Privacy Policy

1. Who we are

Hongkong Minigame Technology Co., Limited is an international entertainment company based in Hong Kong that specialises in the mobile environment. We create and publish free mobile and HTML5 games and applications that aim to entertain, inform and connect people. MiniGame is one of our publishing brands.

This policy applies to the personal data we collect and process when we:

• develop and publish mobile and HTML5 games and apps (“our Games”);
• serve advertising tailored to the interests of users (“our Ads services”); and
• operate this corporate website (the “Website”).

For the purposes of applicable data protection law, Hongkong Minigame Technology Co., Limited is the data controller. If you have any questions about this policy or our privacy practices, please contact our Data Protection Officer using the details in the Contact section.

2. Our games and apps

Why we collect data

• To provide the service you asked for — for example, recording that you completed level one so that level two is unlocked. Legal basis: performance of the service.
• To run analytics and understand how players use our Games so we can improve them — for example, identifying that a feature is frustrating or a level is too difficult. Legal basis: your consent, collected through the in-app consent notice.
• To show advertising tailored to your interests, which allows us to keep our Games free. Legal basis: your consent, collected through the in-app consent notice.

You can withdraw your consent at any time from the privacy settings in our Games. If you refuse or withdraw consent you will still see ads, but they may be less relevant to you.

What data we collect

• The apps and games you use;
• Your IP address;
• Your mobile advertising identifier (Apple IDFA or Google Advertising ID), which you can reset or restrict at any time in your device settings;
• Technical information about your device and connection (user agent, connection type, timestamps);
• How you interact with our Games and with the ads shown in them (for example, sessions, progress, number of ads served and clicks).

Who we share data with

We do not share your personal data with third parties without your prior consent. When you consent to analytics and advertising, we may share the data listed above with the following categories of recipients:

Advertising partners — who help us monetise ad inventory so we can offer free games. They usually collect data through their own software development kits (SDKs):

Analytics partners — who provide tools to help us understand and improve how players use our Games:

Authorities — only where we are required to do so by applicable laws and regulations.

3. Meta (Facebook) platform data

Some of our Games and HTML5 games may integrate Meta platform features such as Facebook Login, Instant Games, the Meta SDK or Meta Audience Network. If you choose to use these features, we may receive the information you authorise Meta to share with us, which is typically limited to your app-scoped user ID, public profile name and profile picture, and game-related information such as scores or in-game progress.

• We use this information only to provide game features such as saving progress, leaderboards and sharing.
• We do not sell Meta platform data, and we do not use it for any purpose other than operating the Game.
• You can request deletion of this data at any time — see our Data Deletion Instructions.

4. Our advertising services

Our Ads services allow us and our publishing partners (usually third-party app developers) to monetise advertising inventory, and allow advertisers to promote their products to interested audiences. To deliver these services we may process data in order to:

• help our publisher partners monetise their ad inventory;
• help advertiser partners promote their products and services and optimise their marketing spend; and
• measure and improve the quality and relevance of our Ads services.

The data processed is limited to the same categories listed in section 2 (apps used, IP address, advertising identifier, device and connection information, and ad interactions). We contractually require our partners to obtain users’ consent before any data is sent to our Ads services. This data is shared only with advertisers and publishers using our Ads services, and only to the extent necessary.

5. Our website

Like most websites, when you visit ours certain information about your connection and device is collected automatically so the site works properly. We and our partners may use cookies and similar technologies to analyse how visitors use the site. You can control cookies in your browser settings; disabling them may affect some functionality.

The data collected through the Website is limited to:

• browsing events and interactions with the Website;
• cookie identifiers, IP address and technical information about your browser or device;
• information you voluntarily provide when you contact us.

We may use Google Analytics to measure website traffic. See Google’s privacy policy and opt out using the Google Analytics opt-out add-on.

6. How long we keep data

We keep personal data only for as long as necessary for the purposes described in this policy, and in any case no longer than 13 months, unless a longer period is required by law.

7. Children

Our services are not directed at children under 16, and we do not knowingly collect personal data from children under 16. If you believe a child has provided us with personal data, please contact us and we will delete it.

8. International transfers

Some of our partners and service providers are located outside Hong Kong and outside the European Economic Area. Where personal data is transferred internationally, we ensure an adequate level of protection — for example, by transferring data to countries recognised as providing adequate protection, or by using the European Commission’s Standard Contractual Clauses or other lawful transfer mechanisms.

9. Security

We use appropriate technical and organisational measures to protect personal data against unauthorised access, loss or misuse. No method of transmission over the internet is completely secure, however, and we cannot guarantee absolute security.

10. Your rights

• Withdraw consent / opt out. You can change your consent at any time from the privacy settings in our Games. We do not sell users’ personal information; adjusting your consent stops data being shared with our analytics and advertising partners.
• Access. On request, we will tell you whether we hold personal data about you and provide a copy.
• Rectification and erasure. You may ask us to correct inaccurate data or delete your data. You can also reset your advertising identifier or enable “Limit Ad Tracking” / “Opt out of Ads Personalisation” in your device settings so that previously collected data can no longer be linked to you. See our Data Deletion Instructions.
• Portability. On request, we will provide the personal data you gave us in a portable format where processing is based on consent or contract.

We respond to all requests within 30 days. You may also lodge a complaint with your local data protection authority.

11. Changes to this policy

We may update this policy from time to time. The “Last updated” date at the top of this page shows when it was last revised. Significant changes will be communicated through our Games or this Website.

12. Contact

Hongkong Minigame Technology Co., Limited
Attn: Data Protection Officer
A105, 1st Floor, Xinyisheng Industrial Building, 18 Chengye Street, Guantang, Kowloon, Hong Kong
Email: support@minigame.wang