Privacy Policy

In this Privacy Policy we explain:

- The ways we collect personal data about you and why we do so

- How we use your personal data, and

- The choices you have about your personal data.

This Privacy Policy applies to all of Smokoko’s games, websites and other related services, collectively the “Services”. Please note that we may from time to time update this Privacy Policy by posting a new version on smokoko.net. If we make any material changes, we will notify you by posting a notice in the Services prior to the change becoming effective. Your continued use of the Services after the effective date will be subject to the new Privacy Policy.

HOW TO CONTACT US

If you have questions about data protection or if you have any requests for resolving issues with your personal data, we encourage you to primarily contact us through our games so we can reply to you more quickly.

Name of the company collecting the personal data (the controller):

SMOKOKO LTD

Pencho Slaveikov Blvd 19A, 1606 Sofia, Bulgaria

[email protected]

THE PERSONAL DATA WE COLLECT

Data you provide us

- Player nickname

- Other data you choose to give us (such as information in player support tickets)

Data we collect automatically

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

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

- Data we collect with cookies and similar technologies (see more below)

- Coarse location data (country or city-specific)

- We also may create a Smokoko and/or game-specific ID for you when you use the Services

 

Data we collect from our partners

- Data we receive if you link a third-party tool with the Services (such as login using your Facebook or Google account)

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

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

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

- Data for advertising and analytics purposes, so we can keep improving our games

 

WHY WE COLLECT YOUR DATA

To make the Services work (performance of a contract) we process data necessary to

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

- Operate the Services

- Verify and confirm payments

- Provide and deliver products and services you request

- Send you communication-related to the Services

 

To make the Services more enjoyable for our players (legitimate interests) we collect and process necessary data to

- Update and develop player profiles

- Develop and improve the Services and player experience

- Manage our relationship with you

- Provide social features as part of the Services

- Customize your Services experience

- Respond to your comments and questions and provide player support

- Provide you offers in the Services related to other Smokoko products and services

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

- Enable you to communicate with other players

 

To show personalized advertisements (legitimate interests or consent depending on applicable jurisdiction) we collect, process and transfer to our third-party partners personal data to:

- Track the content you access in connection with the Services and your online behavior

- Deliver, target and improve our advertising and the Services

 

To keep the Services safe and fair

Ensuring a level playing field in the Services is a top priority for us.

In order to keep the Services and their social features safe and fair, to fight fraud and ensure acceptable use otherwise, we have a legitimate interest to process necessary data to

- Analyze and monitor the use of the Services and its social features

- Moderate chats either automatically or manually

- Take action against fraudulent or misbehaving players

 

To analyze, profile, and segment

In all of the above cases and purposes, we may analyze, profile and segment all collected data in anonymized form.

 

With your consent

With your consent, we may process your data for additional purposes, such as using your location based on your IP address to show you local events.

 

WHO CAN SEE YOUR DATA

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

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.

Partners working for Smokoko

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

Smokoko’s development partners

Smokoko works as a publisher for several game development companies. These development partners may process your personal data for the purposes described herein and where applicable, working as joint controllers of the processed data together with Smokoko. A list of these partners is available at Smokoko Partners.

Other companies and public authorities

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

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

Advertising and social media partners

The Services include features from our partners, such as social media interaction tools and in-game advertising. A list of these partners is available at Smokoko Partners. These partners may access your data and operate under their own privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices.

International data transfers

Our Services are 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 Privacy 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.

 

YOUR RIGHTS AND OPTIONS

Opt-out of targeted advertising

You can always opt-out of directed advertising in our games by checking the privacy settings of your device. Please review your device’s user manual on how to do so. For more information, see also: Smokoko Partners

Access the personal data we hold about you

If you request, we will provide you a copy of your personal data in an electronic format.

Your other rights

You also have the right to correct your data, have your data deleted, object how we use or share your data, and restrict how we use or share your data. If certain personal data is processed based on consent given by you, such consent can also be withdrawn by you at any time, for example in the applicable game’s settings.

We will respond to all requests within a reasonable timeframe. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact your local data protection authority within the European Economic Area for unresolved complaints.

 

COOKIES AND SIMILAR TECHNOLOGIES

Like most online services, we and our partners use cookies and similar technologies to provide and personalize the Services, analyze use, target advertisements and prevent fraud. You can disable cookies in your browser or device’s settings, but some parts of the Services may then not function properly.

 

HOW DO WE PROTECT YOUR DATA

Security Safeguards

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 unauthorized access or against loss, misuse or alteration.

Data retention

We retain your data for as long as your account is active or as needed to provide you the Services. 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.

 

AGE LIMITS

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 our Services. 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.