Effective
as of April 10, 2023.
Last
updated April 10, 2023.
This
Privacy Policy describes the privacy practices of Matchy
in connection with the Matchy mobile application (the
“Game”) and matchy.game website (the “Site”).
Welcome to Matchy’s Privacy Policy!
If
you decide not to read this entire Privacy Policy, we want you to walk away
with a few key points about Matchy’s privacy practices:
If
you have any questions about our privacy practices, please email contact@matchy.game.
Here’s
more on our privacy practices. Individuals located in the European Economic Area should also read our Notice to European Users below.
When
you use the Game, we may collect information about you, including:
Other Sources: We may also collect
personal data about individuals that we do not otherwise have from, for
example, publicly available sources, third-party data providers, brand
partnerships, or through transactions such as mergers and acquisitions. We use
this information to operate, maintain, and provide you with the features and
functionality of our Services.
We
may use information you provide for the following purposes:
To operate and improve the Game:
To send you marketing and
promotional communications. We may send you marketing communications as
permitted by law. You will have the ability to opt-out of our marketing and
promotional communications as described in the Opt-out of marketing section below.
To
display advertisements to you. If you use the free version
of the Game, we work with advertising partners to display advertisements within
the Game. These advertisements are delivered by our advertising partners and
may be targeted based on your use of the Game or your activity elsewhere online.
To learn more about your choices in connection with advertisements, please see
the section below titled “Targeted online advertising.”
For compliance, fraud
prevention, and safety. We may use your personal information and disclose it to law
enforcement, government authorities, and private parties as we believe
necessary or Appropriate to: (a) protect our, your or others’ rights, privacy,
safety or property (including by making and defending legal claims); (b)
enforce the terms and conditions that govern the Service; and (c) protect,
investigate and deter against fraudulent, harmful, unauthorized, unethical or
illegal activity.
With your consent. In some cases, we may specifically ask for your consent to
collect, use or share your personal information, such as when required by law.
To create anonymous,
aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from
your personal information and other individuals whose personal information we
collect. We make personal information into anonymous, aggregated or
de-identified data by removing information that makes the data personally
identifiable to you. We may use this anonymous, aggregated or de-identified
data and share it with third parties for our lawful business purposes.
We
may share your information in the following circumstances:
Affiliates. We may share Game usage
information with our subsidiaries and affiliates, for purposes consistent
with this Privacy Policy.
Service providers. We may share your personal information with services providers
that perform services on our behalf or help us operate the Game (such as
customer support, hosting, analytics, email delivery, marketing, and database
management services). These third parties may use your personal information
only as directed or authorized by us and in a manner consistent with this
Privacy Policy, and are prohibited from using or disclosing your information
for any other purpose.
Advertising partners. When we use third-party cookies and other tracking tools, our
advertising partners may collect information from your device to help us
analyze use of the Site and the Game, display advertisements on the Game and
advertise the Site and Game (and related content) elsewhere online.
Third-party platforms and social media
networks. If you have enabled features
or functionality that connect the Game to a third-party platform or social
media network (such as by logging into Matchy using your account with the
third-party, providing your API key or similar access token for the Game to a
third-party, or otherwise linking your account with the Game to a third-party’s
services), we may disclose the personal information that you authorized us to
share. We do not control the third-party platforms’ use of your personal
information, which is governed by that third party’s privacy policy and terms
and conditions.
Professional advisors. We may disclose your personal information to professional
advisors, such as lawyers, bankers, auditors and insurers, where necessary in
the course of the professional services that they render to us.
For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud
prevention and safety purposes described above.
Business transfers. We may sell, transfer or otherwise share some or all of our
business or assets, including your personal information, in connection with a
business transaction (or potential business transaction) such as a corporate
divestiture, merger, consolidation, acquisition, reorganization or sale of
assets, or in the event of bankruptcy or dissolution.
We
may be required to use and share your personal information to comply with
applicable laws, lawful requests, and legal process, such as to respond to
subpoenas or requests from government authorities.
In
this section, we describe the rights and choices available to all users. Users
who are located within European can find additional information about their
rights below.
Opt out of marketing
communications and other push notifications. You may opt out of marketing-related communications and other
notifications we may send you via push notification by changing the settings on
your mobile device.
Device permissions. You may revoke any permissions you previously granted to us,
such as permission to access your camera, camera roll, or microphone through
the settings on your mobile device.
Cloud processing. You may request that we remove your information by clicking the
“Request account removal” button in the “Support” section of the Game Settings
on your mobile device or by contacting us.
Cookies & Browser Web Storage. Most browsers let you remove or reject cookies. To do this,
follow the instructions in your browser settings. Many browsers accept cookies
by default until you change your settings. Please note that if you set your
browser to disable cookies, the Site may not work properly. Similarly, your
browser settings may allow you to clear your browser web storage.
Targeted online advertising. Some of the business partners that collect information about
users’ activities on or through the Site or Game may be members of
organizations or programs that provide choices to individuals regarding the use
of their browsing behavior or mobile application usage for purposes of targeted
advertising.
Site
users may opt out of receiving targeted advertising on websites through members
of the Network Advertising Initiative by clicking here or the Digital Advertising
Alliance by clicking here. Game users may opt out of receiving targeted advertising in
mobile apps through participating members of the Digital Advertising Alliance
by installing the AppChoices mobile app, available here, and selecting the user’s choices. Please note that we also may
work with companies that offer their own opt-out mechanisms and may not
participate in the opt-out mechanisms that we linked above.
In
addition, your mobile device settings may provide functionality to limit our,
or our partners’, ability to engage in ad tracking or targeted advertising
using the Google Advertising ID or Apple ID for Advertising associated with
your mobile device.
If
you choose to opt-out of targeted advertisements, you will still see
advertisements online but they may not be relevant to you. Even if you do
choose to opt out, not all companies that serve online behavioral advertising
are included in this list, so you may still receive some cookies and tailored
advertisements from companies that are not listed.
Choosing not to share your personal
information. Where we are required by law
to collect your personal information, or where we need your personal
information in order to provide the Game to you, if you do not provide this
information when requested (or you later ask to delete it), we may not be able
to provide you with our services. We will tell you what information you must
provide to use the Game by designating it as required at the time of collection
or through other appropriate means.
Third-party platforms or social media networks. If you choose to connect to the Game via a third-party platform
or social media network, such as by using Facebook login, you may have the ability
to limit the information that we may obtain from the third-party at the time
you login to the Game using the third-party’s authentication service or
otherwise connect your account. Subsequently, you may be able to control your
settings through the third-party’s platform or service. For example, you may
access and change your settings through the Facebook settings page for Apps and Websites. If you withdraw our ability to access
certain information from a third-party platform or social media network, that
choice will not apply to information that we have already received from that
third party.
The
Game may contain links to other websites, mobile applications, and other online
services operated by third parties. These links are not an endorsement of, or
representation that we are affiliated with, any third party. In addition, our
content may be included on web pages or in mobile applications or online
services that are not associated with us. We do not control third party
websites, mobile applications or online services, and we are not responsible
for their actions. Other websites, mobile applications and online services
follow different rules regarding the collection, use and sharing of your
personal information. We encourage you to read the privacy policies of the
other websites, mobile applications and online services you use.
We
use commercially reasonable security practices to help keep the information
collected through the Game secure and take reasonable steps to verify your
identity before granting you access to your account (if you have an account
with us). However, Matchy cannot ensure the security of any information you
transmit to Matchy or guarantee that information on the Game may not be
accessed, disclosed, altered, or destroyed.
Please
do your part to help us. You are responsible for maintaining the
confidentiality of your login information and device identifiers, and for
controlling access to communications between you and Matchy, at all times. Your
privacy settings may also be affected by changes the social media services you
connect to Matchy make to their services. We are not responsible for the
functionality, privacy, or security measures of any other organization.
With
respect to the information that we may collect, we will retain such information
in a personally identifiable format only for as long as necessary to fulfill
the purposes we have set out in this Privacy Policy. You may also ask that we
delete your information using the “Request account removal” button as described above or by contacting us.
We
store the information we collect in connection with the Game on Amazon Web
Services and Google Cloud Platform. For Amazon Web Services, we specify the US
as the data storage location, for Google Cloud Platform, we specify data
storage at an available location closest to you when you use the Game. Your
personal information may be accessed by our service providers in other locations
outside of your state, province, or country. Your device ID (and general Game
usage information) may also be accessed by the Company’s technical support team
in other locations outside of your state, province, or country. We rely on the
Privacy Shield, as described below, for transfers of data from
the EU and Switzerland to Matchy in the United States.
Ticket
to the Moon, Inc. is the US entity that publishes and hosts the Game. Ticket to
the Moon, Inc. complies with the EU-U.S. and the Swiss-U.S. Privacy Shield
Frameworks as set forth by the U.S. Department of Commerce regarding the
collection, use, and retention of personal information transferred from the European
Union and Switzerland to the United States. Ticket to the Moon, Inc. has
submitted its certification to the Department of Commerce that it adheres to
the Privacy Shield Principles. If there is any conflict between the terms in
this Privacy Policy and the Privacy Shield Principles, the Privacy Shield
Principles shall govern. To learn more about the Privacy Shield program, and to
view our certification, please visit www.privacyshield.gov.
Ticket
to the Moon, Inc. may transfer your personal information to third parties as
described in this Privacy Policy. Ticket to the Moon, Inc. maintains contracts
with its third-party service providers restricting their access, use and
disclosure of personal information in compliance with our Privacy Shield
obligations. Ticket to the Moon, Inc. may be liable if these third parties fail
to meet those obligations and we are responsible for the event giving rise to
the damage.
In
compliance with the Privacy Shield Principles, Ticket to the Moon, Inc. commits
to resolve complaints about our collection or use of your personal information.
European individuals with inquiries or complaints regarding our Privacy Policy
should first contact Ticket to the Moon, Inc. at contact@matchy.game. Ticket to the Moon, Inc. has further committed to refer
unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution
provider located in the United States. If you do not receive timely
acknowledgment of your complaint from us, or if we have not resolved your
complaint, please visit www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of
JAMS are provided at no cost to you. If neither Ticket to the Moon, Inc. nor
JAMS resolves your complaint, you may have the ability to engage in binding
arbitration through the Privacy Shield Panel. Additional information on the
arbitration process is available on the Privacy Shield website at www.privacyshield.gov.
Ticket
to the Moon, Inc. may be required to disclose personal data in response to
lawful requests by public authorities, including to meet national security or
law enforcement requirements. The Federal Trade Commission has jurisdiction
over Ticket to the Moon, Inc.’s compliance with the Privacy Shield. Ticket to
the Moon, Inc.’s commitments under the Privacy Principles are subject to the
investigatory and enforcement powers of the Federal Trade Commission.
The
Game is not directed at children under the age of 13, and our Terms
of Use do
not allow children under 13 years of age to use the Game. If we learn that we
have collected personal information of a child under the age of 13, we will
delete it. We encourage parents with concerns to contact us.
We
reserve the right to modify this Privacy Policy at any time. If we make
material changes to this Privacy Policy, we will notify you by updating the
date of this Privacy Policy and posting it on the Game. We may, and if required
by law, will, provide notification of changes in another way that we believe is
reasonably likely to reach you, such as through the Game.
Any
modifications to this Privacy Policy will be effective upon our posting the new
terms and/or upon implementation of the new changes on the Game (or as
otherwise indicated at the time of posting). In all cases, your continued use
of the Game after the posting of any modified Privacy Policy indicates your
acceptance of the terms of the modified Privacy Policy.
Please
direct any questions or comments about this Policy or privacy practices to contact@matchy.game. You may also write to us via postal mail at:
Ticket to the Moon, Inc.
Attn: Legal – Privacy
2025
Guadalupe St, Suite 260, Austin, Texas, 78705, USA
The
information provided in this “Notice to European Users” section applies only to
individuals who reside in Europe.
Personal information. References to “personal information” in this Privacy Policy are
equivalent to “personal data” governed by European data protection legislation.
Controller and EU Representative. Ticket to the Moon, Inc. is the controller of your personal
information covered by this Privacy Policy for purposes of European data
protection legislation.
We have appointed Legal Bridge as our representative in the European Union for
data protection matters, pursuant to Article 27 of the General Data Protection
Regulation of the European Union. To contact Legal Bridge, please visit https://legal-bridge.com. Alternatively, you may
call Legal Bridge at +420 775 700 329, or write to Legal Bridge Сzech
Republic, 110 00 Praha 1, ul. Havlickova 15/1682.
Legal bases for processing. We use your personal information only as permitted by law. Our
legal bases for processing the personal information described in this Privacy
Policy are described in the table below.
|
Processing purpose Details
regarding each processing purpose listed below are provided in the section
above titled “How we use your personal information”. |
Legal
basis |
|
Processing is necessary to perform the contract governing our
provision of services in connection with the Game, or to take steps that you
request prior to signing up for the Game. If we have not entered into a
contract with you, we process your personal information based on our
legitimate interest in providing the services you access and request in
connection with the Game. |
|
|
To send you marketing and promotional
communications |
These activities constitute our legitimate interests. We do
not use your personal information for these activities where our interests
are overridden by the impact on you (unless we have your consent or are
otherwise required or permitted to by law). |
|
Processing is necessary to comply with our legal obligations. |
|
|
Processing is based on your consent. Where we rely on your
consent you have the right to withdraw it any time in the manner indicated
when you consent or in the Game. |
Your rights
European
data protection laws give you certain rights regarding your personal
information. If you are located within the European Union, you may ask us to take
the following actions in relation to your personal information that we hold:
You
may submit these requests by email to contact@matchy.game or our postal address provided above.
If
you would like to submit a complaint about our use of your personal information
or our response to your requests regarding your personal information, you may contact
us or submit a complaint to the data protection regulator in your
jurisdiction. You can find your data protection regulator here.
We
are required by the California Consumer Privacy Act of 2018 (“CCPA”) to provide
to California residents an explanation of how we collect, use and share their
personal information, and of the rights and choices we offer California
residents regarding our handling of their personal information.
We
do not sell personal information. As we explain in this Privacy Policy, we use
cookies and other tracking technologies to analyze Site and Game traffic and
use, and to facilitate advertising. If you would like to opt out of our (and
our third party advertising partners’) use of cookies
and other tracking technologies, please review the instructions provided in the Online
Tracking Opt-out Guide.
In
addition to disclosures of personal information to our service providers and
professional advisors, for compliance, fraud prevention and safety, and in
connection with a business transfer, as described in the “How We Share Your Personal Information” section of the Privacy Policy, the following chart further
describes our privacy practices with respect to the personal information of our
California consumers.
|
Sources
of personal information |
Purposes
for which we may collect and use the personal information |
Data
Sharing |
||
|
Photographs |
Physical description |
You |
To operate and improve the Game |
Shared with third-party platforms (e.g., social media
networks) at your direction Shared with cloud service providers (i.e., Google Cloud
Platform and Amazon Web Services) |
|
Game usage information |
Online identifiers Internet or network information Inferences |
You Automatic collection |
To operate and improve the Game To send you marketing and promotional communications |
Shared with affiliates that provide services to us |
|
Purchase Matchy |
Commercial information Online identifiers |
The app store provider through which you purchased your
subscription (i.e., Google or Apple) |
To operate and improve the Game |
None |
|
Social media information |
Identifiers Online identifiers |
Third-party platforms |
To operate and improve the Game |
Shared with third-party platforms (e.g., social media networks)
at your direction |
|
Device data Online activity data |
Online identifiers Internet or network information Inferences |
You Automatic collection |
To display advertisements to you |
Collected directly by advertising partners |
Except
as excluded from the scope of this notice above, the CCPA grants California
residents the following rights.
Please
note that the CCPA limits these rights by, for example, prohibiting us from
providing certain sensitive information in response to an access request and
limiting the circumstances in which we must comply with a deletion request. If
we deny your request, we will communicate our decision to you.
You
are entitled to exercise the rights described above free from discrimination.
To
request access to or deletion of personal information:
Identity verification. The CCPA requires us to verify the identity of the individual
submitting a request to access or delete personal information before providing
a substantive response to the request. We may attempt to verify your identity
by asking you to confirm information that we have on file about you or your
interactions with us. Where we ask for additional personal information to
verify your identity, we will only use it to verify your identity or your
authority to make the request on behalf of another consumer.
Authorized agents. California residents can empower an “authorized agent” to submit
requests on their behalf. We will require the authorized agent to have written
authorization confirming such authority.
|
Statutory Category |
Data Elements within
the Category |
|
Commercial
Information |
Records
of personal property, products or services purchased, obtained, or
considered, or other purchasing or consuming histories or tendencies. |
|
Identifiers |
Real
name, alias, postal address, unique personal identifier, customer number,
email address, account name, social security number, driver’s license number,
passport number, or other similar identifiers. |
|
Inferences |
The
derivation of information, data, assumptions, or conclusions from any other
category of Personal Information to create a profile about a person
reflecting the person's preferences, characteristics, psychological trends,
predispositions, behavior, attitudes, intelligence, abilities and aptitudes. |
|
Internet
or Network Information |
Browsing history, search history, and information regarding a
person’s interaction with an Internet website, application, or advertisement. |
|
Online
Identifiers |
An
online identifier or other persistent identifier that can be used to
recognize a person, family or device, over time and across different
services, including but not limited to, a device identifier; an Internet
Protocol address; cookies, beacons, pixel tags, mobile ad identifiers, or
similar technology; customer number, unique pseudonym, or user alias;
telephone numbers, or other forms of persistent or probabilistic identifiers
(i.e., the identification of a person or a device to a degree of certainty of
more probable than not) that can be used to identify a particular person or
device. |
|
Physical
Description |
An individual’s physical characteristics or description (e.g.,
hair color, eye color, height, weight). |
Like many companies online, we may use
services provided by Google, Facebook, Twitter and other companies that use
tracking technology. These services rely on tracking technologies – such as
cookies and web beacons – to collect directly from your device information
about your browsing activities, your interactions with websites, and the device
you are using to connect to the Internet. There are a number of ways to opt out
of having your online activity and device data collected through these
services, which we have summarized below:
Note that because these opt-out mechanisms are
specific to the device or browser on which they are exercised, you will need to
opt-out on every browser and device that you use.