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
- Legal basis for data processing
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.
- 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
3.2 Data we collect automatically.
- 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
In most cases, we also create a CoolGames-specific ID for you when you use the Service.
3.3 Data we collect from our partners.
- 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
- Purpose of data collection
We use your personal information for following purposes:
4.1 To make the Service work.
To perform the contract, we process data necessary to
- 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
4.2 To make the Service more suitable for our players.
To provide a great Service to our players, we have a legitimate interest to collect and process necessary data to
- 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
4.3 To show personalized advertisements.
To show you personalized advertisements in the Service as well as in other websites and services (including email) we have a legitimate interest to process necessary data to
- Track the content you access in connection with the Service and your online behaviour
- Deliver, target and improve our advertising and the Service
- For information on how to opt-out from personalized advertisements, see section 'Opting out of cookie tracking' below.
4.4 To keep the Service safe and fair.
Ensuring a level playing field in the Service is a top priority for us. For more information on our acceptable use policy, see the CoolGames Terms of Service.
In order to keep the Service and its social features safe and fair, to fight fraud and ensure acceptable use otherwise, we have a legitimate interest to process necessary data to
- Analyse and monitor use of the Service and its social features
- Moderate chats either automatically or manually
- Take action against fraudulent or misbehaving players
4.5 To analyse, profile, and segment.
In all of the above cases and purposes, we may analyse, profile and segment all collected data.
4.6 With your consent.
With your consent, we may process your data for additional purposes, such as using your GPS location to show you local events.
- Cookies and Automated Information Collection
Like many websites, CoolGames and service providers acting on our behalf, like Google Analytics, store log files and use tracking technologies such as "cookies" to collect information. A cookie is a small data file that is transferred to your computer’s hard disk or your mobile device for record-keeping purposes. The Service may send cookies to a computer or a mobile device when a user accesses or views a Service. Information contained in a cookie may be linked to personal information for purposes such as improving the quality of CoolGames’ Service, tailoring recommendations to interests, and making the Service easier to use.
Third party advertisers on the Services may also use, place or read cookies or other technologies as described below on your browser, and those practices are subject to their own policies. Cookies can be disabled at any time by changing your web browser’s options to stop accepting cookies, to prompt you before accepting a cookie from the websites you visit or limit the type of cookies you allow. Flash cookies operate differently than browser cookies and cookie management tools available in a web browser may not remove flash cookies. If you do not accept cookies, however, you may not be able to use all features, portions or functionalities of the Service.
We and our service providers may also employ other technologies including (i) web beacons, which allow us to know if a certain page was visited or whether an e-mail was opened; (ii) tracking pixels, which allow us or our advertising partners to advertise more efficiently and effectively by excluding our current users from certain promotional messages, identifying the source of a new installation or delivering ads to you on other websites; and (iii) local shared objects also known as flash cookies, which help us to reduce fraud, remember your in-game preferences and speed up load times.
5.1 Tracking technologies
We and our service providers use these log files, tags, and tracking technologies to collect and analyse certain kinds of technical information, including;
• the type of device you are using;
• your operating system version;
• your mobile device’s identifiers, like your MAC Address, Identifier For Advertising (IDFA), and/or International Mobile Equipment Identity (IMEI);
• your browser types;
• your browser language;
• referring and exit pages, and URLs;
• platform type;
• the number of clicks on a page or feature;
• domain names;
• landing pages;
• pages viewed and the order of those pages;
• the amount of time spent on particular pages; and
• game state and the date and time of activity on our websites or games.
In some cases, we will connect this information with your social network ID or CoolGames user ID.
5.2 Opting out of cookie Tracking
Most browsers are initially set to accept cookies, but you can (re)set your browser to refuse all cookies or to indicate when a cookie is being sent. You can opt out of receiving cookies from certain third-party advertising networks by resetting your browser. You may also use the following link to the Network Advertising Initiatives cookies opt-out page or the link to the European Interactive Digital Advertising Alliance (EDAA) opt-out page. However, some features and services may not function properly if cookies are disabled.
- Who can see your data
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 organizations 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.
- 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 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 Service. 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 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.
- 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.
- 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 consent
If you wish to exercise any of the rights set out above, please contact us through firstname.lastname@example.org.
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
This document has been updated on May 25th, 2018