Privacy Policy

1. Contact us

If you have any questions or suggestions about this policy, or would like to exercise your rights, please email us: [email protected].

To ask us to delete your data, email our customer care team at [email protected] and tell us which app your request is about (see section 14).

Data controller: PS Games Pty Ltd (PS Games P/L), ABN 74 608 950 894, 901/2 Newquay Promenade, Docklands VIC 3008, Australia.

2. General information on the processing of personal information

Using our apps and website may involve processing personal information (called “personal data” under the GDPR). This means any information about an identified or reasonably identifiable person. An IP address, a device or advertising identifier, or a player ID can be personal information. We collect information you give us (for example a display name, or an email you send us), information collected automatically when you use an app (for example device type, app version and identifiers), and information we receive from app stores and sign-in providers.

Australia. We only collect personal information that is reasonably necessary for our apps and website (APP 3). We use and disclose it for the purpose we collected it for, or a related purpose you would reasonably expect (APP 6). We take reasonable steps to protect it (APP 11). You can ask for access to it and for it to be corrected (APPs 12 and 13). Overseas disclosure (APP 8) is explained in section 4.

EU, EEA and UK. We process personal data only where the law allows it: with your consent (Art. 6(1)(a) GDPR); to perform a contract with you, such as providing an app feature you use, or to take steps at your request before entering into one (Art. 6(1)(b) GDPR); to comply with a legal obligation (Art. 6(1)(c) GDPR); or where it is necessary for our legitimate interests or those of a third party, unless your interests or fundamental rights and freedoms override them (Art. 6(1)(f) GDPR).

We do not sell personal information, and we do not make decisions about you based solely on automated processing that have legal or similarly significant effects.

3. How long we keep data

Unless a section below says otherwise, we keep personal information only as long as we need it for the purpose we collected it for, or to meet our contractual or legal obligations. Retention periods for each app are in sections 24 to 30. Where an app’s online records are not deleted automatically, we keep them until you ask us to delete them (section 14) or until we close that feature. Emails and support requests are kept in our mailbox for as long as we need them to deal with your request and keep our business records.

4. Service providers and overseas disclosure

We use the service providers below to run our apps and website. Where a provider processes data on our behalf (a “processor”), it may only use the data to provide its service to us, under a contract that requires appropriate technical and organisational security measures. Some providers, such as the app stores, Google Play Games and Apple Game Center, and OpenAI when you use your own API key, are independent of us and handle data under their own privacy policies. We note this in the table.

Overseas disclosure (APP 8). Most of these providers are outside Australia. We disclose personal information mainly to recipients in the United States (Google, Amazon Web Services, MongoDB, Supabase, AppLovin, Cloudflare and Apple). Some providers may also process it in Ireland, Germany and other EU countries (Apple, Meta, Exit Games) and in other countries where they operate data centres. Our website and customer-care mailboxes are hosted by Odoo in Australia. Before we disclose personal information overseas, we take reasonable steps to make sure the recipient handles it consistently with the APPs, for example through the provider’s data processing terms.

Transfers from the EU, EEA and UK. When personal data of people in the EU or EEA is transferred to the United States, we rely on the EU-US Data Privacy Framework (DPF), which the European Commission adopted in July 2023, for providers certified under it: Google LLC, Amazon Web Services, MongoDB, AppLovin Corporation and Cloudflare, Inc. For other transfers, including to Australia, we rely on the European Commission’s Standard Contractual Clauses, which also back up the DPF in providers’ terms (for example Supabase, and Google’s data processing terms). The UK Extension to the EU-US DPF and the Swiss-US DPF cover UK and Swiss users in the same way.

5. Data collection during downloading

When you download one of our apps, we do not send any information to the app store (Apple App Store or Google Play). To find out what data an app store collects and processes when you download an app, see its privacy policy. We have no control over the data the app stores collect. They are independent controllers of that data within the meaning of Article 4(7) GDPR.

6. App permissions

Our apps ask only for the device permissions their features need. Your device shows them before you install the app or when a feature first needs them. The permissions we use are:

• Internet and network state (all apps with online features): to connect to online play, ads and the other services in section 4.
• Advertising ID (our apps with ads: Hong Kong Style Mahjong, Hong Kong Style Mahjong 3D, Sudoku Challenge and Showdown Poker): to show and measure ads, as explained in section 16. On iOS, Hong Kong Style Mahjong asks for permission to track through Apple’s App Tracking Transparency prompt, and we only access your advertising identifier (IDFA) if you allow it.
• Billing (Hong Kong Style Mahjong and Hong Kong Style Mahjong 3D): for in-app purchases.
• Notifications (Hong Kong Style Mahjong 3D, and earlier versions of Showdown Poker): to send you game notifications, if you allow them.
• Microphone (UnRecorded): to record meetings you choose to record. Recording only happens while you are recording in the app.
• Approximate location (Hong Kong Style Mahjong on Android): this permission is listed in the app, but the app never asks you for it and does not use your location, so your device does not grant it. We will remove it in a future update.

The legal basis for technically necessary permissions is Art. 6(1)(b) GDPR. For optional permissions it is your consent, which you give through your device’s permission prompt (Art. 6(1)(a) GDPR).

On iOS, you can see and change what our apps can access at any time in the Settings app. On Android, go to Settings > Apps, choose the app, and select Permissions.

7. Contacting us and support

You can contact us by email, through the contact page, live chat or support ticket portal on our website, or with an app’s “report a problem” option. We use what you send us (your name, email address, message and any attachments) only to reply to you and to fix problems.

In Hong Kong Style Mahjong, “report a problem” opens your own email app with a message to [email protected]. The message includes a screenshot of the game, the game log, the app version, your device model and operating system version, and your game settings. You can review or remove any of this before you send it.

Our mailboxes, live chat and support tickets are hosted by Odoo S.A. (section 4). The legal basis is Art. 6(1)(b) GDPR where your message relates to an app you use, and otherwise our legitimate interest in answering you (Art. 6(1)(f) GDPR).

8. Sign-in and player identities

Most of our apps do not ask you to create an account with a password. Depending on the app:

• Anonymous sign-in (Hong Kong Style Mahjong, Chessmith): Firebase Authentication signs you in without an email or password and gives you a random ID.
• Google Play Games (Hong Kong Style Mahjong, Hong Kong Style Mahjong 3D and Sudoku Challenge on Android): if you sign in, Google gives the app your Play Games player ID and gamer name for achievements and leaderboards. Hong Kong Style Mahjong also uses your gamer name as your online display name and uses your player ID to back up your progress (section 25).
• Apple Game Center (Hong Kong Style Mahjong and Hong Kong Style Mahjong 3D on iOS): used for leaderboards and achievements.
• Sign in with Google (Silicon Schism on Android) and Sign in with Apple (Silicon Schism on iOS): we receive your account identifier, your email address and whether it is verified, and (from Google) your name. We use them to create and secure your pilot account (section 26).
• Email and password (Hong Kong Style Mahjong 3D): you can create an account with your email address, a password and a display name, managed by Firebase Authentication (section 30).
• Username and password, or guest (Showdown Poker): you can register with a username, your name, email address and a password, or play as a guest identified by your device. Accounts created with Facebook Login in earlier versions keep working (section 29).

The legal basis is Art. 6(1)(b) GDPR. You can stop using sign-in at any time and ask us to delete your data (section 14).

9. Facebook and social sharing

Our current apps do not include the Facebook SDK and do not offer Facebook Login (“Facebook Connect”) for new sign-ins. Showdown Poker accounts that were created with Facebook Login in earlier versions of the app still hold the Facebook user ID, name and profile picture link we received at the time (section 29).

Hong Kong Style Mahjong for iOS lets you share a post using your device’s built-in sharing feature. What you share, and with whom, is up to you and the service you share to. Hong Kong Style Mahjong for Android can open our Facebook page inside the app. Meta handles your data on that page under its own privacy policy (section 15).

10. Online play and leaderboards

Some of our games have online play and leaderboards: Hong Kong Style Mahjong, Hong Kong Style Mahjong 3D, Chessmith, Silicon Schism and Showdown Poker. To run these features we process a player ID, your display name, your online status, the moves and state of online games, results and scores, and your IP address, which is needed to connect your device to the game server. Other players can see your display name and, where the game has one, your leaderboard entry. Each app’s section (24 to 30) sets out exactly what is shared and who can see it. The legal basis is Art. 6(1)(b) GDPR.

11. In-app purchases and paid apps

You can play our games without giving us your contact or payment details. In-app purchases, such as Remove Ads in Hong Kong Style Mahjong ($2.99) and coin packs and Remove Ads in Hong Kong Style Mahjong 3D, and paid app downloads, such as Silicon Schism on the App Store, are processed entirely by Google Play or the Apple App Store. They collect your payment details under their own terms and privacy policies. We never see your card or bank details.

We receive only the information needed to deliver and restore what you bought: the product, an order or transaction ID or purchase token, and the purchase status. On Android, Hong Kong Style Mahjong also checks whether our older paid version of the app is installed on your device, and if it is, removes ads at no charge. The legal basis is Art. 6(1)(b) GDPR. Refunds are handled by the app store.

12. Technical logs

When you use our online features or website, our servers and those of our service providers (Google Firebase, Odoo, Cloudflare, Exit Games, and our game server on Amazon Web Services, see section 4) automatically record technical information, such as your IP address, the time of the request, the request itself, and device or browser information. We use these logs only for technical administration, troubleshooting and security. This is our legitimate interest (Art. 6(1)(f) GDPR). Providers delete their logs according to their own retention periods. On our own game server, web access logs are kept for about 10 days. Other application and system logs on that server do not yet have a fixed retention period.

13. Security and fraud prevention

We take reasonable steps to protect personal information from misuse, loss and unauthorised access (APP 11). For example, Hong Kong Style Mahjong, Chessmith and Silicon Schism connect to our services over encrypted connections, our Firebase databases only accept requests from signed-in app users, and Showdown Poker passwords are stored only as salted hashes. We do not use third-party fraud-detection or attribution services other than Google’s conversion measurement (section 16). Our advertising partners (Google and AppLovin) may use ad data to detect invalid traffic and ad fraud under their own policies. The legal basis is our legitimate interest in keeping our apps secure (Art. 6(1)(f) GDPR).

14. Deleting your data

You can ask us to delete the personal information we hold about you for any of our apps. Email [email protected] with the subject “Data deletion request”. Please tell us which app your request is about, and include the details we need to find your data, such as your display name or player ID, or for Silicon Schism, Showdown Poker and Hong Kong Style Mahjong 3D the email address or username you sign in with. You can use these links, which fill in the subject for you:

• Data deletion request – Hong Kong Style Mahjong
• Data deletion request – Chessmith
• Data deletion request – Silicon Schism
• Data deletion request – Sudoku Challenge
• Data deletion request – UnRecorded
• Data deletion request – Showdown Poker
• Data deletion request – Hong Kong Style Mahjong 3D

We will respond within 30 days. If we can’t match your request to any data from the details you give, we will ask for more. We may also ask you to confirm the request comes from you. We will delete the data we hold on our servers and with our processors, such as online game records, leaderboard entries, sign-in records and progress backups, unless we need to keep something by law. Copies in server backups may remain for a limited period until those backups are replaced.

Some data is not held by us. Data stored only on your device is deleted when you delete it in the app or uninstall the app. For data held by Google Play Games, Apple Game Center, the app stores, or OpenAI (if you used your own API key), contact that provider. To stop ad personalisation, see section 18.

15. Our Facebook page

We run a Facebook business page for Hong Kong Style Mahjong (facebook.com/hksmahjong). When you visit it, Meta Platforms Ireland Limited processes your data under its own privacy policy (facebook.com/privacy/policy). Meta gives us anonymised statistics about how people use the page (Page Insights), and for that processing Meta and we are joint controllers under Art. 26 GDPR (facebook.com/legal/terms/information_about_page_insights_data); Meta is responsible for handling your rights requests about it. Our legitimate interest is understanding how the page is used and improving it (Art. 6(1)(f) GDPR). We cannot link Page Insights to an individual profile. If you message us through the page, we use your message only to answer you.

16. Advertising in our apps

Some of our free apps show ads, which keeps them free to play. They use Google AdMob (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA): Hong Kong Style Mahjong (Android and iOS), Hong Kong Style Mahjong 3D, Sudoku Challenge (Android) and Showdown Poker. On Android, Hong Kong Style Mahjong also lets AppLovin Corporation bid to show ads through AdMob (mediation). Chessmith, Silicon Schism and UnRecorded show no ads.

To show ads, measure them and prevent ad fraud, AdMob and its partners process your device’s advertising ID, your IP address, information about your device and the app, and your interactions with ads. Ads can be personalised (based on your interests) or non-personalised (based on context, such as the app you are using). Google and AppLovin act as independent controllers for their own use of this data. See how Google uses it at policies.google.com/technologies/partner-sites.

Consent. In the EEA, the UK and Switzerland, Hong Kong Style Mahjong for Android asks for your consent through Google’s consent message before ads are shown. Sudoku Challenge and Hong Kong Style Mahjong for iOS do not yet show this message; we are adding it in an upcoming update. On iOS, ads are only personalised using your IDFA if you allow tracking in Apple’s App Tracking Transparency prompt.

Measuring our ad campaigns. From time to time we run Google Ads app campaigns to promote our apps. To measure them, Google Analytics for Firebase in Hong Kong Style Mahjong and Hong Kong Style Mahjong 3D shares conversion events, such as the first time you open the app or make an in-app purchase, with Google Ads, together with the app-instance ID and, where permitted, the advertising ID. On iOS, Hong Kong Style Mahjong also uses Google’s on-device conversion measurement. This currently applies to all users; the legal basis is our legitimate interest in measuring our advertising (Art. 6(1)(f) GDPR).

In the EEA, the UK and Switzerland, Hong Kong Style Mahjong for Android relies on your consent for personalised ads (Art. 6(1)(a) GDPR), which you can withdraw at any time (section 18). Sudoku Challenge and Hong Kong Style Mahjong for iOS do not yet show Google’s consent message, and we have not yet confirmed that Mahjong 3D and Showdown Poker show it before ads, so in those apps we do not currently ask for that consent. Until we add it, you can limit personalised ads through your device settings: on Android, delete or reset your advertising ID in your device’s ads settings; on iPhone and iPad, do not allow tracking in Apple’s App Tracking Transparency prompt, or turn off “Allow Apps to Request to Track” in Settings. Conversion measurement for our ad campaigns currently applies to all users (section 16).

The legal basis for non-personalised ads is our legitimate interest in funding free apps (Art. 6(1)(f) GDPR). Buying Remove Ads in Hong Kong Style Mahjong or Hong Kong Style Mahjong 3D turns off ads in that app. We no longer use Unity Ads or the Facebook Audience Network.

17. Google Firebase

We use Google Firebase, a platform from Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA), to run the online features of Hong Kong Style Mahjong, Hong Kong Style Mahjong 3D and Chessmith. We use Firebase Realtime Database for online games, online status, leaderboards and progress backup, Firebase Authentication for sign-in, Cloud Functions to clean up old online games, and Firebase Hosting for Hong Kong Style Mahjong invite links. Hong Kong Style Mahjong 3D also uses Remote Config, Cloud Storage, App Check (which checks with Google Play that requests come from a genuine copy of the app) and Cloud Messaging. Our Realtime Databases and Cloud Functions are located in Google’s us-central1 region in the United States. Google processes this data on our behalf. Details for each app are in sections 24, 25 and 30.

Google Analytics for Firebase is used in Hong Kong Style Mahjong and Hong Kong Style Mahjong 3D. It records how the app is used, such as the first time it is opened, sign-ins, scores, purchases, use of features like the Mahjong Coach, and the app version. It uses an app-instance ID and, where permitted, the advertising ID. Chessmith, Silicon Schism, Sudoku Challenge, UnRecorded and Showdown Poker do not use Firebase Analytics. None of our apps uses Firebase Crashlytics. Our Firebase projects are linked to AdMob and Google Ads so that we can measure ads and campaigns (section 16); only pseudonymous identifiers are used for this.

Consent. Google Analytics for Firebase collects this usage data for all users. The legal basis is our legitimate interest in improving our apps (Art. 6(1)(f) GDPR). We are adding a consent setting for analytics in the EEA, the UK and Switzerland in an upcoming update.

The legal basis for Firebase services that run app features is Art. 6(1)(b) GDPR. Google LLC is certified under the EU-US Data Privacy Framework (section 4). Google’s privacy policy is at policies.google.com/privacy, and Firebase privacy information is at firebase.google.com/support/privacy.

18. Your advertising choices

You can limit or turn off personalised ads at any time:

Android

1. Open Settings, then Google (or the separate Google Settings app on some devices).
2. Tap Ads (on some devices, All services > Ads).
3. Tap Delete advertising ID or Reset advertising ID. On older versions of Android, turn on Opt out of Ads Personalisation.

iOS

1. Open Settings.
2. Tap Privacy & Security, then Tracking, and turn off tracking for our app (or turn off Allow Apps to Request to Track).
3. You can also turn off Personalised Ads under Privacy & Security > Apple Advertising.

In the EEA, the UK and Switzerland you can change your consent choice in Hong Kong Style Mahjong for Android by clearing the app’s storage (Settings > Apps > Hong Kong Style Mahjong > Storage > Clear storage) or reinstalling the app; the consent message is then shown again. You can also manage how Google personalises ads at myadcenter.google.com.

19. The right to object

If you are in the EU, EEA or UK, you have the right under Art. 21 GDPR to object, at any time and on grounds relating to your situation, to processing based on Art. 6(1)(e) or (f) GDPR. We will then stop that processing unless we have compelling legitimate grounds that override your interests, or we need it to establish, exercise or defend legal claims. To object, email [email protected].

20. Your rights

Everyone. Under the Australian Privacy Principles you can ask us for access to the personal information we hold about you (APP 12) and ask us to correct it (APP 13). You can also make a complaint (section 23).

People in the EU, EEA and UK also have these rights under the GDPR and UK GDPR:

• Access to your personal data and information about how we process it (Art. 15).
• Correction of inaccurate data (Art. 16).
• Erasure of your data (Art. 17). See section 14 for how to ask.
• Restriction of processing (Art. 18).
• Portability: receiving the data you gave us in a structured, commonly used, machine-readable format, and having it sent to another controller (Art. 20).
• Objection to processing based on legitimate interests (Art. 21, see section 19).
• Withdrawal of consent at any time, without affecting processing that took place before you withdrew it (Art. 7(3)).
• Complaint to your local data protection supervisory authority (Art. 77, see section 23).

To exercise your rights, email [email protected]. For deletion, use [email protected] (section 14). Please tell us which app your request is about. We respond within 30 days. We may need to confirm who you are before we act on a request.

21. Children’s privacy

Our apps are made for a general audience and are not directed to children under 13. We do not knowingly collect personal information from children under 13, including for the purposes of the US Children’s Online Privacy Protection Act (COPPA). If you are a parent or guardian and believe your child has given us personal information, email [email protected], tell us which app it relates to, and we will delete it.

22. Privacy contact and postal address

Our privacy contact is Paul Vella, who can be reached at [email protected]. You can also write to us at:

PS Games Pty Ltd (PS Games P/L)
Attn: Privacy
901/2 Newquay Promenade
Docklands VIC 3008
Australia

ABN 74 608 950 894.

23. Complaints

If you have a complaint about how we handle your personal information, please contact us first at [email protected]. We will respond within 30 days.

If you are not satisfied with our response, you can complain to the Office of the Australian Information Commissioner (OAIC): www.oaic.gov.au, phone 1300 363 992.

If you are in the EU, EEA or UK, you also have the right to lodge a complaint with the data protection supervisory authority where you live or work, or where you believe an infringement took place (Art. 77 GDPR). In the UK this is the Information Commissioner’s Office (ico.org.uk).