Privacy Policy

Friday, Mar 24, 2023

This is the Privacy & Cookies Policy (the ‘Policy’) of Game Cookie Studio (‘Game Cookie Studio’). This Policy describes the ways in which Game Cookie Studio collects and uses information about you when you play one of Game Cookie Studio’s games (each a ‘Game’ and together the ‘Games’) on a browser, through a social networking site, or as an app. It also details how Game Cookie Studio collects and uses information about you when making a complaint to Game Cookie Studio by e-mail.

Game Cookie Studio may change this Policy at any time and when this happens we will notify you of any changes to this Policy by noting this on our Website as well as within the Games. The changes will apply to your use of the Website and/or our Games after we have notified you. If you do not wish to accept the new Policy you should stop using the Website and/or playing our Games (as applicable). If you continue to use our Games after the changes, your continued use of the Website and/or your continued playing of any of our Games show us your agreement to be bound by the new policy.

For the purposes of data protection legislation, Game Cookie Studio is the controller for the processing of your personal data. The notification indicates what data is processed by Game Cookie Studio and for what purpose, and to which persons or entities the data will be provided. If you have any queries about this Policy, please contact Game Cookie Studio using the contact details mailto:feedbackgamepark@gmail.com

1 WHAT PERSONAL DATA IS AND WHO DOES THIS POLICY APPLY TO

Personal Data means information that identifies, relates to, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or household, including identifiers such as a real name, alias, device identification number, location data, an online identifier, commercial information (including products or services purchased), or as further defined under the General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”) (as applicable). We indicate in this Policy the information we collect from you.

By playing the Games or visiting the Website you are agreeing to be bound by this Policy in respect of the information collected about you. Game Cookie Studio may change this Policy at any time. Game Cookie Studio shall deem your continued use of the Games. This Policy applies to the following people:

A. people who use the Games; and

B. people who make complaints to us by email.

2 PEOPLE WHO CONTACT OR MAKE COMPLAINTS TO Game Cookie Studio BY EMAIL

When Game Cookie Studio receives complaints by email it shall file any relevant document and may retain details of the complainant, and other individuals identified in the complaint. Game Cookie Studio will only use this information to process the complaint and to check on Game Cookie Studio’s services and staff.

Game Cookie Studio shall retain information in relation to a complaint for a maximum of six (6) years after its closure, in a secure environment, and access to it will be restricted on a ‘need to know’ basis. Game Cookie Studio relies on the legitimate interests processing ground to collect the information set out in this paragraph.

It is in Game Cookie Studio’s legitimate interests to collect such items of personal data listed here because this is necessary in order to analyze and respond to your complaint.

The items of personal data collected are not of a nature whereby your rights and freedoms as a data subject are outweighed by such data collection.

3 PEOPLE WHO USE THE GAMES

A. Game Data:

Game Cookie Studio will collect the following information from you when you use the Games:

i. if you make any purchases, Game Cookie Studio will collect certain information in relation to your purchases (please see paragraph 4(b) below) (“Finance Data”);

ii. if you consent or where we are otherwise permitted to send such communications in accordance with applicable data protection and electronic marketing legislation, to provide you with a newsletter and other marketing information which we consider you may be interested in (for example in relation to ours or our group’s other games) (“Marketing Data”); and

B. Financial Information:

Your purchase and in-app purchases within the Games are handled through the platform on which you purchased the Game or through other payment processors (e.g. the Apple App Store, Google Play). Game Cookie Studio does not retain any card or payment details, although Game Cookie Studio does keep a record of your purchases and your aggregate spending.

4 HOW GAME COOKIE STUDIO USES COLLECTED INFORMATION FROM PEOPLE WHO PLAY THE GAMES

Game Cookie Studio will use the information it collects as set out above:

A. in relation to the Game Data, offer the Games to the player in question;

B. in relation to the Analytics Data, to facilitate the improvement of the Games and your experience of the Games;

C. in relation to the Game Data and Finance Data to complete your transactions;

D. in relation to the Game Data to provide technical support in relation to player inquiries, resolving disputes, collecting fees, and troubleshooting;

E. in relation to the Game Data to prevent fraud or illegal activities;

F. in relation to the Game Data to serve targeted adverts to you (where you consent to this). You may opt-out of your Game Data being used for this purpose (or change your settings at any time) within the “Ad Settings” item of the “Settings” menu in-Game or by: (i) for iOS, going to “Settings”, scrolling down to “Privacy”, scrolling down to “Advertising” and then shifting the “Limit Ad Tracking” slider to the right; and (ii) for Android, going to “Settings”, scrolling down and clicking on “Google”, scrolling down and clicking on “Ads” and then shifting the “Opt out of Ads Personalisation” slider to the right.;

G. in relation to the Marketing Data, to provide information about the Games, applications, services, and other digital goods which Game Cookie Studio thinks may be of interest to you. You can tell us to stop this at any time by sending an e-mail to mailto:gamecookie966@gmail.com;

H. share with third parties for the purposes as described in paragraph 5 below.

I. Device ID, Device Information (application version, battery level, WiFi strength, available space, network type, OS version, platform, carrier, country code, series ID, Android ID, IDFV, device language, screen DPI, device resolution, screen direction, brand, manufacturer, device model, XID (if you are a guest user, generated from your existing device information, model, manufacturer, Android ID), time zone settings, RAM, ROM, and CPU information), registration time and login time.

J. Where We use this information:

to confirm the current network type;

to provide users with network-type display;

to facilitate the automatic download of important resources via WIFI;

to improve our services, including the functionality of the Game;

for security and verification purposes;

identify and address bugs and assess game function for optimization; and

to combat users registering for multiple accounts.

5 SHARING INFORMATION WITH THIRD PARTIES

Game Cookie Studio will not pass your information to third parties other than as described in this paragraph. Game Cookie Studio may, subject to its obligations to comply with applicable data protection legislation, share your information with third parties including:

A. the third parties who assist Game Cookie Studio in collecting the Analytics

6 CHILDREN’S PRIVACY

Game Cookie Studio’s are intended for anyone who is legally entitled to own a device that accesses them and plays them and anyone who is legally entitled to make in-app purchases by the payment functionality the Games provide.

However, Game Cookie Studio does not knowingly collect personally identifiable information in relation to children under the age of 13. If Game Cookie Studio discovers it has collected personal data in relation to any children under 13 Game Cookie Studio shall take reasonable steps to delete such information.

You may also be required to obtain your parents’/guardians’ permission to play the Games if you are under 18, as indicated in our Terms of Service.

7 CONTACT DETAILS

If at any time you would like to contact Game Cookie Studio about your views on this Policy or any inquiry relating to your personal information, including but not limited to your rights under the GDPR and/or CCPA (as applicable), you can do so by sending an e-mail to us at mailto:gamecookie966@gmail.com

8 EXERCISING YOUR RIGHTS

You can contact us using the details set out in paragraph 7 above if you wish to:

(i) access a copy of the personal data that we hold about you including what categories of personal data we have collected or hold about you; the categories of sources from which we collect the personal data; the business or commercial purpose for collecting or disclosing the personal data; the categories of third parties with whom we share your personal data; and the specific pieces of personal data that we have collected about you);

(ii) correct any items of personal data that we hold about you;

(iii) have any items of personal data that we hold about you erased or object to our processing of such items of personal data; and/or

(iv) if applicable pursuant to the CCPA, receive a free copy of your personal data within 45 days of your verifiable request in a structured, commonly used, and machine-readable or commonly used electronic format on request.

Game Cookie Studio may ask you to verify your identity before Game Cookie Studio responds to such requests.

Please note that under the CCPA, Game Cookie Studio is not required to delete information that is necessary to perform certain actions as outlined in the CCPA (e.g. to complete a transaction for which the information was collected or to provide the goods or services requested by you).

You will not be discriminated against in retaliation for exercising the above rights and rights under the CCPA.

9 COOKIES AND OTHER SIMILAR TECHNOLOGIES

A. What are Cookies?

Cookies are small text files that are placed on your device when you visit a Website. Other similar technologies, defined in this policy as “Technologies”, are third-party technologies used in a Game.

Game Cookie Studio’s use of cookies and Technologies is detailed below.

In our Games, we use Technologies that track or store your data for advertising, attribution, or analytics purposes.

B. Disabling Cookies:

The use of the cookies and Technologies described above improves the functionality of the Games.

If you do not want these cookies and/or Technologies to be served on your device, you are able to disable them by changing the settings on your device.

10 Family Privacy

We consider ourselves to be family-oriented, however, we have decided to voluntarily implement higher child protection standards even though our products and services are not directed to, and we do not knowingly collect personal information from children under 13, with the sole exception of persistent identifiers as described below. If we learn that we have collected personal information other than the persistent identifier of a child under the age of 13, we will take all reasonable steps to delete the information as soon as possible. If you become aware that your child has provided us with personal information without your consent.

To preserve the family-friendly reputation of our Apps, we age-gated some of the features in our Apps, so that they are not available for use by children under 13. The age gate is being conducted after the download of some of our Apps for specific territories to assure the privacy and protection of younger users of our Apps. The features enabling potential collection and sharing of personally identifiable information, except for persistent identifiers, are disabled for device IDs of users who did not pass the age gate. For the user’s safety, it is not possible to change the age later on. We do not store the year of birth of users who have identified themselves as below the age of 13 in our Apps, but only the information that their device ID did not pass the age gate.

The only personal information we collect from users who have identified themselves as below the age of 13 for the purposes of offering our services are persistent identifiers (such as device ID, IDFA, IDFV, advertising ID, publisher-provided ID, and IP address). Such persistent identifiers are used and shared with third parties solely for providing support for internal operations meaning to place a contextual advertisement (including frequency capping), to authenticate users of or personalize the content on Apps, to maintain or analyze the functioning of the Apps, personalize the content of the App (such as sending push notifications), to perform network communications to protect the security or integrity of the user or the App, to ensure legal or regulatory compliance.

When using the persistent identifiers, we will not contact users under the age of 13, display behavioral advertising to them, or do any user tracking or profiling. In addition, we strive that all of our advertising partners adhere to the same standards for the collection, usage, and disclosure of children’s personal information as we do, but we cannot be responsible if they breach the commitments, they gave to us regarding the collection of information. In case of such breaches, you agree that our liability is limited to the amounts we can receive as indemnification for the breaches from our advertising partner. We will send push notifications only to users who allow us to do so to reengage them in terms of using the App. You may unsubscribe at any time by following the instructions in the section Push Notifications of this Privacy Policy. We strive to ensure that the content of the push notifications will always be family-friendly. Push notifications are local, contextual, and sent in the app only and not from a server or in conjunction with other user information.

Game Cookie Studio