Privacy Policy of KAYA

This Application collects some Personal Data from its Users.

Entity Type: Individual

Last Updated: 25.05.2018

Kaya's Privacy Policy has been adopted to explain how we store and use the information collected about users online on our websites, during the usage of our products (games and apps) and/or services on mobile platforms.

Kaya respects the privacy rights of Users and recognizes the importance of protecting the information collected. By accepting our Privacy Policy and Terms of Service, you consent to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy. If you have any questions or concerns, please contact our Support Team at [email protected]

1. Introduction

Kaya may be collectively referred to herein as “Kaya”, “we”, or “our”, as the context requires.

Kaya is a developer and publisher of various customization and personalization apps for mobile devices. By using or installing our websites, Applications, Games or any of the related services, you signify your assent to our Privacy Policy and understanding that Kaya may process your data in accordance with this Privacy Policy. If you access our games from a third party Social Networking Site (“SNS”), or through any other web or mobile source or app store, you may be required to also read and accept their Terms of Service and Privacy Policy.

  • IF YOU DO NOT AGREE WITH AFORESAID, PLEASE DO NOT USE OUR SITES, APPLICATIONS OR MOBILE GAMES.

2. Information that we collect

Kaya collects both personal and non-personal User information. Personal information is information that identifies you and that may be used to contact you online or offline.

Personal and sensitive information collection and permission handling:

- Should Kaya request and collect any of the following permissions or sensitive user data: microphone, camera, accounts, contacts, or phone, the data will be handled securely, including transmitting it using modern cryptography.

- Sensitive permissions will be used exclusively for improving app's features and enhancing user's experience in utilizing the app and the functionality in general. Sensitive user data will not be published or disclosed without user's consent;

- Should Kaya handle non-public or contact information, the information will not be published or disclosed without user's consent.

Personal data will be processed in accordance with the applicable legal provisions (Art. 6 I 1 b) and f) EU GDPR) or on the basis of your consent or in order to decide on the establishment of an employment relationship if you apply for a position with us (Art. 6 I 1 a) and b), 88 I EU GDPR).

2.1. Kaya may collect personal information from our online Users as follows:

Information collected will vary depending upon the activity or service and may include (but not restricted to) your name, email address, phone number, home address, birth date, Facebook account, friends list, mobile phone number and credit card information. Other Personal Data collected may be described in other sections of this privacy policy or by dedicated explanation text contextually with the Data collection. The Personal Data may be freely provided by the User or collected automatically when using this Application. Any use of Cookies - or of other tracking tools - by Kaya or by the owners of third party services used, unless stated otherwise, serves to identify Users and remember their preferences, for the sole purpose of providing the service required by the User. You can choose not to provide (when such opportunity is provided) certain information, but then you might not be able to take advantage of many of our features. Users are responsible for any Personal Data of third parties obtained, published or shared through services that Kaya offers and confirms that they have the third party's consent to provide the Data to the Owner.

2.2. When you use any Kaya' game at an SNS such as Facebook or Google +, you allow Kaya to access certain information from your profile for that site. The information you allow Kaya to access varies by game and SNS, and it is affected by the privacy settings you establish at the SNS. You can control and find out more about these settings at the SNS where you play our game. By playing a Kaya' game through an SNS, you are authorizing Kaya to collect, store, and use in accordance with this Privacy Policy any and all information that you agreed the SNS could provide to Kaya through the SNS Application Programming Interface. Your agreement takes place when you “accept” or “allow” (or similar terms) one of our applications on an SNS.

2.3. When you use any Kaya' game at mobile platforms such as iTunes App Store, Google Play, Amazon App Store, Windows Phone or any other mobile platform or store where we publish games and apps you allow Kaya to access certain information from your profile for that site, store or service. The information you allow Kaya to access varies by game and mobile platform, and it is affected by the privacy settings you accepted on the mobile platform. You can control and find out more about these settings at the mobile platform where you download or play our game. By playing a Kaya' game through a mobile platform, you are authorizing Kaya to collect, store, and use in accordance with this Privacy Policy any and all information that you agreed the mobile platform could provide to Kaya through the mobile platform Application Programming Interface. Your agreement takes place when you “accept” or “allow” or "install" or "download" (or similar terms) one of our applications on a mobile platform.

•Registration for sites, SNS, games, mobile games, mobile apps.

•Registration for Kaya and/or other service accounts;

•User support and/or technical service requests;

•Player match up and other head-to-head online competitions and/or special game-specific events;

•Contest registration and prize acceptance;

•Creation of a personal profile;

•Access to our products and/or services on social networks or other third party services; and

•Otherwise through use of our software, mobile or online services where personal information is required for use and/or participation.

2.4. Non-personal information, alone, cannot be used to identify or contact you.

Kaya collects non-personal information about your use of our online and mobile products and services both on our websites and in the course of game play and software usage.

When you browse certain portions of the Service, we may automatically collect and record standard user information and clickstream data about your visit (through the use of cookies, analytics, SDKs and otherwise) as a part of our analysis of the use of the Service. For example, when you visit or request a web page from our server, we may record the IP address of the user’s machine, the time, date, and URL of the request and information about the browser being used, and other information regarding the visit, such as the pages visited on the Service, the time spent on each page, any advertisements clicked and any search terms used (collectively “Log Data”).

When you use our online and mobile products and services, we may collect certain non-personal information including gender, zip code, information about your computer, hardware, software, platform, game system, media, mobile device, including device IDs, incident data, Internet Protocol (IP) address and other information.

3. Where we store information about you?

Kaya stores information about you on servers located in the United States, but reserves the right to transfer information elsewhere at its sole discretion. Personal data collected within the European Union may be transferred to and stored at, a destination outside the European Union. Data we collect may also be processed by staff operating outside the US and the EU who works for us or for one of our suppliers. By submitting your personal data, you agree to this transfer, storing or processing. Users have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, canceled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

4. How Kaya uses information collected?

Kaya uses your information only as follows:

• Kaya collects and uses User's personal information in association or through different API or SDK of Social Network Sites, Mobile Platforms, Data Analysis Networks or Mobile Ad Networks. By installing or using our services or games you (User) also agree on any such additional Privacy Policy provided by such Site, Platform or Network. Here are some of the such companies used on our Sites or in our Games or Apps so you can check or opt-out your data through their Privacy Policy forms: iTunes, Google Play, Amazon, Facebook, AppAnnie, Flurry, Admob, Google Analytics, Vungle, AppLift, MobPartner, Unity, Chartboost, AdColony, Glispa, and many others.

•To improve our software and services by providing experiences and recommendations, language and location customization, personalized help and instructions.

•To provide our products and services to you and fulfill your specific requests;

•To better understand the behavior and preferences of our Users, to troubleshoot technical problems, to deliver advertising, for the purposes of the proper functioning of our products and services and improving them; to handle users accounts and all in-app payments.

•To send you messages about our products and services, new products, features, enhancements, special offers, upgrade opportunities, contests, and events of interest;

•To enable user-to-user communications;

5. How does Kaya protect your information?

Kaya understands the importance of keeping your information safe and secure. Kaya will make commercially reasonable precautions to protect your personal information and ensure the security of our systems. However, there is no 100% secure method of transmission over the Internet or method of electronic storage. We cannot assume responsibility or liability for unauthorized access to our servers and systems. It is important for you to protect yourself against unauthorized access to your passwords and your computer. We strongly recommend that you implement measures to protect your computer or mobile device from unauthorized access, such by using firewall protection and anti-virus software. Be sure to sign off when finished using a shared computer or mobile device.

6. How we disclose information collected?

We disclose your information to third parties, that is parties other than Kaya, in the following circumstances:

6.1. From time to time Kaya employs third party contractors to collect personal information on our behalf to provide email delivery, product, prize or promotional fulfillment, contest administration, credit card processing, shipping or other services on our sites or in our mobile games and apps. We ask some third party contractors, such as credit agencies, data analytics, ad networks or market research firms, to supplement personal information that you provide to us for our own studies or other uses. When our third party agents or service providers collect and/or have access to any information other than non-personal, anonymous and/or aggregated data, Kaya requires that they use data consistent with our stated privacy policies and protect the confidentiality of personal information they collect or have access to in the course of their engagement by Kaya. These third parties are prohibited from using your personal information for any other purpose without your specific consent.

6.2. We may share your information with subsidiaries, partners, and affiliates that we work with, own or control, but only if those entities are either subject to this Privacy Policy or follow practices at least as protective as those described in this Privacy Policy.

6.3. The Service supports and may encourage interaction among players. Your SNS friends may see your name, profile photo and descriptions of your game activity, your game profile. Other players may also be able to send you game requests or even friend requests through the related SNS’ communication channels or through API of the mobile platform.

6.4. Kaya may share aggregated information (information about you and other users collectively), anonymous information and certain technical information (including IP Addresses, MAC Addresses for mobile devices and mobile device IDs) to develop and deliver targeted advertising in the service and on the websites of third parties. We may also allow advertisers to collect this information within the Service and they may share it with Us.

6.5. We reserve the right to disclose your information when we believe release is appropriate to comply with the law, judicial proceedings, court order or other legal processes; enforce or apply our Terms of Service and other agreements; or protect the rights, property, or safety of Kaya, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction purposes.

6.6. In the event that Kaya undergoes a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, we may transfer all of your information, including personal information, to the successor organization in such transition.

7. How can you access and update or delete your information?

7.1. You can correct or update your account information at any time by logging on our sites or SNS and navigating to different account settings. Should you be unable to log in or wish to have your account(s) deactivated, you may send an e-mail to our Support Team at [email protected]. You can put “Delete my Account” or “Update my information” in the subject line and include your first name, last name, e-mail address and user ID number (if applicable) in the body of the e-mail. We will be happy to review, update or remove information as appropriate. We may still retain your information in our files, however, to resolve disputes, enforce our user agreement, and due to technical and legal requirements and constraints related to the security, integrity, and operation of our websites, mobile games and apps.

7.2. If you have granted Kaya access to your SNS account information through our application or mobile game, you may manage the information that Kaya receives about you from an SNS. For this purpose, you will need to follow the instructions at that site for updating your information and changing your privacy settings.

7.3. You may also have the right subject to certain exceptions to be given a copy of certain data that Kaya may hold about you (and for which we may charge a small fee to process) and to have any inaccuracies in the data that Kaya holds about you corrected and/or erased. You may exercise any such rights by emailing our Support Team at [email protected]. We will need sufficient information from you to establish your identity and to verify your access request, and also to assist us in handling your request. Requests will be processed as soon as possible and not later than 45 days.

8. Information about Children

Kaya does not sell products or in-apps to children and does not knowingly collect personal information from children. We sell products for children to adults. If you are under age of 13, you may use our Sites or Mobile Games and Apps only with the involvement of a parent or a legal guardian.

9. Changes to our privacy policy

If we decide to make any changes to our Privacy Policy, we will add a new Privacy Policy version number and the date when it has been updated so you can stay informed. We may supplement this process by placing notices in our games and on other websites of ours. We urge you to periodically check this privacy policy page for updates. Any update to our Privacy Policy is valid without your new acceptance.

10. Terms of service and notices

If you choose to visit a Site, use any of our Games or Apps, your visit and any dispute over privacy is subject to this Policy and our Terms of Service. If you have any concerns about your privacy, please contact us with a thorough description or your question or concern via the postal addresses or email address in section 12 of this Privacy Policy, and we will try to resolve it.

11. Your rights

Before you read and consent to our Privacy Policy, we would like to introduce your rights regarding the personal information you provide as a user of our product.

Right to withdraw your consent in accordance with Art. 7 para. 3 GDPR (e.g. you can contact us if you wish to cancel a previously given consent to a newsletter)

Right to access your data in accordance with Art. 15 GDPR (e.g. you can contact us if you would like to know what data we have stored about you)

Right to correct your data in accordance with Art. 16 GDPR (e.g. you can contact us if your e-mail address has changed and we should replace your old e-mail address)

Right to have your data deleted in accordance with Art. 17 GDPR (e.g. you can contact us if you want us to delete certain data that we have stored about you)

Right to limit data collection in accordance with Art. 18 GDPR (e.g. you can contact us if you do not want us to use your e-mail address for newsletters, but only to send absolutely necessary e-mails)

Right to take your data with you in accordance with Art. 20 GDPR (e.g. you can contact us to receive your data, if you want to upload it to another service)

Right to object how your data is handled in accordance with Art. 21 GDPR (e.g. you can contact us if you do not agree with any user analytics procedures as described within this privacy policy)

Right to send complaints to the supervisory authority in accordance with Art. 77 para. 1 f GDPR (e.g. you can contact the data protection supervisory authority directly)

12. Contact us

If you have any questions about the privacy aspects of our products or services, or would like to make a complaint having to do with a privacy matter, please send a written request as follows:

Kaya,

Support Team: [email protected]