Friendealer International Network Inc.
Privacy Policy
Effective 25 October 2026 · Version 2.2
This policy explains how Friendealer International Network 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 International Network 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 International Network Inc. For any question or request: [email protected] (subject: "Privacy").
2. Our principle: minimal data
MRAYA works without a user account, without ads and without tracking. 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. The App only connects to the internet to buy and restore MRAYA Eternal.
3. Information we collect
3.1 In the App
- Purchase of MRAYA Eternal: the purchase confirmation provided by Apple or Google (receipt, product identifier, transaction identifier and date, price and currency, store country), a random identifier created by the App, which contains neither your name nor your Apple or Google account, as well as the App and system versions, the language and the connection's IP address. This information is processed by our provider RevenueCat to verify the purchase, restore it on your devices and prevent fraud.
- The App uses no advertising identifier (IDFA, Google advertising ID) and includes no advertising or tracking tools; it therefore never asks for "App Tracking Transparency" permission.
- Anonymous statistics and crash reports (Google Firebase Analytics and Crashlytics): game events (a level started or solved, its number of moves, a hint asked, a world completed, the MRAYA Eternal page viewed or the purchase made), the device model, the App and system versions, the language and the country, and a random identifier of this installation — never your name, your account or an advertising identifier. A crash report describes the error and the device. Statistics follow the switch Settings › Anonymous statistics: in the European Economic Area, the United Kingdom and Switzerland they stay off until you turn them on; elsewhere they are on and you can turn them off at any time. Crash reports stay on, to keep the App stable.
3.2 On the Site
- If you voluntarily join the waitlist: your email address, the page language, the date and time of sign-up and proof of your consent (box checked and wording shown).
- To block abuse, a one-way fingerprint (SHA-256 hash) of your IP address is kept for about one hour, never the address itself.
- The usual technical logs of our host (Cloudflare), needed to run and secure the Site.
We do not collect names, postal addresses, phone numbers, contacts, photos, precise location or health data.
4. How we use it
- To provide, improve and secure the App and the Site.
- To verify, unlock and restore your purchase of MRAYA Eternal, and to prevent fraud.
- To keep our accounting and tax records of sales.
- To email you about MRAYA's launch if you joined the waitlist.
- To meet our legal obligations and enforce our rights.
We do not sell or rent your personal information, and we do not use it to show you ads or to profile you.
5. Consent
We ask for express, free and informed consent, for specific purposes. Purchase information is only processed if you choose to buy or restore MRAYA Eternal, and only for the purposes described in section 4. 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).
Anonymous statistics follow the switch in the App's settings, which you can change at any time (section 3.1).
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:
- RevenueCat, Inc. — verification and restoration of in-app purchases: revenuecat.com/privacy.
- Google LLC (Firebase Analytics and Crashlytics) — anonymous statistics and crash reports from the App: firebase.google.com/support/privacy.
- 650 Industries, Inc. (Expo) — delivery of the App's updates: when the App checks for an update, Expo's servers receive the device's IP address, its system and the App's version, used only to send the right update: expo.dev/privacy.
- Apple (App Store, payments): apple.com/legal/privacy.
- Google Play (payments): policies.google.com/privacy.
- Cloudflare, Inc. — Site hosting and waitlist storage: cloudflare.com/privacypolicy.
- An email delivery platform (for example Brevo or Mailchimp) if we use one for the launch announcement; it will be named here before any email is sent.
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
Payment for MRAYA Eternal is handled entirely by Apple or Google. Neither Friendealer International Network Inc. nor RevenueCat receives, processes or stores any payment data (card number, banking details). We only receive confirmation that a purchase took place, without your name or email address.
9. Retention
- Waitlist: until you unsubscribe or, at the latest, 24 months after MRAYA's launch, then deleted.
- Anti-abuse IP fingerprint: about one hour.
- App data: on your device, deleted when you uninstall the App.
- Purchase information: as long as it is needed to restore your purchase, then for the period required by accounting and tax laws (generally six years after the end of the fiscal year concerned).
- Incident register and correspondence about your requests: as long as the law requires.
- Anonymous statistics: 2 months; crash reports: 90 days.
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 International Network 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:
- promptly take reasonable measures to reduce the risk of harm and prevent a recurrence;
- 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;
- 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.
Because MRAYA works without an account, we cannot link a purchase to your name. For a request about your purchase, include the Apple or Google receipt (order number) so we can find it.
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, along with the random purchase identifier (section 3.1).
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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