Midasbuy

Privacy Policy


Last modified: 31 May, 2021

Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.

Here is a summary of the information contained in this privacy policy ("Privacy Policy"). This summary is to help you navigate the Privacy Policy and it is not a substitute for reading everything! You can use the hyperlinks below to jump directly to particular sections.

What information do we need to provide the Service?

If you register an account to use the Service then we will need some information from you to set this up. If you choose to set up your profile using a social media account, we also collect information including email, profile picture and nickname from that social media account. If you need to get in touch with us, we will retain some information so that we can get back in touch with you and address any concerns. We will also process some information when you use the Service (e.g., to facilitate your transactions). More Information.

How will we use your information?

We use your information to provide the many functions and services that comprise the Service. We also use your information for account verification, security purposes and to support and improve the Service. We do not share your information with any third parties, except where we need to in order to provide the Service (e.g., use local cloud providers or to back up your data; use our affiliates around the world to help us to deliver the Service), or where we are instructed to by a court, authority or compelled by law. More Information.

Who do we share your information with?

We use some third parties to help us deliver the best possible experience (e.g., cloud services to back up your data and support services). When we use a third party, we only do this to process or store your information for the purposes described in this Privacy Policy. We also have affiliates around the world who help us deliver the Service and we may be required by a court or legal obligation to disclose certain information in some circumstances. More Information.

Where do we process your information?

Our servers are located in Hong Kong and the People’s Republic of China (for the purpose of this Privacy Policy, this term excludes Hong Kong, Taiwan and Macau) ("PRC"). Your information can be accessed from outside of where you live by our support, engineering and other teams around the world, including Singapore, Hong Kong and the PRC. More Information.

How long do we keep hold of your information?

We generally retain your information for the period during which you use the Service (or have credits which may be used to purchase virtual goods and items ("Game Credits")) after which time your data is deleted (as further described in this Privacy Policy), unless otherwise required by applicable laws. More Information.

How can I exercise my rights over my information?

Depending on where you are, you may have certain rights with respect to your information, such as rights of access, to receive a copy of your data, or to delete your data or restrict or object to our processing of your data. More Information.

How to get in touch with us

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, please contact us here.

How will we notify you of changes?

Changes to this Privacy Policy will be posted here. Please check this page frequently to see if there are any updates or changes to this Privacy Policy. More Information.

Contact Information

Data Controller: High Morale Developments Limited | Email: Privacy@midasbuy.com

EU Representative: Tencent International Service Europe B.V. | Email: eudataprotection@tencent.com

Turkey Data Controller Representative: Özdağıstanli Ekici Avukatlık Ortaklığı | Email: tencent@iptech-legal.com (Özdağıstanli Ekici Avukatlık Ortaklığı is our data controller representative and its authority is limited to the authorities stipulated under the Law on Protection of Personal Data w. no 6698. Özdağıstanli Ekici Avukatlık Ortaklığı is not authorised for any other matters such as Service conduct, bans, investigations, civil or criminal complaints.

Korea Representative: Tencent Korea Yuhan Hoesa | Email: Privacy@midasbuy.com


Welcome to Midasbuy !

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with the Midasbuy service including the website for Midasbuy (the "Service"), and sets out your choices and rights in relation to that information. Please read it carefully – it is important for you to understand how we collect and use your information, and how you can control it.

If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop using the Service. By using the Service you are acknowledging our rules regarding your personal information as described in this Privacy Policy.


The Service is operated by High Morale Developments Limited ("we", "our" and "us").

For the purpose of data protection laws, the data controller of your personal information in relation to the Service is High Morale Developments Limited. The registered address of High Morale Developments Limited is 29 Floor, Three Pacific Place, 1 Queen’s Road East Wanchai, Hong Kong.

Our representative in the EU for the purpose of EU data protection laws is Tencent International Service Europe B.V., which is a Dutch company within the Tencent group. The registered address of Tencent International Service Europe B.V. is 26.04, Gustav Mahlerplein 2, 1082 MA, Amsterdam, the Netherlands. Our representative in the EU can be contacted at eudataprotection@tencent.com.

Our data protection officer can be contacted at Privacy@midasbuy.com.

Our representatives for data protection purposes in certain jurisdictions are as follows:

Jurisdiction

Representative

Address

Contact details

EU

Tencent International Service Europe B.V.

Gustav Mahlerplein 2, 1082 MA, Amsterdam, the Netherlands

eudataprotection@tencent.com

Korea

Tencent Korea Yuhan Hoesa

152, Taeheran-ro, Gangnam-gu(Gangnam Finance Center, Yeoksam-dong), Seoul, Korea

Privacy@midasbuy.com

Turkey

Özdağıstanli Ekici Avukatlık Ortaklığı.

Varyap Meridian Grand Tower ABlok Al Zambak Sok No: 2 K: 32 D. 270 Ataşehir Istanbul Turkey

tencent@iptech-legal.com


Please reach out to us if you have any questions or concerns regarding the processing of your personal information. You can contact us anytime at Privacy@midasbuy.com.

  1. Scope of Privacy Policy

This Privacy Policy covers the treatment of personal data gathered when you are using or accessing the Service. This Privacy Policy also covers our treatment of any personal data that the operators of our games ("Game Operators") share with us or that we share with the Game Operators.

This Privacy Policy does not apply to the activities of Game Operators or other third parties that we do not own or control, including but not limited to any third party websites, services and applications ("Third Party Websites") that you elect to access in connection with the Service. While we attempt to facilitate access only to those Third Party Websites that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third Party Websites.

You may be able to sign up for or access the Service through a separate platform operated by a Game Operator. When you submit personal data to us via a Game Operator, your use of that platform is also governed by the Game Operator's policies and procedures. Please review each Game Operator's governing policies before using their services.

  1. The Types of Personal Information We Use

This section describes the different types of personal information we collect from you and how we collect it. If you would like to know more about specific types of data and how we use that data, please see the section entitled "How We Use Your Personal Information" below.

The following is a high-level summary of the types of personal information we use:

  1. Information you provide to us (either directly or through a third party)
  1. Information about you generated as part of the Service

We automatically collect certain data from you when you use the Service, namely:


  1. Information relating to any purchases you make on the Midasbuy platform
  1. Cookies

We use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) ("Cookies") to enhance your experience using the Service. Cookies are small files which, when placed on your device, enable us to provide certain features and functionalities.

You have the option to permit installation of such Cookies or subsequently disable them. You may accept all Cookies, or instruct the device or web browser to provide notice at the time of installation of Cookies, or refuse to accept all Cookies by adjusting the relevant Cookie retention function in your device. However, in the event of your refusal to install Cookies, the Service may be unable to operate as designed.

For more information about our Cookies policy, click here.

  1. Children

Children must not use the Service for any purpose, except where their parent or guardian has provided consent (to the extent this option is available in your jurisdiction).

By children, we mean users under the age of 18 years old; or in the case of a country where the minimum age for processing personal information differs, such different age. For users located in certain countries we have listed the relevant minimum age in the table below.


Country in which the user is located

Minimum age of the user

Algeria

19

Australia

18

Bangladesh

18

Brazil

18

Cambodia

18

Canada

13

Colombia

18

Egypt

18

European Economic Area / United Kingdom / Switzerland

16

Hong Kong

18

India

18

Indonesia

21

Japan

20

Kingdom of Saudi Arabia

15

Kuwait

21

Macau

18

Malaysia

18

Mexico

18

Morocco

18

Myanmar

18

New Zealand

16

Philippines

18

Qatar

18

Republic of Korea

14

Russia

14

Singapore

18

South Africa

18

Taiwan

20

Thailand

20

Tunisia

18

Turkey

18

United Arab Emirates

21

United States

16

Vietnam

16


We do not knowingly collect personal information from children under these ages for any purpose. If you believe that we have personal information of a child under these ages without parental/guardian consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us at Privacy@midasbuy.com and we will delete such information.

  1. How We Use Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why. For users who live in the United Kingdom, the European Economic Area, Switzerland, or Turkey (each a "Relevant Jurisdiction"), it also identifies the legal basis under which we process your data.

Personal Information

Use

Legal Basis (only relevant if you are located in a Relevant Jurisdiction)

Information you provide to us (either directly or through a third party)

User Information: date of birth (not stored), name, username, email address and Facebook nickname and profile picture.

If you connect to the Service through a Game Operator or Third Party Website, then we will also collect the details provided by that third party such as the referring website.

We use this information to facilitate your purchase in Midasbuy in accordance with your request.

Necessary to perform our contract with you to provide the Service.

Transaction Data: bank, invoice information such as billing address, email address, credit card type, phone number, account holder information e.g. account name, user name, Midasbuy registration date, number of successful orders in past three months, whether the card number was manually inputted and pasted, game ID, login method, IP address, device fingerprint (which includes information like time zone, browser information, CPU class, platform you used i.e. iOS, android or web), card details and shipping information, your payment information provided to us bythird party payment processors. (purchase payment date, merchant transaction ID).

We use this information to detect fraudulent activity and verify transactions.

It is in our legitimate interest to ensure the integrity of the Service and that your details are not being used fraudulently.

Support Information: If you contact us, we will process the email address you used for communications as well as any other personal information you choose to include in your email to us.

We use this information to facilitate our handling of your support request.

It is necessary for us to use this information to perform our contract with you to provide the Service.

Sweepstakes Participation Information: name, country, player ID, email address, phone number, payment method

If you participate in a sweepstakes event, we use this information to send you your prize and provide you with a rebate or top-up if you win.

We collect this information with your consent.

Information about you generated as part of the Service

Browser and Device Information: details of your browser version, operating system version, country, RFID tag, IP address, open ID, internet connection, page loading time, type of mobile or computing device, date and time stamps of actions, number of visits, time using the Midasbuy platform, networks, flow through the Midasbuy platform or referral source, and player ID.

We use this information to facilitate your purchase in Midasbuy in accordance with your request.

It is necessary for us to use this information to perform our contract with you to provide the Service.

In-game status information: If you have made a purchase using our Service, a Yes or No confirmation of whether you are active in-game in the country in which your online payment account is from.

We use this information to detect fraudulent activity and verify transactions.

It is in our legitimate interest to ensure the integrity of the Service and that your details are not being used fraudulently.

Mobile device fingerprint data (a digital signature that does not collect any biometric data): your device fingerprint, time of creation, time zone, device OS information and browser type, platform information, QQ login state, node, screen size and font, audio fingerprint, battery status, domain, adblock.

We use this information for fraud verification purposes.

It is in our legitimate interest to ensure the integrity of the Service and that your details are not being used fraudulently.

Information relating to any purchases you make on the Midasbuy platform

Purchase Information: items purchased and their cost, the time, date and currency of the purchase, order ID, open ID, player ID, country, game account balance and purchase history.

If you pay with paytm, we will collect your email address.

If you pay with tpay, we collect your telephone number.

If you pay with your bank card, we will collect the card number, the expiry date, the card holder's name and the billing address.

We use this information to facilitate your purchase in Midasbuy in accordance with your request and provide access to your transaction history.

It is necessary for us to use this information to perform our contract with you to provide the Service.

  1. How We Store and Share Your Personal Information

The Tencent group operates around the world. Pursuant to our contract with you to provide you with the Service, your personal information will be processed on servers that may not be located where you live. No matter where our servers are located, we take appropriate measures to safeguard your rights in accordance with this Privacy Policy. Our servers are located in:

In addition, your information can be accessed from outside of where you live by our support, engineering and other teams around the world, including Singapore, Hong Kong and the PRC.

Only where necessary will we share your personal information with third parties. Situations where this occur are:

  1. The Security of Your Personal Information

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted through the Service or otherwise via the Internet; any transmission is at your own risk.

  1. Data Retention

We do not keep your data for longer than is necessary unless we are required to do so under law. For further details on how long we keep your data, please refer to the time periods set out below.

Personal Information Retention Policy
User Information (other than date of birth which we do not store), Browser and Device Information, In-game status information, Purchase Information, Support Information, Transaction Data

We generally store this data for the lifetime of your use of the Service (i.e. until account deletion in accordance with your request) and then delete it within 30 days.

However, we retain transaction data (which includes your name and user ID as well as bank details) for 160 days from the date of the last transaction involving the credit card. We do this even where you request that we delete your account because this is in line with our legal obligations and is also necessary to ensure that we can perform our contract with you.

Where you do not request account deletion, the data will be retained for one year after each applicable Game is closed, before it is deleted.

Sweepstakes Participation Information Stored for the duration of the sweepstakes event and then deleted within 10 days.
Device Fingerprint Data Retained for up to one week after collection for verification purposes and deleted thereafter.

If we are required to retain your information beyond the retention periods set out above, for example to comply with applicable laws, we will store it separately from other types of personal information.

  1. Your Rights

Some jurisdictions’ laws grant specific rights to users of the Service, which are set out in this section.

This section entitled "Your Rights" applies to users that are located in the Relevant Jurisdictions.

The sub-sections entitled "Access", "Correction" and "Erasure" also apply to users that are located in Brazil, Canada, India, Russia and South Africa.

The sub-sections entitled "Access" and "Correction" also apply to users that are located in Singapore. Additionally, the sub-sections titled "Access", "Correction", "Erasure" and "Objection" also apply to users that are located in the Philippines.

The sub-section entitled "Advertising" also apply to users that are located in Hong Kong, Macau, Japan, Malaysia, Singapore, Korea, Thailand, United States, Canada, Australia, New Zealand, Brazil, Cambodia, Egypt, India, Indonesia, Laos, Mexico, Morocco, Myanmar, Philippines, Russia, Taiwan, Turkey, UAE, Saudi Arabia and Vietnam.

You have certain rights in relation to the personal information we hold about you, depending on where you are located. Some of these only apply in certain circumstances (as set out in more detail below). We must respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). To exercise any of your rights, please contact us at Privacy@midasbuy.com.

Access

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 account. If you believe we hold any other personal information about you, please contact us at Privacy@midasbuy.com.

Portability

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., sweepstakes participation information) or pursuant to our contract with you (e.g., user name), as described above in the section " How We Use Your Personal Information". 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, with certain exceptions. We will provide further information to you about this if you make such a request.

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 (for example, where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).

Correction

You have the right to correct any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your Service account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at Privacy@midasbuy.com.

Erasure

You can delete your account, or remove certain personal information, by logging into your Service account. If there is any other personal information you believe we process that you would like us to erase, please contact us at Privacy@midasbuy.com.

We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, 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 Service 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 (for example, 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.

Objection

You have the right to object to our processing of your personal information. We will consider your request in other circumstances as detailed below; you may submit your request by contacting us at Privacy@midasbuy.com.

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 at Privacy@midasbuy.com. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service. Announcements

We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend access to the 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.

Advertising

Where you have given us consent to do so we may also use your data to provide you with information about goods and services which may be of interest to you. Where you have given us consent to do so we may also transfer your personal data to third parties (namely our service providers, business partners and other companies in our group) who may provide you with information about their goods and services that may be of interest to you. If you do not want us to use your data in this way, please tick the relevant box situated on the form or page on which we collect your data. You can also opt-out of receiving future marketing communications from us at any time by following the directions contained in the e-mail to unsubscribe, or by contacting us at Privacy@midasbuy.com.

The categories of marketing subjects for which we propose to use your personal data (name, email address and phone number) are as follows: social media services, gaming services, financial services, internet security services, media content and entertainment services.

  1. Contact & Complaints

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to: Privacy@midasbuy.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 Privacy@midasbuy.com 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.

  1. Changes

If we make any changes to this Privacy Policy, we will post the updated Privacy Policy here. Please check this page frequently to see if there are any updates or changes to this Privacy Policy.

  1. Language

Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version of this privacy policy, the English version shall prevail.






SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

Some jurisdictions’ laws contain additional terms for users of the Service, which are set out in this section.

If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our Privacy Policy above.


Algeria


By using this Service, you give us your consent for the collection, storage, treatment and use of your personal information, and transfer of your personal information to a third party (e.g. local cloud providers to back up your data or our affiliates around the world to help us deliver the Service) located in Hong Kong, Singapore, the PRC and the United States (as described in the Privacy Policy) where it is manually and electronically treated.


Australia

Overseas Recipients


We take reasonable steps to ensure that third party recipients of your personal information located outside Australia handle your personal information in a manner that is consistent with Australian privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients.

Access

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 account. If you believe we hold any other personal information about you, please contact us at Privacy@midasbuy.com.

Correction


You have the right to correct any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your Service account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at Privacy@midasbuy.com.


Children


If you are under the age of 18, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Service.

Transacting Anonymously


Where practicable, we will give you the option of not identifying yourself or using a pseudonym when registering an account on or using the Service. You acknowledge that if you do not provide us with your personal information, we may be unable to provide you with access to certain features or sections of the Service, including social media integration and In-Service purchases.


Your Rights


If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the Australian Information Commissioner (Telephone: +61 1300 363 992 or email enquiries@oaic.gov.au ).


Data Transfers


While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, you acknowledge and agree that we cannot control the actions of third party recipients and so cannot guarantee that they will comply with those privacy laws.

Bangladesh

Agreement


By accepting this Privacy Policy, you expressly state that you authorise us to collect, use, store, and process your personal data, including disclosing to third parties, to the extent provided by this Privacy Policy. By clicking "accept", you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to Singapore, Hong Kong and the PRC.

Age Restriction


In order to use the Service, you represent that you are at least 18 years old and, therefore, legally capable of entering into binding contracts.

Brazil

This section applies to users located in Brazil:


Language


This Privacy Policy is provided in Portuguese for users located in Brazil. In case of dispute, the Portuguese version of this Privacy Policy shall prevail.


Consent Revocation


Whenever we use your personal information based on your consent, you may revoke the consent that you have previously given for the collection, use and disclosure of your personal information, subject to contractual or legal limitations. To revoke such consent, you may terminate your account or you can contact Privacy@midasbuy.com. This may affect our provision of the Service to you.


Parental and Guardian Consent


If you are under the age of 18, you should not use the Service for any purpose without first obtaining parental/guardian agreement to this Privacy Policy (both for themselves and on your behalf). We do not knowingly collect personal information from any children under the age of 18 without such consent. Please contact our Data Protection Officer if you believe we have any personal information from any children under the age of 18 without such parental/guardian consent – we will promptly investigate (and remove) such personal information.


BY ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY STATE THAT YOU AUTHORISE US TO COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL INFORMATION, INCLUDING, DISCLOSING TO THIRD PARTIES, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY.

California

This section applies to California residents covered by the California Consumer Privacy Act of 2018 ("CCPA").


Collection and Disclosure of Personal Information

Over the past 12 months, we have collected and disclosed the following categories of personal information from or about you or your device:

We collect your personal information for the following purposes:


For additional information about what each type of personal information is used for, see Section 5 (" How We Use Your Personal Information") in the main portion of the Privacy Policy.


We disclose personal information to the following types of entities:


In the past 12 months, we have not sold Personal Information of California residents within the meaning of "sold" in the CCPA.

Rights under the CCPA:

If you are a California resident, you have the right to:


We aim to fulfil all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.


How to Exercise Your Rights

First, you may wish to log into your account and manage your data from there. If you are a California resident to whom the CCPA applies, you may also exercise your rights, if any, regarding other data by contacting us at Privacy@midasbuy.com.

Canada

If you are located in Canada and wish to obtain written information about our policies and practices with respect to our service providers located outside Canada, you may contact us at Privacy@midasbuy.com. Our privacy experts who monitor this email address are also able to answer any questions users may have about the collection, use, disclosure or storage of personal information by our service providers.


Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any purpose other than as provided in this Privacy Policy.

Colombia

Language

This Privacy Policy is provided in Spanish for users located in Colombia. In case of dispute, the Spanish version of this Privacy Policy shall prevail.

How We Use Your Personal Information

From the entry into force of this Privacy Policy, at the time of the collection of your personal data, we will request your prior authorization, by informing you about the specific purposes of the processing of your personal data for which such consent is obtained under the Privacy Policy.


Your authorization may be expressed (i) by writing, (ii) orally or (iii) through unequivocal conducts that allow us to reasonably conclude that your authorization was granted, such as the act of accepting the Privacy Policy. We may keep evidence of said authorizations, while respecting the principles of confidentiality and privacy of information.


Your Rights

As a data subject you have certain rights, including (i) to access, update and rectify your personal data; (ii) to request a copy of the consent you have given us; (iii) to be informed about how we have processed your personal data; (iv) to file claims before your country’s data protection authority; (v) to revoke the consent you have given us to process your personal data, unless the processing is based on compelling legitimate grounds or is needed for legal reasons; (vi) to ask for the suppression of your personal data (right to erasure); and (vii) to freely access your information.


You can contact us if you want to exercise any of these rights through our contact information in the section "Contact & Complaints" of this Privacy Policy.


Proceedings For The Exercise Of Your Rights


Queries (rights to access): You can file queries regarding the processing of your personal data by us. Queries will be attended to within a maximum term of ten (10) business days from the date of receipt. When it is not possible to attend the query within the said term, you will be informed of the reasons for the delay and we will indicate the date on which the consultation will be attended to, which may, in no case, exceed five (5) business days following the expiration of the first term.


Claims (right to correction and erasure): You have the right to file claims in relation to the processing of your personal data by clearly describing the facts that give rise to your claim. The term to attend to the claim will be fifteen (15) business days from the date of receipt. When it is not possible to attend to the claim within the said term, you will be informed of the reasons for the delay and the date on which the claim will be handled, which may, in no case, exceed eight (8) business days following the expiration of the first term.

Egypt

This Privacy Policy is provided in Arabic for users located in Egypt. In case of dispute, the Arabic version of this Privacy Policy shall prevail.


By clicking "accept" or by proceeding with the sign up process, you acknowledge that you have read, understood, and consented to this Privacy Policy. If you do not consent to this Privacy Policy, you must not use the Service.


You are acknowledging your consent to the processing, storage, and cross-border transfer of your personal data. The cross border transfer may be to any country in which we have databases or affiliates, in particular Singapore, Hong Kong and the PRC.


You also acknowledge your consent to receiving marketing messages from us, whether through e-mails or pop-ups or other such means.


If you are a new user, you have seven days to inform us of any objection you may have to this Privacy Policy.


As an Egyptian data subject, you have certain rights under the Egyptian Personal Data Protection Law.


France

Your Rights


Instructions for the processing of your personal data after your death


You have the right to provide us with general or specific instructions for the retention, deletion, and communication of your personal data after your death.


The specific instructions are only valid for the processing activities mentioned therein and the processing of these instructions is subject to your specific consent.


You may amend or revoke your instructions at any time.


You may designate a person responsible for the implementation of your instructions. This person will be informed of your instructions in the event of your death, and be entitled to request their implementation from us. In the absence of designation or, unless otherwise provided for, in the event of the death of the designated person, their heirs will have the right to be informed of your instructions and to request their implementation from us.


When you wish to make such instructions, please contact us at Privacy@midasbuy.com.

Hong Kong

As a Hong Kong data subject you have legal rights in relation to the personal information we hold about you (to the extent permitted under applicable laws and regulations).

You are entitled to make a subject access request to receive a copy of the data we process about you, to make a data correction request as well as have a right to object to the use of your personal data for direct marketing purposes. A fee may be chargeable by us for complying with a data access request.

India


Age Restrictions


Parental consent is required for children under the age of 18 years to use the Service.


Sensitive Personal Information

Sensitive Personal Information under local law includes passwords, financial information (such as bank account, credit card, debit card or other payment instrument details), biometric data, physical or mental health, sex life or sexual orientation, and/ or medical records or history, but does not include information available in the public domain, or provided under Indian laws, including the Right to Information Act, 2005.


Sharing Of Your Sensitive Personal Information

Where we permit any third parties to collect and use Sensitive Personal Information, we shall use reasonable measures to ensure that the third parties do not further disclose the Sensitive Personal Information to the extent required by applicable laws.


Withdrawal Of Consent

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 at Privacy@midasbuy.com. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service.


Indonesia

Consent

By accepting and consenting to this Privacy Policy, you agree that we may collect, use and share your personal information in accordance with this Privacy Policy, as revised from time to time. If you do not agree to this Privacy Policy, you must not access or use our Service and we have the right to not provide you with access to our Service.

Parental and Guardian Consent

If you are under the age of 21, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Service.

Data Subject Rights

You have the right to access your personal information stored in our Service from time to time in accordance with applicable data privacy laws and regulations in Indonesia.

Data Breach

In the event we fail to maintain the confidentiality of your personal information in the Service, we will notify you through the contact information provided by you or via the Service, to the extent required by local laws and regulations.

Data Retention

We will retain your personal information in line with legal requirements.

Notification to Amendment of this Privacy Policy

If you fail to explicitly express your objection to any amended version of this Privacy Policy within fourteen (14) days of the date the relevant amended version of this Privacy Policy is made available, you will be considered as having accepted the changes and agreed to the new Privacy Policy. However, you may stop using or accessing our Service by unsubscribing or ceasing your use of the Service at any time, if you cease to agree with the amended Privacy Policy.

Data Accuracy and Third Party Consent

You are responsible for making sure that any personal details which you provide to us are accurate and current. In order to confirm the accuracy of the information, we may also verify the information provided to us, at any time. You hereby represent that you have secured all necessary consent(s) before providing us with any other person’s personal information (for example, for referral promotions), in which case we will always assume that you have already obtained prior consent, and as such, you will be responsible for any claims whatsoever from any party arising as a result of the absence of such consent(s).

Japan

Minimum Age

If you are under the age of 20, you must obtain your parent’s or legal guardian’s consent to register an account on and use the Service.

Consent to transfer to third parties

By clicking "accept", you consent to the transfer of your personal information to third parties, which may include the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to Singapore, Hong Kong and the PRC.


Your Rights


You may request us to notify you about the purposes of use of, to disclose, to make any correction to, to discontinue the use or provision of, and/or to delete any and all of your personal information which is stored by us, to the extent provided by the Act on the Protection of Personal Information of Japan. When you wish to make such requests, please contact us at Privacy@midasbuy.com.

Kingdom of Saudi Arabia

You consent to the collection, use, disclosure, export and storage of your personal information as described in this Privacy Policy including (without limitation) for the purposes of showing you advertising or marketing information about goods and services which may be of interest to you.

Kuwait

You represent that you are at least 21 years old, or 18 years old and have obtained parental/guardian consent and, therefore, legally capable of contracting under the applicable laws and regulations in Kuwait.

By accepting this Privacy Policy, you expressly state that you authorise us to collect, use, store, and process your personal data and to disclose this data to third parties whether inside or outside of Kuwait, in line with the provisions of this Privacy Policy.

Macau SAR

You have the right not to provide your personal information. However, as a result, we may not be able to provide the Service to you. As a Macau SAR data subject you have legal rights in relation to your personal information (to the extent permitted under applicable laws and regulations). You are entitled to make a subject access request to request a copy of the data we process about you, to make a data correction request, and have the right to oppose the use of your personal information for marketing or any other form of commercial prospecting, or on any grounds of personal nature. A fee may be chargeable by us for complying with a data access request.

Malaysia

Language


In the event of any discrepancy or inconsistency between the English version and Bahasa Melayu version of this Privacy Policy, the English version shall prevail.

Parental and Guardian Consent

If you are under the age of 18, please do not use the Service.

In the event you are agreeing to this Privacy Policy in order for a minor to access and use the Service, you hereby consent to the provision of personal information of the minor to be processed in accordance with this Privacy Policy and you personally accept and agree to be bound by the terms in this Privacy Policy. Further, you hereby agree to take responsibility for the actions of such minor, and that minor’s compliance with this Privacy Policy.

Your Rights

Right of access: You have the right to request access to and obtain a copy of your personal information that we have collected and is being processed by or on behalf of us. We reserve the right to impose a fee for providing access to your personal information in the amounts as permitted under law.

When handling a data access request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data access request.

Right of correction: You may request for the correction of your personal information. When handling a data correction request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data correction request.

Right to limit processing of your personal information: You may request to limit the processing of your personal information by using the contact details provided above. However this may affect our provision of the Service to you.

Contact

To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.

Mexico

Language

This Privacy Policy is provided in Spanish for users located in Mexico. In case of dispute, the Spanish version of this Privacy Policy shall prevail.

Age Restrictions

You won’t be able to use the Service unless you are 18 years old or you have obtained parental/guardian agreement to this Privacy Policy (both for themselves and on your behalf).

Types of Personal Information We Use

For clarification purposes, in section 2 "The Types of Personal Information We Use" and section 5 "How We Use Your Personal Information" you can find full details about the personal data we use. Therefore, we are providing you with complete information about the personal data we use, in terms of the Federal Law on Protection of Personal Data held by Private Parties and other applicable regulations.

Purposes of Processing

Some of the purposes of processing stated above are for voluntary purposes, including to show you recommendations and advertising. We may also use your personal data for the voluntary purpose of sending information to your email that we may consider relevant to you. You may object to the processing of your personal data for voluntary purposes as stated in the section "Your Rights" below.

Please be informed that we may also use your personal data to comply with legal obligations or requests from competent authorities, assert or defend our rights before the competent authorities / courts, respond to requests you send us in relation to your personal data and to carry out the transfer of personal data detailed in section 6 "How We Store and Share Your Personal Information".

Data Transfer Consent

In general, we do not require your consent to carry out the transfers detailed in section 6 "How We Store and Share Your Personal Information". However, we require your consent to transfer your personal data to a third party that acquires all or substantially all of us or our business.

By using the Service and providing us with your personal data, you agree to the data transfers detailed above that require your consent. You may exercise your rights in connection with your personal data as stated in the section "Your Rights" below.

Your Rights

The sub-sections entitled "Access", "Correction", "Erasure", "Objection", "Restriction of Processing to Storage Only ", which includes the limitation to the use and disclosure of your personal data, and "Advertising" included in the section "Your Rights" above also apply to users that are located in Mexico.

You also have the right to revoke the consent that you have provided us to process your personal data.

To exercise any of your rights, contact our Data Protection Officer at Privacy@midasbuy.com.

To know more about your rights, as well as the applicable means, procedures and requirements to exercise any of your rights, please contact our Data Protection Officer at Privacy@midasbuy.com.

Cookies

Through the use of cookies, we collect certain information related to your browsing and device, some of which may be considered personal data. You may be able to refuse or disable cookies by adjusting your browser settings. Because each browser is different, you should consult the instructions provided by your browser. If you choose to refuse, disable, or delete cookies, some of the functionalities of the Service may no longer be available to you. For more information about our use of cookies and how to disable them, please visit our Cookie policy.

Morocco

The protection of your privacy is an important principle for us. We collect information for purposes strictly necessary for the proper use of the Service.


By accepting these conditions of use, you explicitly accept that your personal data may be subject to processing by the Service.


Kindly note:


New Zealand

This section applies to users located in New Zealand:

Overseas Recipients

We take reasonable steps to ensure that third party recipients of your personal information located outside New Zealand handle your personal information in a manner that is consistent with New Zealand privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients.

Access

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 account. If you believe we hold any other personal information about you, please contact us at Privacy@midasbuy.com.

Correction

You have the right to request the correction of any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at Privacy@midasbuy.com.

Children

If you are under the age of 16, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Service.

Your Rights

If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the New Zealand Privacy Commissioner (www.privacy.org.nz).

Data Transfers

While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, you acknowledge and agree that we cannot control the actions of third party recipients and so cannot guarantee that they will comply with those privacy laws.

Peru

Transfers and delegation of personal information occur as set out in this Privacy Policy and the section "Republic of Korea".

You may exercise rights related to the protection of personal information by requesting access to your personal information or the correction, deletion or suspension of processing of your personal information, etc. pursuant to applicable laws such as the Personal Data Protection Law (the "Law").

You may also exercise these rights through your legal guardian or someone who has been authorised by you to exercise the right. However, in this case, you must submit a power of attorney to us in accordance with the Law.

Upon your request, we will take necessary measures without delay in accordance with applicable laws such as the Law.

You can also withdraw your consent or demand a suspension of the personal information processing at any time.

If you consider that your request has not been met you may file a claim with the Peruvian National Authority of Personal Data Protection.

Contact

To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.


Philippines

Minimum Age

You must be at least 18 years of age to be able to use the Service.

Your Rights

You are entitled to the following rights:


Consent

By consenting to this Privacy Policy, you consent to us:

Qatar

If you are using the Service in Qatar, you consent (for the purposes of Law No. 13 of 2016 on the Protection of Personal Data, as may be amended from time to time) to the processing of your information in accordance with this Privacy Policy.

Republic of Korea

How We Store and Share Your Personal Information


Provision of personal information to third parties

We provide your personal information to third parties as described below:

Name of Recipient (and contact information) Types of Personal Information provided Purpose of Use by Recipient Period of Retention and Use by Recipient

Adyen N.V.

( dpo@adyen.com)

Transaction data including payment information, payment date, merchant transaction ID, Midasbuy account registration email.


If a user has made a purchase using Midasbuy: a Yes or No confirmation of whether user is active in-game in the country in which user’s online payment account is from.

To detect fraudulent activity and transactions. For the data retention period specified under"Data Retention"

Delegation of Processing

For the performance of the services detailed in this Privacy Policy, we delegate the processing of your personal information to the following professional service providers:

Delegatee Description of Delegated Services
腾讯云计算(北京)有限责任公司 / Tencent Cloud Computing (Beijing) Co., Ltd. Data processor: Processes and stores data on behalf of the data controller

Overseas Transfer of Personal Information

We transfer personal information to third parties overseas as follows:

Recipient (Contact Information of Information Manager) Country to which Your Personal Information is to be Transferred Date and Method of Transfer Types of Your Personal Information to be Transferred Purposes of Use by Recipients Period of Retention of Use by Recipient
腾讯云计算(北京)有限责任公司 / Tencent Cloud Computing (Beijing) Co., Ltd. ( dataprivacy@tencent.com ) PRC, Hong Kong Transmitted from time to time All personal information collected Storage of personal information For the data retention period specified under "Data Retention"

Data Destruction

Personal information is retained in accordance with the data retention periods as detailed in section 8 "Data Retention". With the exception of the personal information set out below, personal information, which has fulfilled the purpose for which it was collected or used, and has reached the period of time during which personal information was to be possessed, will be destroyed in an irreversible way. Personal information stored in electronic files will be deleted safely in an irreversible way by using technical methods, and printed information will be destroyed by shredding or incinerating such information.

Personal information required to be retained beyond the data retention periods as detailed in section 8 "Data Retention" are required to be retained pursuant to the following laws:


Act on the Consumer Protection in Electronic Commerce, Etc. Article 6 of the Act on the Consumer Protection in Electronic Commerce

In an electronic commerce or a mail-order sale:

  • Records regarding labelling and advertising (6 months)
  • Records regarding execution or withdrawal of a contract (5 years)
  • Records regarding the payment of a price and the supply of goods and services (5 years)
  • Records regarding customer services or dispute resolution (3 years)
Protection of Communications Secrets Act Article 41 of the Decree of the Act, Article 15-2 of the Protection of Communications Secrets Act
  • Log records, IP address (3 months)
  • The date of telecommunications by users, the time that the telecommunications start and end, the frequency of use (12 months)

Your Rights

You may exercise rights related to the protection of personal information by requesting access to your personal information or the correction, deletion or suspension of processing of your personal information, etc. pursuant to applicable laws such as the Personal Information Protection Act ("PIPA").

You may also exercise these rights through your legal guardian or someone who has been authorized by you to exercise the right. However, in this case, you must submit a power of attorney to us in accordance with the Enforcement Regulations of the PIPA.

Upon your request, we will take necessary measures without delay in accordance with applicable laws such as the PIPA.

You can also withdraw your consent or demand a suspension of the personal information processing at any time.

Additional Use and Provision of Personal Information

In accordance with the PIPA, we may use or provide personal information within the scope reasonably related to the initial purpose of the collection, in consideration of whether disadvantages have been caused to data subjects and whether necessary measures have been taken to secure such as encryption, etc. We will determine with due care whether to use or provide personal information in consideration of general circumstances including relevant laws and regulations such as the PIPA, purpose of use or provision of personal information, how personal information will be used or provided, items of personal information to be used or provided, matters to which data subjects provided consent or which were notified/disclosed to data subjects, impact on data subjects upon the use or provision, and measures taken to protect subject information. Specific considerations are as follows:


Domestic Privacy Representative

Pursuant to the Article 32-5 of Network Act and Article 39-11 of the amended PIPA, the information regarding the domestic agent is as follows:

Contact

To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.

Russia

If you are using the Service in Russia, by using the Service you consent to:


The sub-sections "Access", "Correction", "Erasure", "Restriction of Processing to Storage Only", "Objection" and "Advertising" of the section "Your Rights" above apply to users in the Russian Federation.

We will notify you of any material changes and may request you to acknowledge such changes. Unless we require your acknowledgment, you shall be deemed to have agreed to the changes if you continue using the Service after the notification.

As regards the representative for Russia, you can contact us at Privacy@midasbuy.com. Please include the word "Russia" in the subject line of your email.

Singapore

By clicking "accept", you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, Hong Kong and the PRC.

Access

You have the right to access your personal information, 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 account. If you believe we hold any other personal information about you, please contact us at Privacy@midasbuy.com.

Correction

You have the right to correct any of your personal information that is inaccurate. You can access the personal information we hold about you by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please contact Privacy@midasbuy.com.

Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted at Privacy@midasbuy.com.

South Africa

You have the right to lodge a complaint with the Information Regulator (South Africa) by emailing it at inforeg@justice.gov.za. The Information Regulator (South Africa)'s physical address is 33 Hoofd Street Forum III, 3rd Floor Braampark, Braamfontein, Johannesburg, South Africa.

Taiwan

We do not knowingly collect or solicit personal information from anyone under the age of 7 or knowingly allow such persons to register on the Midasbuy platform. If you are under 7 years of age, please do not attempt to use or register for our Service or send any personal information about yourself to us. No one under the age of 7 may provide any personal information to us while using the Service. In the case of users located in Taiwan, persons under the age of 20 are required to obtain parental/guardian consent prior to using the Service.

Thailand

By clicking "accept", you acknowledge that you have read, understood, and agree to this Privacy Policy. If you do not agree with this Privacy Policy, you must not use the Service.

You may request us to discontinue, to restrict the use or provision of, and/or to request for data portability of any and all of your personal information which is stored by us, to the extent provided by the applicable data privacy laws and regulations in Thailand, including the Thai Personal Data Protection Act. When you wish to make such requests, please contact us at Privacy@midasbuy.com.

We will give you notice by email of any material changes to this Privacy Policy, and give you an opportunity to reject such changes, failing which the changes will become effective as stated in the notice.

Turkey

Our Data Controller Representative in Turkey for the purpose of compliance with the Turkish Law on Personal Data Protection ("DPL") and its secondary regulations, Özdağıstanli Ekici Avukatlık Ortaklığı, can be contacted at Privacy@midasbuy.com. Please include the word "Turkey" in the subject line of your email.

You have legal rights, which are set forth in Article 11 of the DPL, in relation to the personal information we hold about you. As a Turkish data subject, you may have the right to apply to the data controller and (to the extent permitted under applicable laws and regulations):


United Arab Emirates

You consent to the collection, use, disclosure, transfer, export (to the extent permitted by applicable laws) and storage of your personal information, as described in the Privacy Policy, including (without limitation) for the purposes of showing you advertising or marketing information about goods and services which may be of interest to you.

We may voluntarily report a cyber-security incident where it constitutes a crime under UAE law (e.g. under the UAE Cybercrime Law). The incident can be reported to the relevant authorities for the purpose of investigations. Please note that voluntary reporting of a cyber-security incident can also be made to the UAE Computer Emergency Response Team ("CERT"). CERT is a security awareness organisation that provides a process for logging incidents and advising on known cyber-security threats in the UAE.

Vietnam

By accepting this Privacy Policy, you expressly agree and authorise us to collect, use, store, and process your personal information, including, lawfully disclosing and transferring it to third parties, as described in this Privacy Policy.

We maintain international standards and security practices for data protection. When your personal information is transferred within or outside your jurisdiction of residence, it will be subject to the same or higher levels of security practices and data protection by the recipient entity as adhered to by us.


Where we permit any third parties to collect and use your personal information, we shall take reasonable measures to ensure that the third parties do not further disclose the personal information.


Your personal information, if required to be disclosed to the law enforcement agencies, public authorities or other judicial bodies and organisations, will disclosed upon receipt of written request from such organisations.

Your Rights

You have the right to access, correct, and erase the personal information we hold about you. You also have the right to withdraw your earlier provided consent to collect, store, process, use and disclose your personal information and to request us to stop providing your personal information to a third party.