MRAYA

Friendealer Inc.

Privacy Policy

Effective 28 September 2026 · Version 1.0

This policy explains how Friendealer Inc., a company registered in Québec, Canada ("Friendealer", "we"), collects, uses, discloses and protects personal information related to the mobile game MRAYA (the "App") and the website mraya.friendealer.com (the "Site"). It is written in accordance with Québec's Act respecting the protection of personal information in the private sector (as amended by Law 25) and Canada's Personal Information Protection and Electronic Documents Act (PIPEDA).

1. Person in charge of the protection of personal information

Friendealer Inc. is responsible for the personal information it holds. In accordance with Law 25, the role of person in charge of the protection of personal information is exercised by the person with the highest authority within Friendealer Inc. For any question or request: [email protected] (subject: "Privacy").

2. Our principle: minimal data

MRAYA works without a user account. Your progress (levels, stars, dragon form, settings, hint credits) is stored only on your device; it is not sent to us and we can neither view nor restore it.

3. Information we collect

3.1 In the App

3.2 On the Site

We do not collect names, postal addresses, phone numbers, contacts, photos, precise location or health data.

4. How we use it

We do not sell or rent your personal information.

5. Consent

We ask for express, free and informed consent, for specific purposes. On iOS, personalised advertising is only used with your "App Tracking Transparency" permission. In regions where the law requires it, a consent form (Google UMP) is shown before any ad request. By default MRAYA requests non-personalised ads. Joining the waitlist requires ticking a separate consent box (Canada's Anti-Spam Legislation, CASL). You may withdraw your consent at any time (section 12).

6. Third parties and processors

We only share information with the providers we need, bound by contract or by their terms to confidentiality obligations. Their own policies also apply:

We may also disclose information where the law requires it, to protect our rights or the safety of others, or as part of a business reorganisation or sale, subject to confidentiality undertakings.

7. Transfers outside Québec and Canada

Our providers may process information in the United States or elsewhere. Before any transfer we assess whether the information will receive adequate protection (s. 17 of the Québec Act) and we frame such transfers by contract. Transferred information may be accessible to the authorities of the country concerned under its laws.

8. Payments

In-app purchases are handled entirely by Apple or Google. Friendealer Inc. does not receive, process or store any payment data (card number, banking details). We only receive confirmation that a purchase took place.

9. Retention

10. Security

We implement reasonable security measures suited to the sensitivity of the information: encrypted connections (HTTPS), access restricted to authorised people only, data minimisation and pseudonymisation. However, no method of transmission or storage is completely secure and we cannot guarantee absolute security. To the extent permitted by law, Friendealer Inc. is not liable for unauthorised access resulting from a breach at a third party (provider, platform or network) beyond its direct control, without prejudice to its legal duties of oversight and notification.

11. Confidentiality incidents

If we have reason to believe that a confidentiality incident (unauthorised access, use or disclosure, or loss) affects information we hold, we:

  1. promptly take reasonable measures to reduce the risk of harm and prevent a recurrence;
  2. assess the risk; if the incident presents a risk of serious injury (Law 25) or a real risk of significant harm (PIPEDA), we diligently notify the Commission d'accès à l'information du Québec and/or the Office of the Privacy Commissioner of Canada, the affected individuals and, where useful, any organisation that can reduce the risk;
  3. record every incident in a register, kept for at least 24 months and provided to the authorities on request.

12. Your rights

You may request access to information about you, its correction, deletion or portability, and withdraw your consent. To exercise these rights, email [email protected] from the address concerned; we may verify your identity and will reply within 30 days. Every waitlist email contains an unsubscribe link.

For advertising: on iOS, Settings › Privacy & Security › Tracking; on Android, Settings › Google › Ads (reset or delete the advertising ID). Because we link no account to App data, we cannot identify your advertising data; such requests should be sent to Google.

13. Children

MRAYA is not specifically directed at children under 13 and does not knowingly collect personal information from them (including under the US COPPA). In Québec, information about a minor under 14 may only be collected with the consent of the person having parental authority; the waitlist is reserved for people aged 14 and over. If we learn that information was collected from a child by mistake, we delete it promptly. Parents: [email protected].

14. Cookies and local storage

The Site uses no advertising cookies or tracking tools. It only stores your language choice in your browser. The App stores your progress on your device.

15. Changes

We may update this policy. The effective date appears at the top of this page; for a material change we will give reasonable notice in the App or on the Site and, where the law requires, ask for your consent again.

16. Complaints

Please write to us first: we will do our best to resolve the matter. You may also contact the Commission d'accès à l'information du Québec or the Office of the Privacy Commissioner of Canada.

If the language versions differ, the French version prevails.

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