1. AN OVERVIEW ON DATA PROTECTION
The following information will provide you with an overview of how we collect your data as well as the purposes we use this data for when you use our games and other services (“Services”).
The term „Personal Data” (or “Data”) comprises all data that can be used to personally identify you, either directly (such as your first and last name, your email address or your telephone number), or indirectly (such as your phone ID, cookie identifier or game data).
We are processing your Data as a controller under EU data protection laws:
Kolibri Games GmbH
If you have any questions or suggestions about data protection or want to reach out to our data protection officer, you can contact us here.
2. COLLECTION AND USE OF YOUR DATA
On the one hand, your Data is collected by you communicating it to us. This may be Data that you enter in a contact form or if you connect our Services to third-party accounts, such as Facebook or Google. Other Data is automatically collected when you download and use our Services. If you watch advertisements within our Services or those of your partners, we may also collect information about the advertisements served and how often you have viewed them, their location in the game and the identifier of your device. We and our partners may also collect information about your actions in relation to the advertisements, such as the page views, the time and the duration of the view.
In order to fully use our Services, it is necessary to provide the data listed below. Without this Data, we are not able to provide our Services in its full extent to you.
We may collect and use your Data when you:
a) Download our games and create an Account
When you download our games, we collect the time, date and install source of your download. When you first play our games, we may automatically generate a user ID (“Player ID”).
b) Use our Sevices
When you use our Services, we may automatically collect your:
- game data such as achieved game levels, rewards, completed events, virtual currency and statistics including the playtime or the use of the various features as well as the data associated with any bugs and malfunctions.
- IP address and approximate location data (derived from your IP address)
- mobile device identifiers such as your device ID advertising ID with your consent
- device data and technical data such as device type and operating system, network connection type and mobile carrier, screen resolution, device language
- user preferences and settings, such as game language, settings regarding push-notifications and in-game sound and music.
We collect this Data to provide you with access to our games, for example to your saved game and unlocked or purchased content and to improve your experience and the security of our Services.
c) Make purchases in our Services
We do not collect or store any payment information such as your credit card number. When you make purchases within our Services, we only collect Data about purchase transaction types and spend you have made using virtual items in the Services.
d) Connect our Services via social link to your friends or connect to our Services with your credentials from a third-party platform
In some of our Services you may also connect your player to third-party accounts such as your Facebook or Google account to participate in social features and highscores. You may also connect our Services to your Game Center account.
If you connect your Facebook account with our Services, the following Data is shared with us:
- Profile picture
- Friends list (optional)
If you connect your account to your Game Center account or other third-party accounts such as Google or Facebook, we may collect your user ID for the third-party services and a login token that allows you to verify your identity without re-entering your credentials for third-party platforms as long as the token remains active.
Some of our Services allow you to create an invitation link that you may send to your friends to connect directly via the Social Feature. If you share your invitation link and participate in the social features, you may choose that your friends and contacts see that you use our Services and you will also be displayed in the highscores of your friends. You can only see your friends that followed your invitation link or participate in the social feature of the same Service and also share this information with their friends and contacts.
You can cancel the connection with your Facebook account at any time by logging into Facebook and selecting the “Settings” option. The connection between Facebook and the app can be deleted under “Apps and Websites”. You can cancel the connection with your Game Center account via the settings menu in our services. To cancel the connection of our Services with your third-party accounts, you can also send a message to our Player Support Team via in-game chat or via email to firstname.lastname@example.org.
e) View personalized advertisements or content within our Services or those of our partners
When you watch ads within our Services or those of our partners we may collect information such as the ad provider, the advertisement watched, the number of times it was watched, its location in the Service and the identifier of your device if you have opted in to personalized advertising. We may also collect information about your actions in relation to the advertisement. Our trusted marketing partners may collect your Data as explained in Section 4 below.
We can combine the Data collected with our partners when you use our Services. We may also use all your Data collected to offer you personalized advertisements, products, services or content via our Services or those of our partners.
If you access our Services on an iOS device, you can opt-in to personalized advertisements by allowing tracking upon first launch of our Services. If you want to opt-out to personalized advertising, you can do this via “Privacy” settings on your iOS device and “Ads” settings on your Android device. If you want to opt-out of personalized advertising, you may also consult Section 9 “Your Rights” under the paragraph “Give and withdraw your consent”.
f) Contact our Player Support team
If you send support requests to our Player Support team by email, via integrated chat within our Services or via messages within social media platforms, we collect and process the Data from your request and Data from your account, such as your Player ID, game data, device data and technical data. We collect this Data to appropriately respond to your requests.
When you send support requests directly via the chat system integrated into our Services, your provided Personal Data will be transmitted to our help desk provider HelpShift Inc. By sending support requests via the chat system, you understand and agree with the transmission of the Personal Data required to process your support request.
The Data sent by you to us via contact requests remains with us until you request us to delete, revoke your consent to the storage or the purpose for the Data storage lapses. Mandatory statutory provisions in particular statutory retention periods remain unaffected.
3. STATISTICS AND ANALYTICS
To improve the features and design of our Services we may analyze all collected data. The analyses of your usage Data are usually conducted anonymously; i.e. the patterns cannot be traced back to you.
4. ADVERTISING NETWORKS
We use third-party analytical tools to deliver advertising and content relevant to your interests.
This collected information includes, but is not limited to installation Data, in-app events, language, platform, device type, operating system version or device IDs such as advertising IDs and usage information.
We use the following advertising networks in order to be able to integrate advertising within our free-of-charge Services. These collect the Data described below for the purpose of providing personalized advertising:
|Advertising network||Provider||Type of Data collected|
|AppLovin||AppLovin Corporation, 1100 Page Mill Road, Palo Alto CA 94304, USA||Device make, model and operating system; Device properties related to screen size & orientation, audio volume and battery, device memory usage; Carrier;
Operating system; Country, time zone and locale settings (country and preferred language); Network connection type and speed;
IP Address; Internet browser user-agent used to access the Services; and Identifier for advertisers
|AdMob/Google||Google Corporation, 1600 Amphitheatre Parkway in Mountain View, California, USA||Online identifiers, including cookie identifiers, internet protocol addresses and device identifiers; client identifiers|
|AdColony||AdColony Inc. 1888 Century Park East, Suite 1450, Century City, CA 90067, USA||IP address, device advertising identifiers, the type of phone or other mobile device used, the operating system, the date and time a particular ad is served, whether one of the ads facilitated by them was delivered and, if applicable, a record if that ad was “clicked” or if it originated from a follow-up action to a third party such as a “conversion” event, combined with Personal Data to help AdColony optimize and/or refrain from advertising for a mobile application that has already been downloaded onto a device.|
|Chartboost||Chartboost One Sansome Street Floor 21 San Francisco, CA 94104, USA||Language, operating system, device type, IP address, MAC address, device ID, Advertising ID, Android ID, statistics on video ads that have been viewed, length of use of an app, Data regarding in-app purchases|
|Facebook Ads||Facebook Inc., 1601 Willow Road, Menlo Park, CA 94025, USA||Device attributes (operating system, hardware, software versions, etc.), processes on the device, identifiers (unique identifiers, device IDs, and other identifiers), device signal (Bluetooth, WLAN, etc.), device settings Data (GPS, camera, photos), network and connections (mobile radio or Internet provider, language, time zone, IP address, etc.), cookie Data.|
|Unity Ads||Unity Technologies 30rd Street, San Francisco, CA 94103, USA||Device information, IP addresses, device identifiers, combined with Unity Analytics to personalize advertising.|
|IronSource||IronSource, 17 Bluxome St, San Francisco CA 94107, USA||Device type (manufacturer and model), operating system, IP address, Advertising Identifier, and/or, time zone, language settings, type of internet connection, geographic information on the device, type of advertising, content of advertising, post-click information related to advertising.|
|Ogury||Ogury Ltd., 3rd floor, Classic House, 174-180 Old Street, London EC1V 9BP.||The type of Device being used (including manufacturer and model); the version number of the Ogury Technologies used by the App; the User’s network status (limited to connection type; gsm, 3G, 4G/wifi etc); the User’s email address & other mobile advertising identifiers on the Device; your Device’s unique Advertising ID; IP Address|
|Vungle||Vungle Inc., 185 Clara Street San Francisco, CA 94107, USA||IP address, Android ID, MAC address, Advertising ID, activity and page visits, language, device information, time zone and city, geographic information, operating system, information about installed apps, and already viewed advertising.|
|TikTok/Bytedance||Beijing Bytedance Technology Co., Ltd. No. A48, Zhichun Road, Haidian District Beijing, Beijing, 100000 China||IP address, device information including, but not limited to, identifier, name, and type of operating system, information obtained from Cookies (as defined below) and other tracking technologies, time zone and locale setting, and server logs (which can include information like access dates and times).|
|Tapjoy||Tapjoy Inc, 353 Sacramento Street, San Francisco CA 94111, USA||Device identifiers, information about the device itself, information about the internet connection used to access our services, information about the app and the SDK, location-related information, ad-related information, survey information, information from advertisers or publishers.|
|Mintegral||Mintegral International Limited, 31F Radiance (Jinhui) Qiyang Rd., Wanging, Chaoyang District, Beijing, China||Personal information including the following: device make, device model, operating system (e.g.iOS), device type (e.g. smartphone, tablet, etc.), device properties related to screen size, orientation and battery, carrier, name and properties of mobile application through which a consumer interacts with the Mintegral Services or services provided by Mintegral’s business partners, country, time zone and locale settings (country and preferred language), network connection type, IP address, Internet browser user-agent used to access the Advertising Services, , network provider, SDK version, timestamp, API key (identifier for application), application version, iOS Identifier for advertising, OS version of device, network status such as WiFi, the geo-location of the device, Advertising ID, international mobile equipment identity (IMEI), , the content type of the ad (what the ad is about, e.g. games, finance, entertainment, news), the ad type (e.g. whether the ad is a text, image, or video based ad), device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL.|
|HyprMX||HyprMX Mobile, LLC, 28 W 44th Street, NY 10036, USA||Registration and survey information, consisting of information you choose to submit
Activity and device information, device, operating system and browser, IP address ads or engagements viewed and interacted with, advertising identifier, geolocation Data, wireless service provider.
|InMobi||InMobi Pte. Ltd, 30 Cecil Street #1908 Prudential Towers, Singapore 049712||Device Identifiers such as advertising IDs and cookie IDS; Location information; Network information such as mobile carrier, IP address; Information about the accessed apps such as app version and app identifier; Device-specific information such as device model, operating system and technical information; Advertising engagement information such as content and type of the ads watched and interaction with ads; Survey information as voluntarily provided (e.g. name, age, email address)|
|Fyber||Fyber Monetization Ltd., 4 Hapsagot Street, Petach-Tikva 4951447, Israel||Device-specific information, such as device type, operating system and model, network provider, browser type, language; mobile application information, such as package name, key words, version.
mobile advertising ID, (Apple IDFA or Google AAID); IP address, network connection type and device GPS location (only if the User provided permission); Information from Supply Partners, such as a User’s age, gender and zip code; Information from other than the mobile application, such as non-precise device location based on IP address, device specifications and User’s interests.
You can object to the use of personalized advertising by making the following settings depending on your device type: On iPhone or iPad, first open “Settings,” tap on “Privacy,” and open “Advertising.” Here you can enable “Limit Ad Tracking.” If you use devices with Android and Google Play Services, first open “Google Settings,” tap on “Advertising,” then open “Disable interest-related ads,” then tap on “OK.”
5. DISCLOSURE OF DATA
We may share your Data with:
- The technical service providers involved in the supply of the Services. As subcontractors, these service providers are under the same obligations as Kolibri Games GmbH to comply with applicable data protection laws.
- The partners who use your Data to provide you with personalized advertisements or Personalized Content.
- Other companies, only in the event of a transfer of Kolibri Games GmbHs activities.
- Administrative or judicial authorities to verify the proper use of our Services or for the purposes of an investigation, in compliance with applicable law. Kolibri Games GmbH always verifies the legitimacy of the request.
In such cases, your Data may be transferred to countries located outside of the European Union who provide an equivalent level of protection. In the event of transfer to other countries, the protection of your Data is especially ensured by the signature of standard contractual clauses approved by the European Commission.
6. DELETION OF YOUR DATA
Unless the law specifies a different retention period, we will delete or anonymize your personal information as soon as it is no longer needed for the purposes for which we collected or used it in accordance with the preceding paragraphs. If Data must be kept for legal reasons, they are blocked and no longer available for further use.
7. BASES OF DATA PROCESSING
We may use your Data in one of the following circumstances:
- The existence of a contract between us to provide you with Services. You enter into this contract with us by accepting our Terms and Conditions.
- Our legitimate interest (or reasonable expectations of users), to offer you the best possible user experience, such as to ensure the security of the Services, moderate the community or respond to your requests and questions.
- If it is required to comply with a legal obligation or document compliance with legal obligations.
- Your consent to offer you advertisements, products, services or personalized content depending on your user profile.
8. AGE LIMITS
To use our Services you must confirm full legal capacity or, in case of restricted legal capacity, obtain the consent of your legal guardian. We do not knowingly collect or ask for personal information from children. In case you can’t confirm full legal capacity, please do not send us any Data about yourself, including name, address or email address. If we learn that we have collected Personal Data of a child, we will delete these as soon as possible. If you think that we might have Data from a child, please contact us at email@example.com.
However, we may collect technical information required for delivering the Service and for the support of our internal operations from all users of our Services. For more information, please see the article on the access and terms specific to minors in our Terms and Conditions.
9. YOUR RIGHTS
Obtain a copy of your Data – “Right of access and data portability”:
At any time, you can request a copy of your Data. You may also consult the Data, use it yourself or transfer it to another service provider.
Correct your Data – “Right to rectification”
You have the right to correct your Data when it is inaccurate or incomplete (for example, change your address).
Delete your Account – “Right to erasure (right to be forgotten)”
You can request the closure of your Account and the deletion of the associated Data.
Limit the use of your Data – “Right to restriction of processing”
You also have the right to request that your Data no longer be used or not be deleted during the time we are processing your request.
Give and withdraw your consent – “Right to object and withdraw your consent”:
At any time, you may withdraw your consent or object to the receipt of newsletters and advertising emails, the personalization of advertisements or the sharing of your Data with our partners (except for technical service providers) by email request to firstname.lastname@example.org.
We will not discriminate against and, therefore, not deny requests without legal reason, provide a different level of service or charge different prices to players that choose to exercise their rights.
If you feel that your rights have not been respected after having contacted us, you have the right to make a complaint to the competent supervisory authority. For the state of Berlin, the competent authority is:
Berlin Commissioner for Data Protection and Freedom of Information
Last updated: November 17th, 2021