Last updated October 10, 2021
Effective October 10, 2021
Our Privacy Commitment
Kiragames respects your privacy rights and recognizes the importance of protecting your personal information. We are also committed to providing additional protections for children who visit and/or use our Services.
Kiragames’ Apps covered by this Privacy Policy include any mobile applications (“apps”) displaying or linking to this Privacy Policy.
This Privacy Policy applies only to information submitted and collected online through the apps and does NOT apply to information that may be collected by Kiragames on our website or offline. At this time, we do not collect any information when you use our website.
Kiragames reserves the right, at any time and without notice, to add to, change, update or modify this Privacy Policy and our Terms of Use, simply by posting such change, update or modification on the apps. Any such change, update or modification will be effective immediately upon posting on the apps. Your continued use of any of our apps will signify your acceptance of these changes.
Our Privacy Policy applies to the collection and processing of personal information by The Kiragames Co., Ltd., and our subsidiaries and affiliated company’s action on our behalf (“Kiragames” or “we”, “us”, or “our”). This Privacy Policy applies only to personal information collected about you as a consumer through the Kiragames network of apps, features, services, events, and communications provided by Kiragames where this Private Policy is posted (“Services”). This policy does not apply to human resources data or the “Kiragames” website.
Our international affiliates and third-party websites or apps that our Services link to, or with whom we may have a presence, or with whom we may license use of our trademarks and copyrights, may collect and use personal information for their own purposes. Where they do so, their respective privacy policies apply. Please review the respective terms and privacy policies of these entities to learn how they process your personal information.
We process data and analytics about the use of our services such as in-game play progress, levels, games played, session length, preferred settings, in-game adverts, in-game preferences, game preferences, the means to use the services, device types, the operating systems, and internet service providers, and general geographic location. . For example, we retrieve Daily Active Users (DAU) and device type from Google Analytics and Apple, so we can understand how many users playing our games daily and from what devices our games are being accessed. We also process data in relation to coarse location, gameplay content, identifiers (user id & device id), purchase history, usage data (product interaction & advertising data), and diagnostics.
We may access or receive information about the ways you use and interact with our Services through third parties services, individuals, and the intermediaries as discussed above and in section 8.
| Purpose of Processing | Categories of Personal Data | Lawful Basis (under the GDPR) |
|---|---|---|
| Analytics | Coarse location, gameplay content, identifiers (user id & device id), purchase history, usage data (product interaction & advertising data), and diagnostics | Legitimate interest in understanding user’s use of the Services |
| Product development | Coarse location, gameplay content, identifiers (user id & device id), purchase history, usage data (product interaction & advertising data), and diagnostics | Legitimate interest in developing the Services offered |
| Advertising | Coarse location, gameplay content, identifiers (user id & device id), purchase history, usage data (product interaction & advertising data), and diagnostics | Legitimate interest in advertising on the app |
We collect personal data and we may use SDKs, cookies, flash cookies, web beacons, and similar technologies to collect your personal information.
We employ third party companies and affiliates to facilitate our Services, to provide the Services on our behalf, to perform service-related services or to assist us in analyzing how our service is used (such as Facebook, Apple, Google Analytics and Amazon). We may collect certain information when you use our Services through these third-party service providers and affiliates, for example, when you connect your account to third-party services or sign in using a third-party partner (like Google Play Game Services, or iOS Game Center).
Below is the list of some, but not all, business partners that we actively share users’ information such as coarse location, gameplay content, identifiers (user id & device id), purchase history, usage data (product interaction & advertising data), and diagnostics. The data is used for third-party advertising and analytics purposes, and it is linked to the user's identity and is used for tracking purposes:
From time to time we may transfer personal data outside the EEA. Such transfer will be subject to appropriate safeguards in accordance with the Data Protection Laws and in accordance with this Privacy Policy. Further details may be obtained by emailing [email protected].
We may provide your information to third party companies to perform certain services, including but not limited to hosting services, payment processing, analytics and to assist us in our marketing efforts. Where we share your information with third-party service providers and business partners, we ensure that we have appropriate agreements in place to protect your information as required by applicable data protection laws.
We may share information we collect or derive with third parties for the following purposes:
We will retain your personal data only for as long as necessary in relation to the reason that we hold it. The criteria used to determine our data retention periods include: (a) the length of time we have an ongoing relationship with you; (b) whether there is a legal obligation to which we are subject; and (c) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
Our Services are not intended to be used by children under the age of 18.
The EU General Data Protection Regulation (GDPR) is a European Union regulation (2016/679). It came into force on the 25th of May 2018. The aim of GDPR is to protect and enhance all EU citizens’ data privacy rights. GDPR applies to anyone that holds or processes the data of an EU citizen, regardless of where the person/company processing that data is based. Information on the lawful basis for processing your personal data under the GDPR is set out below.
| Purpose of Processing | Categories of Personal Data | Lawful Basis (under the GDPR) |
|---|---|---|
| Analytics | Coarse location, gameplay content, identifiers (user id & device id), purchase history, usage data (product interaction & advertising data), and diagnostics | Legitimate interest in understanding user’s use of the Services |
| Product development | Coarse location, gameplay content, identifiers (user id & device id), purchase history, usage data (product interaction & advertising data), and diagnostics | Legitimate interest in developing the Services offered |
| Advertising | Coarse location, gameplay content, identifiers (user id & device id), purchase history, usage data (product interaction & advertising data), and diagnostics | Legitimate interest in advertising on the app |
If You Are Located in the EU:
The GDPR provides certain rights to individuals including:
These rights may be subject to certain exemptions and may be restricted in certain circumstances and pursuant to the law in your jurisdiction.
If you have any questions on how we process your data or wish to exercise any of your rights please contact [email protected]. We would hope that we may resolve any issue that you might have, however you also always have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction if you are located in the EU.
If You Are Located in California:
Under the CCPA, you have the right to request a copy of your data, request we send your data to a third party or that we delete your data. All of these rights are subject to limitations.
Based on the CCPA’s broad definition of the term “sale,” certain data collection on our Services by third parties for purposes of interest-based advertising and social media tools may be a “sale” under the CCPA. You have the right to request that we do not sell your information.
If you have any questions on how we process your data or wish to exercise any of your rights please contact: [email protected].
We may amend this Privacy Policy at any time in response to changing legal, technical or business developments. If we make a change to how we collect, use, or share your personal information, we will describe the changes, and, if required by law, seek your consent for such changes. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. Therefore, please review this Privacy Policy from time to time so that you are aware when any changes are made to it.
This Privacy Policy only covers the way we treat personal information and non-personal information we collect on the Services. You should be aware that our website may from time to time contain links to third-party websites. Kiragames is not responsible for the privacy practices or the content of such sites. If you are concerned about the privacy policy of a certain third party, we recommend that you read the privacy policy of the site to which you link before you submit any personal information. By accessing any external sites, you agree to the privacy policies of those sites.
All questions, comments or enquiries should be directed to Kiragames at [email protected].