Multi Tech Apps

1. SUMMARY

Multi Tech Apps is a game development studio of Sotec Consulting SL. Multi Tech Apps is committed to making sure that kids’ privacy is safeguarded and we aim to comply with all (privacy) regulations worldwide, like the Children’s Online Privacy Protection Act (COPPA) in the US.If you want to know what data is collected by our apps and how this is handled, please review this policy. If you have any questions or concerns, send us an email via admon@socem.com, we are here to help.

OUR APPS

Multi Tech Apps offers apps for learning and leisure purposes for children. Our portfolio includes one title:

Drawely: Draw Color Cute Girls - bundle id: com.drawely.drawely

When using the apps we produce for parents and children (the “Games”) our company and its subsidiaries (together “COMPANY” or “We”) may collect information including usage data. When adults or parents visit http://www.appsmultitech.com// (the “Website”), we may also collect information on the usage of our website for adults and parents. This data collection is discussed in greater detail below.

If you are accessing the Games or Website from within the European Union (EU) or are an EU citizen, please review the Lawful Bases for Processing Personal Data and Individual Rights sections below for more information on how your personal data will be processed and the rights you have regarding this processing.

Information collected through our Games Information Collected Automatically By:

Multi Tech Apps: Most of our apps note your IP address and use this to determine the country the device is located. The IP address is not stored on our systems, but we keep track of the country our app is functioning in. This information cannot be connected to a unique device and is never shared with third parties.

Firebase is an attribution tool that lets us know which sites, apps or platforms users of some of our apps may come from. This specific tool is only used in relation to adult users of our apps or sections of our apps targeted at adults (such as subscription purchase areas).

For more information on Firebase, please see their privacy policy here: privacy policy

Unity Analytics: Unity technologies makes the software engine for some of our Games. It collects analytical information to better understand your use of our Games and to improve them for you. Unity does not share any personal information with other third parties. Unity will use the collected information only in anonymized form for their own products.

For more information on Unity please see the privacy policy here, and for more information on the exact data collected you can refer to the appendix below.

Adjust is an attribution tool that lets us know which sites, apps or platforms users of some of our apps come from. This specific tool is only used in relation to adult users of our apps or adult sections of our apps (such as subscription areas).

For more information on ADJUST please see their privacy policy here.

2. INFORMATION PROVIDED THROUGH OUR GAMES

Child users do not have the ability to provide any personal information when using the Games beyond what is collected automatically (as noted above). Adult users can use the Support link within the adult/parent area of the app to access the customer support features on the Website. If you submit a support ticket on our Website, you must provide an email address and may provide your name. We do not require you to provide your full name to contact us.

3. HOW YOUR INFORMATION IS USED

We use the information collected through our Games and Websites for getting a better understanding of their use and the preferences of our visitors. We do not use this information for any other purpose or make it available to any other party (beyond those disclosed above), unless in order to comply with a legal obligation to do so (e.g. court order) or in case the ownership of the information changes due to a merger, acquisition or restructuring involving Multi Tech Apps.

4. HOW YOUR INFORMATION IS SHARED

Any personal information automatically collected by us is used solely to improve our service and we do not provide this information to any third party (beyond those disclosed above), unless in order to comply with a legal obligation to do so (e.g. court order) or in case the ownership of the information changes due to a merger, acquisition or restructuring involving Multi Tech Apps.

Information that is collected on our Websites by scripts from Google will also be available to Google. Multi Tech Apps, has no control over the collection or usage of this information by Google and does not accept any liability for the same. However, we believe that the collection and usage of information by Google is compliant with relevant regulations. According to the disclosures of Google they will use this information as follows:

According to the best of our knowledge Google uses the information collected to provide us with a better understanding of the use of our Websites and of the preferences of our visitors. Google will also use the information collected to personalize advertisements that are shown to you while surfing the web or while using Google services. Please refer to http://www.google.com/policies/privacy/ and more specifically here: https://support.google.com/adwordspolicy/answer/143465?hl=en&rd=1 for more information. You can also opt-out using the following Google tool: Google Analytics opt-out browser add-on (https://tools.google.com/dlpage/gaoptout/). Click here to opt-out of Google Analytics.

5. LAWFUL BASES OF PERSONAL DATA

If you are an individual in the European Union (EU) or an EU citizen, we collect and process data about you only where we have legal bases for doing so under applicable EU laws. This means we collect and process your data only when:

Where we rely on your consent to process your personal data, you have the right to withdraw or decline consent at any time. If you wish to withdraw your consent, please contact us using the information in the Contacts for Individual Rights Requests section. Some examples of our legitimate interests and the data being processed include:

Network and information security (IP address, Device ID)
Customer Support and fraud prevention (name, email address)
Improving our products and services (hardware information, activity logs)

Where we rely on our legitimate interests to process your personal data, you have the right to object. More information on exercising this right can be found in the Individual Rights section below.

We do not collect any other information

When you download and use our Games, or surf our Websites, we don’t require you to provide any information and we don’t collect any personal information, except general information explained above, including unique device identifiers and cookies (as specified above) to anonymously identify your computer or device so we can deliver a better experience. We do not share such information with third parties.

We do not knowingly contact or collect personal information from children under 16. If you believe we have inadvertently collected such information, please contact us so we can remove the information.

6. INDIVIDUAL RIGHTS

Multi Tech Apps makes certain choices available to you when it comes to your personal data. Please review the below information outlining your choices and how to exercise them. We will respond to all requests within a reasonable timeframe. If our full response will ever take more than a month due to complexity or scope, we will notify you of this and keep you updated.

Review and update your data: You have the right to access and update any personal data that we have collected. To review the data that we have and update it as required, please submit a request using the contact information at the end of this section. We may request more information to confirm your identity before releasing or modifying any personal data.

Delete your data: You also have the right to have your personal data deleted. This is sometimes known as the ‘right to be forgotten’. To request that we delete all personal data about you, please submit a request using the contact information at the end of this section. We may request more information to confirm your identity before deleting any personal data.

After you delete your personal data from our services, we may not immediately delete residual copies from our active servers and may not immediately remove data from our backup systems for archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so. We may also decline to honor this request in certain specific situations, such as if the data is necessary to comply with a legal obligation or to exercise/defend a legal claim.

Restrict Processing: You have the right to restrict how we process your personal data in certain circumstances. This is an alternative to requesting the deletion of your data. Rather than requesting we delete all your personal data, you may request that we limit our uses of your personal data to specific purposes. You may wish to request we restrict our processing if you contest the accuracy of your personal data and we are working to verify this information, or if you want us to retain your personal data in connection to a legal claim but cease processing it.

Data Portability: You have the right to obtain copies of your information in a structured, commonly used format that you can move your data between our service and the services of others. We may request more information to confirm your identity before providing any personal data.

Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or when our processing of your data is based on legitimate interests You may request that we stop processing your personal data for direct marketing purposes. This is an absolute right and we cannot refuse this request. Beyond direct marketing, if you wish to exercise this right, you must give specific reasons why you object to our processing of your data, based on your particular situation. Even after receiving such a request, we may continue processing if it is necessary for the exercise/defense of a legal claim or if we can demonstrate a compelling legitimate ground for the processing.

If any request made under this section is clearly unfounded or excessive, we may reject the request or require a reasonable fee to honor the request. If we decide to reject your request, we will inform you of the reasons for not taking action and provide information on other possible remedies. If we decide that a reasonable fee is necessary, we will promptly inform you and will comply with the request upon receipt of this fee.

Contact for Individual Rights Requests

Email: support@appsmultitech.com

Physical Mail: Avda. Brasil, 17 8F - 28080 - Madrid

If you are an EU citizen or reside in the EU and wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority.

Data Retention

Multi Tech Apps may retain users’ data for the following purposes:

To develop new features and improve the Games and Website;
To support subsequent customer service inquiries;
To improve the safety and security of the Games and Website; or
Comply with our legal obligations.

We will retain your information for as long as is reasonably necessary in relation to the purposes for which this data was collected. In many instances, we will retain your data while it is necessary for your use of the Games or Website, which may include maintaining this information beyond when you cease using the Games or Website.

Updates to this Privacy Policy

This privacy policy was last updated on the date that appears at the top of this document. Our privacy policy may change from time to time, and we explicitly reserve our right to do so. If we make any material changes to our policies, we will place a prominent notice on our website or application. We will obtain prior parental consent if any changes we make to this Policy affect users under the age of 13 in a way that requires such consent under COPPA.

7. APPENDIX

Multi Tech Apps collects the following information through our Games:

IP Address (the internet address the Game uses to connect to the Internet; this information is used to know which country the device is in, and is not stored by Mixpanel);
Unique Device Identifier (a unique number that lets us tell the devices apart);
Device type (e.g. iPad Pro, Galaxy S10, etc.);
OS version (type of operating system and the version thereof);
Game version (specific Game(s) and the versions thereof); and
Length of play session.

Unity collects the following information through our Games:

Unique device identifier generated from the device MAC/IMEI/MEID (which is immediately converted into a different number using a one-way hash);
A number identifying the app that is running;
Country of installation (mapped from IP address, which is not retained);
Build version (Unity version);
Device manufacturer and model;
Operating system and version running on your system or device;
Browser type;
Language;
The make of the CPU, and other technical information on the CPU;
A number indicating if the app is in debug modus;
The DPI (screen pixel density);
Graphics card type, vendor name and other technical specifications of the graphics card;
Graphics card driver name and version (example: “nv4disp.dll 6.10.93.71″);
Graphics API in use (example: “OpenGL 2.1″ or “Direct3D 9.0c”);
Amount of system and video RAM present;
Current screen resolution;
Version of the Unity Player;
Version of the Unity Editor used to create the content;
Sensor flags (e.g. device support for gyroscope, touch pressure etc.)
A checksum of all the data that gets sent to verify that it did transmit correctly;
A timestamp of when the data was received (collected from server);
Unique device ID and AD ID; and
Application or bundle identification of the game installed.

Information that is collected through our Games by Unity will be available to Unity and is shared by Unity in de-identified and/or aggregated form with certain third parties. We have explicitly indicated to Unity that our products are aimed at children under 13 (which means Unity is aware that the handling of information should be COPPA compliant).