Privacy Policy

We have the utmost respect for your privacy and understand that your personal information is important to you.

Memory Lane Games Limited and its subsidiaries and affiliates (“MLG”, “we”, “us” or “our”) are committed to protecting and respecting your rights to privacy. The basis on which any personal data we collect from you, or that you provide to us, will be processed by us on a lawful basis is set forth in this privacy policy, our terms of use (https://memorylanegames.com/terms-of-use) and the EU General Data Protection Regulation 2016/679 (“GDPR”) as implemented in the Isle of Man (https://memorylanegames.com/privacy-policy-gdpr).

Please read the following carefully to understand our views and practices regarding your personal data and how we will collect, use and disclose such information. This privacy policy applies to all of the software, services, information, tools, features and functionality offered by MLG on our mobile applications known as "Memory Lane Games" and “Memory Lane Games Lite”, and the content, features, software, related technology and services therein (the "Apps"). Should we ask you to provide personal data when using our Apps, such personal data will only be used in accordance with this privacy policy.

IMPORTANT: BY USING THE APPS, YOU GIVE YOUR CONSENT THAT ALL PERSONALLY IDENTIFIABLE INFORMATION ("PII") THAT YOU SUBMIT OR THAT IS COLLECTED THROUGH THE APPS, INCLUDING ANY PII RELATING TO YOUR DEPENDENTS, MAY BE PROCESSED BY MLG IN THE MANNER AND FOR THE PURPOSES DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS SET FORTH HEREIN, PLEASE DO NOT USE THE APPS.

MLG will generally be the controller of your PII provided to, or collected by or for, or processed in connection with the Apps.

1. Who to contact about your PII

If you have any questions about our use of your PII you can e-mail [email protected].

2. Purposes of Processing Your PII

We process your PII for specific and limited purposes, including the provision of the Apps. We ask only for PII that is adequate, relevant and not excessive for those purposes and internally to help us improve our Apps and to help resolve any problems with the Apps. In particular, and without limitation, we may use PII held about you in the following ways and for the following purposes:

  • To enable you to carry out the main purpose of the Apps, meaning share your photographs and games, we may collect: (1) your mobile device configuration (for further information please see “User Information”); (2) Submitted Content (as defined in the Terms of Use) uploaded to the Apps; and (3) Apps usage patterns (for further information please see “Traffic data collected through the Apps”). All of the above mentioned PII are saved to the cloud for backup (for further information please see Section 4 of this privacy policy).

  • In order to provide you with information, support, products or services that you request from us or which may be of interest to you, where you have consented to be contacted for such purposes, including information about new products, features or special offers we ask you for your: (1) first and last name; (2) email address; and/or (3) telephone number. Please note that you do not have to provide the above mentioned PII but in such a case we may not be able to provide you some of the features of the Apps.

  • On the Apps, we may collect any PII that you post and/or upload and/or transmit through the Apps, including, but not limited to, any Submitted Content using the Apps and any details that you provide relating to such Submitted Content such as the names of the people (including people-tagging) in the Submitted Content.

  • To enable internal record keeping.

3. PII We Collect

In connection with your use of the Apps, we may collect the following types of PII:

User information

  • When you use the Apps, we may automatically receive and record information from your device and browser, including your cookie information, your country, regional and language settings, device model, operating system, IDFA, mobile carrier and software and hardware attributes.

  • Our systems may automatically record and store technical information (software, hardware and regional settings) regarding the method and nature of your use of the Apps, including, without limitation, the date on which you downloaded and installed the Apps, which parts of the Apps our users view and/or use and the dates and times on which they viewed or used such parts of the Apps, impressions, the number of views they get and any actions they make in the Apps (such as when Submitted Content was edited, deleted, shared and with whom, or metadata relating to Submitted Content tagged by you (e.g. captions, dates, people-tagging). For further information please see section “Traffic data collected through the Apps”.

  • Third party providers that work with us use your IP address to help us with server problem diagnosis and to administer the Apps. An IP address is a numeric code that identifies your device on a network, or in this case, the Internet. Your IP address is also used to gather broad demographic information. We may also perform IP lookups through third party providers to determine which domain you are coming from (e.g. aol.com, yourcompany.com) to more accurately gauge our users' demographics.

  • Subject to the acceptance of your specific consent we may share PII with third parties for their direct marketing purposes.

Traffic data collected through the Apps

  • In addition to the information we collect as described above, we may use technology to collect information about the use of the Apps. For example, our systems may automatically record and store browser information, exit point, usage time, platform type, operating system information, number of clicks and cookies. This technology does not identify you personally, it simply enables us to compile statistics about our users and their use of the Apps. When you use the Apps, our third-party providers record information (“Log Data”), including information that your browser automatically sends whenever you visit a website, or that your mobile app automatically sends when you’re using it. This Log Data includes your browser type and settings, the date and time of your request, how you used the Apps, cookie data and device data.

 

  • In addition to Log data, we collect information about the device you’re using the Apps on, including type of device, operating system, settings, unique device identifiers and crash data that helps us understand when something breaks. Whether we collect some or all of this information often depends on what type of device you’re using and its settings. For example, different types of information are available depending on whether you’re using a Mac or a PC, or an iPhone or Android phone. To learn more about what information your device makes available to us, please also check the policies of your device manufacturer or software provider.

 

  • Furthermore, the Apps contain hyperlinks to other pages, widgets and features. We may use technology to track how often these links are used and which pages, widgets and features of the Apps our users choose to view. Again, this technology does not identify you personally it simply enables us to compile statistics about the use of these hyperlinks.

Cookies

  • In order to keep you logged in to the Apps we may use temporary cookies that remain on your device for a limited period of time, for as long as the Apps are provided / not terminated. We may also use persistent cookies that remain on your device until the Apps are removed. Cookies by themselves cannot be used to discover the identity of the user. A cookie is a small piece of information which is sent to and stored on your device. Cookies do not damage your device. Most browsers or devices may allow you to block cookies but you may not be able to use some features of the Apps if you block them. You may set most browsers to notify you if you receive a cookie (this enables you to decide if you want to accept it or not).

 

  • We may also use web beacons via the Apps to collect information. Web beacons or "gifs", are electronic images that may be used in our Apps or in our emails. We may use web beacons to deliver cookies, count users and to tell if an email has been opened and acted upon. As mentioned below, we may use service providers or third parties' services (for further information about any service provider and third parties please see Section 4 “Information Sharing” to this privacy policy) who also uses such or similar tracking technologies when you use the Apps.

 

User communications

  • When you send an email or other communication to MLG, we may retain those communications in order to process your inquiries, respond to your requests and improve our Apps. We may send you push notifications to offer you special updates in respect of the Apps. You should be able to opt-out of these notifications at the device level. We may also send you newsletters and promotional communications if you joined our mailing list, you may opt-out of this service at any time by clicking UNSUBSCRIBE at the bottom of each email or by submitting a request to [email protected].

Links

  • Links to other sites and applications may be provided by MLG as a convenience to our users. MLG is not responsible for the privacy practices or the content of other sites and applications and you visit them at your own risk. We recommend that you carefully read the terms of use and privacy policies of such sites and applications. This privacy policy applies solely to PII collected by us through the Apps or otherwise in accordance with the Terms of Use.

Third Parties

  • We sometimes supplement the information that you provide with information that is received from third parties (see further information below under “Information Sharing”; also, at your convenience, see a list of third party service providers is available at: https://memorylanegames.com/privacy-policy-gdpr).

 

  • For illustration by way of an example, if you interact with Facebook and/or WhatsApp and/or any other social media network or other social media plug-in in the Apps (such as a Facebook "Like" button) ("App Platforms") in connection with the Apps (such as by sharing a photo or video on Facebook or WhatsApp via the Apps), we may receive information from your respective App Platform account, including your name, profile picture, email address, and any information defined as public pursuant to the policies of such App Platforms.

 

  • You are responsible for your decision to share your Submitted Content with others, including on the App Platforms. You should check your App Platforms privacy settings to understand and change the information sent to us through the App Platforms. MLG is not responsible for the privacy practices of such third parties and/or App Platforms. We recommend you to carefully read the terms of use and privacy policies of such third parties and/or App Platforms before using their services and connecting to the Apps. This privacy policy applies solely to PII collected by us through the Apps or otherwise in accordance with the Terms of Use.

Dependents

  • We care about the safety of children. Therefore, the Apps are not directed towards children under 18, who are not allowed to use the Apps or provide PII. If you are under the age of 18 or the age of legal majority where you reside if that jurisdiction has an older age of majority, you must obtain parental consent (or consent from your legal guardian) prior to using our Apps. We do not knowingly contact or engage with children under the age of 18 (or the age of legal majority where you reside if that jurisdiction has an older age of majority) without said parental consent (or consent from your legal guardian). If you have reason to believe that a child under the said age has provided us with their PII, please contact us at the address given above and we will endeavor to delete that PII from our databases.

 

  • If you are a parent or guardian who knows or has discovered that your child or dependent under the age of 18 or someone else has submitted your child’s PII or other information without your consent, permission, or authorization; upon request, we will promptly remove your child’s PII or other information from our database, cease the use of such information and direct any other party with access to such information to do the same.

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  • If you have a firm and reasonable basis to believe that photos or videos of any children that you have discovered were not submitted appropriately, please contact us at the address given above and we will consider conducting necessary actions to protect the children’s rights, including contacting the person submitted such photos or videos or delete them.

Maintenance

  • MLG uses the PII that you provide or that we collect to operate, maintain, enhance, and provide the Apps.

Analysis

  • MLG uses PII that you provide or that we collect under the terms of this privacy police to understand the usage trends and preferences of our users, to improve the way the Apps work and look, and to create new features and functionality.

4. Information sharing

MLG is a worldwide service. By providing any PII to us pursuant to this privacy policy all users fully understand and unambiguously consent to this privacy policy and to the collection and processing of such PII. The server on which the Apps are hosted and/or through which the Apps are processed may be outside the country from which you access them and may be outside your country of residence. Some of the uses and disclosures mentioned in this privacy policy may involve the transfer of your PII to various countries around the world that may have different levels of privacy protection than your country.

We take additional measures when information is transferred from the European Economic Area (EEA). This includes having standard clauses approved by the European Commission in our contracts with parties that receive information outside the EEA. We also rely on European Commission adequacy decisions about certain countries, as applicable, for data transfers to countries outside the EEA. By submitting your PII through the Apps, you consent, acknowledge, and agree that we may collect, use, transfer, and disclose your PII as described in this privacy policy. In this regard please see our GDPR webpage available at: https://memorylanegames.com/privacy-policy-gdpr.

Nevertheless, the Company only shares PII with other companies or individuals in the following limited circumstances:

  • As required for the provision of the Apps, including, without limitation, sharing information with payment service providers and other service providers (including for analysis and statistics), and with App Platforms, all on our behalf based on our instructions and in compliance with this Privacy Policy and applicable laws, which are currently App Store and Google Play.

  • The App servers that are used to store your PII are owned and hosted by Google Cloud Platform (GCP) (their privacy policy and practices may be found athttps://policies.google.com/privacy).

  • You may choose to share your Submitted Content and other PII with others on or through the Apps. In addition, your Submitted Content, other PII, and any other information that you voluntarily post on the Apps may become visible by the public on the Apps, subject to any applicable privacy settings that you set. If you do not want your Submitted Content or other PII or information to be visible by others, please be sure to set your privacy setting on your phone to "Private". Once you have shared your Submitted Content and other PII or information with others (via various channels available through the application), or set your privacy setting to "Public", it may be re-shared by others. You are solely responsible for your decision to share your Submitted Content and other PII and information with others and/or to make your Submitted Content and other PII and information visible by others.

  • We have your consent.

  • We provide PII to trusted service providers for the purpose of processing PII on our behalf. We require that these parties agree to process such PII based on our instructions and in compliance with this Privacy Policy, any applicable laws and any other appropriate confidentiality and security measures. 

  • We have a good faith belief that access, use, preservation or disclosure of such PII is reasonably necessary to (a) satisfy any applicable laws, regulation, legal process or enforceable governmental request; (b) enforce applicable agreements and/or their terms, including investigation of potential violations thereof; (c) detect, prevent, or otherwise address fraud, security or technical issues; or (d) protect against imminent harm to the rights, property or safety of MLG, its users or the public as required or permitted by law.

  • If we become involved in a merger, acquisition, or any form of sale of some or all of our assets or in the event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, you will be notified on a best efforts basis via email and/or a prominent notice on our website, of any change in ownership, uses of your PII, and choices you may have regarding your PII. In any of the circumstances above, your PII will continue to be used in accordance with this Privacy Policy.

  • We obtain assurances from our agents that they will safeguard PII through measures consistent with this Privacy Policy and further privacy measures and protocols. Where we have knowledge that an agent is using or disclosing PII in a manner contrary to this Privacy Policy, we take commercially reasonable steps to prevent or stop the unauthorized use or disclosure.

5. Information security

We follow generally accepted industry standards to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of PII. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your PII, we cannot guarantee its absolute security.

  • We strive to maintain the reliability, accuracy and completeness of PII that we collect and to protect the privacy and security of our users. We keep your PII only for as long as reasonably necessary for the purposes for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements.

  • We limit access to PII about you to employees, contractors and service providers who we believe reasonably need to come into contact with that PII. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

  • We have physical, electronic, and procedural security measures and safeguards to reasonably protect PII. Our servers and our databases are protected by industry standard security technology, such as industry standard firewalls and password protection.

  • Although we cannot guarantee against any loss, misuse, unauthorized disclosure, alteration or destruction of data, we try to prevent such unfortunate occurrences, including by implementing corporate procedures in this regard. If you have reason to believe that your use of the Apps is no longer secure, please immediately notify us of the problem by contacting us.


 

6. Data integrity, accessing and updating personal information

MLG processes PII only for the purposes for which it was collected and in accordance with this Privacy Policy or any applicable service agreements. We review our data collection, storage and processing practices to ensure that we only collect, store and process the PII needed to provide or improve our Apps. We take reasonable steps to ensure that the PII we process is accurate, complete, and current, but we depend on our users to update or correct their PII whenever necessary. Nothing in this Privacy Policy is interpreted as an obligation to store information, and we may, at our own discretion, delete or avoid from recording and storing any and all information.

  • Upon receipt of your written request and enough information to permit us to identify your PII, in accordance with the instructions further detailed here: https://memorylanegames.com/privacy-policy-gdpr, we will disclose to you the PII we hold about you. Upon your request, we will also correct, amend or delete any PII that is inaccurate and notify any third party who received this PII from us of the necessary changes.

  • We do not charge for complying with a correction request, however, for all other requests, we may charge a small fee to cover its costs. Requests to delete PII are subject to any applicable legal and ethical reporting or document retention obligations imposed on MLG.

  • We ask individual users to identify themselves and the PII requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical, or for which access is not otherwise required.

7. Enforcement

MLG regularly reviews its compliance with this Privacy Policy. Please feel free to direct any questions or concerns regarding this Privacy policy or our treatment of PII by contacting us. When we receive formal written complaints, it is MLG’s policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of PII that cannot be resolved between MLG and an individual.

If you're based in the European Economic Area and think that we haven't complied with data protection laws, you have a right to lodge a complaint with the Data Protection Commission in the United Kingdom or with your local supervisory authority.

8. Updates to this Privacy Policy

We may update this Privacy Policy from time to time in its sole discretion and without notification. You are bound by such updated and we encourage you to periodically review this Privacy Policy for the latest information about our privacy practices. Your use of the Apps following these changes means that you accept the revised privacy policy.

9. Data Security and Encryption

Data security is an utmost priority for us. In our Apps we take the following procedures to ensure all user data is kept safe and secure:

  • All users are only ever registered under a completed anonomously and randomly generated, RFC4122-compliant user ID.

  • Any analytic events are tracked using this unique ID and no analytics data is shared with third parties.

  • No personal information is entered at any time or stored on our servers - the only data points we record are whether what games you like or dislike so we can deliver better games to you everyday.

  • Games that are location specific may use the users location (with their in-app permission granted) to retrieve games relevant to their local area. This location is sent over https securely to our Firebase servers and does not persist in any way once the games have been retrieved.

  • Our service does not allow for any peer-to-peer communication through the Apps.

  • Our storage and database solutions have custom security rules to prevent external access from any party except our development and game creation teams.

Last Updated: 25 February 2022