PRIVACY POLICY

Last updated:December 24th, 2024.

Privacy Policy Facebook Instant Games

MesApp respects and protects your personal data.

MesApp collects, processes or uses personal data exclusively within the applicable legal framework. Therefore, the high data protection level of the General Data Protection Regulation (GDPR) holds true.

Field of application

1. We develop games ("Facebook Instant Games") that are available on the social network Facebook, a platform provided by the Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook"). In this privacy policy we inform you on the collection, processing and use of data concerning the Facebook Instant Games.

2. Insofar as individual services of MesApp have different privacy policies, these apply.

3. The Facebook Instant Games can only be accessed via the Facebook network, which is operated solely by Facebook, and only if you have registered for the Facebook network and are logged in to your Facebook account. The processing of data by Facebook when you register your Facebook account and every time you access the Facebook network is excluded from the field of application of this privacy policy. Likewise, cookies that Facebook may use for statistical evaluations when you access the Facebook platform are not within this privacy policy's scope. Facebook organizes the aforementioned data processing independently and on its own responsibility, without us having any influence on this. For further information on this data processing by Facebook see the Facebook's privacy policy: https://www.facebook.com/privacy/explanation.

Data processed when accessing and using the Facebook Instant Game

1. When you first access one of our Facebook Instant Games, Facebook will assign you one unique ID per Facebook Instant Game (the "Facebook Instant Game ID"), which is linked to your personal information, and will disclose this ID to us. Facebook also provides us with the first name you have entered in your Facebook account, your profile picture, the language selected, and the country you are playing from. Further, Facebook checks which other Facebook users, with whom you are connected on Facebook (so-called Facebook friends), have already played the respective Facebook Instant Game and notifies us of the results. MesApp receives and uses the Facebook Instant Game ID and the other aforementioned data solely to create your player profile in the Facebook Instant Game to the extent necessary for using the game. Hence, the data processing in this context is carried out for the purpose of performing the contract with you on the use of the Facebook Instant Game pursuant to Art. 6 (1) (b) GDPR.

We would like to point out that MesApp does not receive any additional personal data from your Facebook user account. MesApp will not use the data to identify you or to create user profiles for purposes other than providing the Facebook Instant Games.

If you want to have the aforementioned data on you including the player profile deleted, you can, for example, send an email to xz@mesapp.com. In order to be able to identify the data concerning you for deletion, we need your Facebook Instant Game ID. Please note that it is not possible to use the Facebook Instant Games without such a player profile. If you use our Facebook Instant Games again after deletion of your player profile, a new player profile will be set up for you.

2. In order for you to access and play the respective Facebook Instant Game including all game functions, MesApp collects and processes data on the use of the Facebook Instant Game (data on game progress such as completed levels, owned skins and player aids used, high scores achieved, ongoing and paused game sessions). This data is linked to the Facebook Instant Game ID and added to your player profile by MesApp. The processing of this data for the use of the Facebook Instant Game is carried out for performance the contract with you on the use of the Facebook Instant Game pursuant to Art. 6 (1) (b) GDPR.
   MesApp does not receive any further personal data of your Facebook account and is not able to identify you via the Facebook Instant Game ID. MesApp will not use this data to create user profiles for any other purpose than to provide the Facebook Instant Games.

3. Each time you access a Facebook Instant Game, Facebook automatically logs your gender, age and the country you are located in while playing. Facebook collects this information as part of an analytics function to provide MesApp with reports and analyses on the general use of the games, based on which MesApp can gain insights for possible improvements and further developments of the Facebook Instant Games. As MesApp only offers the Facebook Instant Games in the network operated by Facebook and therefore has no general access to the Facebook network, MesApp generally does not obtain any information on Facebook user accounts or other data that would allow conclusions to be drawn about the identity of individual players. The only exceptions to this are the data mentioned in Sect. 2.1, which MesApp only obtains and uses to create player profiles. Also, MesApp will not merge the data from the analytics function with other data about individual players, in particular not with the data mentioned in Sect. 2.1.
   At the beginning and during a game, Facebook will also collect information about your game session, such as the respective Facebook Instant Game, the language used, the beginning and end of a game session, how you accessed and started the game, what elements and levels of the game you use, whether you successfully completed a level, and, if applicable, the number of other players. MesApp

4.  analyses this data and uses the insights from these evaluations to further develop and optimise the design of the Facebook Instant Games. However, MesApp only processes the Facebook Instant Game ID in connection with these evaluations of the game sessions and does not process any data from the player profiles which could provide information about the identity of individual players. It is therefore not possible for us to attribute the analysed data about the game sessions to individual persons. We also do not create profiles of individual players from these evaluations of game sessions, nor do we link these evaluations with data from the analytics function.
   The data processing in connection with the above analyses of general game use and game sessions is based on our legitimate interest pursuant to Art. 6 (1) (f) GDPR, which consists in the continuous improvement of our games to ensure the best possible, entertaining gaming experience. For such adjustments based on user experience, we need to know the actual use of the games.

5. Furthermore, Facebook uses the aforementioned, recorded information independently and on its own responsibility for its own, individual purposes and also collects and processes additional data including information from your Facebook account for these purposes, without us being involved or having any influence on this. Details of this use of your personal data are explained in the Facebook privacy policy, which you can view under https://www.facebook.com/privacy/explanation.

6. We would like to point out that data processing by Facebook can also take place outside the EU or the European Economic Area, in particular on Facebook servers located in the United States. This can result in risks for the users, because, for example, the enforcement of the users' rights could become more difficult. In this particular case, Facebook and we guarantee that appropriate protection measures are in place in accordance with Article 44 et seq. GDPR. In particular, Facebook and we have agreed on the standard data protection clauses of the EU Commission as a precautionary measure which provide for appropriate protection measures for the specific case, such as encryption of the data, in accordance with Article 46 (2) lit. c) GDPR. The measures are also continuously developed and supplemented to the extent necessary to ensure an adequate level of data protection throughout.

Data security

1. MesApp has taken appropriate technical and organisational measures to protect personal data against accidental loss, damage, unauthorised access or unauthorised changes. In particular, MesApp will transmit data only in encrypted form. However, MesApp points out that privacy and data security cannot be guaranteed for transmissions outside MesApp's sphere of influence.

2. The classification of Platform Data is PRIVATE DATA, we will follow the Data Handling Guidelines to process/access that data.

   • Storage of platform data on organizational and removable devices is only allowed when there is a clear and actionable business purpose.

   • Platform data held on organizational devices and removable devices is deleted once the business purpose for storing them no longer exists.

3. About Meta access tokens

   • Must not be written such that another user or process could read it.

   • Process or store Meta access tokens on server side:

     • Must be protected using a data vault with separate key management service (KMS) and where access to the decryption key is limited to the application.

     • Must not be written to log files.

4. About Meta App Secret

   • MesApp never expose the app secret outside of a secured server environment (e.g., it is never returned by a network call to a browser or mobile app and the secret is not embedded into code that’s distributed to mobile or native/desktop clients).

5. About Vulnerabilities and Security Issues

   • MesApp test the app and systems for vulnerabilities and security issues at least every 12 months.

   • MesApp will resolve all critical and high severity vulnerabilities related to server before released to production.

   • MesApp will test the cloud configuration for security issue related to server host before released to production.

Facebook Audience Network

1. Our Facebook Instant Games implement the so-called Facebook Audience Network, a service of Facebook for serving advertisements. This service is used by Facebook to display advertisements in our Facebook Instant Games. When an advertisement is to be displayed in a Facebook Instant Game or clicked on, Facebook will record notably your interaction with the advertisement, your IP address and, if applicable, your further usage behaviour after the click on the advertisement. Facebook processes this information in order to measure the success of the respective advertising and to provide us with excerpts of the results. However, Facebook only provides MesApp with access to aggregated data on the results of the advertising feed, which MesApp cannot trace back to individual persons. Besides, MesApp only receives excerpts of data in the context of the advertisements that cannot be attributed to individual persons. In particular, MesApp in does not receive and process any IP addresses or cookies from user devices or other data that allow conclusions to be drawn about the identity of individual users.

2. Facebook autonomously decides on the specific advertisements that are displayed in each case and on the processing of your personal data in the context of selecting and playing these advertisements. MesApp can only exclude certain categories, in particular sensitive categories (such as depictions of violence, politics, religion) by choosing between default settings. Facebook uses this information to display the advertisements: which specific Facebook Instant Game you are playing, information about your usage behaviour in the Facebook social network and your interaction with other content in the Facebook network, as well as information that you have entered in your Facebook account. Facebook also uses cookies for this purpose. Further information on the data processing by Facebook regarding the Facebook Audience Network can be found at https://www.facebook.com/ads/about/?entry_product=ad_preferences and is explained in the Facebook privacy policy: https://www.facebook.com/privacy/explanation.

3. You will only receive personalised advertising via Facebook Audience Network if you have consented to this in your Facebook settings. The legal basis is therefore Art. 6 (1) (a) GDPR. Of course, you can withdraw your consent at any time for the future by changing your Facebook settings under the following link: https://www.facebook.com/ads/preferences. Please note that we can only provide the Facebook Instant Games free-of-charge with advertise funding. This means that even if you do not consent to receive personalised advertising, you will still see ads in Facebook Instant Games, but they will not be personalised, i.e., they will not be tailored to your personal interests. We have a legitimate interest in displaying advertisements in our Facebook Instant Games in order to generate revenue and thereby offer our games to you for free. There is also no indication apparent that your interest in not receiving advertising through Facebook Audience Network is prevailing when you voluntarily play our Facebook Instant Games for free. The associated data processing is therefore justified in accordance with Art. 6 (1) (f) GDPR.

4. The data processed within the Facebook Audience Network can be transferred to Facebook servers, which are also located in the United States. We have concluded the standard data protection clauses adopted by the EU Commission with Facebook for transferring data by the Facebook Audience Network, having included the implementation of appropriate protective measures. Facebook and we also regularly review the need for possible additions and, if necessary, the implementation of additional appropriate protection measures within the meaning of Article 44 et seq. GDPR, to the extent as this is necessary to continuously grant a suitable level of data protection.

Usage analysis via Firebase

1. The Instant Game implements functions of the Firebase service, which is provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google").

2. Data on the general use of the Instant Game are collected and evaluated via the Firebase service (so-called Google Analytics for Firebase). For these purposes, information on whether and how you use certain parts of the Facebook Instant Games is collected together with the IP address, a hash of your Facebook Instant Game ID and other technical data on your device and the configurations assigned to it (hereinafter "Device-Related Data"), such as the manufacturer and model of the device, the language setting and the advertising ID as well as the country from which you use the Instant Game. At no time will personal data from your player profile, such as your username and Facebook Instant Game ID, be transmitted to Google in clear text.
   Google evaluates such data on our behalf and compiles aggregated reports for us. We use these reports to gain insight into the general use of the Instant Game, in order to use this information to improve the content and functions of the Instant Game and, in particular, to eliminate existing errors and problems. In addition to this we also get access to the in-game activity of individual users through Google, based on an anonymized user-id. Nevertheless, it is not relevant for MesApp which User used the respective Instant Game and to what extent. It is therefore not a matter of creating user profiles for MesApp but rather of providing functional Instant Games through the analysis of aggregated reports from Google. Google may also transfer these data to servers operated by Google LLC in the USA and analyse them there. However, in member states of the European Union or in other states that are party to the Agreement on the European Economic Area your IP address will be shortened and thus made anonymous before it is transmitted to a Google server in the USA.

3. Google also processes the aforementioned data collected via the Firebase service to the extent covered by its own privacy policy which you can find at https://policies.google.com/privacy. There you will also find additional information on Google's handling of personal data.

4. We would like to point out that the transmission of data to servers in the USA used by Google LLC may involve additional risks, for instance the enforcement of your rights to these data may be more difficult. In order to counter these risks, we have concluded the standard data protection clauses by the EU Commission with Google LLC for this data transfer and also stipulated appropriate protective measures therein, which, depending on the need for protection of the data, also include data encryption and can be improved in accordance with the legal and technical conditions for appropriate protection of the data. If data is transferred to Google LLC in the USA, such transfer is based on Article 46 (2) lit. c) GDPR.

5. We only use Firebase for the data analysing purposes described above, if you consent to it via your Facebook settings. In these cases, the legal basis for the processing of your data is Article 6 (1) sentence 1 lit. a) GDPR. You may revoke an already granted consent for data processing at any time with effect for the future. We have further concluded a data processing agreement with Google in accordance with Article 28 GDPR on data processing in the context of error analysis. Accordingly, Google will only process the data collected in this context in accordance with our instructions for this purpose. This forwarding of data to Google is therefore based on Article 28 GDPR.

Storage period and erasure of data

1. We process your personal data as long as it is necessary to achieve the purposes of the processing, or is prescribed by a legal obligation to store the data. Subsequently, the data is deleted in accordance with statutory laws.

2. Data that we store for legal reasons, however, is stored for as long as this is required by law. After expiry of a statutory retention period, the data will be deleted without undue delay, unless there are other reasons within the meaning of Art. 17 (3) GDPR opposing the deletion.

Data security

MesApp has taken appropriate technical and organisational measures to protect personal data against accidental loss, damage, unauthorised access or unauthorised changes. In particular, MesApp will transmit data only in encrypted form. However, MesApp points out that privacy and data security cannot be guaranteed for transmissions outside MesApp's sphere of influence.

Security Incident Management

1.Security Incident Response. ConchGame will maintain a security incident response plan for monitoring, detecting, and handling possible security incidents affecting Covered Data. The security incident response plan at least includes definitions of roles and responsibility, communication, and post-mortem reviews, including root cause analysis and remediation plans.

2.Monitoring. ConchGame will monitor for any security breaches and malicious activity affecting Covered Data.

Access Lifecycle Management Standard

1. Purpose

• 1.1 This standard provides detailed guidance and requirements for securely managing the access account lifecycle for personnel accessing Information Systems.

2.Scope and Applicability

• 2.1. Scope

  • 2.1.1 All Information Systems are in scope for this standard.

• 2.2. Applicability

  • 2.2.1 All personnel are required to comply with this policy

3.Roles & Responsibilities