Privacy policy

1. Introduction

This Privacy Policy explains who we are, how we collect, share and use personal data about you, and how you can exercise your privacy rights. This Privacy Policy applies to CoolGames’ games, websites and related services, which we here collectively call the Service. We may periodically update this Privacy Policy by posting a new version on www.coolgames.com. If we make any material changes, we will notify you by posting a notice in the Service prior to the change becoming effective. Your continued use of the Service after the effective date will be subject to the new Privacy Policy.

If you have questions about data protection, or if you have any requests concerning your personal data, we encourage you to primarily contact us through the game, so we can reply to you more quickly.

Name of the data controller: CoolGames b.v.

Address: Herengracht 433, 1017 BR Amsterdam, the Netherlands

E-mail: [email protected]

2. Legal basis for data processing

The legal basis for data processing including use of cookies is Art. 6(1)(f) of the GDPR.
If the e-mail contact is aimed to conclude a contract or serves the contract execution, additional legal basis for the processing is Art. 6 (1)(b) GDPR.

3. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer various kinds of personal data about you which we have grouped together as follows:

3.1 Data you provide us.

   -   Contact information (such as name and email address)

   -   Player name and password

   -   Profile information (such as profile photo, friends)

   -   Your messages to the Service (such as chat logs and player support tickets)

   -   Other data you choose to give us

   -   Data about your account and game progress

   -   Your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI)

   -   Data about your device, such as device name and operating system, browser type and language

   -   Data we collect with cookies and similar technologies

   -   General location data

   -   Precise geo-location data (GPS, with your consent)

   -   Data about your use of the Service, such as gameplay data and your interactions with other players inside the Service

   -   Data we receive if you link a third-party tool with the Service (such as Facebook, Apple, KakaoTalk, LINE or Google)

   -   Demographic data (such as to determine the coarse location of your IP address)

   -   Data to fight fraud (such as refund abuse in games or click fraud in advertising)

   -   Data from platforms that the games run on (such as to verify payment)

   -   Data for advertising and analytics purposes, so we can provide you a better Service

   -   Create accounts and allow you to play our games and use our Service

   -   Operate the Service

   -   Verify and confirm payments

   -   Provide and deliver products and services you request

   -   Send you Service-related communications

   -   Update and develop player profiles

   -   Develop and improve the Service and player experience

   -   Manage our relationship with you

   -   Provide social features as part of the Service

   -   Customize your Service experience

   -   Respond to your comments and questions and provide player support

   -   Provide you CoolGames offers in the Service as well as in other websites and services, and by email

   -   Send you related information, such as updates, security alerts, and support messages

   -   Enable you to communicate with other players

Apart from CoolGames, your data can be accessed by others in the following situations:

6.1 Other players and users

Social features are a core component of our games. Other players and users may, for example, see your profile data, in-game activities and read the messages you have posted.

6.2 Partners working for CoolGames

CoolGames has partners to perform services for us. These partners process your data only at and according to CoolGames’ instructions to provide the Service, such as hosting, player support, advertising, analytics and fraud prevention.

6.3 Other companies and public authorities.

To combat fraud and illegal activity, we may exchange data with other companies and organisations and provide it to public authorities in response to lawful requests.

We may also disclose your data to comply with the law or to protect the rights, property or safety of us, our players or others.

7. How we protect your data

In order to help ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorised access or against loss, misuse or alteration.

7.1 Data retention

We retain your data for as long as your account is active or as needed to provide you theService. We will for example periodically de-identify unused game accounts and we regularly review and de-identify unnecessary data.
Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.

7.2 Age limit

We do not knowingly collect or solicit personal data about or direct or target interest based advertising to anyone under the age of 13 or knowingly allow such persons to use ourServices. If you are under 13, please do not send any data about yourself to us, including your name, address, telephone number, or email address. No one under the age of 13 may provide any personal data.

If we learn that we have collected personal data about a child under age 13, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under the age of 13, please contact us.

7.3 International transfers outside of EEA

Our Service is global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Policy. Adequate safeguards that our partners may use include standard contractual clauses approved by EU Commission and the Privacy Shield certification in case of transfers to the USA.

8 Legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. We set out below a brief description of such rights:

8.1 Right to access your personal data

This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

8.2 Right to correct your personal data

This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

8.3 Right to erase your personal data

This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

8.4 Right to object to processing of your personal data

Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms

8.5 Right to restrict the processing of your personal data

This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; or (b) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it

8.6 Right to request the transfer of your personal data to you or to a third party

We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

8.7 Right to withdraw your consent at any time where we are relying on consent to process your personal data

This will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consentIf you wish to exercise any of the rights set out above, please contact us through [email protected].

8.8 Costs

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

8.9 Information required

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

8.10 Response time

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests, in which case we will inform you of an extension period. In this case, we will keep you informed on progress.

9. Policy updates

We may update our Privacy Policy from time to time to reflect changes in technology, legislation, our operations, or as we otherwise determine is necessary or appropriate. Any such changes will become effective when we make the revised policy available on our website. We encourage you to review the date above frequently to ensure you are aware of when our policy was last revised, and to help you better understand the nature of your interactions with us.

This document has been updated on May 25th, 2018