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PRIVACY NOTICE
We at Key Games Network B.V. (“Key Games”, “Azerion Casual” “we”, “us” or our”)
respect your privacy and recognise the importance of providing a secure environment for
your personal data. Therefore, we are committed to being transparent about how we
collect and process your personal data.
The purpose of this privacy notice (“Privacy Notice”) is to inform you as a user about why
and how we process your personal data (that is any information that can be linked or
attributed to you, (“Personal Data”) when you play our games that link to this Privacy
Notice (“Games). This includes information regarding with whom we will share your
Personal Data, how long we will retain it, and which rights you have in relation to the
processing.
In this Privacy Notice, we will give you general information about how we process your
Personal Data. We will furthermore give you more detailed information on the specific
processes within our Games.
I. GENERAL INFORMATION
In this part of our Privacy Notice, you will find general information about how we process
your Personal Data when you play our Games. For specific information with more details
about our processing activities, please see the specific information below.
II. Who is Responsible for the processing of your Personal Data?
Key Games Network B.V. Boeingavenue 30 1119PE SCHIPHOL-RIJK, Netherlands is
responsible (“the Data Controller”) for the processing of your Personal Data.
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1. Information Specific to My Dolphin Show and Play Along
Miffy Games
This section includes information specific to the data processing activities for My
Dolphin Show and Play Along Miffy games.
Please note that if a game is for children or for a mixed audience, we do not serve
interest-based advertising. We also do not actively collect information from users
when they play a game directed at children.
1.1. What information does Azerion collect?
Azerion collects certain information when you play our Games. As a general principle,
we do not collect and do not ask you to provide any “special categories of Personal
Data”, which is any particularly protected information such as data concerning
health, religion, political opinions or philosophical beliefs, sexual preferences or
orientation. We may also collect information from third parties such as payment
service providers.
We process the following types of your Personal Data:
1.1.1. Personal Data provided by you:
Information provided in relation to our customer service: When you contact
support, we collect your contact details (your username and your email address),
information about your request (subject and content of your request), and your
device information (IP address for location analysis, device ID and user ID).
Information provided in relation to transaction and payment: When you make
a purchase on our Games (e.g. new characters, skins or outfits) we collect information
which is related to your transaction, for example the payment method, purchased
items and date. We do not collect any card data or financial information, you will be
redirected to app stores acting as payment providers for the transaction of your
payment; we only receive payment confirmation details from our payment provider.
Information provided via social media: We manage various social media accounts
and fan pages for our games. When you contact our fan pages, we collect your social
media account details (your name or username and your profile photo) and
information about your correspondence (contents of your message).
1.1.2. Personal Data we receive or generate from your use of our Games
Your usage: We collect information about how you play our Games. This information
includes the actions you take within the game (e.g. your achievements such as the
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level reached, the items purchased within our Games and the amount you spent in
our Games), the time and duration of your activity. Part of this information will be
stored in your account (such as your in-game progress).
1.1.3. Personal Data we collect from third parties
Payment Providers: If you make an in-app purchase, the transaction will be
processed by a third-party payment provider and will be subject to privacy policies of
third-party payment providers. For these transactions, we do not receive any
complete financial information (such as your full credit card information) but receive
information which is related to your transaction, for example the payment method,
amount, status and date.
1.2. For What Purpose Do We Process Your Personal Data?
When you play our Games, we use the information that we have about you:
To provide you with our Games and associated websites, and continuously
improve their features;
To store your gaming history;
To provide help desk and support services;
To analyze the functioning of the Game and associated websites;
To enable in-app purchases;
To prevent fraud and crime;
To enforce our policies and terms of use
To meet legal and tax obligations.
To determine the legal requirements for processing of your Personal Data
(based on your location and your age)
To keep records related to purchases
1.3. On which legal basis do we process your Personal Data?
Performance of a contract: We process your Personal Data for the performance of a
contract or to take steps prior to entering into a contract to which you are a party.
For example, where it is necessary to process your in-game purchase and the
associated payment, in context of customer service, to support the operation of the
game or facilitate the delivery of requested services.
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Compliance with legal obligations to which we are subject: We process your
Personal Data to comply with legal obligations, for example, in order to verify your
age, for tax and accounting purposes or legal disputes.
Legitimate interests: We also process your Personal Data to the extent that the
processing is necessary for our legitimate interests or those of third parties while
applying appropriate safeguards that protect your privacy.
1.4. Where will my Personal Data be processed?
Our Games are hosted within the European Economic Area (EEA) and your personal
data will be stored by Azerion in the EEA. To the extent that your personal data is
processed by our partners in a country outside of the EEA, we have taken all such
measures as are necessary to ensure an adequate level of protection for your
personal data in accordance with the requirements of applicable data protection
legislation including the execution of the European Commission’s standard data
protection clauses (also known as Model Clauses).
1.5. How long do we store your Personal Data?
Your personal data will only be stored for a period necessary for your use of our
Games for the purposes as described in this Privacy Notice or necessary for the
establishment, exercise of defense of legal claims or resolving disputes. Afterwards,
we will delete or anonymize your Personal Data. Please note that you always have
the right to request erasure of your personal data, after which we will take reasonable
measures to delete your personal data. However, you acknowledge that even if you
have requested deletion of your personal data, we may retain some information.
1.6. Which third parties have access to your data?
We will not disclose your Personal Data to any party who is not authorised to process
them. To manage our Games, we will share your Personal Data internally with
members of our responsible departments, technical support or customer support
involved in the gaming process and in each case only if access to your Personal Data
is necessary for the performance of their roles.
Moreover, and only when necessary to fulfil the purposes mentioned above, we
disclose your Personal Data to the following recipients or categories of recipients or
allow the following third parties to collect your Personal Data in connection with your
use of our Games. If you have any questions about how these third parties use your
information, we recommend you review their policies and contact them directly.:
Hosting and content delivery: Our Games are hosted by external companies
providing servers. Every time you make a request, for example by clicking on a link
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on our Games, the information allowing this request (e.g. device information and
information on requested content) as well as online identifiers (your IP address) will
be sent to the external servers. This data is used to show you the content you
requested. We process this data on the basis of legitimate interest, to provide our
Games and ensure their functionality.
Payment Service Providers: Azerion may also use third-party payment service
providers (“PSP”), offering payment transaction services to Azerion in order to sell a
product or service through our Games. The PSP acts a data controller with regards to
the personal data related to the transactions processed for the purpose of purchasing
the product or service. The transaction data may include your personal details, your
payment card details, and the transaction details. Whenever you buy something in
our Games (e.g., a virtual game item), the information that you provide to the PSP is
subject to their privacy policies, not ours. The legal basis for this processing is the
performance of a contract. After you have purchased a product or service, Azerion
and the PSP have a legal requirement to retain your information for a legally
determined period of at least 7 years. Azerion shall be allowed to notify a PSP
regarding a user that engages in (or who a party believes has engaged in) any activity
that is illegal, that violates any person’s rights, or that led to such a user’s suspension
or termination of use of the Games. Azerion shall be allowed to notify a PSP regarding
a user who engages in (or who a party believes has engaged in) any activity that is
illegal, that violates any person’s rights, or that resulted in such user’s suspension or
termination of use of a Game.
Customer Support Partners: Azerion uses third party service providers in order to
offer our users customer support services. We may share personal data such as the
communication content, IP address, email address, and username (“Correspondence
Data”) with these partners. The Correspondence Data may be processed by Azerion
and business partners for the purpose of communication with you, blocking users,
changing email addresses, reactivating or blocking accounts, adding or removing in-
game items, and other customer support services. The legal basis for the processing
of the Correspondence Data is performance of contract.
Partner networks: Azerion may use partner network providers who assist us to
distribute the Game in order to enable as many gamers as possible to play the Game.
Law enforcement, government authorities or courts: We disclose your Personal Data
in response to lawful requests from public authorities, including law enforcement,
government authorities, supervisory authorities or courts.
Other third parties: We also disclose your Personal Data in the event of any
contemplated or actual reorganization, merger, sale, joint venture, assignment,
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transfer or other disposition of all or any portion of our business or assets (including
in any insolvency or similar proceedings).
1.7. Your rights
To the extent permitted by applicable data protection laws and regulations, you have
the following rights in relation to your Personal Data:
Access to the Personal Data we hold about you
Request the update or correction of your Personal Data
Receive your Personal Data in a structured, commonly used and machine-
readable format
Request the deletion of your Personal Data where there is no good reason for
us to continue to process it
Restrict the processing of your Personal Data
Withdraw your consent
Right to object
If you wish to exercise these rights, you can by sending a written request to Azerion
B.V., Beechavenue 182 1119 PX, Schiphol-Rijk, The Netherlands, detailing your
request, (to prevent misuse of requests for information), or sending an email
containing your request to: dpo@azerion.com.
Azerion does not knowingly process personal data from anyone under the age of 16
without parental consent. In the event we find out that we have processed personal
data of anyone under the age of 16 without parental consent, we will promptly delete
such data. Parents of users under the age of 16: if you wish to have access to your
child’s personal data to view, correct, or delete the information that we have
collected about your child, please send a written request to Azerion B.V.,
Beechavenue 182 1119 PX, Schiphol-Rijk, the Netherlands, detailing your request
along with a copy of your passport (to prevent misuse of requests for information),
or send an email with all such information to dpo@azerion.com. After verification,
the copy of your passport will be shredded.
In the event you have any questions or concerns in relation to the processing of your
personal data, you can send an email to our Data Protection Officer by email at
dpo@azerion.com.
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If you are not satisfied with our responses and/or support to resolve your concerns,
you have the right to lodge a complaint with a supervisory authority, in particular in
the European Union (or European Economic Area) Member State where you work,
normally live, or where any alleged infringement of data protection laws occurred.
2. Information On Other Games
2.1. What types of Personal Data do we process and how do we
collect it?
When you play our Games, we collect, use, store and transfer different kinds of Personal
Data. As a general principle, we do not collect and do not ask you to provide any “special
categories of Personal Data”, which is any particularly protected information such as data
concerning health, religion, political opinions or philosophical beliefs, sexual preferences or
orientation.
The information we collect depends on which of our Games you have played and how you
have played them. We process the following types of your Personal Data:
2.1.1. Personal Data provided by you
When you use our Games, you provide or be asked to provide us certain information,
including:
Information provided in relation to our customer service: When you contact
support, we collect your contact details (your username and your email address),
information about your request (subject and content of your request), and your
device information (IP address for location analysis, device ID and user ID).
Information provided in relation to transaction and payment: When you make a
purchase on our Games (e.g. purchased items, extra in-game lives, hints to clear a
level or removing ads via payment) we collect information which is related to your
transaction, for example device information, country, region and the postal code.
We do not collect any card data, you will be redirected to appstores acting as
payment providers for the transaction of your payment, we only receive payment
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confirmation details from our payment provider. For more information, please see
the service specific information below.
Information provided via social media: We manage various social media accounts
and fan pages for our games. When you contact with our fan pages, we collect your
social media account details (your name or username and your profile photo) and
information about your correspondence (contents of your message). Never share
information or personal data that is harmful for yourself or others.
Your profile information: In some of our Games, you need to create a player profile
that other players can see. When you create a player profile, we collect profile
information provided by you to personalize your profile (such as a nickname or
character name, flag of a country chosen by you as part of your profile and
customized outfit of your avatar). This information will be combined with your user
ID.
2.1.2. Personal Data we receive or generate from your play of our
Games
When you play our Games, we also process device-related information and information
about how you interact with our Games, including:
Technical information: We collect information about your device/device settings
you use for the purposes described below. The information we obtain from your
device(s) includes the type of your device, device ID(s), user ID, IDFA or Google
Advertising ID, online identifiers (your IP address), timestamp, geolocation data
(based on your IP address and limited to the country) and other technical
information.
Your usage: We collect information about how you play our Games. This
information includes the actions you take within the game (e.g. your achievements
such as the level reached, the items purchased within our Games and the amount
you spent in our Games), the time and duration of your activity, and your interaction
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with advertisements (clicks, instals and creative views). Furthermore, we collect
information about the websites or apps that led you to our Games. Part of this
information will be stored in your account (such as your in-game progress).
2.1.3. Personal Data we collect from third parties
In certain scenarios, we will also obtain your Personal Data from third parties, in strict
compliance with applicable data protection laws and regulations. Your Personal Data may
be provided by the following third parties:
Payment Providers: If you make an in-app purchase, the transaction will be
processed by a third-party payment provider and will be subject to privacy policies
of third-party payment providers. For these transactions, we do not receive any
complete financial information (such as your full credit card information) but receive
information which is related to your transaction, for example the payment method,
amount, status and date.
Social Networks and connected third-party platforms:
For some of our Games, you have an option to connect with your Facebook account
by using your credentials with our log-in process. We receive certain information
about you from Facebook such as your first and last name, your profile picture, your
email address, your Facebook user ID, age-range and your authentication token. In
order to benefit from additional features in our Games (such as an achievement
system and leaderboards), you may also log-in with your Google Play Games or
Apple Game Center account. If you choose to log-in, we receive from Google or
Apple your game service username, email address, profile photo and levels reached
in the game service. To learn more about which data is processed when you use
these Games, please see the section with service specific information below.
User acquisition companies: If you click on our advertisements shown to you in a
third-party network or platform, we will receive campaign information (the
campaign ID, clicks on our ads, creative views), information about installs of our
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Games, your location, purchase data (purchase is made or not) and technical
identifiers (such as advertisement ID) from our user acquisition partners.
Other third parties: We also receive information about your approximate
geolocation (the country you are located in) from third parties (e.g. Google). We use
this information to comply with our legal obligations applying to the processing of
your Personal Data, customize certain services to your location, and for fraud or
abuse prevention purposes.
To learn more about which data is processed when you play our Games, please see the
section with service specific information below.
2.2. For what purpose do we process your Personal Data?
Depending on which Games you are playing and which privacy settings you have selected,
we process your Personal Data for the following purposes:
Provision and improvement of our Games
to allow you to play our Games
to create and manage your profile
to restore your account if you ever lose access
to facilitate your purchase, to verify and confirm your payment
to facilitate content sharing on social networks
to provide technical support and respond to your requests
to identify and correct any bugs/errors
to indicate the popularity of our Games
to assess the quality of our Games
to understand and improve your experience
Personalization of your game experience
to remember your preferred game settings
to remember you next time you play one of Games
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to provide you personalised in-game offers
to provide you rewards for daily log-ins to our Games
Marketing and analytics
to deliver (targeted and non-targeted) advertising in our Games
to show you advertisements for our Games on other websites or apps
to measure the effectiveness of advertising
to personalise advertising for you
to pay our business partners for the promotion of our Games
to send you push notifications, informing you about new content and in-game offers
Prevention of fraud and illegal activity
to investigate fraud and illegal behaviour in our Games
to enforce our policies and terms of use
Compliance with our legal or regulatory obligations
to determine the legal requirements for processing of your Personal Data (based on
your location and your age)
to keep records related to purchases
to respond to your requests related to your data subject rights
to comply with our legal obligations (e.g. tax and accounting obligations)
to inform you about any updates to this Privacy Notice
Please see the section with service specific information below for a more detailed
description of the purposes for which we process your Personal Data within our Games.
2.3. Do we engage in profiling activities?
If you consent to this via the consent management pop-up when you first initiate some of
our Games, we use tracking mechanisms to track your Personal Data for profiling purposes.
This allow us to serve relevant content to you and adjust both our Games and ads to your
interests. You have the right to object to this type of processing and you can also go to your
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in-game settings to review and amend your privacy choices related to this type of
processing at any time.
2.4. On which legal basis do we process your Personal Data?
We process your Personal Data for the purposes described in this Privacy Notice, based on
the following legal grounds:
Your consent: We process your Personal Data if you have provided your consent for
a specific purpose. For example, when you initiate our Games for the first time, we
ask for your consent for the data processing in the context of showing you
personalised content, offers and recommendations and for showing you interest
based ads. You have the right to withdraw your consent at any time, for example by
changing your in-game settings. Alternatively, you can always contact us from our
contact details below. Please note that this will not affect any processing carried
out before you withdraw your consent.
Performance of a contract: We process your Personal Data for the performance of
a contract or to take steps prior to entering into a contract to which you are a party.
For example, where it is necessary to process your in-game purchase and the
associated payment, in context of customer service, to support the operation of the
game or facilitate the delivery of requested services.
Compliance with legal obligations to which we are subject: We process your
Personal Data to comply with legal obligations, for example, in order to verify your
age, for tax and accounting purposes or legal disputes.
Legitimate interests: We also process your Personal Data to the extent that the
processing is necessary for our legitimate interests or those of third parties while
applying appropriate safeguards that protect your privacy. For example, we process
your Personal Data for improvement of our Games provided to you or to provide
you with a better user experience.
Please see for additional information the section with service specific information below.
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2.5. With whom do we share your Personal Data?
We will not disclose your Personal Data to any party who is not authorised to process them.
To manage our Games, we will share your Personal Data internally with members of our
responsible departments, technical support or customer support involved in the gaming
process and in each case only if access to your Personal Data is necessary for the
performance of their roles.
Moreover, and only when necessary to fulfil the purposes mentioned above, we disclose
your Personal Data to the following recipients or categories of recipients or allow the
following third parties to collect your Personal Data in connection with your use of our
Games. If you have any questions about how these third parties use your information, we
recommend you review their policies and contact them directly.:
External service providers: We share your Personal Data with external service
providers who perform services on our behalf, like customer support services, IT
services, analytics services and marketing services. Where we share your Personal
Data with external service providers, we have appropriate agreements in place to
ensure that your Personal Data is processed in compliance with applicable data
protection laws.
Backend as a service providers: In order to improve our development productivity
while delivering high-quality games to you, we use backend as a service platform in
our Games. These platforms automate backend side development for us so that we
only have to write and maintain the frontend. In other words, our Games do not
need to contain all the code in themselves and instead they fetch information from
the backend as a service solution. All features in our Games that you interact with
such as advertisements, in-game purchases, daily rewards and push notifications
are provided via a backend as a service tool. We share your Personal Data with the
backend as a service provider to deliver our games to you and for maintaining our
games. Backend as a service provider also offers analytics services and we share
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your personal data in this respect to be able to understand how well our games
perform.
Payment providers: If you make in-app purchases, the transaction will be processed
by a third-party payment provider and will be subject to the privacy policies of third
party providers.
External advertising companies: With your consent, we share your Personal Data
with third-party advertising companies or allow third-party advertising companies
to collect your Personal Data when you use our Games. If you choose not to receive
personalised ads at all, we will still show you ads, but they may not reflect your
interests as those ads will be content specific and not user specific. Please note that
by clicking on a third-party advertisement, you may be redirected to the third-party
advertiser’s environment over which the third party is in control.
Social networks and connected third-party platforms: For a number of our Games,
we have included a share button which enables you to share certain content on
social media. Once you press the button, you will be asked to log-in with your social
media platform credentials or other application credentials (such as your email
address for email apps or your phone number for sharing content on messengers).
In this case, the content you want to share (e.g. a screenshot from the game or your
high score) will be sent to the respective social network or third-party platform.
For some of our Games, you will find a Facebook share button which enables you to
share certain content on your Facebook timeline. Once you press the button, you
will be asked to log-in to your Facebook profile. In this case, the content you want
to share (e.g. a screenshot from the game or your high score) will be sent to
Facebook. Please be aware that because of how Facebook and its share function
works, Facebook collects data (such as your IP address and device information) even
if you do not use the share button.
We have included a Facebook and Google Play Games button on our Games and
Apple Game Center login on our iOS version to enable users to integrate with their
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social media profiles as and when they see fit to do so. Such parties may capture
some of your data that way. Please be aware that because of how Facebook and
Facebook Connect works, Facebook collects data (such as your IP address and device
information) even if you do not log-in and do not use applications via Facebook.
These parties are data controllers of the data collected through log-in for their own
purposes.
In order to increase the competitiveness for a few of our Games, we encourage you
to interact with other players. If you play these Games with your Facebook account,
your Facebook friends who also play our Games will see your name, photo, player
profile (which may include the information described above in Personal Data
provided by you), and descriptions of your in-game activity. Your Facebook friends
will also be able to interact with you through in-game activities such as comparing
high scores or sharing extra lives.
Law enforcement, government authorities or courts: We disclose your Personal
Data in response to lawful requests from public authorities, including law
enforcement, government authorities, supervisory authorities or courts.
Other third parties: We also disclose your Personal Data in the event of any
contemplated or actual reorganisation, merger, sale, joint venture, assignment,
transfer or other disposition of all or any portion of our business or assets (including
in any insolvency or similar proceedings).
Please see the section with service specific information below for more information about
the third parties we share your data with. Furthermore, you can find the third parties your
Personal Data be shared with by clicking on the following link:
3rd party list
2.6. Where will my Personal Data be processed?
In general, your Personal Data is stored on servers within the European Union (EU)/the
European Economic Area (EEA). We have implemented appropriate safeguards to protect
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your Personal Data when it is transferred outside the EU/EEA, including the execution of
the European Commission’s standard data protection clauses (also known as Model
Clauses) to provide safeguards for your Personal Data.
2.7. How do we protect your Personal Data?
We have implemented appropriate technical and organisational security measures
designed to protect your Personal Data against accidental, unlawful or unauthorised
destruction, loss, alteration, access, disclosure or use. We update and test our security
standards on an ongoing basis. In addition, we take reasonable steps to assure that third
parties to whom we transfer your Personal Data provide sufficient protection of Personal
Data.
2.8. How long do we store your Personal Data?
We will not retain your Personal Data longer than necessary to fulfil the purposes for which
the data was collected or to fulfil our legal obligations or necessary for the establishment,
exercise of defence of legal claims or resolving disputes. Afterwards, we will delete or
anonymize your Personal Data. Please note that you always have the right to request
erasure of your personal data, after which we will take reasonable measures to delete your
personal data. However, you acknowledge that even if you have requested deletion of your
personal data, we may retain some information after you have closed, or we have deleted,
your account with us.
2.9. What are your rights in respect of your Personal Data?
To the extent permitted by applicable data protection laws and regulations, you have the
following rights in relation to your Personal Data:
Access to the Personal Data we hold about you
Request the update or correction of your Personal Data
Receive your Personal Data in a structured, commonly used and machine-readable
format
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Request the deletion of your Personal Data where there is no good reason for us to
continue to process it
Restrict the processing of your Personal Data
Withdraw your consent
Right to object
In the event and to the extent that we process your Personal Data based on our legitimate
interests, you have the right to object to the processing on specific grounds relating to your
particular situation. In such cases we will no longer process your Personal Data unless we
have compelling legitimate grounds for the processing which override your interests, rights
and freedoms, or for the establishment, exercise or defence of legal claims.
You also have the right to object where we are processing your Personal Data for direct
marketing purposes (including profiling). In such a case, we will stop processing your
Personal Data for marketing purposes.
You can exercise these rights by sending a request to the contact details set out below,
providing your email address and other mandatory information (such as your user ID or
device ID) as well as a description of your request.
If you believe we have not complied with our obligations under applicable data protection
laws and regulations, you can lodge a complaint with a competent data protection
authority, for example the Autoriteit Persoonsgegevens in the Netherlands.
III. How can you contact us?
If you have any queries about this Privacy Notice or how we use your Personal Data or if
you wish to exercise any of your rights, please contact us via e-mail to dpo@azerion.com.
IV. How often do we update this Privacy Notice?
We regularly review this Privacy Notice. When there is a material change that will have a
relevant impact on the processing of your Personal Data, we will inform you with a message
or notification on our Games.
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This Privacy Notice was last updated on:
Version: Last Updated:
2.0 14.03.2024
V. Additional Information for California Residents
This section for California residents supplements the information provided in this Privacy
Notice and applies solely to players, and others who reside in the State of California. We
provide this section to comply with the California Consumer Privacy Act of 2018 (CCPA) and
the regulations issued under it; accordingly, this section addresses the specific
requirements of the CCPA and should be read together with this Privacy Notice.
We collect information that identifies, relates to, describes, references, is capable of being
associated with, or could reasonably be linked, directly or indirectly, with a particular
consumer or device. In particular, we have collected the following categories of personal
information (envisaged by the CCPA) from consumers within the last twelve (12) months:
Category A Identifiers (such as your device identifier, demographic information -such as
your country, your username, email address, any information you may choose to provide -
such as your age or your language-)
Category B- Personal information categories listed in the California Customer Records
statute (Cal. Civ. Code § 1798.80(e))
Category D Commercial information (such as purchase history)
Category F Internet or other similar network activity (such as your interaction with our
ads, your IP address)
Category G Geolocation data
The CCPA provides consumers (California residents) with specific rights regarding their
personal information.
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You have the right to access specific information i.e. you may request that we disclose
certain information to you about our collection and use of your personal information over
the past 12 months.
You have the right to deletion which means that you may request that we delete any of
your personal information we collected from you and retained, subject to certain
exceptions.
You have the right to opt out of any sale of your personal data by us to third parties. Please
note that your right to opt out does not apply to our sharing of personal data with service
providers, who are parties we engage to perform a function on our behalf and are
contractually obligated to use the personal data only for that function.
You can exercise these rights by sending a request to the contact details set out above,
providing your name, your email address as well as a description of your request.
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VI. SERVICE SPECIFIC INFORMATION
In this part of our Privacy Notice, you will find specific information on how your Personal
Data is processed. For general information about data processes that apply, please see
above.
Please note that this section is not applicable to My Dolphin Show and Play Along Miffy
games.
Hosting and content delivery:
Our Games are hosted by external companies providing servers. Every time you make a
request, for example by clicking on a link on our Games, the information allowing this
request (e.g. device information and information on requested content) as well as online
identifiers (your IP address) will be sent to the external servers. This data is used to show
you the content you requested. We process this data on the basis of legitimate interest, to
provide and improve our Games and ensure its functionality.
Age-gating and Consent:
For some of our Games, you have to be at least 13 or above years of age to play. When you
play these Games for the first time, we will ask your age bracket (0-12, 13-15 or 16+). Only
if you indicate being at over 13 or above years of age, you will be able to proceed and
provide (or not provide) your consent for our advertising, analytics and profiling activities,
obtained via a consent pop-up. We ask for your age bracket and your consent in order to
fulfil our legal obligation.
Some of our games are directed to children who are below the age of 13. We are doing our
utmost to not obtain any data other than strictly necessary to function in the games.
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Creation/administration of your account:
In order to attach all content and items within our Games to you, we create an account in
an automated way based on a random user id. We store your account data (user ID and
device ID) based on the performance of a contract.
Furthermore, for our Games that requires to create a profile, we will store your
personalized profile’s in-game progress and your virtual assets (customized outfits, in-game
currency).
If you choose to register using your Facebook, Google Play Games or Apple Game Center
account, we receive certain information about you from the respective third-party provider
like e.g. your name, your profile picture, your email address and an authentication token.
This information will be stored for your account’s lifetime to ensure that your in-game
progress and information is connected with the third-party platform and that you can log-
in with your credentials.
Your account data will be stored for as long as your account exists, based on the
performance of a contract. You can delete your account at any time, for example by
submitting a deletion request by contacting our Data Protection Officer through sending an
email to dpo@azerion.com. We may retain your account data after a deletion request due
to legal or regulatory requirements or for the reasons stated in this Privacy Notice.
Facebook Connect
We are offering you the opportunity to sign up for some of our Games through Facebook
Connect. In order to do this, you will be redirected to Facebook where you can log-in using
your Facebook account. Afterwards, your Facebook account will then be linked to our
Games.
Depending on your Facebook settings, linking your account will allow the following data to
be transmitted to us and/or retrieved by us: email address, name, profile photo and other
data that you have set to the public on your Facebook profile.
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We shall only use this information for identification purposes and contract processing. For
more information on Facebook Connect and the privacy settings, please refer to the
Privacy Policy and Terms of Use of Facebook Inc.
If you use Facebook Connect to register for and log into an account, your Personal Data
will be transmitted to Facebook, Inc. 1601 Willow Road Menlo Park, California 94025 in
the United States.
You can unlink the accounts at any time and revoke the transfer of data with future effect
by changing your settings on Facebook (here) and through in-game settings menu.
Google Play Games
Our Games also employs the Google Play Games sign-in button, which is operated by
Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States
(Google). The link can be identified by a “joystick” symbol available in the main menu of
Games.
We are offering you the opportunity to sign-in for our Games through Google Play Games
in order to benefit from additional features in our Games (such as an achievement system
and global leaderboards). To do this, you will be redirected to Google where you can log
in using your Google user data. Your Google Play Games account will then be linked to our
Games.
Please note that you are able to play our Games without logging-in via Google Play Games;
our full function with only missing features will be the ones provided by Google.
Depending on your Google settings, linking your account will allow the following data to
be transmitted to us and/or retrieved by us: username, email address, profile photo,
friends list and levels reached in the service, including any personal information you have
made publicly available on your Google profile.
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We shall only use this information for identification purposes and contract processing. For
more information on Google and the privacy settings, please refer to the Privacy Policy and
Terms of Use of Google Inc.
The purpose and scope of data collection via Google, the processing and use of such data,
as well as your rights thereof and personal settings regarding privacy protection can be
found in the Google privacy settings section https://policies.google.com/privacy?hl=en-US
You can unlink the accounts at any time and revoke the transfer of data with future effect
by changing your settings on Google (here).
Apple Game Center
You may also sign-in to our Games by your Apple Game Center in order to benefit from
additional features in our Games (such as an achievement system and global
leaderboards). To do this, you will be redirected to Apple where you can log in using your
Apple user data. Your Apple Game Center account will then be linked to our Games.
Depending on your settings, linking your account will allow the following data to be
transmitted to us and/or retrieved by us: username, email address, profile photo and levels
reached in the service, including any personal information you have made publicly
available on your Google profile.
For more information on Apple and the privacy settings, please refer to the Apple Privacy
Policy at: https://www.apple.com/legal/privacy/en-ww/
Facebook Integration:
In order to make our Games more interactive experiences, some of our Games are
integrated with Facebook. Our Facebook integrated Games offer you Facebook as
more than just a log-in service. If you prefer, Facebook can become part of your
gaming experience. For instance, you can ask lives from your Facebook friends when
you are out of them or you can seek assistance (hints) from your Facebook friends.
Depending on your Facebook settings, your account will allow the same data as
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Facebook Connect to be transmitted to us and/or retrieved by us: email address,
name, profile photo and other data that you have set to the public on your Facebook
profile.
Azerion Connect:
Azerion Connect provides a single sign on (SSO) service by generating a unique user
ID for each user. The user ID is recognised and verified by all third party platforms,
portals and services that are part of the Azerion Connect ecosystem. Azerion Connect
collects information about the users’ device/device settings and may combine this
information across the different devices.
The information Azerion Connect obtains from the devices include the device type,
the device ID, platform/portal/service ID (client id), country, screen resolution, the
creation date of the data record and the user ID assigned to the user.
Azerion Connect doesn’t share any personal data with any third party platforms.
The legal basis of processing the Personal Data is in Azerion Connect’s legitimate
interest.
Customer Support:
If you contact us for customer support, an external customer service company will process
your email address and/or your username (optional), and the content of your request. In
order to provide you with support, this information will be processed together with your IP
address, device information (device ID, model, OS, game language, carrier), the user ID, user
segment, and the last steps taken within our Games. The request history is stored for your
account’s lifetime to enable handling of newer requests based on your previous request
and to improve our services.
We process this data on the basis of the performance of a contract as far as the information
is required to answer your request. The continued storage of your request history is based
on our legitimate interest, in order to improve our services and for potential legal disputes.
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Payments:
If you make in-app purchases, you will be redirected to an external payment provider
(Google or Apple depending on your device) for the transaction of your payment.
The transactions will be processed by the third-party payment provider. While we do not
collect and do not receive any financial data (such as your bank account data), we collect or
receive from third-party payment providers the following information related to your
transaction: the purchased amount and item (product ID and transaction ID), your country
(for currency), your user ID, your device ID, device information (user agent), time stamp,
callback ID and the status of your payment.
We process your Personal Data in connection with your payments on the basis of the
performance of a contract in order to facilitate your in-game purchase.
Logging of all in-game activities:
In order to help you with any issues you might have with our Games, to understand how
our software works, and to investigate fraud and illegal behaviour in our Games, we collect
and store all the steps you take within them, together with the following information: your
account ID, your IP address and device information (user agent or mobile device
information), mobile advertising ID in our logs which.
This process is based on our legitimate interests to be able to analyse and solve any
potential issue with our Games.
Analytics:
We use various analytics services to understand which features you like in our Games, how
you use or interact with them and how well our Games perform. The analytics data helps
us to improve our Games for you, to develop new items and features, to find crashes, issues
and bugs in our Games.
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For in-game analytics services to measure the performance of interaction of our Games
with users, we process your in-game activities (such as your in-game purchases, gameplay
statistics), device information and user ID.
For generic analytics to measure technical performance of our Games, we process
information about your device, crash reports, and data generated from playing our Games,
such as technical data generated during playing. We process this information to improve
the performance of our Games.
We process this information based on consent.
Achievements and leaderboards:
Other than competitive features provided via Google Play Games or Apple Game Center,
for some of our Games, we also offer in-game leaderboards to compare high scores with
other players and earn badges that show achieved in-game milestones. For providing
achievements and leaderboards, we collect user id, score, milestone id (in-game activities)
and callback id.
Daily challenges and rewards:
We reward our players that keep on playing our Games on a daily basis and offer them
awards in the form of either in-game currency or in-game items. We also aim to incentivize
players to play our Games consistently by offering new challenges, tasks or missions every
day that only lasts for 24 hours. In order to offer you daily stuff, we collect user ID, last login
date and timestamp. Please note that this information is stored on your device locally and
remains as long as our Games are installed on your device.
Third-party advertising within our game:
In our Games, we show advertising from different advertising companies. These
advertisements can be personalized or non-personal content related (contextual) ads. In
order to show you personalized ads and only if you have provided your consent, we will use
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third-party advertising companies to collect your Personal Data. The collected data includes
your device information, like IP address and device identifiers, your location data, your in-
game activity (such as purchase events and your game play sessions), information regarding
the delivery of ads and your interaction with them.
You can adjust your privacy preferences at any time in your in-game settings. If you choose
not to receive personalised ads at all, we will still show you ads, but they may not reflect
your interests as those ads will be content specific and not user specific.
For some of the ads shown in our Games, you can earn virtual currency if you watch the ads
(“rewarded ads”). In order to credit the virtual currency to your account, we process the
following Personal Data: your device type, device language, country and in-game behaviour.
This process is based on our and third-party advertising companies’ consent, to encourage
you to watch the ad and spend money for the product shown in the ad.
New user acquisition:
In order to acquire new users, we create advertisements (banners/videos) for our Games
and provide our advertisements to third-party user acquisition companies which show our
ads in their apps or on their websites. If you click on the banner/video shown to you in a
third-party app or on a third-party website, you will be redirected to the app stores (Google,
or Apple) where you can install our Games (or in this case, the specific game that you clicked
on the banner). The information that you have clicked/viewed the advertisement
(campaign information) will be sent from the user acquisition companies to an attribution
platform provider and will then be passed by Appsflyer to the app store. If you install one
of our Games, the campaign information will also be passed from the app store to us and
will be processed to measure the effectiveness of our advertisements. The described data
processing activities help us prevent fraud, to track and optimize our campaigns, and to
reward our user acquisition partners. This is based on our consent.
When you start playing our Games, we collect and share post install events (for example,
the level you reached within the game and purchase segments) either through the
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Appsflyer SDK or directly with the user acquisition companies which helps them optimizing
their services. We share these post install events based on your consent.
Segmentation:
We collect information about your in-game behaviour (such as first paid, installation date,
last paid, last played, levels completed, milestones achieved, number of purchases, total
paid amount along with your user information) and we create user segments (groups of
users with similar in-game behaviour) and analyse how certain groups behave in our games.
Based on the segments that they are included, we show users customized shop inventory,
offers and promotions. Different in-game items will be offered to different user segments.
This process is based on your consent.
Social media sharing service:
For a number of our Games, we have included a share button which enables you to share
certain content on social media. Once you press the button, you will be asked to log-in with
your social media platform credentials or other application credentials (such as your email
address for email apps or your phone number for sharing content on messengers). In this
case, the content you want to share (e.g. a screenshot from the game or your high score)
will be sent to the respective social network or third-party platform.
For some of our Games, you will find a Facebook share button which enables you to share
certain content on your Facebook timeline. Once you press the button, you will be asked to
log-in to your Facebook profile. In this case, the content you want to share (e.g. a screenshot
from the game or your high score) will be sent to Facebook. Please be aware that because
of how Facebook and its share function works, Facebook collects data (such as your IP
address and device information) even if you do not use the share button.
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Push Notifications
In some of our Games, you can receive push notifications about new content and offers or
personal updates (such as your lives have been renewed). For this purpose, user notification
service will process information about the status of the push notification (notification
received/viewed) and device information. You can turn off the push notifications in your in-
game settings (and also from the settings menu of your device) at any time.
Third parties:
If you click here, you will see an overview of the third parties we share your Personal Data
with, or that may share your Personal Data with us.