Privacy Policy

Last update: October 22nd, 2021

 

WHO ARE WE AND WHAT IS THIS DOCUMENT?

MWM, which is located 54, Avenue du Général Leclerc, 92100, Boulogne Billancourt, France and can be contacted by email at: contact@mwm-apps.com, (hereinafter “MWM“), develop and publish mobile apps and games (hereinafter “MWM Apps and Games”) and the website www.mwm.io (hereinafter the “Website”). 

MWM is very mindful of respecting your private life and the confidentiality of Personal Data relating to you (hereinafter “Personal Data”). This privacy policy is intended to inform you of how your Personal Datas are collected, processed and stored by MWM and its processors when you use the MWM Apps and Games and related services, regarding MWM’s ads and ads services as well as MWM’s website.

 

 

By using and or registering on MWM Apps and Games and MWM’s Website you hereby accept and agree to be bound by the present Privacy Policy. 

Some MWM Apps and Games might have a specific Privacy Policy. If those Apps and Games present specific Privacy Policy linked through the Apple or Google play store page of the App or Game and/or within each individual App or Game, the Privacy Policy of such Apps and Games supersede the present Privacy Policy. 

MWM undertakes to process your Personal Data in accordance with the applicable laws and regulations, and in particular 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, or “GDPR”, and Law No. 78-17 of 6 January 1978 on information technology, data files and liberties, in its current version (hereinafter the “Applicable Regulations”).

Please note that MWM can amend this privacy policy at any time, in full or in part. If the privacy policy is amended, you will be informed by a push notification or an email sent to you with a link toward the updated privacy policy.

 

MWM may collect and process your Personal Data to : 

I. develop and publish MWM Apps and Games,

II. serve advertising tailored to the your interests and

III. operate our MWM’s websites. 

 

I. MWM APPS AND GAMES

 

  1. WHAT PERSONAL DATA DO WE COLLECT AND WHAT FOR? 

MWM processes your Personal Data for the purposes and on the legal bases set out below.

 

1.1   Personal Data collected when you register on the App

What kind of Personal Data: If available, when you register on the App, you must provide a certain amount of information, particularly your username, email and password. You may also add a profile picture and a short presentation to your profile if available.

If available, you can also decide to sign up with Apple, using your Apple ID, or with Facebook which will transmit to MWM the public information on your Facebook profile: name, surname, profile picture, and if you chose to share it or if authorized in your Facebook settings, your email address. Please note that if you chose to hide your email address, MWM won’t have it, but we will nevertheless be able to communicate with you through Apple or Facebook. 

Legal basis: MWM processes such Personal Data for the creation and management of your account and for providing the services offered via MWM Apps and Games. This processing is necessary for entering into and executing a contract with you. 

You are informed that MWM also uses your email address to send you service messages, and information relating to the MWM Apps and Games (e.g. contents created by the community, tutorials, new features etc.), and direct marketing emails or newsletters relating to other similar products or services offered by MWM, on the basis of its legitimate interests to communicate with you and inform you of new products or services.

You hereby acknowledge that some of your Personal Data (username and profile picture) will be visible to other users of the MWM Apps and Games when you post content. 

Please note that most of the time, you can also access the MWM Apps and Games as a “visitor”, without registering. The above Personal Data will then not be collected. 

 

1.2   Personal Data collected when you subscribe

What Kind of Personal Data: In case of in-app purchases, your card details and invoice information (name, surname and postal address) are collected and processed by Google or Apple, depending on the app store of your device. 

Legal Basis: Such Personal Data will only be processed for the payment or subscription you ordered. This processing is necessary for entering into and executing a contract with you. 

 

1.3   Personal Data collected when you contact MWM through MWM Apps and Games

What Kind of Personal Data: While you are using the MWM Apps and Games, you may contact MWM for various purposes. While doing so, MWM might collect Personal Data such as your e-mail address, your name, surname, and any other information you include in your messages.  

Legal Basis: MWM will process your Personal Data based on its legitimate interests to process and answer your questions and claims. 

 

1.4   Personal Data collected when you use the MWM Apps and Games

What kind of Data:  While you use MWM Apps and Games and in order to better organize and manage the contents presented on the MWM Apps and Games, to run analytics and understand how users interact with our product and services in order to continuously improve it, and to to serve advertising tailored to the preference and interests of our users, MWM may collect Data limited to:

      • The apps you are using
      • Your IP address
      • Your Mobile Advertising ID (Apple IDFA or Google AAID – which are technical identifiers developed by mobile operating systems for advertising purposes which remain under your control and can be reset or erased at any time in through your device settings)
      • Technical information about the device you use and your connection (user agent, type of connection, timestamp)
      • Data pertaining to your activities on our applications and notably the way in which you interact with our applications (for instance, how and when you use our applications) and with the advertising served in our applications (for instance, number of ads served, potential clicks)

 

Legal Basis: Those Personal Data are collected upon your express consent.

 

 

  1. WITH WHOM MAY YOUR DATA BE SHARED AND WHY ?

The first time you connect on MWM Apps and Games, a pop up will be displayed, informing you that if you give your consent, your advertising ID (IDFA) and other data, such as location data, and other demographic and interest data about you will be collected and transmitted to our Ad partners and Analytic companies (see-below) for the purpose of providing you with a personalized advertising experience and analytics purpose. You are free to refuse or agree to such processing.

When you consent to the collection of data for advertising and analytics purpose, we may share the data listed above with the following categories of recipients:

 

  • Ad partners: that allow us to monetize the ad inventory of MWM Apps and Games and provide users with free products and services.


Those partners usually collect data via their own tools (software development kits or “SDK”). you will find a list of our partners implemented advertising SDK through our applications and the privacy policies of their services that describe their practices and allow you to exercise your rights directly toward them hereafter:

 

  • Analytic companies: that provide us with tools and technologies that allow us to better understand how users interact with our services and will help us improve it. Those partners also usually collect data via their own SDK. you will find a list of our partners implementing analytical SDK through our applications hereafter:

 

 

  • Authorities: only to the extent we are obliged to by applicable laws and regulations.

 

  • Service providers: technical, hosting or client support services providers such as: 

 

  • MWM may also need to share your Personal Data with its external advisors (lawyers, accountants, etc.).

 

 

II. PERSONALIZED ADVERTISING

 

  1. WHAT PERSONAL DATA DO WE COLLECT AND WHAT FOR? 

MWM Ads services allow MWM and its publisher partners (most of the time MWM Ads partners are third party mobile application providers) to monetize advertising inventory by allowing advertisers to serve personalized advertising to users. 

What kind of Data:  While you use the Apps and in order to help advertiser promote their products and services and improve our own Ads services, MWM may collect data limited to:

      • The apps you are using
      • Your IP address
      • Your Mobile Advertising ID (Apple IDFA or Google AAID – which are technical identifiers developed by mobile operating systems for advertising purposes which remain under your control and can be reset or erased at any time in through your device settings)
      • Technical information about the device you use and your connection (user agent, type of connection, timestamp)
      • Data pertaining to your activities on our applications and notably the way in which you interact with our applications (for instance, how and when you use our applications) and with the advertising served in our applications (for instance, number of ads served, potential clicks).

 

Legal Basis: In order to deliver such services for its partners, MWM can receive and process data for different legitimate purposes:

 

    • To help advertiser partners promote their products and services : 

MWM ads services help advertisers promote their products and services to an audience that has demonstrated interests in similar products and services and allow them to optimize their marketing spends.

 

    • To improve MWM Ads services :

MWM is committed to constantly improve the services delivered to its publishers and advertisers. In order to do so, MWM Ads processes the data listed above in a way that notably allows it to better understand how users interact with the ads of our advertiser partners and optimize their user experience.

 

 

  1. WITH WHOM DO WE SHARE YOUR PERSONAL DATA? 

 

Data collected for the purposes of MWM Ads services are only shared with the following categories of recipients and only to the extent such data is necessary for the purpose they are following: 

 

      • Advertisers that are using MWM Ads services to serve personalized or non-personalized advertising.
      • Publishers that are using MWM Ads services to monetize their advertising inventory.

 

III. MWM WEBSITE

 

  1. WHAT PERSONAL DATA DO WE COLLECT AND WHAT FOR? 

 

1.1 When you directly contact MWM

What kind of Data: While browsing and using MWM’s website and contacting MWM, MWM might collect and process your Personal Data in one of two ways:

    • When contacting the address: ariane@mwm.io for Public Relations inquiries or interview requests, you might communicate Personal Data to MWM based on your declaration such as e-mail address, name, surname, contact information etc. ;
    • When using the contact form you are invited to provide certain Personal Data, such as your name, surname, e-mail address, phone number, resume etc. 

 

Legal Basis: Aforementioned collection and processing of Personal Data are done based on our legitimate interests to process and answer your questions and application. 

 

  1. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

 

Regarding you contacting MWM for Public Relations inquiries or interview requests, no Personal Data pertaining to those might be shared to any third party. 

 

Regarding your application, MWM uses a third party provider, i.e. Lever to process and collect applications and Personal Data related. As such, when you apply through Lever, your Personal Data are also shared to Lever, which Privacy Policy regarding such collection may be viewed at the following address: https://help.lever.co/hc/en-us/articles/360028434011-Service-Privacy-Notice 

 

IV.  HOW LONG DO WE STORE YOUR PERSONAL DATA FOR? 

 

You are hereby advised that MWM shall not keep Personal Data collected, received and processed for the purposes described in this policy longer than necessary for the purposes described above in this section. 

It means that for Data collected and processed when registering on MWM Apps and Games, MWM shall store your Personal Data for any length of time required for the use of your account, as such, your Personal Data will be permanently deleted when you delete your account. If your account remains inactive for a period of 3 years after the final user action, MWM will send you an email to inform you of the deletion of your account. 

You are hereby informed that MWM reserves the right to store your Personal Data in its temporary archives where strictly necessary to defend its rights in the event of a dispute, for the applicable limitation period. 

Also, please note that considering its status of hosting service provider, MWM is subject to a legal obligation to retain some Personal Data relating to you for a duration of one year, on the basis of article 6.II of the Law 2004-575 of 21 June 2004 on confidence in the digital economy (LCEN). 

 

 

V.  INTERNATIONAL TRANSFERS

 

Some of the partners and processors referred to in this policy are located outside of the European Union.

In such case, we ensure that:

    • The Personal Data is transferred to countries recognized as offering an equivalent level of protection or,
    • Personal Data is transferred to certified entities under the Privacy Shield or,
    • For Personal Data transferred outside of countries recognized by the European Commission as having a sufficient level of protection, any of the mechanisms offering appropriate guarantees is used, for which provision is made by applicable regulations, and in particular the adoption of the standard contractual clauses of the European Commission.

 

 

VI.  HOW CAN YOU EXERCISE YOUR RIGHTS?

 

In accordance with the Applicable Regulations, you have the rights to access, rectify, and delete your Personal Data. Under the conditions of the Applicable Regulations, you also benefit from the rights to request the limitation of the processing, the portability of your Personal Data, and the right to object to processing for reasons pertaining to your personal situation when the processing is based on MWM’s legitimate interest. You can also communicate instructions about the fate of your Personal Data in the event of your death.

 

You can also, at any time, and without reason, object to the processing of your Personal Data for the purposes of direct marketing.

 

You can exercise these rights with MWM by sending your request accompanied by a copy of an identity document by email to the following email address: privacy@mwm-apps.com or by mail, writing to the following address: MWM, 54, Avenue du Général Leclerc, 92100, Boulogne Billancourt, France.

 

In any case, you may, at any time, submit a claim to the CNIL (French Data Protection Authority) (www.cnil.fr).