Last Updated: 1st September 2018 by Lakoo

1. Introduction

1.1 This Privacy Policy explains how Lakoo Games Limited (“Lakoo”, “we”, “us”) collect, process and store any personal data belonging to you, meaning information about you which is personally identifiable such as your name, address, telephone number or email address. Such information is referred to throughout this policy as “Personal Information” or “data”. This Privacy Policy applies to information we collect when you use our websites, mobile applications and other online products and services (collectively, the “Services”).

1.2 By accessing and/or using our Services you consent to us collecting, processing, storing and sharing your Personal Information in the ways set out in this Privacy Policy. If you have any concerns about providing data to us or having it used in any manner permitted in this Privacy Policy you should not use our Services. As set out in the terms and conditions relating to our Services, you must be at least 18 years old to access and use our Services.

2. Collection of Information

2.1 We may collect and process the following data about you:

• information that you provide us when using our Services, or when you create an account with us;

• details of your use of our Services and the resources that you access (for example, information about how and when you play our games or visit our website(s), or what device you use to access our Services);

• if you contact us or respond to messages and communications that we send to you, we may keep a record of that correspondence;

• your interactions with us on our social media channels;

• we may also obtain information from other sources and combine that with information we collect through our Services. For example, if you create or log into your account through a social media site, we will have access to certain information from that site such as your name, display name, account information, phone number, profile picture, email address, gender, date of birth and friend lists, in accordance with the authorization procedures determined by such social media sites.

• information we collect via cookies, as explained further below.

You acknowledge that we may rely upon such information and that you are responsible for any damages or losses which may result from any inaccuracies, including without limitation, the inappropriateness of a service/product to your profile.

3. Cookies

3.1 We use cookies and other similar technologies. Cookies are small files which store some information on your computer or mobile device.

3.2 We use cookies and similar technologies:

• to allow us to recognise you and your device, for example by identifying your IP address;

• to allow our Services to interact with a third party social network or platform (where you have chosen to allow such interaction);

• to allow our payment processors to process your payment instructions;

• to provide you with more customized Services, for example to provide our Services in the correct language;

• to obtain data which will allow us to understand how people are using our Services so that we can improve them.

3.3 By accessing our website(s) or using our Services you consent to our use of cookies in accordance with this Privacy Policy. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

3.4 We may use third-party web services on our Services. The service providers that administer these services use technologies such as cookies (which are likely to be analytical/performance cookies or targeting cookies), web server logs and web beacons to help us analyse how visitors use our Services and make the information displayed on it more relevant to your interests. The information collected through these means (including IP addresses) is disclosed to these service providers. These analytics services may use the data collected to contextualise and personalise the marketing materials of their own advertising network.

4. Payment Information

4.1 When you purchase Services on our website(s), we may collect certain payment information from you on behalf of our payment service providers, but this information is temporarily cached in a way that is unreadable by Lakoo. When you purchase items via our apps (such as those you can purchase in the App Store, via Amazon Kindle or on Google Play) we do not collect or store any payment information from you.

5. Use of Information

5.1 You agree that we (or a supplier or group company acting on our behalf and only under our instructions) may use your Personal Information for the purposes of:

• contacting you, for example as part of customer service or to send you updates about our Services;

• managing your account and relationship with us and improving your experience when you use our Services;

• research, surveying, and engaging with you, for example by sending you communications (including by email) for these purposes;

• to create reports, analysis or similar services for use by us for the purposes of research or business intelligence, for example to track potential problems or trends with our Services;

• preventing cheating, crime or fraud. We may also need to pass your information to fraud prevention agencies and other organisations involved in crime and fraud prevention;

• send you technical notices, updates, security alerts and support and administrative messages; and

• as otherwise expressly set out in this Privacy Policy or as required by law.

6. Sharing of Information

6.1 We will disclose the personal information we hold about you to:
• our group companies and affiliates;
• third party service providers used by Lakoo;
• banks, other financial institutions and, risk management agencies;
• payment service providers;
• third party companies in the event that Lakoo is involved in a corporate transaction such as an actual or potential merger, joint venture, consolidation or asset sale;
• professional advisors such as attorneys, accountants, auditors, financial and other professionals;
• regulatory authorities including tax authorities;
• law enforcement agencies, courts and other relevant tribunals.

6.2 The data that we collect from you may be transferred to, and stored at, a destination outside Hong Kong. It may also be processed by persons mentioned above in this section who operate outside Hong Kong.

6.3 By submitting your personal data you agree to this transfer, storing or processing of data outside Hong Kong. We will take all steps reasonably necessary to ensure that your data is treated securely in accordance with this privacy policy.

7. Interaction with third party social networks or platforms

7.1 The Services may offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take on our Services with other media, and vice versa. The use of such features enables the sharing of information with your friends or the public, depending on your settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

7.2 You understand that where you allow your account with us to interact with any third party social network or platform, we may share data about you with your contacts (and vice versa) in order that you may enjoy playing socially. This data includes your display name your social media profile picture and your scores and/or progress in our games.

7.3 You can make changes to what data a third party social network or platform shares with us, or stop our Services interacting with that social network or platform by adjusting your settings with that third party provider, however you may find you are not able to enjoy all of the same features of our Services.

7.4 We may also collect personal information about you from third party entities when we seek to verify your identity as part of our regulatory requirements. This may include, for example, identity verification agencies, credit referencing agencies, risk management agencies and similar bodies.

8. For how long will we retain your information?

8.1 We will retain your Personal Information for as long as is necessary to fulfill the purposes for which it was collected or as needed to provide you with Services. We may retain your Personal Information after you have closed any account you have with us or after we have ceased providing Services to you if retention of your Personal Information is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes between members, prevent fraud, cheating or abuse, or enforce this Privacy Policy or any other agreement we may have with a user.

9. Services Updates

9.1 If you sign up an account for the Services with us, we may use your personal information to send you push notifications or email communications. These communications may relate to your account status, social interactions with us or may include our Sevices updates and promotions. You can ask us stop sending marketing messages or modify your email preferences by opt out of receiving updates at any time by clicking the “Unsubscribe” link at the bottom of any email from us, or by contacting us at any time using the contact details in “How to contact us” below.

10. Your rights

10.1 Individuals whose personal information we hold may be entitled to access their personal information, or to request that it is erased, that its processing is restricted, or that any inaccurate personal information is rectified. You may also have the right to object to the processing of your personal information, or in some circumstances to obtain a copy of the personal information in machine readable format. Any such request should be submitted in writing to: [email protected]. If you would like to submit a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please contact us at: [email protected]. We will reply to your compliant as soon as we can.

10.2 If you feel that your complaint has not been adequately resolved, you have the right to contact your local data protection supervisory authority, which for in Hong Kong, is the Privacy Commissioner for Personal Data.

11. Security
11.1 We protect your personal information by using reputable third party data storage service provider such as Google Cloud Platform and Amazon Web Services with proper data security technology enforced. We take reasonable measures to help protecting information about you from unlawful destruction or loss, alteration, theft, misuse and unauthorized access or disclosure.

12. Minors
12.1 Protecting the privacy of young children is especially important. We do not knowingly collect or solicit personal information from anyone under the age of 18 (or the age of legal consent for the jurisdiction the user is located in) (a “minor”) or knowingly allow such persons to register with us. If you are a minor, please do not submit any personal information through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy & Cookies Policy by instructing their children never to provide personal information to our Services. If we become aware that a minor has shared any information with us, please contact us at [email protected], we will take steps to remove that information.

13. Changes to this Privacy Policy
13.1 The Policy will be reviewed from time to time to take account of changes to our operations or practices and, further, to make sure it remains appropriate to any changes in law, technology and the business environment. Any personal information held will be governed by our most current Policy.

14. Links
14.1 The Service may include links to other websites on the internet. We are not responsible for the content of these sites or for any other privacy practices on these internet sites. Before providing your personal information via any other website, we advise you to examine the terms and conditions of using that website and its privacy policy. Our terms of use and our privacy policy apply only to information collected by us in accordance with this Policy.

15. How to contact us
15.1 To find out more about how your Personal Information will be used, please contact us by email at [email protected].