Our Policies
TMK WEALTH CITY
PRIVACY POLICY
Effective Date: August 18, 2026
Last Updated: August 18, 2026
This Privacy Policy explains how THE MILLIONAIRE KID (FZC) ("TMK", "Company", "we", "us" or "our") collects, uses, stores, protects and shares personal data when you access or use TMK Wealth City, including the mobile game, related applications, Game-related webpages, account functions, support services and associated services (collectively, the "Game").
TMK is committed to respecting the privacy of its users and processing personal data in accordance with applicable data-protection and privacy laws, including the laws of the United Arab Emirates.
This Privacy Policy should be read together with the TMK Wealth City Terms and Conditions.
1. WHO WE ARE
The entity responsible for personal data processed in connection with TMK Wealth City is:
THE MILLIONAIRE KID (FZC)
Licence No.: 11025
Block B-B55-094
Sharjah Research Technology and Innovation Park Free Zone
Sharjah, United Arab Emirates
Email: admin@themillionairekid.com
Website: www.themillionairekid.com
For purposes of applicable data-protection law, TMK acts as the controller of personal data that TMK determines how and why to process.
Certain third parties, including Apple, Google, advertising providers, analytics providers, cloud-service providers and independent financial-service providers, may separately act as controllers or processors of data in accordance with their own privacy policies and legal obligations.
2. AGE REQUIREMENT
TMK Wealth City is intended for users aged 18 years and above.
You must be at least 18 years old to create an account or use the Game.
We may request your date of birth, age, age range or other reasonable age-assurance information to confirm eligibility for the Game or particular features.
TMK does not knowingly permit persons under 18 to create or maintain a TMK Wealth City account.
If we become aware that personal data has been collected from a person under 18 contrary to this Policy or our Terms, we may restrict or close the account and delete or otherwise appropriately handle the relevant personal data, subject to applicable legal requirements.
Users must not provide a false age or attempt to bypass age restrictions.
3. PERSONAL DATA WE MAY COLLECT
The personal data collected depends on how you use the Game, the device you use and the features enabled in the version of TMK Wealth City available to you.
Account and Profile Data
Where an account is required or available, we may collect information such as your name or username, email address, account identifier, age or date-of-birth information, country or region, language, login information, authentication information and account preferences.
Passwords are not intended to be stored by TMK in readable form. Authentication credentials should be protected using appropriate security measures.
Gameplay and Progress Data
We may collect information generated through your use of TMK Wealth City, including game progress, levels, virtual balances, virtual assets, simulated investments, scores, achievements, decisions, purchases and sales made within the simulation, game settings, missions, rewards and interactions with Game features.
This information relates to your activity inside the Game.
TMK Wealth City is a financial-literacy simulation. Virtual money, virtual investments and other virtual Game assets have no real-world monetary value and do not represent actual financial accounts or investments.
Device, Technical and Usage Data
When you use the Game, certain technical information may be generated automatically, including IP address, device type, operating system, app version, device language, time zone, connection information, session information, crash information, diagnostic information, security logs, timestamps and interactions with the Game.
Where permitted by applicable law and platform rules, the Game or approved service providers may also process device or advertising identifiers for analytics, attribution, fraud prevention or advertising purposes.
Purchase Information
TMK Wealth City may offer optional in-app purchases.
Where purchases are processed through the Apple App Store, Google Play or another authorised app marketplace, payment credentials such as your full payment-card number are generally processed by the relevant platform rather than directly by TMK.
TMK may receive transaction-related information necessary to confirm and administer a purchase, such as a transaction or receipt identifier, product purchased, purchase status, currency, price, date and relevant account identifier.
Advertising, Sponsorship and Referral Information
TMK Wealth City may contain advertising, sponsorships, promotional placements and links to third-party businesses, including banks, brokers, financial institutions, payment providers and financial platforms.
We may collect information concerning the display of and interaction with such content, such as impressions, clicks, referral events, campaign identifiers and attribution information.
Where personalised advertising, cross-app tracking or similar processing requires your consent or device permission, TMK and its providers will only use such processing subject to the applicable consent and platform requirements.
TMK does not provide a bank, broker or other advertiser with your TMK account profile merely because its advertisement appears in the Game.
Where a particular referral or promotion would require TMK to transfer identifiable personal data to a Third-Party Provider, we will provide an appropriate disclosure and obtain consent where required before making that transfer.
Customer Support and Communications
If you contact us, we may collect your name, email address, account identifier, correspondence, screenshots or information you choose to provide and technical information reasonably necessary to investigate and respond to your enquiry.
Notifications
If push notifications are enabled, we may process a device notification token and your notification preferences to deliver Game-related notifications. You may disable notifications through your device settings.
Security and Fraud-Prevention Information
We may process account, device, network, transaction and usage information where reasonably necessary to identify attempted hacking, cheating, account compromise, payment manipulation, fraudulent activity, abuse, cybersecurity threats or violations of our Terms.
4. INFORMATION TMK DOES NOT REQUIRE FOR THE FINANCIAL SIMULATION
TMK Wealth City is an entertainment and financial-literacy simulation and does not itself provide banking, brokerage, investment-management, deposit-taking or real-money trading services through the simulated Game.
Accordingly, TMK does not require users to provide their real brokerage password, online-banking password, payment-card PIN, actual investment-portfolio credentials or similar financial-account credentials in order to play the Game.
Users should never provide such credentials to TMK through customer support or other communication channels unless TMK expressly introduces a lawful feature requiring specific information and provides the necessary privacy disclosure beforehand.
If you leave TMK Wealth City through a link to an independent bank, broker or other financial-service provider, information submitted directly to that provider is governed by that provider's privacy policy and systems rather than this Privacy Policy, except to the extent TMK separately receives personal data relating to the referral or transaction.
5. HOW WE COLLECT PERSONAL DATA
We may collect personal data directly from you when you create an account, enter information, make selections, contact us, request support or exercise privacy rights.
Other information may be generated automatically when you use the Game.
We may also receive limited information from authorised platforms and service providers, including Apple, Google, authentication providers, analytics providers, advertising or attribution providers and other service providers, where permitted by applicable law.
If personal data is obtained from a third party, we will process it only for appropriate and disclosed purposes and subject to applicable privacy requirements.
6. HOW WE USE PERSONAL DATA
We process personal data to provide, operate, maintain and secure TMK Wealth City; create and administer accounts; save Game progress; provide Game features; authenticate users; process and verify purchases; provide customer support; troubleshoot technical problems; detect fraud, hacking and misuse; protect users and TMK systems; improve Game stability, design and performance; understand how features are used; manage advertising and sponsorships; measure advertising and referral performance where permitted; communicate important service information; comply with legal obligations; establish or defend legal rights; and respond to lawful requests from competent authorities.
Where we send marketing communications directly to you, we will obtain consent where required and provide a reasonable method to opt out.
We will not use personal data collected for one purpose for a materially different incompatible purpose without an appropriate legal basis and, where required, further notice or consent.
7. BASIS FOR PROCESSING
Depending on the circumstances and applicable law, TMK may process personal data based on your consent; where processing is necessary to provide the Game or perform our contractual obligations to you; where processing is required or authorised by applicable law; where necessary to establish, exercise or defend legal claims; or where processing is reasonably necessary for security, fraud prevention and protection of users, TMK or third parties as permitted by applicable law.
Where processing depends on consent, you may withdraw that consent using the mechanisms provided within the Game, your device settings or by contacting TMK.
Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.
Certain information may be necessary to provide a feature or maintain an account. If you choose not to provide information that is necessary for such functionality, that feature may not be available.
8. ANALYTICS
TMK may use analytics and diagnostic technologies to understand Game performance, identify crashes, measure engagement, detect technical problems and improve TMK Wealth City.
Where analytics involves personal data or identifiers, such data will be processed in accordance with this Privacy Policy, applicable law and platform requirements.
TMK seeks to minimise the personal data used for analytics and may use aggregated or de-identified information where reasonably possible.
Information that has been irreversibly anonymised so that it can no longer reasonably identify an individual may be used for statistical, analytical, security, research and Game-development purposes.
9. ADVERTISING AND TRACKING
TMK Wealth City may display advertising and sponsored content.
Depending on the Game version, applicable law, device settings and your choices, advertising may be contextual or personalised.
Where Apple requires permission through its App Tracking Transparency framework, TMK will not engage in activity constituting tracking that requires such permission unless the user has granted the applicable permission.
Where consent is required for advertising identifiers, personalised advertising, cross-service measurement or similar processing, such processing will be subject to the applicable consent mechanism.
You may be able to limit advertising personalisation or tracking through your device settings and any privacy controls offered within the Game.
Refusing optional advertising or tracking consent will not prevent TMK from using information that is strictly necessary for security, fraud prevention, core Game operation or other processing permitted by applicable law.
TMK does not sell personal and sensitive user data.
10. THIRD PARTIES WITH WHOM DATA MAY BE SHARED
TMK may disclose personal data only where reasonably necessary and permitted by applicable law.
Recipients may include cloud-hosting and infrastructure providers; database and storage providers; authentication providers; cybersecurity and fraud-prevention providers; analytics and crash-reporting providers; customer-support providers; communication providers; advertising, attribution and marketing providers where permitted; professional advisers such as lawyers, auditors and accountants; Apple, Google and other app-distribution platforms; and competent governmental, judicial, regulatory or law-enforcement authorities where disclosure is legally required or permitted.
TMK may also disclose relevant information in connection with an actual or proposed merger, restructuring, financing, acquisition, sale of business or transfer of assets, subject to appropriate confidentiality and data-protection measures.
Service providers processing personal data on TMK's behalf are expected to process the data only for authorised purposes and to provide appropriate protection for that information.
TMK will not knowingly appoint a third-party service provider to process personal data on TMK's behalf where the provider cannot provide appropriate protection consistent with applicable law and TMK's obligations.
11. BANKS, BROKERS AND OTHER INDEPENDENT THIRD PARTIES
Advertisements or links within TMK Wealth City may direct you to an independent bank, broker, payment provider, financial platform or other Third-Party Provider.
Once you leave the Game and interact directly with such a provider, the third party may independently collect personal, identity, financial, payment or regulatory information from you.
TMK does not control the third party's independent data-processing activities.
Before submitting personal data to an external provider, you should review that provider's privacy policy, legal terms, licensing information and security practices.
Any real-world account opening, deposit, investment, trade, loan or financial transaction is separate from the TMK Wealth City simulation.
12. INTERNATIONAL AND CROSS-BORDER DATA TRANSFERS
TMK is established in the United Arab Emirates.
Some technology, hosting, analytics, communications or other service providers used in connection with the Game may process or store information outside the UAE.
Where personal data is transferred outside the UAE, TMK will take measures required by applicable UAE data-protection law, which may include verifying an appropriate level of protection, using appropriate contractual or organisational safeguards or relying on another legally permitted transfer mechanism.
TMK will seek to ensure that personal data transferred internationally continues to receive appropriate protection consistent with applicable law.
13. DATA SECURITY
TMK takes reasonable and appropriate technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, alteration, disclosure or destruction.
These measures may include access controls, authentication controls, restricted administrative privileges, security monitoring, secure development practices, vulnerability management, backup procedures and encryption of personal data in transit using appropriate encrypted communications such as HTTPS/TLS.
Access to personal data should be limited to personnel and service providers that reasonably require access for authorised purposes.
No internet-connected service can guarantee absolute security. Users are responsible for maintaining the confidentiality of their login credentials and should notify TMK promptly if they believe their account has been compromised.
Where a personal-data breach occurs, TMK will investigate the incident and provide notifications to users and/or competent authorities where required by applicable law.
14. DATA RETENTION
TMK retains personal data only for as long as reasonably necessary for the purposes for which it was collected and in accordance with applicable legal requirements.
Account and Game-related information may normally be retained while an account remains active or while reasonably necessary to provide the Game.
When an account is deleted, personal data associated with that account will be deleted, anonymised or otherwise removed from active use without undue delay unless TMK is required or permitted to retain particular information for purposes such as legal compliance, accounting, transaction records, dispute resolution, cybersecurity, fraud prevention, enforcement of legal rights or protection against abuse.
Information retained for a mandatory or legitimate legal purpose will not be used for unrelated purposes and will be deleted or anonymised when the applicable retention requirement ends.
Residual copies may temporarily remain in secure backup systems until they are overwritten or deleted as part of ordinary backup cycles.
Aggregated or irreversibly anonymised information that no longer constitutes personal data may be retained for longer periods.
15. ACCOUNT AND DATA DELETION
If TMK Wealth City allows creation of an account, users will be provided with a readily accessible method within the Game to request deletion of their account.
Account deletion means deletion of the account and associated personal data that TMK is not legally required or otherwise lawfully permitted to retain. Merely disabling or freezing an account will not be treated as account deletion.
Users may also submit a privacy or deletion request through TMK's designated online account-deletion resource or by contacting:
TMK may take reasonable steps to verify the identity of the person requesting deletion in order to prevent fraudulent or unauthorised requests.
Deleting your TMK Wealth City account does not automatically cancel subscriptions or payment arrangements administered independently by Apple, Google or another platform. Where applicable, users should separately manage those arrangements through the relevant platform.
Account deletion may permanently remove Game progress, achievements, virtual assets and other account-linked information and may not be reversible.
16. YOUR PRIVACY RIGHTS
Subject to applicable law and any lawful exceptions, you may have the right to request information about personal data TMK processes about you and the purposes for which it is processed; request access to personal data; request correction of inaccurate or incomplete personal data; request deletion or erasure; request restriction or cessation of certain processing; withdraw consent where processing is based on consent; object to certain processing where applicable; request a portable copy of eligible personal data and, where technically feasible, request transfer to another controller; and raise concerns relating to automated processing where applicable.
TMK does not intend to use automated processing within TMK Wealth City to make decisions producing legal or similarly significant real-world effects concerning users.
Automated gameplay rules may determine simulated Game outcomes, recommendations, difficulty, events, rewards or similar entertainment features based on actions taken within the Game. Such Game decisions relate to the simulation and do not determine a user's eligibility for real financial products or services.
To exercise a privacy right, contact:
Please include sufficient information for TMK to identify the relevant account and understand your request. TMK may request reasonable identity verification before responding.
Rights may be subject to exceptions provided by applicable law, including where retention or processing is required for legal claims, security, fraud prevention, compliance obligations or protection of the rights of others.
17. WITHDRAWING CONSENT AND PRIVACY CHOICES
Where processing is based on consent, you may withdraw consent through any privacy settings made available within the Game, through applicable device or operating-system settings or by contacting TMK.
You may disable push notifications through your device settings.
You may adjust advertising or tracking permissions through the controls made available by Apple, Google or your device operating system.
Where marketing communications are sent by email, you may use the unsubscribe method provided in the communication or contact TMK.
Withdrawal of optional consent will not affect your ability to use functionality that does not reasonably depend on the relevant data processing.
18. DEVICE PERMISSIONS
TMK will seek to request only device permissions reasonably relevant to implemented Game features.
Where a feature requires access to information protected by a device permission, the Game will request the relevant permission through the operating system and explain the purpose where required.
TMK will not intentionally use a permission for an undisclosed purpose.
You may manage permissions through the settings of your device. Disabling a permission may prevent functionality that genuinely depends on that permission from operating.
19. APPLE APP STORE AND GOOGLE PLAY
Where TMK Wealth City is downloaded through the Apple App Store or Google Play, Apple or Google may independently collect and process information in connection with app distribution, installation, purchases, subscriptions, security, analytics and platform operation.
Such processing is governed by the relevant platform's own privacy terms.
TMK will maintain the privacy disclosures provided through the applicable app-store privacy and data-safety systems so that they accurately reflect the Game's current data practices.
If TMK changes the Game in a way that materially changes its collection, use or sharing of data, TMK will update this Privacy Policy and applicable app-store disclosures as required.
20. CHANGES TO THIS PRIVACY POLICY
TMK may update this Privacy Policy from time to time because of changes to the Game, technology, service providers, business operations, legal requirements, regulatory requirements or app-store requirements.
The "Last Updated" date at the beginning of this Privacy Policy will identify the latest version.
Where required by applicable law, TMK will provide appropriate notice of material changes and obtain additional consent where necessary.
Users are encouraged to review this Privacy Policy periodically.
21. CONTACT AND PRIVACY REQUESTS
Questions, complaints, requests to exercise privacy rights and other privacy enquiries may be directed to:
THE MILLIONAIRE KID (FZC)
Licence No.: 11025
Block B-B55-094
Sharjah Research Technology and Innovation Park Free Zone
Sharjah, United Arab Emirates
Privacy Email: admin@themillionairekid.com
Website: www.themillionairekid.com
If you believe TMK has not appropriately addressed a privacy concern, you may also have the right to submit a complaint to the competent data-protection or regulatory authority in accordance with applicable law.
22. LANGUAGE
This Privacy Policy may be made available in Arabic and English.
For users in the United Arab Emirates, the interpretation and application of this Privacy Policy remain subject to mandatory provisions of applicable UAE law.
Nothing in this Privacy Policy limits any privacy, data-protection or consumer right that cannot lawfully be excluded or restricted.