Last update: 21st of May 2018.
- How to contact us?
- For what purpose we collect your personal data?
- What kind of personal information do we collect and how?
- From where do we receive personal information?
- To whom we disclose data and do we transfer data outside EU or EEA?
- How do we protect your personal data and how long do we store them?
- What are your rights as a data subject?
- Special Note About Children’s Privacy
- Your California, U.S.A. privacy rights
1. How to contact us?
If you have questions about data protection or if you have any requests regarding your personal data, we encourage you to primarily contact us through our games so we can reply to you more quickly.
Name of the data controller:
Koukoi Games Oy (also known as Koukoi Games Ltd.)
(hereafter ”we” or ”Koukoi Games”).
2. For what purpose we collect your personal data?
We will collect and process your personal information only (i) where we need the personal information to perform a contract with you or provide you with the Service, (ii) where the processing is in our legitimate interests and not overridden by your rights, (iii) where we have your consent to do so.
The purpose of the processing of which the personal data are intended are:
- create game or application accounts and allow users to play our games or use our applications;
- present our Services and its contents to you;
- provide you with information, products or services that you request from us;
- identify and suggest connections with other Services users;
- generally operate and improve our Services;
- understand you and your preferences to enhance your experience and enjoyment using our Services;
- respond to your comments and questions and provide customer service;
- send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
- communicate with you about promotions, rewards, upcoming events, and other news about products and services offered by Koukoi Games and our selected partners;
- enable you to communicate with other users;
- link or combine it with other information we get from third parties, to help understand your preferences and provide you with better services;
- carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
- notify you about changes to our Services or any products or services we offer or provide though it;
- to analyze user trends and target certain promotions;
- to send you merchandise or other physical promotional materials;
- to send you push notifications through our mobile games or applications to send you game or application updates, high scores and other service related notifications that may be of importance to you;
- to offer you the opportunity to invite your contacts from a third party service (such as your Facebook friends) so that those contacts can be located in the Services and/or so you can invite them to join you in the Services;
- and for any other purpose with your consent.
We use profiling to identify your online behavior and purchase habits and create profiles based on the information. We use this information to target marketing and develop our services.
3. What kind of personal information do we collect and how?
We process the following personal data from you in connection with the Services we provide:
- information that you provide by filling in forms on our Services. This includes information provided at the time of registering to use our Services, downloading and/or installing games and/or applications, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Services;
- information that you choose to provide us when registering, logging into or using our Services through social media services (such as Facebook);
- records and copies of your correspondence (including e-mail addresses), if you contact us;
- your responses to surveys that we might ask you to complete for research purposes;
- details of transactions you carry out through our Services and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Services. However, we do not collect information about your credit card numbers or any other digital credentials or PIN numbers with respect to your payment methods;
- your search queries on the Services;
- information we request when you contact our customer service group.
- you also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Services, or transmitted to other users of the Services or third parties (collectively, “User Content”). Your User Content are posted on and transmitted to others at your own risk. Although we limit access to certain portions of the Services, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Services with whom you may choose to share your User Content. Therefore, we cannot and do not guarantee that your User Content will not be viewed by unauthorized persons;
- location-based information for the purpose of providing you with the correct versions of our Services (including games and applications);
Analytics. We use your information to enable analytics provided by third parties such as DeltaDNA, UnityAnalytics and Appsflyer. We use analytical information for supporting business analysis and operations, business intelligence, product development, improving products and services, personalizing content, providing advertising, and making recommendations. We do not link the information we store within the analytics software to any personal data you submit within our Services. For more information, please see our full partner list here.
Automatically collected information and cookies. In addition, as you navigate through and interact with our Services, we may automatically collect certain information about your equipment, browsing actions and patterns, including:
- details of your visits to our Services, including traffic data, location data, logs and other communication data and the resources that you access and use on the Services;
- information about your computer and internet connection, including your IP address, language, operating system and browser type and referring web site addresses may be logged automatically;
- and your unique device ID (persistent / non-persistent), hardware type, media access control (“MAC”) address, international mobile equipment identity (“IMEI”), the version of your operating system (“OS”), your device name, your email address (if you have connected to Facebook or Google+), and your location (based on your Internet Protocol (“IP”) address).
The information we collect automatically is statistical data, and does not identify any individual. This information is useful to us for troubleshooting and helps us understand usage trends. It helps us to improve our Services and to deliver a better and more personalized service by enabling us to:
- estimate our audience size and usage patterns;
- store information about your preferences, allowing us to customize our Services according to your individual interests;
- speed up your searches;
- recognize you when you return to our Services;
- improve gameplay;
- and improve application usage.
The technologies we use for this automatic data collection may include:
- Web Beacons. Pages of our Services and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs., pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
5. From where do we receive personal information?
We receive data primarily from the following sources: from the data subject himself (when downloading and playing our Game, using our Services and when logging into the Service via SN-Service) and from other similar reliable sources.
6. To whom do we disclose data and do we transfer data outside of EU or EEA?
We may disclose to the following categories of third parties the personal information which you provide yourself to the Service or which we collect in the Service:
- Service providers, such as data storage service providers, which enable us to provide the Service to you;
- Our advertising and analytics partners which may process your personal data for the purposes described herein and where applicable, working as joint controllers of the processed data together with us. A list of these partners is available here;
- Public authorities, such as law enforcement, if we are legally required to so or if we need to protect our rights or the rights of third parties; and
- Our subsidiaries and affiliates; or a subsequent owner, co-owner or operator of the Service and their advisors in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our stock and/or assets, or in connection with bankruptcy proceedings, or other corporate reorganization.
Moreover, we may disclose information to third parties in an aggregate format that does not constitute personal information and does not allow identification of individual users.
7. How do we protect your personal data and how long do we store them?
Only those of our employees, who on behalf of their work are entitled to process customer data, are entitled to use a system containing personal information. Each user has a personal username and password to the system. The information is collected into databases that are protected by firewalls, passwords and other technical measures. The databases and the backup copies of them are in locked premises and can be accessed only by certain pre-designated persons.
We store the personal information for as long as is necessary considering the purpose of the processing. Additionally, we retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
We regularly assess the need for data retention in light of the applicable legislation periodically de-identify unused game accounts and we regularly review and de-identify unnecessary data. In addition, we take reasonable measures to ensure that the personal information in the register is not incompatible, obsolete or inaccurate considering the purpose of the processing. We rectify or delete such information without delay.
8. What are your rights as a data subject?
You have the following rights as a data subject:
- You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.
- Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
9. Special Note About Children’s Privacy
Child directed sections of the service
Although our Services are intended to a general audience, we may from time-to-time have special sections intended, in part, for children. For the sake of clarity, those sections in the Services are not targeted to children under 13 years of age as a primary audience. We also do not knowingly collect personal information from children under 13 years of age within such sections, except as may be permitted by COPPA. In order to protect the children’s privacy, we have implemented age screen mechanism in accordance with COPPA which treats users based on their self-reported age. Accordingly, features and services such as social networking plug-ins, behaviorally targeted advertising, and collection of data for building user profiles are not available to users under 13 years of age. We also do not allow our third-party partners who engage in such practices to access personally identifiable data from users under 13.
We and our third-party partners however do collect non-personally identifiable information from users under 13 years of age. Such a non-personally identifiable information is strictly limited to persistent identifiers (such as a customer number held in a cookie, IP address, device serial number, or a unique device identifier) which are used for sole purpose of providing support for the internal operations of the Services. Such internal operations include, without limitation activities necessary for the Services to maintain or analyze its functioning, authenticate users or personalize content and to serve contextual advertising or cap the frequency of advertising as permitted by COPPA. We also ensure that persistent identifiers are not used or disclosed to contact a specific individual or for any other purpose.
Sections of the services which are directed to general audience
In accordance with the foregoing, majority of our Services are directed to general audience. These sections are not intended to children under 13 years of age, therefore no one under 13 years of age may not use those sections or provide any personal information within those sections of the Services. We do not knowingly collect or solicit personal information from or direct or target behaviorally targeted advertising to anyone under 13 years of age or knowingly allow such persons to use these sections of the Services. If you are under 13 years of age, please do not send any information about yourself to us while using these sections of the Services, including your name, address, telephone number, or email address. No one under 13 years of age may provide any personal information.
In the event that we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under the age of 13, please contact us at email@example.com.
If we learn that we have inadvertently gathered personal information from children under 13 years of age, we will dispose of that information, or otherwise treat it in accordance with COPPA and other applicable laws and regulations. If you are a parent or guardian and you believe that your child under 13 years of age has provided us with personal information, please contact us at firstname.lastname@example.org.
If you have additional questions about our data collection practices related to children under the age of 13, please contact us at email@example.com, or alternatively at Koukoi Games Oy, Valtatie 67, FI-90500 Oulu, Finland.
10. Your California, U.S.A. privacy rights
Residents of the State of California in the United States of America (“California”) have the right to request from certain businesses with whom the California resident has an established business relationship a list of all third-parties to which the Company, during the immediately preceding calendar year, has disclosed certain personal data for direct marketing purposes. We are only required to respond to a customer request once during any calendar year. To obtain this information, you should send a request to firstname.lastname@example.org with the subject heading “California Privacy Rights.” In your request, please attest to the fact that you are a California resident and provide a current California address for our response. Please be aware that not all information sharing is covered by the California Privacy Rights requirements and only information on covered sharing will be included in our response.