Effective date : January 6th, 2025

Million Victories SAS, a French company, with a share capital of 117,844.39 euros, registered with the Lyon Trade and Companies Register under the number 830 912 051, whose head office is located at 34 rue Verlet Hanus, 69 003 Lyon, France (hereinafter “Million Victories” or “We” or “Us”), is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you play our mobile game “Million Lords” (hereinafter the “Game”).

You can contact Us :

• by email at [email protected]
• by postal mail at 34 rue Verlet Hanus, 69 003 Lyon, France

1. Your acceptance of this Privacy Policy

By playing Million Lords, you acknowledge that you have read and accepted this Privacy Policy without limitation or reserve. If you do not agree, please refrain from using the Game. This Privacy Policy forms a legal agreement between you and Million Victories.

2.  Data processed

To allow You to play the Game, We can collect the different type of data following:

• data You provide us : pseudo, clan messages, support messages and data you choose to give us (for instance to identify a lost account);
• data we collect automatically from our partners, such as Facebook, Android Google Play and Apple App Store identifiers;
• data You create in the Game about your Game progress, your gameplay and your interactions with other players;
• data collected automatically by our partners that we can consult such as IDFA identifier, mobile device name, mobile device OS, location data, payment information (i.e. bank account).

We also create a specific ID to identify you in our database.

You acknowledge and accept that the following data will be accessible to all players : pseudo,  global chat and clan messages and some data about your game progress. On the contrary, all other data (and especially e-mail address) will only be accessible to Million Victories and its partners.

Acceptance of this Privacy Policy implies your acceptance to the collection and processing of the aforementioned data by Million Victories through the Game.

The aforementioned data are essential for the use of the Game. If these data are not provided, You cannot create your pseudo/profile and play the Game.

3. Purpose of collecting Personal Data

The Personal Data collected will be used by Million Victories to :

• allow you to play our Game;
• improve the players experience;
• keep the Game safe and fair;
• show advertisements in the Game;
• analyze, profile and segment collected data.

4. Accessibility of Personal Data

You acknowledge and accept that your data will be accessible to others in the following situations :

• other players will see your pseudo, some Game results and the messages you posted (global chat and clan messages);
• Million Victories works with partners and these partners process your data at and according to Million Victories’s instructions to provide some services such as hosting, analytics.

5. Protection of Personal Data

You undertake to provide accurate and up-to-date information and to inform Million Victories without delay of any changes by sending the information concerned by this change to [email protected].

The data are processed and are stored by Million Victories for a period no longer than necessary for the purposes for which they are collected and processed, beyond the period strictly necessary for the management of our relationship. In this respect, your data are processed for the duration of our relationship. In this regard you are informed that your personal data will be deleted within two (2) years without any activity on your account, without prejudice to conservation obligations or limitation periods.

The Personal Data are not transferred to third parties for advertising and promotional purposes without your prior consent. Nevertheless you are informed that we can show advertisements in the game at your request. Certain Personal Data may be transferred to a third country considered as offering an inappropriate level of protection, when necessary for the performance and the execution of the Game, because the Game is global by nature. We take steps to ensure adequate safeguards are in place to protect your data as explained in this Privacy Policy. Adequate safeguards that our partners may use include standard contractual clauses approved by EU Commission and the Privacy Shield certification in case of transfers to the USA, available on the Privacy Shield Framework website (https://www.privacyshield.gov). In this regard, you are informed that we may transfer personal data to Germany, Western Europe and US as part of our relationship with our partners that save the data you provide to us and that track our support reports.

In order to help ensure a secure and safe player experience, We are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration.

6. Your rights

You have a permanent right of access, rectification, opposition, erasure, restriction and portability to all your personal data, in accordance with applicable European laws and French law. You also have a right to lodge a complaint with the CNIL or any other competent supervisory authority. You may at any time make a request to Million Victories to find out what are the personal data stored about You by Million Victories and, upon request, You may modify these data by sending an e-mail to the Data Protection Officer of Million Victories to the following address: [email protected]; or a letter to the following address : Million Victories SAS, 34 rue Verlet Hanus, 69 003 Lyon, France.

7. The duration of the Privacy Policy

7.1. This Privacy policy shall enter into force when You accept them, when You install the Game and create your pseudo.

It remains in effect as long as You use and play the Game.

7.2. You may quit the Game at any time, for any reason or no reason, by uninstalling the Game. 

You may also close your profile and terminate this agreement at any time, for any reason or no reason, by sending an email to the following address: [email protected].

7.3. We may terminate this agreement and exclude You from the Game, if You breach any of your essential obligations under this Privacy Policy and fail to cure such breach within fifteen (15) days after receiving written notice thereof from Us, without prejudice to any damages that may be claimed as a result of such breach. 

Upon such exclusion from the Game, You shall immediately cease to use and play the Game and You agree to no longer access (or attempt to access) the Game. 

8. The modification of this Privacy Policy

We reserve the right to modify this Privacy Policy from time to time by notifying You of changes through the Game. These modifications will only be connected to technical evolutions of the Game and will not result in any increase of price nor affect the quality of the Game.
Unless We state otherwise, such modifications are effective when You accept them by ticking the box provided for that purpose.
To continue using and playing the Game You will need to agree and to accept this updated Privacy Policy. If You refuse to accept the updated Privacy Policy, your access to the Game will be suspended by Million Victories, as from the effective date of the updated Privacy Policy and until You accept them.

9. Dispute Resolution and Applicable Law

You agree that this Privacy Policy shall be governed by and construed in accordance with the laws of France.

If a dispute arises between You and Million Victories, We strongly encourage You to first contact Us by  sending an email to the following address: [email protected], or to seek a satisfactory solution by going to our customer support site at https://millionvictories.com.

In accordance with Articles L. 611-1 and following of the French Consumer Code, in the event of a dispute, You may have recourse to a contractual mediation procedure or any other alternative dispute resolution method.

You are also hereby informed of the existence of the European online dispute resolution platform.

10. Miscellaneous

10.1 Severability 

You and Million Victories agree that should any provision be held invalid or declared invalid pursuant to a law or regulation or pursuant to a final and non-appealable decision by a court with jurisdiction, the remaining provisions hereof shall retain their effectiveness and scope, if the contractual balance is kept between the Parties

10.2 Assignment

You shall not assign or transfer any rights or obligations under this Privacy Policy without Million Victories’s prior written consent.

10.3 Entire Agreement 

This Privacy Policy, any supplemental policies and any documents expressly incorporated by reference herein, contain the entire understanding of You and Million Victories, and supersede all prior understandings of the Parties hereto relating to the subject matter hereof, whether electronic, oral or written, or whether established by custom, practice, policy or precedent, between You and us with respect to the Game.

10.4 No Waiver 

The failure by You or Us to enforce any provisions of this Privacy Policy or to exercise any right in respect thereto shall not be construed as constituting a waiver of its rights thereof.