Privacy Policy

Welcome to Spunkey Monkey, our iOS and Android mobile applications (our “APP”). At we take the protection of your data very seriously, and in the below we explain what data we collect when you use our APP and services and how it is used.

General Information

What is Personal Information?

Personal Information is any information relating to personal or material circumstances that relates to an individual. This may include, a name, date of birth, e-mail address, postal address, or telephone number but also online identifiers such as IP addresses or device ID`s.

What is processing?

"Processing" means any operation or set of operations which is performed upon Personal Information, whether or not by automatic means. The term is broad and covers virtually any handling of data.

Who is responsible for data processing?

The responsible party for data processing is Mojoc (“Mojoc”, “we”, “us”, or “our”). If you have any questions or if you wish to exercise your rights, please contact us via email at info@mojoc.net.

What are the legal bases of processing?

As a responsible Company, we only process your Personal Information if at least one of the following applies:

For the fulfillment of contractual obligations
- The purposes of the data processing are primarily based on the service we provide.

Within the framework of our legitimate interests

Where necessary, we process your data beyond the actual performance of the contract in order to safeguard legitimate interests of us or third parties. Examples are:

Ensuring IT security and IT operations,
Measures for business management and further development of our services,
Defense against third-party claims and enforcement of own claims.

Based on your consent
- Insofar as you have given us your consent to process Personal Information for certain purposes.

About our APP

In principle, our APP is designed to have data protection-friendly default settings. This includes, for example, that only such personal data is collected that is required for the function of the APP (principle of data minimization). As such we have made sure that as little as possible information that directly identifies you is collected.

We assure you of the lawful and responsible handling of all data that you transmit to us as a user of our APP and would like to transparently present to you below which data we process, what we use it for and whether and, if so, to what extent it is stored by us and/or transmitted to third parties.

Data we collect automatically

Downloading the APP

The APP can be downloaded from the "Google Playstore" a service offered by Google LLC, or the Apple App service "App Store" a service of Apple Inc. Downloading it may require prior registration with the respective App store and/or installation of the respective App store software.

Installing the APP

As far as we are aware, Google collects and processes the following data: License check, network access, network connection, WLAN connections, and location information. However, it cannot be ruled out that Google also transmits the information to a server in a third country. We cannot influence which Personal Information Google processes with your registration and the provision of downloads in the respective App store and App store software. The responsible party in this respect is solely Google as the operator of the Google Play Store.

As far as we are aware, Apple collects and processes the following data: device identifiers, IP addresses, location information, it cannot be excluded that Apple also transmits the information to a server in a third country. We cannot influence which Personal Information Apple processes with your registration and the provision of downloads in the respective app store and app store software. The responsible party in this respect is solely Apple as the operator of the Apple App Store.

Device information

Google and Apple may collect information from and about the device(s) you use to access the APP, including hardware and software information such as IP address, device ID and type, device-specific and APP settings and properties, APP crashes, advertising IDs (AAID), information about your wireless and mobile network connection such as your service provider and signal strength; information about device sensors such as accelerometer, gyroscope, and compass.

Unity

Our app is built using the game development platform Unity. This uses software modules and libraries that come from Unity Technologies itself or third parties and become an inherent part of our App (called a game engine). During the execution of the app, personal data may be processed by Unity itself, including device identification numbers (so-called UDID - unique device identifiers, IP address). Data such as the device type, country of app installation, advertising ID, sensor markings (e.g., from the pressure or acceleration sensor), game identification number (app ID) and the checksum of the transmitted data are also processed.

Using Unity also means that the services are using "Unity Analytics". Unity Analytics collects the personal data such as IP addresses and device identification number (so-called UDID - unique device identifiers). Other data collected includes device specifications (device type, device language), usage data, information about in-app behavior, custom event data (where applicable).

Data we collect directly

In principle there are only two ways we can collect data form you directly:

If you send us feedback, or a support request, your email address will only be used for correspondence with you and only to clarify your support case. Your data will not be passed on to third parties. The data of your request will be deleted after completion.

In the course of the support you have requested, it may be necessary for you to provide us with some of your personal data so that we can fulfill our contractual obligations. The data transmitted in this context will be deleted after the end of the support.

General Principles

Who receives my data?

Within Mojoc, those that need your data to fulfill our contractual and legal obligations will receive access to it.

Processors used by us may also receive data for these purposes. These are companies in the categories of IT services, telecommunications, and sales and marketing. Where we use processors to provide our services, we take appropriate legal precautions and corresponding technical and organizational measures to ensure the protection of Personal Information in accordance with the relevant legal provisions.

Data is only passed on to third parties within the framework of legal requirements. We only pass on users' data to third parties if this is necessary, for example, for contractual purposes or on the basis of legitimate interests in the economic and effective operation of our business or you have consented to the transfer of data.

How long will my data be stored?

As far as necessary, we process and store your Personal Information for the duration of our business relationship, which also includes, for example, the initiation and execution of a contract.

In addition, we are subject to various storage and documentation obligations, which result from the minimum statutory retention periods. The retention and documentation periods specified there are 2 to 6 years.

How do we secure your data?

We have implemented numerous security measures (“technical and organizational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Information processed through our Platform.

Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Information may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Information may have been compromised as expeditiously as possible after which the breach was discovered.

Is data transferred internationally?

We may transfer your Personal Information as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Information when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organizational measures to protect the Personal Information we transfer.

Special Category Data

Unless specifically required when using our services and explicit consent is obtained for that service, we do not process special category data.

Automated decision-making

Automated decision-making is the process of making a decision by automated means without any human involvement. Automated decision-making including profiling does not take place.

Your Rights and Privileges

Privacy rights

You can exercise the following rights:

Right to information
Right to rectification
Right to deletion
Right to data portability
Right of objection
Right to withdraw consent

If you have any questions about the nature of the Personal Information we hold about you, or if you wish to exercise any of your rights, please contact us.

Updating your information

If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.

Withdrawing your consent

You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

Access Request

In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Information or to make a correction requested by you, we will tell you why.

Changes

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us using the details provided above.

Effective Date

Friday, 12th of June, 2023