users to leave our Apps and enter third party sites, products or services. These linked sites, products and services are not under our control . Most of such linked sites, products and services provide legal documents, including terms of use and privacy policies, governing the use of these sites. It is always advisable to read such documents carefully before using those sites and services so that you know what kind of information they are collecting.16. Cookies & Local Storage
When you access or use the Apps, we and/or our Third Parties may use industry-wide technologies such as “cookies”, web beacons, tags and local storage (or other similar technologies), which store certain local information on your device(“Local Storage”) , to identify a User’s device and ‘remember’ things about the User which may enable automatic activation of certain features (for example, if a User muted the sound within the App at a certain stage, this preference will be stored in the cache on the device and maintained the next time the User accesses the App on his device), monitoring of use of the Apps (counting Users who visit certain pages, use certain tools, viewed certain advertisements), frequency capping (for example, if we promote another App, this ensures that we do not advertise the same App more than a set number of times), to improve the quality of our services, measure ad performance, provide relevant ads etc. and making the User’s App experience and usage simpler, more relevant, convenient and effortless. Such information is locally stored in the User’s device. We and/or our Third Parties may access such information. Third Parties may use both session cookies (which expire once you close the App) and persistent cookies (which stay on the User’s device until he/she deletes them). Such Local Storage used by the Apps may store non-personal information (such as the different pages viewed by a User within the App) as well as User persistent identifier and geo-location data, which will be collected in accordance with the terms specified herein. It is easy to prohibit and/or delete the Local Storage, including via uninstalling the App from your mobile device and/or through the Settings option of your device. Most browsers and platforms will allow you to erase cookies from a device, block acceptance of cookies, or receive a warning before a cookie is stored. In order to erase or disable the Local Storage option you may use the settings option of your device or according to the specific instructions provided by the technology provider and/or Third Parties privacy policies and terms of use. However, if you block or erase cookies, or change the settings of your device, your App experience may be affected and may be limited.17. “Do Not Track” and Opt-out of Certain Third Parties’ Interest-Based Services
A User may prevent or limit targeted advertising from device settings which may vary from device to device. For example, if you are using an iOS device with iOS 7 or a newer version, this can be done from settings/privacy/advertising by resetting advertising identifiers or limiting ad tracking settings. If you are using a Google Android device with Android 2.3 or a later version, you can find the ad identifier settings in the app drawer under Google Settings> Ads. Please note that activation of any applicable “Do-not-track” settings on the User’s mobile device or any other device-level setting opt outs for targeted advertising, (to the extent such options exist) may not cease all tracking activities by our Third Parties’ service providers.18. International Data Transfer
We may transfer (and store) information collected about you, including Personal Information, to affiliated entities, or to other third party service providers across borders and from your country or jurisdiction to other countries or jurisdictions around the world (all solely for legitimate business purposes). Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, wherever your Personal Information is transferred.19. California Privacy Rights
19.1 To the extent applicable, if you are a California resident under the age of 18 and a User, California Business and Professions Code Section 22581 may permit you to remove content or Personal Information you have publicly posted. If you wish to remove such content or Personal Information and you specify which content or Personal Information you wish to be removed, we will do so in accordance with applicable law.Categories of Personal Information | Categories of sources from which information is collected: | Business or commercial purposes for collection, use and sharing: | Disclosed for business purposes to the following categories of third parties: |
---|---|---|---|
Personal and online identifiers (such as unique online identifiers, IP address) | Consumers | Marketing;
Advertising; Authentication; Identity resolution; Fraud detection; Fulfillment services; Facilitating transactions; Auditing related to our interactions with you; Legal compliance; Detecting and protecting against security incidents, fraud, and illegal activity; Debugging; Performing services (for us or our service providers) such as account servicing, processing orders Affiliates; Service providers; and Government agencies and payments, and analytics; Internal research for technological improvement; Internal operations; Activities to maintain and improve our services; and Other one-time uses |
Affiliates; Service providers; and Government agencies |
Internet or other electronic network activity information (such as interactions with an application, or advertisement) | Consumers; Service Providers; Affiliates not under the Collins Mwai brand |
Marketing; Advertising; Authentication; Identity resolution; Fraud prevention; Fulfillment services; Facilitating transactions; Auditing related to our interactions with you; Legal compliance; Detecting and protecting against security incidents, fraud, and illegal activity; Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics; Internal research for technological improvement; Internal operations; Activities to maintain and improve our services; and Other one-time uses |
Affiliates; Service providers; and Government agencies |
Commercial or
transactions
information (such
as records of
personal property
or products or
services
purchased,
obtained or
considered; purchasing or consuming histories or tendencies) |
Consumers; Service Providers; App store providers; Affiliates not under the Collins Mwai brand |
Fulfillment
services; Facilitating transactions; Auditing related to our interactions with you; Debugging; Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics; Internal research for technological improvement; Internal operations; Activities to maintain and improve our services Other one-time uses |
Affiliates; Service providers; App store providers; and Government agencies |
Geolocation information | Service Providers | Marketing; Advertising; Fulfillment services; Facilitating transactions; Auditing related to our interactions with you; Legal compliance; Debugging; Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics; Internal research for technological improvement; Internal operations; Activities to maintain and improve our services; and Other one-time uses |
Affiliates; Service providers; and Government agencies |
Inferences drawn from the above information about your predicted characteristics and preferences | Consumers | Marketing; Advertising; Legal compliance; Detecting and protecting against security incidents, fraud, and illegal activity; Debugging; Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics; Internal research for technological improvement; Internal operations; Activities to maintain and improve our services; and Other one-time uses |
Affiliates; and Government agencies |
Your Rights Regarding Personal Information. California residents have certain rights
with respect to the personal information collected by businesses. If you are a California
resident, you may exercise the following rights regarding your personal information,
subject to certain exceptions and limitations:
The right to know the categories and specific pieces of personal information we
collect, use, disclose, and sell about you, the categories of sources from which we
collected your personal information, our purposes for collecting or selling your personal
information, the categories of your personal information that we have either sold or
disclosed for a business purpose, and the categories of third parties with which we have
shared personal information.
The right to request that we delete the personal information we have collected from
you or maintain about you.
The right to opt out of our sale(s) of your personal information. Please note that if you
opt out of certain types of sales, we will be unable to provide you with the services that
rely on such sales.
The right not to receive discriminatory treatment for the exercise of the privacy
rights conferred by the CCPA.
To exercise any of the above rights, please contact us by email to:
collinsmwai@gmail.com
and submit the required verifying information.
Note that we may need to request additional information from you to verify your identity
or understand the scope of your request, although you will not be required to create an
account with us to submit a request or have it fulfilled. We will require you to provide, at
a minimum, information verifying your identity and providing the agent with written
permission to make the request for you. We do not knowingly sell the personal
information of minors under 16 years of age.
Deletion and Modifications of Information
You or, as applicable, your legal guardian, may request, by sending us an email to collinsmwai@gmail.com , the following:20. Security
Security of your information is very important to us. We take reasonable measures to maintain the security and integrity of our Apps and User information and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures. Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur. TO THE FULLEST EXTENT PERMITTED BY LAW THE COMPANY SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED DISCLOSURE OR ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR THE THEFT, ALTERATION, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION INCLUDED IN THE USER GENERATED CONTENT.21. Changes to the Privacy Policy
The terms of this Privacy Policy will govern the use of the Apps and any information collected therein. We reserve the right to change this policy at any time, so please re-visit this page frequently to check for any changes. In case of any material change, we will make reasonable efforts to post a clear notice on the Apps and/or our website at . Such material changes will take effect five (5) days after such notice was provided on our App and/or Site, whichever is earlier. Otherwise, all other Changes to this Privacy Policy are effective as of the stated “Last Revised” and your continued use of the Apps on or after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.22. Got any Questions?
If you have any questions (or comments) concerning this Privacy Policy, you are most welcome to send us an email to the following address: collinsmwai@gmail.com and and we will make an effort to reply within a reasonable timeframe.