1. COMMITMENT TO DATA PROTECTION
Meridian Interactive Pte. Ltd. ("Meridian," "the Company," "we," "us," or "our"), a Singaporebased interactive entertainment company with a place of business at 60 PAYA LEBAR ROAD #0416 PAYA LEBAR SQUARE SINGAPORE 409051, is committed to protecting the privacy and security of our users ("User," "you," or "your").
This Privacy Policy describes our practices with respect to the collection, use, disclosure, and retention of information processed in connection with our casual games, mobile software, and digital platforms (collectively, the "Services"). We operate in compliance with the Singapore Personal Data Protection Act 2012 (PDPA) and other applicable global privacy laws and frameworks. By accessing or using the Services, you consent to the processing of your information as set forth in this Privacy Policy.
2. SAFEGUARDING MINORS AND VULNERABLE USERS
Meridian recognizes the unique privacy risks facing younger users in the digital environment.
2.1 AgeGating and Compliance
• Our Services are designed for a general audience but include casual gaming content that may appeal to minors. We do not knowingly solicit or collect personal information from children under the age of 13. We comply strictly with the Children's Online Privacy Protection Act (COPPA) and similar applicable laws in other jurisdictions.
2.2 Parental Oversight and Rights
• We encourage parents and legal guardians to monitor and participate in their children's online activities. If you are a parent or guardian and believe your child has provided us with personal information without your consent, we will work with you to address the matter. Parents may:
• Review any information collected from their child;
• Request the immediate deletion of such information;
• Withdraw consent for any future collection of information relating to the minor.
2.3 Preventive Data Deletion
• If Meridian becomes aware that personal data has been collected from a child under 13 without verifiable parental consent, we will conduct an internal "Data Purge" to remove such records from our production systems and cease all further processing associated with that account.
3. CATEGORIES OF DATA PROCESSED
To maintain the functionality and competitive integrity of our casual games, we process the following categories of information:
3.1 Voluntarily Submitted Data
• Registration Information: Usernames, email addresses, and age verification details provided during account creation.
• Support Interactions: Information submitted when contacting [email protected], including records of issues and technical inquiries.
• Promotional and Survey Data: Information provided when entering contests or responding to player surveys.
3.2 Automatically Collected Technical Data (Device Identifiers)
• As you use the Services, we automatically collect technical information from your device, including:
• Unique Device Identifiers: International Mobile Equipment Identity (IMEI), Media Access Control (MAC) address, and Android ID.
• Advertising Identifiers: Resettable identifiers such as Apple's Identifier for Advertisers (IDFA) and Google Advertising ID (GAID).
• Device and System Information: Operating system version, device model, battery status, and screen resolution.
• Network Information: IP addresses and associated coarse geolocation data.
3.3 ThirdParty Integration Data
• If you use social login features (e.g., Apple, Google, or Facebook), we receive certain profile information as permitted by your privacy settings with those thirdparty providers.
4. TRANSPARENCY REGARDING DEVICE IDENTIFIERS (IMEI/MAC)
Meridian uses hardwarelevel identifiers to maintain a secure and consistent gaming experience.
4.1 Purpose and Necessity
• We collect IMEI and MAC addresses for the following technical and operational purposes:
• AntiCheat and Fair Play: To detect and prevent unauthorized multiaccounting, botting, and script use that distorts casual game mechanics.
• Game Progress Preservation: To bind game progress, high scores, and ingame utility items to a specific physical device, preserving data across app updates and temporary uninstalls.
• Security and Fraud Prevention: To distinguish legitimate users from automated malicious actors and protect our systems from DDoS attacks.
• Hardware Optimization: To use aggregated device data to improve game performance and stability across different hardware configurations.
4.2 Data Retention for Identifiers
• We maintain a strict data retention policy for hardware identifiers:
• Active Use: Identifiers remain associated with your user profile for as long as your account is active.
• Inactivity Period: If an account is inactive for 24 consecutive months, we will disassociate IMEI/MAC addresses from the user profile, making such data anonymized and no longer personally identifiable.
• Legal Requirements: We may retain identifiers for longer periods as required by ongoing legal investigations or Singapore statutory obligations.
4.3 OptOut and Limitation Rights
• Hardware Identifiers (IMEI/MAC): These are systemlevel identifiers essential for fraud prevention and progress saving. You may not opt out of their collection while continuing to use the Services. If you do not consent to the collection of IMEI or MAC addresses, you must not install or must immediately uninstall our applications.
• Advertising Identifiers (IDFA/GAID): These are usercontrollable. You may opt out of targeted advertising tracking by enabling "Limit Ad Tracking" (iOS) or "Optout of InterestBased Ads" (Android) in your device settings.
5. USER DATA CONTROL AND ACCOUNT MANAGEMENT
Meridian provides users with tools to manage their data and digital presence.
5.1 Permanent Account Deletion
• You may terminate your relationship with Meridian and request deletion of your data by:
• Using the "Delete My Account" option in the ingame settings menu; or
• Submitting a formal deletion request to [email protected].
• Effect of Deletion: Upon successful deletion, your account, game progress, and all associated ingame utility items will be permanently removed. This action is irreversible.
5.2 Withdrawal of Consent
• Under the PDPA, you may withdraw your consent to specific data processing activities (e.g., marketing communications) at any time. You may do so by adjusting your inapp settings or contacting our Data Protection Office.
5.3 Uninstallation
• Uninstalling the application will stop any future data collection from your device but does not automatically delete historical data stored on our servers. We recommend using the Account Deletion tool (Section 5.1) before uninstalling if you wish to have your data deleted.
6. LEGAL BASES FOR DATA PROCESSING
• We process your information based on the following legal grounds:
• Contractual Necessity: To provide the game features you request and manage your virtual items.
• Legitimate Interests: To secure our network and maintain fairness within our gaming community.
• Legal Compliance: To comply with obligations under Singapore law, including tax reporting and antimoney laundering requirements.
• Consent: For optional activities such as sending newsletters or processing precise geolocation data.
7. DATA DISCLOSURE AND SHARING
Meridian does not sell your personal information. We share information only with the following categories of recipients:
7.1 Authorized Service Providers
• We engage thirdparty service providers that assist in operating the Services, including:
• Cloud infrastructure providers (e.g., Google Cloud, AWS) for secure data storage;
• Analytics providers (e.g., Adjust, Firebase) to measure and improve game performance;
• Payment processors (App Store, Google Play) to handle transactions.
7.2 Legal and Regulatory Disclosures
• We may disclose your information to Singapore or international law enforcement or regulatory authorities if we have a goodfaith belief that disclosure is necessary to:
• Comply with a court order, subpoena, or other legal requirement;
• Protect the safety and rights of Meridian, our users, or the public;
• Prevent or investigate fraud, illegal activity, or a security incident.
7.3 Corporate Transactions
• In the event of a merger, divestiture, restructuring, or sale of assets, your information may be transferred as part of the transaction, subject to the same privacy protections set forth in this Privacy Policy.
8. INTERNATIONAL DATA TRANSFERS AND PDPA COMPLIANCE
• As a Singaporebased company, your data may be stored on servers located outside your country of residence. We ensure that international transfers of personal data comply with standards at least equivalent to those under the Singapore PDPA. We use Standard Contractual Clauses and strong encryption to protect your data during transmission and storage.
9. DATA SECURITY MEASURES
• We maintain a comprehensive information security program designed to protect your information from unauthorized access, use, disclosure, or loss. Our safeguards include:
• Encryption: AES256 encryption for data at rest and TLS encryption for data in transit;
• Access Controls: Strict leastprivilege access policies for our personnel;
• Security Monitoring: Regular security audits and penetration testing of our game servers.
10. USER RIGHTS UNDER PDPA AND GDPR
• Depending on your jurisdiction of residence, you may exercise the following rights:
• Access & Data Portability: Request a copy of your personal data in a structured, commonly used format;
• Correction: Request correction of inaccurate personal data;
• Objection & Restriction: Object to or restrict certain processing activities, such as marketing profiling;
• Erasure: Request deletion of data that is no longer necessary for its original purpose.
• To exercise these rights, contact our Data Protection Officer at [email protected].
11. DATA RETENTION PERIODS
• We retain personal information only for as long as necessary to fulfill the purposes for which it was collected or as required by applicable law:
• Account Data: Retained for the active life of the account;
• Transaction Records: Retained for up to 5 years to comply with Singapore tax laws;
• Anonymized Analytics: May be retained indefinitely, as such data is no longer personally identifiable.
12. CHANGES TO THIS PRIVACY POLICY
• Meridian may update this Privacy Policy periodically to reflect changes in our practices, technology, or legal requirements. We will notify you of material changes by:
• Posting the revised policy on our website;
• Displaying an ingame notice or popup;
• Updating the "Last Updated" date at the top of this policy.
13. CONTACT INFORMATION AND DISPUTE RESOLUTION
• If you have questions about this Privacy Policy or our data handling practices, or wish to submit a privacy complaint, please contact us:
• Meridian Interactive Pte. Ltd.
• 60 PAYA LEBAR ROAD #0416PAYA LEBAR SQUARE SINGAPORE 409051
• Email: [email protected]