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Magic Play Loyalty Program & Website Privacy Notice

Overview

Thank you for choosing Magic Play. This Privacy Notice (“Notice”) explains how Magic Play Yazilim Limited Sirketi, a private limited company established under the laws of the Republic of Turkey (“Magic Play”, “we”, “our”, or “us”), collects, uses, stores, and shares your personal information through our website, mobile application, and any related offerings (together referred to as the “Platform”, “App”, or “Services”).

By accessing or using our Services, you acknowledge that you have read, understood, and agree to the practices described in this Notice. This document forms an integral part of our Terms of Use.

Please note that this Privacy Notice does not extend to any third-party games or content accessed via our Services. The developers of those third-party games (“Game Partners”) are solely responsible for the handling of your data within their products, and their individual privacy policies govern such processing. We encourage you to review their policies before using any such third-party offerings or exercising any privacy rights related to their games.

Before using the Platform, we recommend that you read this Privacy Notice thoroughly. If you do not agree with any section of this Notice, please refrain from using our Services.

 

The entity responsible for the management, protection, and lawful use of your personal data in accordance with this Notice is Magic Play. You can find our legal and contact information below:

Legal Name: Magic Play Yazilim Limited Sirketi

Business Address: Altinova Mah. 518 Sok. Sama Buttim Is Merkezi No:1 Osmangazi Bursa 16250, Turkey

Email Contact: [email protected] (please include “Privacy” in the subject line)

 

User Consent & Age Limitations

When you proceed with account registration and click the “ACCEPT & CONTINUE” button, you confirm that you’ve reviewed, understood, and accepted the conditions outlined here (at which point you will be referred to as the “User”). If you are under the age of 18 or disagree with any part of these terms, you are not permitted to create an account or access Magic Play’s services.

Terms of Service

Our Terms of Use include and incorporate our Privacy Policy. By accessing any part of our Services, you agree to comply with all such terms. You can always find a link to our Terms of Use at the bottom of most pages on the Magic Play website.

Modifications to This Notice

We may revise this Notice from time to time at our sole discretion. The latest version will reflect the current “Last Updated” date, and a notice will be issued via our mobile app. We recommend checking this page periodically to stay informed. If you do not accept the revised version, we kindly ask you to discontinue use of the Services.

Please note that Magic Play only gathers and uses your personal data for specific, legitimate purposes outlined in this Notice, and in accordance with relevant data protection laws. This ensures both transparency and accountability in how your information is managed.

This Privacy Notice is intended to provide clear insight into our data handling practices. We encourage you to reach out using the contact details provided in this document if you need further clarification or have any concerns.

 

A. INFORMATION WE COLLECT FROM YOU

1. Information You Provide to Magic Play Directly

“Personal Data” in this context refers to any information that can be used to identify you as an individual, and which you provide to us through the Magic Play platform. This includes, but is not limited to, your full name, contact details such as phone number or email address, physical address, unique identifiers like a Social Security number (where applicable), and other personal details you may share when engaging with our Services. All such information is retained in identifiable form and handled in accordance with this Privacy Policy.

a. Data Gathered During Account Registration

Whenever you sign up for Magic Play or interact directly with our Services, we collect certain details from you. This includes information such as your name, email address, communication preferences, and choices made within your account settings. We may also collect specific technical data — for instance, IP address, approximate device location, and advertising identifiers — when you use our mobile application. Some data may also come via integrated third-party tools. For more on such data, refer to the “Service Providers Processing Data on Our Behalf” section of this Policy.

The following data may be collected when you register or use the platform:

  • Full Name: Your first and last names are captured at account creation.

  • Age: Used to verify eligibility in accordance with age restrictions and to customize available content.

  • Gender (Optional): If you choose to provide it, gender information helps us offer a more tailored user experience. This setting can be modified at any time via your account preferences.

  • Google or Facebook Login: If you register using Google or Facebook, we use this login to link your identity and send essential platform updates, announcements, or promotional material. Email addresses associated with those accounts may also be accessed.

  • Profile Photo: If your Google/Facebook profile picture is used — or if you upload a new one — it may appear on leaderboards or other public areas. You can opt out at any time by removing or changing the photo.

  • Phone Number: This is used primarily for SMS-based verification. With your consent, it may also be used to notify you of limited-time campaigns or exclusive offers.

  • Face ID or Video Verification: To maintain the integrity of reward claims and deter abuse, a video selfie may be required during prize redemption.

  • Preferences: Your choices around interface language, notification settings, and similar options are stored to enhance your in-app experience.

  • Direct Support Communications: Any messages you send us — including support tickets, emails, or surveys — help us understand your needs and improve our service quality.

  • Promotional Entries: When you enter contests or participate in special offers, we may collect extra details as required by those campaigns — including contact information and identifiers needed to process your entry.

b. Device Information We Collect

This section outlines the technical data gathered from your device, helping clarify how Magic Play utilizes such data to improve your experience while maintaining transparency.

  • IP Address: We collect your device’s IP address, which can help determine a general location (such as city or country) and is also used for networking and security diagnostics.

  • Geolocation: With your permission, we may access your device’s geographic location data — such as latitude and longitude — to provide location-relevant features. Note that this data is not continuously tracked but collected intermittently.

  • Mobile Device Identifiers: We use device-specific IDs, including those like the IMEI or Android’s advertising ID, to identify devices and enhance platform security.

  • Ad Identifiers: We use third-party identifiers such as Google’s Advertising ID to track the success of promotional campaigns and tailor ad experiences. You may opt out by changing your device’s privacy settings.

  • Device Specs: Details like operating system, device type, and language preferences help us optimize how the application behaves on your specific hardware.

c. Behavioral and Interaction-Based Data

We also collect insights based on your use of the platform, including how you interact with content and services. Here’s a breakdown:

  • Connection Logs: We gather information about your device’s network behavior, apps used to access the service, and visited web content to help us enhance stability and identify potential risks.

  • Gameplay Metrics: With your consent (and depending on Game Partner policies), we may track gameplay history — like session length, in-game purchases, progress, and errors. Please note that if a user joins Magic Play via your referral, they may see limited details about your gameplay solely for verification of eligibility.

  • Installed App Metadata: If you grant permission, we may identify relevant apps already present on your device that can enrich your Magic Play experience. This includes securely transferring app package data to our systems to suggest compatible content.

  • File Storage Usage: Storage access is used for reading and writing shared content, allowing for full functionality in specific features.

  • Usage Patterns: Aggregated app usage history — including how frequently and for how long the app is used — is analyzed over time intervals (days, weeks, or months) for performance and engagement tracking.

  • Audience Segmentation: By using interaction data (e.g., gameplay behavior, geolocation, usage time), we create user groups to enhance personalization. These insights help us deliver content and services that are more tailored to your preferences.

B. How and Where Personal Information is Stored

Data Hosting in Germany:

Your personal data is securely hosted on servers operated by Amazon AWS and Microsoft Azure, located within Germany. However, some of your data might be accessed, processed, or stored in other regions, such as the United States, depending on where our service partners are based.

Security Considerations:

We strive to collaborate only with trusted service providers and enforce contractual data protection agreements. However, it’s important to note that privacy regulations in some regions may not offer the same level of protection as those in Germany, the United States, or the EEA/UK. In rare cases, international access to your personal data may be possible by partners operating from outside these regions.

GDPR Alignment:

When data is collected from users in the UK or EEA, it is transferred and hosted in Germany under GDPR-compliant conditions. Transfers to countries outside the EEA follow appropriate legal safeguards, such as Standard Contractual Clauses (“model clauses”).

C. How We Use Your Personal Data

According to applicable data protection laws, we are only allowed to use your personal information if one of the following lawful bases applies:

  • You have explicitly consented.

  • Processing is required for our legitimate interests or those of another party, as long as this does not override your rights.

  • It’s necessary to comply with legal obligations.

  • It’s required for legal defense or claims.

  • It serves a substantial public interest.

Before using your data for purposes not already detailed in this document, we will inform you and seek your approval when required.

1. Consent

By using the Platform or registering an account, you are granting your clear and informed consent for us to collect and use your personal information, as outlined in this Privacy Notice. If you do not agree, please refrain from using the Services.

We do not gather or sell personal data for commercial resale.

You may receive updates, promotions, or product information from us if you’ve provided your permission to do so. Depending on your chosen communication preferences (email, phone, push notifications), we may use these methods to inform you about new services or offerings that match your interests. Your data may also be shared with group companies for similar marketing purposes, subject to your consent. You can always update or revoke your communication preferences in your account settings.

If your consent is the only legal basis for processing your data, you have the right to withdraw it at any time. Do note that such withdrawal may limit your access to certain features or services. The withdrawal will not impact prior processing done under valid consent, nor will it affect processing justified on legal grounds separate from consent. For more details, refer to the section titled “Withdrawal of Consent to Collect Personal Information.”

2. Our Lawful Basis: Legitimate Interests

In certain situations, we may process your personal data based on what is legally referred to as our “legitimate interests,” rather than requiring explicit consent. This approach allows us to operate and improve our Platform while still considering your rights and privacy.

To do this, we assess whether the benefits of using your personal data outweigh any potential impact on your rights. This is especially important when fulfilling legal obligations, ensuring transparency, or preventing the unauthorized use of your information for purposes you haven’t agreed to — such as third-party marketing.

We evaluate each use case through a fairness test. If it passes, we rely on legitimate interest as a legal basis to carry out the described data activities responsibly and transparently.

Below are some key reasons we process data under this basis:

  • Personalized User Journey: Using behavioral data, Magic Play curates personalized suggestions for games, features, and content based on what you engage with most.

  • Active Platform Use: Engagement with partner applications helps unlock benefits, achievements, and reward opportunities through the Magic Play system.

  • Service Optimization: Analytics data is used to oversee game installs, reward redemptions, and overall experience quality, enabling a smoother service.

  • Promotional Strategy: Marketing analytics allow us to better communicate our offerings across various platforms and user segments.

  • Participation Events: Data helps manage user participation in special promotions, such as contests or giveaways, ensuring winners are selected fairly.

  • Performance Attribution: Details regarding game installation or reward delivery help us validate usage and maintain accurate logs.

  • Platform Protection: We collect data to monitor for irregular behavior, minimize fraudulent access, and keep your rewards and account safe.

  • Facial Verification for Security: In select cases, a short encrypted video (captured using third-party tools) may be requested to verify your identity. This process:

    • Prevents account duplication

    • Protects reward eligibility

    • Discourages cheating through automation or bots

Additional Data-Driven Goals Include:

  • Innovation: Insights from user behavior drive the development of new products and improvements to existing ones.

  • Reporting: Aggregated metrics help refine service performance and unlock value through platform analytics.

  • Content Relevance: Understanding how users interact helps tailor communication and content delivery.

  • AI-Based Personalization: Machine learning uses data to offer a unique platform experience per user profile.

By understanding how these systems function, you can confidently use the platform knowing that your personal data is handled with care and fairness.

 

3. Processing Based on Contractual Necessity

By registering and using the Platform, you enter into a binding agreement with us as outlined in our Terms of Use. As part of that agreement, we need to collect and process certain personal information to fulfill our responsibilities to you and uphold our contractual commitments. For this reason, the legal foundation for handling your personal data is the contract you form with us when you become a user.

4. Compliance with Law & Legal Protections

We may be legally required to handle your personal data in order to comply with applicable laws. Additionally, if a legal dispute arises or we need to assert or protect our rights in court, we may process your data to that extent.

In certain cases, we may also share your personal data with external parties — without your prior consent — if we have strong reason to believe it’s necessary for legal purposes. This might include identifying or contacting someone responsible for harming our systems, infringing on our rights or the rights of others, or otherwise violating laws or causing damage. We will only share such data when legally justified and in accordance with our obligations.

5. Public Interest Grounds

In rare cases, your personal data may be used when there is a significant public interest at stake, provided that such processing aligns with the conditions laid out by data protection regulations.

 

D. Data Practices That Require Additional User Awareness

a. Automatically Captured Information

Some technical data described in the “Personal Data We Collect” section is collected passively as you interact with the Platform. This may include:

  • Aggregated app usage metrics

  • Your session identifiers

  • Timestamps of access

  • Device specifications

  • Push notification interactions

b. Push Notification Preferences

To support the features outlined in this policy, Magic Play may send you push notifications. In most cases, you can control these notifications through your device’s settings — either for this app specifically or across all apps. Please note that disabling these messages may affect how certain features function.

c. Protecting Children’s Information

We are strongly committed to protecting the privacy of children. We do not knowingly collect data from users under the age of 18. By using the Platform, you confirm that you are 18 or older. If we discover that someone under 18 has provided false information to register, we will promptly deactivate the account and remove their data. If you suspect we have inadvertently collected information from a minor, please notify us at [email protected].

Additional notes:

  • Third-party games accessed via the Platform are governed by their own privacy rules.

  • Use of the Platform is restricted to individuals aged 18 or older.

  • We may retain certain data where legally required or necessary for service delivery.

  • For cookies and tracking tech, please refer to our Cookie Policy.

d. Third-Party Websites

Our Services may include links to other apps or platforms (e.g., Google Play Store). These external sites are operated by third parties and follow their own privacy policies. We encourage you to review those documents directly to understand how your data may be handled.

e. How to Revoke Consent

You can request the removal of your consent for data processing by emailing us at [email protected]. Once we receive your request:

  • Processing Halted: We’ll stop using your personal data within a reasonable timeframe.

  • Impact of Withdrawal: Withdrawing consent may limit your access to certain features — such as loyalty rewards. It does not affect data processed lawfully before your withdrawal.

  • Deleting Your Account: If you choose to close your account, all unused rewards will be permanently lost. A confirmation email will be sent once your deletion request is finalized.

f. Marketing Communications

If you’ve agreed to receive promotional updates, we may send you marketing messages. You can opt out anytime using the provided instructions in those messages. Note that even if you opt out of promotions, we may still contact you with important updates about your account or services you’ve requested.

 

E. Service Providers Handling Personal Data on Our Behalf

To support the functionality and operations of our Platform, we may engage third-party vendors and external service providers to process your personal data as outlined in this Privacy Policy. These parties are contractually obligated to maintain strict confidentiality and data security standards. They are not permitted to use your data for their own objectives or disclose it to others unless we have given explicit permission.

If you have an existing independent relationship with any of these providers outside the scope of our services, then their own privacy terms will apply to your engagement with them directly.

a. Advertising Partners

We work with advertising partners that help deliver ad content, including banners or other placements, on our platform. These ads may be targeted based on user preferences or activity. However, not all personal data is used for ad targeting.

Some advertising services rely on technologies such as Trackers or behavioral retargeting to personalize content — including based on activities that occur outside of our app. You can review the privacy practices of each service to learn more. Most of these platforms offer opt-out mechanisms. Additionally, users can manage advertising preferences through their device settings (e.g., mobile OS ad preferences) or by visiting the Network Advertising Initiative’s opt-out page.

AdMob (Google Ireland Limited)

AdMob is an advertising solution offered by Google Ireland Limited. It may use your data to deliver personalized ads. To learn more about how Google uses information, refer to Google’s partner policy.

Location of processing: Ireland — Privacy Policy — Opt Out

AdGem

Alongside any personal data we may share, AdGem can gather additional information through several data collection technologies:

  • Cookies: Small text files placed on your device that track your activity and preferences to enhance your experience. Some AdGem services require cookies to be enabled and may not function properly if disabled.

  • Web Server Logs: These logs track your interaction with web content — such as pages visited, search queries used, IP address, and cookies loaded during your session.

  • Device Information: AdGem may gather technical information about the device you use to access the Platform, such as hardware specs, OS version, browser type, unique identifiers, and network data.

  • SDK Data: If a customer integrates AdGem’s SDK into their app, end users interacting with that app may allow AdGem to access relevant usage data under their Privacy Policy.

 

Facebook Audience Network

(Facebook Ireland Ltd)

Facebook Audience Network is a mobile advertising service that delivers ads based on user preferences and activity. It uses device identifiers like the Android Advertising ID or IDFA (iOS) and cookie-like technologies.

You can adjust how Facebook shows you ads by updating your Facebook Ad Settings. Some targeting can also be controlled through your device’s ad preferences.

  • Data Processed: Tracker; unique device identifiers; usage data

  • Place of Processing: Ireland

  • Privacy Policy – Opt Out

Adjust

(Adjust GmbH)

Adjust is a mobile analytics and advertising attribution tool.

AdColony

(AdColony, Inc.)

AdColony delivers mobile video and display ads, including rewarded ads.

Tapjoy

(Tapjoy, Inc.)

Tapjoy provides rewarded ad placements in mobile apps.

Liftoff

(Liftoff Mobile, Inc.)

Liftoff specializes in user acquisition and behavioral targeting.

PubMatic

(PubMatic, Inc.)

PubMatic enables real-time programmatic ad serving.

Smaato

(Smaato, Inc.)

Smaato provides mobile ad monetization solutions.

TripleLift

(TripleLift, Inc.)

TripleLift is a native advertising platform focused on seamless ad integration.

Unruly

(Unruly Group Ltd)

Unruly specializes in video ads and digital storytelling formats.

InMobi

InMobi is a mobile advertising provider offering personalized ad services.

Mintegral

(Mintegral International Ltd.)

Mintegral offers programmatic ad services including video and native formats.

AppLovin

(AppLovin Corporation)

AppLovin delivers performance-based ads in mobile applications.

myTarget

(MGL MY.COM (CYPRUS) LIMITED)

myTarget serves ads across mobile and social platforms with targeting tools.

DT Exchange

(Digital Turbine Inc.)

DT Exchange facilitates ad delivery and optimization across mobile apps.

Pangle

(Bytedance Pte. Ltd.)

Pangle provides monetization tools primarily for Bytedance (TikTok) ecosystems.

Google Ad Manager

(Google Ireland Limited)

Google Ad Manager allows publishers to run advertising campaigns with external ad networks, even when no direct relationship exists. It utilizes the DoubleClick Cookie to monitor user interaction with ads and content within the app.

To understand how Google handles personal data, see the Google Partner Policy.

Users can manage ad preferences or opt out of DoubleClick tracking by visiting Google Ad Settings or YourOnlineChoices.

  • Data Processed: Trackers; usage data

  • Place of Processing: Ireland

  • Privacy Policy

Google AdSense

(Google Ireland Limited)

Google AdSense also uses DoubleClick Cookies to serve personalized advertisements based on user behavior and browsing history.

Users can disable this tracking via Google Ad Settings.

Unity Ads

(Unity Technologies ApS)

Unity Ads provides ad delivery services for mobile games and apps, including rewarded video and interstitial formats.

Aarki

(Aarki Inc.)

Aarki delivers personalized mobile advertising campaigns using machine learning and user segmentation.

Fluct

(Fluct Inc.)

Fluct offers ad-serving technologies, particularly for in-app video and native advertising in Japan.

Vungle

Vungle provides video ads and monetization tools for mobile developers.

Chartboost

(Chartboost Inc.)

Chartboost specializes in in-app advertising, particularly for mobile games.

Ironsource

(Ironsource Mobile Ltd.)

Ironsource offers ad mediation and monetization services, including rewarded video ads and offerwalls.

b. Analytics Services

These services help us understand user behavior and analyze traffic patterns within the app.

Google Analytics for Firebase

(Google Ireland Limited)

Google Analytics for Firebase is a tool that tracks usage and engagement in mobile apps. It may share collected data with other Firebase tools, such as Crashlytics, Remote Config, or Notifications.

This service uses mobile identifiers and cookie-like technologies. Users can manage or disable certain tracking via device ad settings or Firebase-related settings in this Privacy Policy.

  • Data Processed: App opens/updates, device details, location, in-app purchases, session count/duration, OS version, advertising ID (e.g. GAID, IDFA), usage behavior

  • Place of Processing: Ireland

  • Privacy Policy – Partner Policy

Flurry Analytics

(Flurry, Inc. – Yahoo! Inc.)

Flurry is an analytics solution for mobile apps. Users can opt out by providing a MAC address or device ID, which stops tracking across all apps using Flurry.

  • Data Processed: Tracker; usage data; additional data as per Flurry’s policy

  • Place of Processing: United States

  • Privacy Policy – Opt Out

Facebook Analytics for Apps

(Facebook Ireland Ltd)

This service tracks user activity within apps and integrates insights from Facebook’s ecosystem.

  • Data Processed: Usage data; additional information as detailed in Facebook’s policy

  • Place of Processing: Ireland

  • Privacy Policy

Unity Analytics

(Unity Technologies ApS)

Unity Analytics tracks user behavior and engagement within apps, often used in games developed using Unity.

  • Data Processed: Usage data; various metrics as listed in Unity’s policy

  • Place of Processing: Denmark

  • Privacy Policy

Yandex Metrica

(YANDEX, LLC)

Yandex Metrica offers heatmaps and session tracking, highlighting areas of user interaction.

  • Data Processed: Tracker; usage behavior

  • Place of Processing: Russian Federation

  • Privacy Policy

Facebook Ads Conversion Tracking (Facebook Pixel)

(Facebook Ireland Ltd)

The Facebook pixel connects user activity on this app with ad campaign data from Facebook, Instagram, and Audience Network to track ad effectiveness.

  • Data Processed: Tracker; usage data

  • Place of Processing: Ireland

  • Privacy Policy

Beta Testing Services

These services allow developers to test early versions of the app with selected users. Some services collect logs, crash reports, and device-specific data during testing.

Google Play Beta Testing

(Google Ireland Limited)

Enables Android users to participate in beta programs through the Google Play Store.

  • Data Processed: Country, device info, logs, tracker, usage data, other data as per Google’s privacy policy

  • Place of Processing: Ireland

  • Privacy Policy

TestFlight

(Apple Inc.)

Apple’s beta testing platform used to distribute pre-release versions of iOS apps.

  • Data Processed: App usage, country, logs, trackers, and related device data

  • Place of Processing: United States

  • Privacy Policy

c. Content Performance and A/B Testing

These services enable the monitoring of user engagement in response to changes in content, layout, or features of the application. They help us evaluate which version of a component (e.g., a button, page layout, or headline) performs better.

Firebase Remote Config

(Google Ireland Limited)

Firebase Remote Config allows us to test different variants of the app by dynamically changing content or configurations without requiring an app update.

  • Data Processed: Various data types as defined in Google’s privacy policy

  • Place of Processing: Ireland

  • Privacy Policy

AppLovin

(AppLovin Corporation)

AppLovin provides both analytics and marketing tools that support A/B testing and performance tracking across campaigns.

  • Data Processed: Country; device data; logs; usage metrics; tracker; other data specified in the provider’s policy

  • Place of Processing: United States

  • Privacy Policy

AppsFlyer

(AppsFlyer Limited)

AppsFlyer helps track user acquisition and engagement while supporting multivariate testing and campaign analytics.

  • Data Processed: Country; device logs and identifiers; tracker; usage data; additional data as outlined in their privacy terms

  • Place of Processing: United States

  • Privacy Policy

d. Handling Payments

Unless stated otherwise, all payments in this application (credit card, bank transfers, digital wallets, etc.) are processed through third-party services. Personal payment details are submitted directly to those services — the app does not store or process them.

The only information we may receive is a status update (e.g., “payment successful”) from the respective provider.

RevenueCat

(RevenueCat, Inc.)

RevenueCat provides subscription and payment management services. It helps track purchase history and user behavior linked to payment events.

  • Data Processed: App launches; device info; unique ad identifiers (e.g., GAID, IDFA); trackers; usage metrics

  • Place of Processing: United States

  • Privacy Policy – Opt Out

Apple App Store Payments

(Apple Inc.)

Payments for iOS apps and in-app purchases are processed through Apple’s system. Data related to transactions is handled solely by Apple under their privacy policy.

  • Data Processed: Payment data

  • Place of Processing: United States

  • Privacy Policy

Google Play Store Payments

(Google Ireland Limited)

Google processes Android app purchases through the Play Store. Payment details are handled directly by Google.

  • Data Processed: Payment data

  • Place of Processing: Ireland

  • Privacy Policy

PayPal

(PayPal Holdings, Inc.)

This application integrates PayPal for in-app purchases. All transactional data is processed securely through PayPal.

  • Data Processed: Payment data

  • Place of Processing: United States

  • Privacy Policy

e. Hosting and Backend Infrastructure

These services host data, files, and system components that allow the app to run, function, and distribute content. Some providers use globally distributed servers, so determining the exact data location may be difficult.

Amazon Web Services (AWS)

(Amazon Web Services, Inc.)

AWS is a widely-used cloud platform that provides hosting and backend infrastructure.

  • Data Processed: Various data types as outlined in AWS’s privacy documentation

  • Place of Processing: United States

  • Privacy Policy

Azure Cloud Services

(Microsoft)

Azure offers hosting, storage, and scalable infrastructure to support the app’s operations.

  • Data Processed: Various data types as defined in Microsoft’s privacy terms

  • Place of Processing: United States

  • Privacy Policy

f. Infrastructure Monitoring

These services help monitor how the app and its features perform, detect issues, and maintain reliability.

Firebase Performance Monitoring

(Google Ireland Limited)

Monitors app speed, responsiveness, and performance metrics.

  • Data Processed: Various performance-related data

  • Place of Processing: Ireland

  • Privacy Policy

Crashlytics

(Google Ireland Limited)

Tracks crashes and technical failures, including device and error logs.

  • Data Processed: Crash reports, device info, UUID

  • Place of Processing: Ireland

  • Privacy Policy

g. Contact Management and Message Delivery

These services help organize user contact information and send messages (emails, push notifications, etc.). They may also track when a message is viewed or interacted with.

Firebase Notifications

(Google Ireland Limited)

Delivers push notifications and can be integrated with Firebase Analytics to enable audience targeting and event tracking.

  • Data Processed: Various communication-related data

  • Place of Processing: Ireland

  • Privacy Policy

h. Platform Services and App Store Hosting

These services act as distribution platforms and offer tools like analytics, e-commerce, and database access. Some operate through distributed systems, so data location may vary.

Apple App Store

(Apple Inc.)

Hosts and distributes the iOS version of the app. Apple collects basic usage analytics to provide developers with performance reports. Users can manage analytics tracking through iOS settings.

  • Data Processed: Usage data

  • Place of Processing: United States

  • Privacy Policy

Google Play Store

(Google Ireland Limited)

Distributes Android apps and collects diagnostic and usage analytics, often aggregated and shared with app developers. Users can opt out of certain analytics in device settings.

  • Data Processed: Usage data

  • Place of Processing: Ireland

  • Privacy Policy

i. Social Features

These services allow users to share content or invite others, and help the platform track user referrals or interactions for marketing and analytics purposes.

Firebase Dynamic Links

(Google Ireland Limited)

Firebase Dynamic Links allows users to share custom app links that are tracked using Google Analytics for Firebase. This helps analyze the user journey, including how the app was opened or installed.

  • Data Processed: Various data types as defined in Google’s policy

  • Place of Processing: Ireland

  • Privacy Policy

Firebase Invites

(Google Ireland Limited)

Firebase Invites lets users share the app via SMS or email. Shared content may include referral codes or in-app elements. These actions are tracked using Firebase Analytics to monitor installs and interactions resulting from invitations.

  • Data Processed: Various data types as specified in Google’s policy

  • Place of Processing: Ireland

  • Privacy Policy

 Push Notifications

This app may send push notifications to deliver updates or content in line with the purposes outlined in this privacy policy.

Users can usually opt out of push notifications via their device settings (e.g., by disabling notifications for this app specifically). Keep in mind that turning off notifications may limit the app’s functionality or your user experience.

 

F. Data Deletion and Retention

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected and for a reasonable time afterward. This may include meeting legal, contractual, or regulatory obligations, as well as our legitimate business interests.

  • Deletion: Physical records are securely shredded, and digital data is permanently erased. Inactive accounts may be removed after 12 months, along with the associated data.

  • Retention: We keep data only as long as needed by law or for as long as you actively use our Services. After account deletion, your information may be stored for an additional 12 months for administrative purposes. Where possible, data may be anonymized and used for legitimate business purposes, such as fulfilling tax obligations.

  • Delete Requests: You can request account deletion using the contact information in this Privacy Policy. Keep in mind that deleting your account will result in the permanent loss of any unredeemed loyalty rewards. If we retain anonymized or de-identified data, it will not be linked back to you. To delete data collected by Game Partners, please refer to their own privacy policies.

G. Disclosure of Personal Data

While your data is primarily used within our platform, there are specific cases where we may share it under controlled conditions:

  • Corporate Affiliates & Transactions: Data may be shared with subsidiaries or affiliates during mergers, acquisitions, or business transitions in compliance with legal agreements.

  • Legal & Security Requirements: We may disclose data when required to protect our rights, respond to legal claims, prevent fraud, or comply with legal obligations.

  • Service Providers: Trusted third-party vendors assist us in areas like infrastructure, security, customer support, and marketing. These providers are bound by contracts to safeguard your data and may combine shared information with other data they have about you.

  • Advertising & Marketing Partners: For personalized advertising, we may share details such as device identifiers and IP addresses with ad networks and analytics platforms.

  • Marketing Vendors: We may share your information with third-party marketing partners for campaigns, testing, and surveys — always in compliance with applicable opt-out rights and legal limits.

  • Analytics Providers: We work with analytics vendors to understand usage patterns and improve our Services.

  • Game Partners: When accessing third-party games through our platform, your data may be shared with Game Partners and their mobile measurement providers in accordance with their privacy policies.

H. Data Security

We take your data protection seriously and apply technical, administrative, and physical safeguards to secure personal data. Only authorized personnel can access this information, and all access is logged and restricted to specific roles.

You also play a role in protecting your data. Do not share your login credentials, and always secure the devices you use to access our Services.

While we implement industry-standard protection, no system is immune to breaches. We are not liable for unauthorized access resulting from transmission errors, third-party actions, or factors outside our control.

In case of a security incident, we will notify you using your registered contact information or through in-app announcements, as appropriate.

Security Measures in Place

  • Database servers are accessible only from secure network locations.

  • Access to data is limited to authorized personnel with signed NDAs, including post-employment protections.

  • All portable devices (laptops, USB drives, etc.) are password-protected.

  • Web and database servers are secured with firewalls.

  • Where feasible, encryption is applied both at rest and in transit.

  • Enforced one-session-per-browser to prevent session duplication.

  • AWS S3 is used for file storage with private access only.

  • PostgreSQL is configured with row-level security to restrict access.

  • IP-based rate limiting is implemented to prevent abuse.

  • Regular external security audits and penetration testing are performed by specialized vendors.

I. Your Rights Regarding Your Personal Data

As a user, you are entitled to exercise various rights over your personal data:

  • Opt-out from Marketing: You may choose not to receive promotional communications from us.

  • Withdraw Consent: You can revoke your consent at any time for data processed based solely on consent (e.g., gender information). This withdrawal does not affect the lawfulness of prior processing or any processing based on legal grounds other than consent.

  • Request Processing Details: You may ask if your personal data is being processed and request further details as outlined in this Privacy Policy.

  • Request Deletion: You can request deletion of your personal data or account. Note: legal obligations may require us to retain certain data.

  • Request Correction: If your data is incorrect, incomplete, or outdated, you may request corrections.

  • Object to Processing: You have the right to object to how we process your data, including automatic processing.

  • Contacting Us: For questions or to exercise your rights, please use the contact information provided in this policy.

J. Supplemental Provisions for Users in the EEA & UK

1. Data Transfers Outside the EU

We use servers located in Germany to keep data within the EU, as explained in “Where We Store Personal Data.” If data must be transferred to third countries (non-EU nations), we rely on one of the following legal bases:

  • Adequacy Decision: The European Commission has deemed the destination country to offer adequate protection.

  • Standard Contractual Clauses: Transfers rely on European Commission-approved legal terms to ensure data security.

  • Code of Conduct or Certification: Data is shared with entities adhering to recognized frameworks with enforceable protections.

  • Explicit Consent: If you have been informed of the risks and provided direct consent, we may proceed with such transfers.

You may request clarification regarding the legal basis applicable to any specific data transfer by contacting us.

2. Your GDPR Rights

In line with the General Data Protection Regulation (GDPR), Swiss and UK data laws, you have the following rights if you are in the EEA or UK:

  • Access: View, download, or request deletion of your personal data.

  • Correction: Request correction of incomplete or inaccurate information.

  • Object: Object to processing based on legitimate interest or for marketing purposes.

  • Erasure: Request deletion where there is no valid reason to keep your data.

  • Data Portability: Receive your data in a structured, machine-readable format or request its transfer to another controller.

  • Withdraw Consent: Revoke your consent at any time. Note: This may affect access to certain features or services.

3. Exercising Your Rights

You can exercise any of these rights by contacting us using the details in this policy. We may require identity verification before processing your request.

If you are based in the EEA, you also have the right to file a complaint with your local data protection authority if you believe your rights have been violated.

 

K. Additional Provisions for California Residents

In accordance with the California Consumer Privacy Act (CCPA), if you are a California resident, you are entitled to additional rights concerning your personal information. These rights include:

1. Right to Know and Request Deletion

We are committed to transparency about how your data is collected and shared:

  • You have the right to request information about the categories and specific pieces of personal data we have collected, used, disclosed, or sold.

  • Twice per year, you may request—free of charge—a report detailing:

    • What personal information we have about you.

    • The categories of third parties with whom we have shared this information.

    • The purposes for which the data was collected or shared.

  • You also have the right to ask us to delete your personal data. Once we receive your request, we will either:

    • Permanently remove your information, or

    • Add your details to a suppression list (e.g., a “do not contact” list) if you prefer to restrict contact without full deletion.

2. Response Timeframes

We aim to fulfill all CCPA-related requests within 45 days.

If we need additional time (up to a total of 90 days), we will notify you with an explanation and expected timeline.

3. Authorized Agents

You may designate a third party to act on your behalf by:

  • Selecting an authorized agent registered with the California Secretary of State.

  • Providing us with:

    • Written permission authorizing the agent to act for you, and

    • Sufficient verification of your identity and the agent’s authority.

We will not process the request until these verifications are complete.

4. Information Use, Collection, and Disclosure Summary

In accordance with Section 1798.140(o) of the CCPA, we provide the following summary chart that outlines:

  • The types of personal information we may collect.

  • The sources from which this information is obtained.

  • The business or commercial purposes for collecting and sharing the data.

  • The categories of third parties with whom such data may be shared.

CATEGORY  

DESCRIPTION  

SOURCES  

BUSINESS USE  

COMMERCIAL USE  

A  

Identifiers – name, email, postal and IP address, unique personal identifier, online identifier, Internet Protocol address, account name  

User provided on registration and upon redeeming points using the online shop, customer service inquiries and claim forms; related and 3rd party sources to verify user-supplied information, selfie in video format  

Operational purposes including customer service; fraud & security incidence detection; website improvement; award prize winners  

None  

B  

Protected classification characteristics under California or federal law  

Age and Gender  

Recommend suitable Games  

None  

C  

Internet or similar network activity -browsing and search history, information on a consumer’s interaction with a website, application, or advertisement  

To determine the performance of media content and analytics purposes  

User provided on registration and upon redeeming points using online shop, customer service inquiries and claim forms; related and 3rd party sources to verify user-supplied information, selfie in video format  

None  

D  

Geolocation data  

Country Identified using IP Address  

Recommend Games for Country  

None  

E  

Inferences are drawn from other personal information  

Profile reflecting a person’s preferences  

Recommend Games based on preference  

None  

 

5. Usage and Disclosure of Data

Although we have shared personal data with third-party service providers over the past 12 months for legitimate business functions, we do not sell your personal information.

In rare instances, data sharing may qualify as a “sale” under California law—even if we receive no monetary compensation. Please note: we do not knowingly collect or share information from individuals under the age of 16.

6. How Long We Keep Your Data

We retain your personal information solely for the duration required to deliver our services, fulfill legal or contractual obligations, or support the purpose for which the data was originally collected.

Accounts that remain inactive for twelve (12) consecutive months may be deactivated, and related data securely deleted, in accordance with our Terms of Use.

7. Rewards and Incentives

Magic Play’s Rewards Program is classified as a “financial incentive” under California law. The benefits offered are proportionate to the value derived from aggregated user insights and behavioral data.

Your participation in the program is entirely optional and can be withdrawn at any time. For more details, please consult our Terms of Use.

8. Your CCPA Rights at Magic Play

As a California resident, you have specific rights under the CCPA:

  • Right to Know: You may ask what personal information we collect, how we use it, and with whom it is shared.

  • Right to Delete: You can request that we remove your personal data from our systems, subject to legal exceptions.

  • Right to Correct: You can ask us to amend inaccurate or outdated information about you.

  • Right to Opt Out: You have the right to opt out of:

    • The “sale” or “sharing” of your personal data.

    • Cross-context behavioral advertising.

  • Right to Limit Use and Disclosure: You may request restrictions on how your sensitive personal data is used or shared.

  • Right to Non-Discrimination: You will not be treated unfairly or penalized for asserting any of your CCPA rights.

To exercise any of these rights or to opt out, please email us at:

📧 [email protected]

We also honor browser-enabled privacy preferences like Global Privacy Control (GPC) signals.

To submit a request to access, delete, or correct your personal data:

  • Use the subject line: “Personal Information Privacy Request”

  • Include your full name, email, and mailing address.

  • Specify which Magic Play service or platform your request refers to.

  • For deletion requests, indicate whether you want a full data removal or placement on a “do not contact” list.

Please note: even after deletion, if your information is re-collected via future activity or through another channel, you may still receive contact unless a global opt-out remains in effect.

Requests will typically be processed within 45 days, with possible extensions if necessary.

9. Fair Treatment Assurance

Magic Play guarantees no discrimination based on your choice to exercise privacy rights under the CCPA. This includes equal access to services, pricing, and quality.

10. Do Not Track (DNT) Disclosures

Many browsers include a “Do Not Track” setting, signaling websites not to track user activity.

However, as with most online platforms, Magic Play does not currently recognize or respond to DNT signals, consistent with the limitations of the California Online Privacy Protection Act (CalOPPA).

 

L. Additional Provisions for Residents of Colorado, Connecticut, and Virginia (USA)

If you reside in Colorado, Connecticut, or Virginia, the following section outlines your additional privacy rights under applicable state laws. For further details about how your personal information is collected, used, disclosed, or shared, please refer to the previously outlined sections titled “Use of Personal Data”, “Disclosure of Your Personal Data”, and “Types of Data Collected.” Note that data shared for targeted advertising or marketing purposes may be classified as a “sale” or “profiling” under applicable legislation.

Depending on your state of residence, you may exercise the following rights:

  • Right to Access: You have the right to request confirmation as to whether we are processing your personal data and to access a copy of that data.

  • Right to Data Portability: You may request a structured, commonly used, and machine-readable copy of your data.

  • Right to Correct Inaccuracies: You can request that we amend any incorrect or incomplete information we maintain about you.

  • Right to Deletion: You can request the removal of your personal data from our systems.

  • Right to Opt Out of Sales or Targeted Advertising: You have the right to opt out of your data being sold or used for targeted advertising purposes.

  • Right to Opt Out of Profiling: You can decline the use of your personal information for profiling in ways that may affect your legal rights or significant decisions.

To invoke any of these rights, please contact us using the instructions provided in this Privacy Policy.

Be sure to include “Personal Information Privacy Request” in the subject line and provide your full name, email address, physical address, and specify the Magic Play service in question. For deletion requests, indicate whether you prefer complete erasure or inclusion on a “do not contact” list.

If your request is denied, you may submit an appeal following the process outlined in the Policy. You also have the option to designate an authorized agent to act on your behalf, subject to identity and authorization verification procedures.

M. Additional Provisions for Users in South Korea

If you access Magic Play services from South Korea, please be advised that your personal data may be transferred outside of the country. These transfers will be conducted in accordance with the Personal Information Protection Act (PIPA) and the Act on Promotion of Information and Communications Network Utilization and Information Protection (Network Act) of Korea.

We implement appropriate safeguards, such as secure communication networks, to protect your data during transfer and storage. Your personal information will only be kept for as long as necessary to fulfill the original purpose for which it was collected, after which it will be deleted or anonymized in compliance with Korean data protection regulations.

 

 

 

COMPANY NAME  COUNTRY  CONTACT OF EMPLOYEE OR DEPARTMENT RESPONSIBLE FOR MANAGING PERSONAL INFORMATION AND LINK TO PRIVACY POLICY  DATE AND TIME OF TRANSFER  PURPOSE OF TRANSFER  PERSONAL INFORMATION ITEMS TO BE TRANSFERRED 
Amazon Web Services, Inc.  U.S.A  Amazon.Com  Upon accessing and using Magic Play services  Hosting and data security and management services for the personal data that we store. Also used for analytics to monitor and track the reliability of the Services  CONTACT OF EMPLOYEE OR DEPARTMENT RESPONSIBLE FOR MANAGING PERSONAL INFORMATION AND LINK TO THE PRIVACY POLICY 
Azure Cloud Services U.S.A  Microsoft.com Upon accessing and using Magic Play services  Hosting and data security and management services for the personal data that we store. Also used for analytics to monitor and track the reliability of the Services  CONTACT OF EMPLOYEE OR DEPARTMENT RESPONSIBLE FOR MANAGING PERSONAL INFORMATION AND LINK TO THE PRIVACY POLICY 
Adjust  U.S.A  Email 
Adjust.Com 		 Upon accessing and using Magic Play services  Advertising, rewards, and fraud detection  Mobile application Google Ad ID, IP address, age, device model, OS version 
Facebook  U.S.A  Facebook.Com  Upon accessing and using Magic Play services  Used for business analytics to better understand how users interact with Magic Play Services  Google Advertising ID 
Google  U.S.A  Google.Com  Upon accessing and using Magic Play services  Used for business analytics to better understand how users interact with Magic Play Services  Google Advertising ID 
AdGate  Canada  Adgatemedia.com  Upon accessing and using Magic Play services  Advertising, and rewards  IP address, user agent 
Adjoe Germany  Adjoe.zone  Upon accessing and using Magic Play services  Playtime (adjoe) is a third feature that is integrated with our app. Playtime allows users to earn in-app currency by playing third-party games and collects devices’ application usage from users. The processing of the data is necessary to recommend, via system messages, the installation of the app available in Playtime that matches users’ interests and calculates the bonuses acquired as a result of users’ use of the corresponding apps. For more information, please refer to Playtime (adjoe) Data Privacy. IP address, user agent, usage access data 

Magic 

Play Analytics

 U.S.A Magic Play – Privacy Policy Upon accessing and using Magic Play services  Magic Play Analytics is a feature that is integrated with our app. Magic Play Analytics allows users to earn in-app currency by playing games and collects devices’ application usage from users. The processing of the data is necessary for fraud prevention, users’ security & privacy. It is also required to recommend, via system messages, the installation of the app available in the app that matches users’ interests and calculates the bonuses acquired as a result of users’ use of the corresponding apps.

Approximate Location, Device ID, Device Model, Operating System, Usage Access Data, Mail, Phone Number

 

 

 

N. Additional Provisions for Residents of Brazil

This section applies to Users located in Brazil and is aligned with the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados – LGPD). Where there is a conflict with the general policy, this section takes precedence.

1. Legal Basis for Processing

We only process your personal data when a valid legal ground under LGPD exists—typically based on your consent, legitimate interest, or legal obligation. For more information, contact us using the details in this Privacy Policy.

2. Categories of Personal Data

For details on the types of personal data we collect, refer to the “Types of Data Collected” section of this Privacy Policy.

3. Data Sharing

Please see the “Disclosure of Your Personal Data” and “Use of Personal Data” sections to learn about how and with whom your data is shared, and the reasons for doing so.

4. Purposes of Processing

We process personal data for the purposes described in the “Use of Personal Data” section, including to deliver services, improve user experience, and comply with legal duties.

5. Your Rights Under LGPD

As a Brazilian resident, you are entitled to:

  • Confirm whether we process your personal data.

  • Request access to your data.

  • Correct inaccurate, incomplete, or outdated data.

  • Request anonymization, blocking, or deletion of unnecessary or unlawfully processed data.

  • Receive information about your consent, including consequences of refusal.

  • Know third parties your data has been shared with.

  • Request data portability to another provider, as long as this doesn’t infringe on our commercial secrets.

  • Request deletion of data processed with your consent, subject to legal exceptions.

  • Withdraw consent at any time.

  • File a complaint with the ANPD (National Data Protection Authority).

  • Object to data processing in cases of non-compliance.

  • Request information about automated decision-making processes.

  • Ask for a review of automated decisions that significantly affect you.

You will not face any discrimination for exercising these rights.

6. Exercising Your Rights

To make a rights request, you or your legal representative can contact us free of charge using the contact info in this Privacy Policy. We aim to respond quickly. For access or confirmation requests, please specify your preferred delivery format (electronic or printed) and whether a simplified or detailed report is needed. Detailed responses will be provided within 15 days, including origin, processing methods, and purposes—unless doing so would compromise our trade secrets.

If your request involves rectification, deletion, anonymization, or blocking, we will inform third parties with whom your data was shared—unless impossible or disproportionately burdensome.

7. International Transfers

If your data is transferred outside Brazil, such transfers will comply with LGPD requirements. Contact us for details.

O. Additional Provisions for Residents of Türkiye (KVKK)

If you are located in Türkiye, this section is provided in accordance with the Turkish Personal Data Protection Law No. 6698 (KVKK) and supplements the rest of this Privacy Policy.

1. Personal Data We Collect

The personal data we may collect includes:

  • Contact information (e.g. email, first and last name if included in username)

  • Profile photos or avatars (if they include identifiable data)

  • Any communication or correspondence with our team

  • Technical details such as IP address, login info, browser type, screen resolution, time zone, plugins, OS, session logs, cookies, traffic data, and other access logs

  • Any other information you voluntarily provide

Please refer to the “Types of Data Collected” and related sections for a full breakdown.

2. Legal Grounds for Processing

We process your personal data based on one or more of the following legal bases under KVKK:

  • Performance of a contract: When necessary to fulfill an agreement with you or your employer.

  • Consent: When you have provided clear, voluntary consent to process your data.

  • Legitimate interest: Where processing is necessary and does not override your fundamental rights.

  • Legal obligations/public interest: Where required by local laws or for matters in the public interest.

Magic Play