1. AN OVERVIEW ON DATA PROTECTION
1.1 General information
The following information will provide you with an easy to navigate overview of which data we collect how as well as the purposes we use this data for when you play our games.
The term „personal 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).
1.2 Data Recording
How do we collect 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, for example. Other data is automatically collected when you download and use our games.
What are the purposes we use your data for?
What rights do you have as far as your information is concerned?
You have the right to receive information about the source, recipients and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. Please do not hesitate to contact us at any time under the address disclosed on the imprint of this website if you have questions about this or any other data protection related issues. You also have the right to log a complaint with the competent supervising agency.
Moreover, you have the right to demand the restriction of the processing of your personal data.
Analysis tools and tools provided by third parties
If you download and use our games, your usage data may be statistically analyzed.
Such analyses are performed primarily with what we refer to as analysis programs. The analyses of your usage data are usually conducted anonymously; i.e. the patterns cannot be traced back to you.
2. GENERAL INFORMATION
The responsible party (referred to as the „controller” in the GDPR) is the natural person or legal entity that single handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g. names, e-mail addresses, etc.).
The controller according to data protection laws is:
Kolibri Games GmbH
Hallesches Ufer 60
If you have any questions or suggestions about data protection, you can send us an email to email@example.com
Our data protection officer can be reached here.
3. COLLECTION AND USE OF YOUR DATA
3.1. Facebook Highscore
You do not need to register in order to play our games. You can however voluntarily connect your game with your Facebook account in order to participate in the Facebook Highscore.
If you connect your Facebook account with our games, the following data is shared with us:
- Profile picture
- Date of birth (if indicated by Facebook)
- Place of residence (if indicated by Facebook)
Please note: If you participate in the Facebook Highscore, your friends can also see that you play our respective game and you will also be displayed in the Highscore of your friends. In addition, when your Facebook account is connected, a list of your friends who also participate in Facebook Highscore and who have connected their Facebook account with their game is shared.
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.”
We collect this data in order to provide our app to you and to be able to connect your account if desired, Article 6(1)(b) GDPR.
To the extent that we, as described above, process your data for the purposes of providing the functions of our app, you are contractually required to provide us with this data. Without this data, we are not able to provide these functions to you.
You are not required to provide the above voluntary information. Without this data, however, we are not able to provide these functions of our app to you.
3.2. Support requests
If you send support requests to us by email, via integrated HelpShift chat within the games or via messages within social media platforms, we collect and process the data from your request and data from your account, such as username and country.
We only collect this data in order to appropriately respond to your questions, to provide our app to you and to be able to process your request based on the contract we passed when you accepted the Terms and Conditions.
When you send support requests directly via the chat system integrated into our games, your provided personal data will be transmitted to our help desk provider HelpShift. 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 (e.g. after completion of your request). Mandatory statutory provisions in particular statutory retention periods remain unaffected.
Our app uses the following permissions:
|Autostart||Necessary for sending notifications to the user|
|Network connection display||Receives information regarding the existence of and connection to networks.|
|Google Play billing service (Android)||Allows the user to purchase in-game products.|
|Full access to the network||Necessary for sending data to the Internet.|
|Location||Necessary to provide contextually relevant and/or personalized customer experiences|
|Search & Siri suggestions (iOS)||If this function is enabled, information from the game can be displayed when searching, looking things up, and when keyboards are displayed, and Siri can learn from use of the app and make suggestions.|
|Notifications (symbols, tones, banners, control of vibration)||If notifications are enabled in the settings, these can be sent to the player in order to display important events over the course of the game.|
|Background updates||If this function is enabled, background updates can take place.|
|Mobile data||The player can allow access to mobile data so that it can use all the functions of the game without being connected to Wi-Fi.|
|Access to local storage||The app characterizes the local storage and accesses it in order to be able to execute the services.|
5. STATISTICS AND ANALYTICS
For the needs-oriented design and statistical analysis of usage of our app, we collect pseudonymized data about how our apps are used, and we evaluate this data statistically.
We collect this data on the basis of a legitimate interest in needs-oriented design.
6. 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 IDFA and usage information.
We use the following advertising networks in order to be able to integrate advertising within our free-of-charge apps. These collect the data described below for the purpose of providing personalized advertising:
|Advertising network||Provider||Type of data|
|AppLovin||AppLovin Corporation, 849 High Street, Palo Alto, CA 94301, 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;
|AdColony||AdColony Inc. 1888 Century Park East, Suite 1450, Century City, CA 90067
|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 Inc., 85 Second Street Suite 100, San Francisco, CA 94105, USA||Language, operating system, device type, IP address, MAC address, device ID, IDFA, Google 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 ApS, Vendersgade 28, Sal 1, Kobenhavn, 1363, Denmark||Device information, IP addresses, device identifiers, combined with Unity Analytics to personalize advertising.|
|IronSource||IronSource Ltd., 28 Lilienblum, Tel Aviv, 6513307, Israel||Device type (manufacturer and model), operating system, IP address, Android Identifier, and/or IDFA, 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.
A 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, such as Google AAID or Apple IDFA.
|Vungle||Vungle Inc., 185 Clara Street San Francisco, CA 94107, USA||IP address, Android ID, MAC address, IFA, UDID, activity and page visits, language, device information, time zone and city, geographic information, operating system, information about installed apps, and already viewed advertising.
|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, Room 701 A, 7th F. OfficePlus @ Prince Edward 794-802 Nathan Road, Kowloon HongKong||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 and the Identifier for Advertising (IDFA) or the Google Advertising ID AAID, GAID, etc., 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.|
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.”
Use of the aforementioned advertising networks and the transmission of the data mentioned is based on our legitimate interest in recouping our investments for operation of our app through advertising.
7. 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 personal 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.
8. 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, unless the data must be kept longer for legal purposes.
If data must be kept for legal reasons, they are blocked. In that case they are no longer available for further use.
9. 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 firstname.lastname@example.org.
10. YOUR RIGHTS
10.1. Right to information
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.
10.2. Right to rectification
You are entitled to demand that we correct forthwith any inaccurate personal data concerning you.
10.3. Right to deletion
You have the right to request the deletion of your personal data. Your data will be deleted if it is no longer needed for the purposes for which it was collected or otherwise processed, if it was unlawfully processed, if you object to the processing or if deletion is mandatory under EU law or under the law of a Member State to which we are subject.
10.4. Right to restriction of processing
You are entitled to demand that we restrict processing in accordance with Article 18 GDPR. This right applies especially if we are not in agreement with the user concerning the accuracy of any personal data. The right persists for the time required to verify its accuracy. In addition such right applies in the following cases: if the user is entitled to demand deletion but instead demands restricted processing; if the data is no longer required for the purposes we are pursuing, but the user needs them in order to assert, exercise or defend legal claims; and if an objection has been raised but its successful exercise is still disputed between us and the user.
10.5. Right to data portability
You are entitled to demand from us whatever personal information you may have given us. Pursuant to Article 20 GDPR, at your request we must provide you with such information in a structured, commonly used and machine-readable format.
If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.
10.6 Right to object
10.7. Right to lodge a complaint
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 region of Berlin the competent authority is:
Berlin Commissioner for Data Protection and Freedom of Information
10.8. Right to non-discrimination
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.
Last updated: January 6, 2021