Last updated on May 24, 2018
If you are an EU resident, this whole Policy applies to you. Miniwan is also committed to protecting the privacy of our users, including children. Please see the "Children’s Privacy and Parental Controls" section below for more information about your rights as a parent or legal guardian of our children users and the measures we take to afford children users with additional protections and comply with the Children’s Online Privacy Protection Act ("COPPA").
It is important for you to understand how the collection and use of your personal information happens and how you may control your personal information. When you contract to use the Service, you accept our rules and policies regarding your personal information and you expressly consent to us collecting, processing, using and storing your personal information, as described in this policy.
Miniwan Technology Co., Limited
Address: ROOM1303 BUILDING B, LIYUAN SQUARE, ROAD DONGBIN, DISTRICT NANSHAN, GUANGDONG SHENZHEN, CHINA
"Personal Data" means any information relating to a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, or an online identifier.
"Processing" means any operation which is performed on personal data, such as collection, recording, organization, structuring, storage, adaptation or any kind of disclosure or other use.
Any other capitalized term that is not defined in this Policy is defined (and has the meaning) set out in our Term of Use.
3. Information Collected on our Website
4. How Mini World Block Art Works
This is how Mini World Block Art works:
An user ID is created automatically for a new user. A virtual character is generated to represent his or her identity in the Mini World Block Art.
Users interact with other users through in-game, personal messaging, and other similar features. Users can remove friends or delete account to restrict or disable communications with other users.
Each user is given one or more pieces of virtual real space on which they can unlock items and characters, ripe golden fruit, trade in the game and accelerate the growth of their gardens.
Users search for, find, and play games made by other users. They play these games with other users around the world, and are identified only by their user ID.
The Mini World Block Art includes virtual currency known as Mini Coins and Mini Beans, 1 Mini Coins=60 Mini Beans; users can purchase Mini coins and Mini Beans in a variety of ways, and use them to buy items for their characters, for in-game items, and other uses.
For more information on how our service works, please see our Terms of Service.
5. Setting Up an Account on Mini World Block Art
Users are given an UID when they first enter the game. Then he or she can name the character. Users may be asked to provide some demographic information such as your age or date of birth, gender, country or language preference (so we can customize your experience on Mini World Block Art).
Users should not create an username that reflects their own name or other personal data. Users should also not pick a password that is easy to guess, and should not share their password. For security reasons, we store passwords in encrypted form.
UIDs are used for participating in Service features and we do not use them to identify individual users outside our Service. UIDs are not shared with third-party companies except for the third-party companies who use or process the UIDs for purposes of helping operate our Service, such as effectuating payments.
Users may be asked to provide or may choose to add an email address or bind to the Facebook account for added verification and/or to enable certain features. The primary purpose for this is to provide account security, as this is the only way for Miniwan to check the authenticity of an account owner. In this circumstance, users under the age of 13 are asked to provide a parent email address. Users may change the email address associated with their account at any time; however, a notification will be sent to the previously provided email address upon making that change.
6. Additional Features and Data Collection on Mini World Block Art
In addition to account setup on Mini World Block Art, we may collect and process information from you in connection with the following features and activities (as applicable):
When you make purchases on the Service. Users can purchase virtual currency or premium subscriptions, for example, in the form of Mini Coins, etc., and use a variety of payment methods. When making purchases, users or their parents may be required to enter billing information, including name, billing address, credit card or other payment information, and billing email. Miniwan may also retain your billing information, transaction details, and purchase history to resolve subsequent billing disputes and inquiries. Miniwan does not retain the full credit card numbers of our users.
When you post or otherwise transmit comments or messages on Mini World Block Art via community features such as public chat or private chat, reviews, profile pictures, personal posts, etc. we may collect these comments and messages, pictures and they may be monitored, filtered and moderated for purposes such as removal of profanity, personal data, and other inappropriate conversations. We may use pre-filtered chat, comments and messages, pictures (of EU and US users over 13) for purposes such as training and improving our filter technology, except that we will not engage in these activities with private chat, comments, pictures and messages of EU users.
When you contact or send communications to Mini World Block Art, for example when you contact customer support, report a problem, or submit questions, concerns, or comments regarding our Service or its content, in which case we may collect contact information such as your email address and other important information about your inquiry or concern. This information is used to respond to your communications, fulfill your requests, or provide other customer support.
When you use or interact with third-party plug-ins that may be available on the Service for users 13 and older, such as third-party social media widgets, share buttons, and/or login mechanisms. These features may include social plugins from Google, Facebook, Twitter or other platforms, and may be subject to the privacy policies of these other companies as posted on their respective websites. When you use these features, certain information from your social media accounts may be accessed by or shared with Miniwan, and likewise, certain information about your use of Mini World Block Art may be posted to your profile on those platforms.
Information relating to your participation in contest, competitions, giveaways, prize draws or other promotions that we may run on our Service or sponsor from time to time. We may process certain contact information (such as your name, email address, and/or phone number) for prize fulfillment purposes, as well as other information or content needed for the specific promotion.
When you respond to or participate in voluntary surveys, which we may offer on our Service from time to time to conduct research or demographic studies. These surveys may collect anonymous information about your likes and dislikes, game play interests and habits, general hobbies and interests, and other lifestyle information or preferences. These surveys will not collect personal data about you.
When you subscribe to other features or activities that we may offer from time to time on the Service and submit or upload information in connection with such features. The data being collected for such features and their intended uses will be evident at the time of data collection.
When you browse, navigate, or otherwise interact with the Service, as outlined in the "Cookies and Similar Technologies" section below.
You are under no obligation to provide personal data to Miniwan when requested. However, if you choose to withhold any requested information, we may not be able to provide you with certain services and features.
In addition to the specific uses above, any information that you provide or that we collect on the Service may be generally used for the following purposes:
To operate, maintain, and improve the Service;
To give you access to the Service and related features, or restrict your access;
To personalize the Service or content on the Service, as well as make it more user-friendly;
To allow you to manage your Mini World Block Art account or account information, update your account settings, and (where applicable) make purchases or subscribe to services;
To communicate with you about the Service (product changes, feature updates, etc.);
To provide technical support or customer service;
To deliver advertising that may be relevant to your interests;
To protect the integrity, safety, or security of the Service or our users, comply with legal obligations, or enforce compliance with our Terms of Service or other restrictions placed on your use of the Service.
7. Cookies and Similar Technologies
What is Cookie
Cookies are text files containing small amounts of information which are downloaded to your device when you visit a certain web address. Cookies are then sent back to the originating web address on each subsequent visit, or to another web address that recognises that cookie. Cookies are widely used in order to make the Services work, or to work more efficiently, as well as to provide information to the Services team.
Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience. Cookies may tell us, for example, whether you have used the Services before or whether you are a new user. They can also help to ensure that advertising you see online are more relevant to you and your interests.
There are two broad categories of cookies:
First party cookies, served directly by us to your device.
Third party cookies, which are served by a third party on our behalf.
Cookies can remain on your device for different periods of time. Some cookies are 'session cookies', meaning that they exist only while your browser or the application is open. These are deleted automatically once you close your browser or application. Other cookies are 'permanent cookies', meaning that they survive after your browser or application is closed. They can be used by the Services to recognise your device when you open and use the Services again.
How to control or delete cookies
Most devices (in the case of mobile applications) and browsers (in the case of web apps and pages) allow you to change your cookie settings. These settings will typically be found in the “options” or “preferences” menu of your browser.
verify login information and allow users to find friends who use Services;
track traffic flow and patterns of travel in connection with the Services;
understand the total number of visitors to the Services on an ongoing basis and the types of devices;
monitor the performance of the Services and to continually improve it;
customise and enhance your online experience;
provide customer service to you; and
enable us to promote the Services to you on third party websites if you have previously signed up for the Services.
Third party advertising and ad networks
If you do not wish to receive our personalized ads, please visit their opt-out pages at the above links to learn about how you may opt out of receiving personalized ads from member companies. For our users that are under the age of 13, Miniwan partners with third-party advertising companies to serve contextual advertising, cap the frequency of advertising, and related uses permitted by COPPA. Miniwan does not show behaviorally-targeted or retargeted ads to users under the age of 13 or track such users for targeted advertising purposes.
8. Information Sharing
Miniwan may share your information as set forth below. Please note that we does not sell personal data about you to third-party companies for their marketing purposes.
Agents and contractors
Miniwan may share users’ information, including personal data like billing information or usernames, with our third-party agents, contractors, or service providers who are hired to perform services on Miniwan’s behalf. These providers may operate or support certain functions of the Service. Below is an illustrative list of functions for which we may use third-party service providers and the names of the providers we may use to perform these functions:
Analytics services (e.g., Google Inc, Appflyer Analytics,Talking Data Analytics);
Advertising services (e.g., Avoidly);
Community filtering and moderation services (e.g., Tencent Cloud service);
Surveys and promotions (e.g., Survey Monkey);
Billing services and payment gateway providers (e.g., Steam, Google, Apple Store);
Hosting and content delivery network services (e.g., AWS, Tencent Cloud).
Public forums and Community areas
We offer users the ability to use reviews and similar means of public discussion. If you use any messaging, posting, or chat functions in Mini World Block Art, you should be aware that any personal data submitted there will be available to anyone who has access to that content, including other users, and can be read, collected, or used by other users of these areas, and could be used to send unsolicited messages. We are not responsible for how other individuals use the information posted in this manner.
We disclose information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:
comply with a legal obligation, process or request;
enforce our terms of service and other agreements, policies, and standards, including investigation of any potential violation thereof;
detect, prevent or otherwise address security, fraud or technical issues; or
protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organisations for the purposes of fraud protection); and
a third party that acquires all or substantially all of us or our business. We will disclose information to a third party in the event that we sell or buy any business or undergo a merger, in which case we will disclose your data to the prospective buyer of such business. We will also disclose information to a third party if we sell, buy, merge or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.
We may share aggregated, automatically-collected, or otherwise non-personal data with third parties for various purposes, including (i) compliance with reporting obligations; (ii) for business or marketing purposes; (iii) to assist us and other parties in understanding our users' interests, habits and usage patterns for certain programs, content, services, advertisements, promotions and/or functionality available through the Services.
9. Security and Data Retention
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of the information transmitted to our services; any transmission of your information is at your own risk.
Miniwan may retain users’ account data internally for the following purposes:
Billing information and transaction histories are retained to resolve subsequent billing disputes and inquiries;
Publicly shared content and game items are retained for use by the community (e.g., a user-created map);
User account history is retained to support subsequent customer service inquiries and to provide, improve and develop the Services;
To promote safety and security on and for the Services; and
To comply with legal obligations.
We may retain your information for as long as is necessary and relevant to your use of the Service and our operations, which may include retaining your information beyond the end of your use of the Service.
Our Services may have links to other sites. We are not responsible for their content, activities, or the way they use the information they collect and/or you may provide to them. Please review their privacy policies.To make clear when you are linking to a third-party site or application, we may display a warning message informing you when you are leaving our Service.
11. Children's Privacy and Parental Controls
If you are under the age of 13, you are required to obtain parental/guardian consent prior to using the or playing on the Service. If you do not get such permission, you should not use our Service. Parents or guardian of a child should contact Miniwan immediately if they have any concerns regarding the Service.
We recognize that children deserve added protections with regard to their personal data and privacy online. For this reason, when users under the age of 13 register for the Service, children users will not have access to certain features, such as social media plug-ins, some forms of third-party advertising, and certain types of notification alerts.
Miniwan do not intentionally collect personal information from children through our Service. If you are the parent or guardian of a child and you believe that we have inadvertently process personal information about that child, please contact us under the contact details as set out in Section 1, above, and we will delete the information from our records as soon as possible.
To make any requests for changes to your child’s account or requests for the removal of personal data collected about you or your child from our Service (as applicable), or to request that we stop the further collection or use of your or your child's personal data in connection with the Service (as applicable), please contact us.
We proactively filter all public and comment areas of the Service (such as chat, forums, group walls, personal posts, etc.) to remove references to addresses, emails, phone numbers, or other personal data regardless of security and privacy settings. All text is also filtered for profanity, phishing, and adult or suggestive content. Our system uses a combination of human and automated processes. However, like all filtering technology, our systems are not 100% effective. We strongly encourage children who use these interactive features on Service never to provide personal information about themselves or any third party, and certainly never to attempt to circumvent our filters or moderation. We also recommend that parents carefully supervise their children when the children participate in online activities.
12. Accessing and Updating Your Personal Data
If personal data about you changes, or if you no longer desire to use our Service, you may correct, update, amend, or deactivate your account under your account settings or by contacting Miniwan using the information set out above in Sec. 1. We will respond to your request within a reasonable timeframe. For children under the age of 13, please see the "Children’s Privacy and Parental Controls" section above.
13.Storage and share Your Personal Data
Miniwan is based in China. Your personal data which we collect are sent to and stored on secure Tencent, Ali and AWS servers. Such storage is necessary in order to process the information.
Miniwan operates globally and we may share the personal data that we collect from you with our the third parties mentioned in the circumstances described above.
14. Additional Information for EU Residents
In the course of visiting our websites and apps, and/or using our services and products, we may process the following personal data:
Login information, which may include your IP address, device type, name, date and time of your visit, information on your browser version, information on your operating system, including language settings, MAC addresses, and User ID. We will process this information to provide you with the websites, apps and our online services. The legal basis for this processing activity is Article sec. 1 sent. 1 lit. b ("performance of a contract") and lit. f ("legitimate interest") GDPR. It is our legitimate interest to guarantee the websites' stability and security.
Account information, e.g. information such as your username, login and password details, user-generated content, and other personal data that are used for participating in the Service feature we are offering. We process this information to provide our Services to you. The legal basis for this processing activity is Article 6 sec. 1 sent. 1 lit. b GDPR ("performance of a contract").
Email addresses you provided us with for added verification and/or to enable certain features. The bases for processing this personal data are Article 6 sec. 1 sent. 1 lit. b ("performance of a contract") and f ("legitimate interest") GDPR. Miniwan has a legitimate interest of providing a safe and secure Platform, especially to protect under-aged Users.
Billing and payment information, when you purchase virtual currency or premium subscriptions, including your name, billing address, credit card or other payment information and billing information. The legal basis for this processing activity is Article 6 sec. 1 sent. 1 lit. b GDPR ("performance of a contract"). We may also retain transactions details and purchase and payment history. The legal basis for processing these personal data is our legitimate interest in being able to resolve subsequent billing disputes and inquiries, Article 6 sec. 1 sent. 1 lit. f GDPR ("legitimate interest").
Information relating to contacting our customer service, e.g. when you report a problem, submit questions, concerns or comments. We may process your email address, your name and information relating to your inquiry or concern in order to respond to your communications, fulfill your requests, or provide other customer support. This processing activity is based on your (implicit) consent according to Article 6 sec. 1 sent. 1 lit. a GDPR and/or Article 6 sec. 1 sent. 1 lit. b GDPR ("performance of a contract"), depending on the initial purpose for contacting our customer support.
Comments or messages you post or transmit on Mini World Block Art via public chats, forum, group walls, personal messages, profile pictures etc. We process this information to monitor, filter and moderate this information for the purposes of being able to remove profanity, personal data, and other inappropriate conversations. Additionally, we may use pre-filtered comments and messages for other purposes such as training and improving our filter technology. The legal basis for this processing activity is Miniwan’s legitimate interest in being able to defend ourselves from possible liability claims that may arise from unlawful comments posted by you, Article 6 sec. 1 sent. 1 lit. f GDPR ("legitimate interest"). Please note that any personal data submitted by you in forums and similar means offered by us is available to anyone who has access to this forum including other users. The personal data posted by you can be read, collected or used by other users of these forums and could be used to send unsolicited messages.
Information relating to your use of or interaction with third party plug-ins, e.g. social plugins from Google, Facebook or Twitter. When you use these features, certain information from your social media accounts may be accessed by or shared with Miniwan, and likewise, certain information about your use of Mini World Block Art may be posted to your profile on those platforms. The legal bases for this processing activity are Article 6 sec. 1 sent. 1 lit. a ("consent") and f ("legitimate interest") GDPR. We have a legitimate interest to improve your website experience and to optimize our service.
Information processed to enable advertising. To market our services, inter alia, via social media platforms in order to bring new users to our websites and to maintain and increase our user base, we may process personal data such as IP addresses, information on users’ browser or operating system, including language settings, location information and user names or user IDs. The legal basis for the processing of this data is Miniwan’s legitimate interest in maintaining our user base, bringing new users to our websites and informing (potential) users about interesting events, Art. 6 sec. 1 sent. 1 lit. f GDPR ("legitimate interest").
Information relating to your participation in contest, competitions, giveaways, prize draws or other promotions that we may run on our Service or sponsor from time to time. We may process certain contact information (such as your name, email address, and/or phone number) for prize fulfillment purposes, as well as other information or content needed for the specific promotion. The legal basis for this processing activity is Article 6 sec. 1 sent. 1 lit. b GDPR ("performance of a contract").
Please note that we do not use your personal data for automated decision making which produces legal effects concerning you or similarly significantly affects you.
Personal data of minors
We strongly recommend that minors under the age of 16 seek consent from a parent or legal guardian before accessing and/or using our Services and providing any personal information.
If you are a user based in the European Union, you may be entitled to exercise some or all of the following rights. If you wish to use any of the rights described below, you may contact us at any time by emailing us at firstname.lastname@example.org.We process and answer your requests without undue delay and in any event within one month of our receipt of the request unless a longer period is required due to the complexity of the request. In this case, our response time can be up to three months in total as permitted by Article 12 of the GDPR.
You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your game account.
You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent (e.g., forum post content) or pursuant to our contract with you (e.g., game play statistics). You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party.
If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (e.g., where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).
You have the right to correct any personal information held about you that is inaccurate. You can access the personal information you have made available as part of your account by logging into your game account and/or the community forum (as applicable).
You can delete your account, or remove certain personal information, by logging into your game account and/or the community forum (as applicable).
You may request that we erase the personal information we hold about you in the following circumstances:
you believe that it is no longer necessary for us to hold such personal information; or
you believe the personal information we hold about you is being unlawfully processed by us.
You can also exercise your right to restrict our processing of your personal information (as described below) whilst we consider your request.
We may need to retain personal information if there are valid grounds under data protection laws for us to do so (e.g., for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the game services and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.
Restriction of Processing to Storage Only
You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (e.g., for the defence of legal claims or for another’s protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.
You may request we stop processing and just store the personal information we hold about you where:
you believe the personal information is not accurate for the period it takes for us to verify whether it is accurate;
you wish to erase the personal information as the processing we are doing is unlawful but you want us to retain the personal information but just store it instead; or
you wish to erase the personal information as it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defence of legal claims.
You have the right to object to our processing of personal information about you. We will consider your request in other circumstances as detailed below by contacting us. To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us.
We may from time to time send you announcements when we consider it necessary to do so (such as when we temporarily suspend Service for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature.
Contact & Complaints
Questions, comments and requests regarding this policy are welcomed and should be addressed to email@example.com.
In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at firstname.lastname@example.org and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the country in which you live or work where you think we have infringed data protection laws.
If we make any material changes to this policy, we will post the updated policy here and notify our users. Please check this page frequently to see any updates or changes to this policy.