Game Distribution User Privacy Notice
We at Key Games Network B.V. (“GameDistribution”, GD”, we”, us or our”) respect
your privacy and recognise the importance of providing a secure environment for your
personal data. Therefore, we are committed to being transparent about how we collect and
process your personal data.
The purpose of this privacy notice (Privacy Notice) is to inform you as a user about why
and how we process your personal data (that is any information that can be linked or
attributed to you, Personal Data”) when you visit www.gamedistribution.com (“Website”)
or play the games in third party platforms that publish Game Distribution games (“Third
Party Platforms”)*. This includes information regarding with whom we will share your
Personal Data, how long we will retain it, and which rights you have in relation to the
processing.
This Privacy Notice applies whenever you visit our Website or play the games distributed
by us on Third Party Platforms or use any of our other services, all of which together we
refer to as “Services”.
*Please note that the explanations provided in this Privacy Notice relate exclusively to the
processing of personal data regarding our games and our Services. When you visit Third
Party Platforms they may be collecting your personal data for their own purposes. If you
would like to learn more about the privacy practices of the respective partner websites
through which our games are provided, please review the Third Party Platform website’s
privacy statement.
GENERAL INFORMATION
In this part of our Privacy Notice, you will find general information about how we process
your Personal Data when you use our Services. For specific information with more details
about our processing activities, please see the service specific information below.
1. Who is responsible for the processing of your Personal Data
Key Games Network B.V. Beechanvenue 182 1119PX SCHIPHOL-RIJK, Netherlands is
responsible (the data controller) for the processing of your Personal Data when you visit
our Website, play the games distributed by us on Third Party Platforms or use our Services.
2. What types of Personal Data do we process and how do we
collect it?
When you use our Services, as further explained, we collect, use, store and transfer
different kinds of Personal Data via cookies, beacons, pixels, tags, and other non-cookie
technologies which will be triggered by our Software Development Kit (“SDK**”). As a
general principle, we do not collect and do not ask you to provide any “special categories
of Personal Data”, which is any particularly protected information such as data concerning
health, religion, political opinions or philosophical beliefs, sexual preferences or
orientation.
**SDK is a collection of software programs for the purpose of creating applications across
web and/or mobile platforms for a particular operating system.
The information we collect depends on which of our Services you use and how you use
them. We process the following types of your Personal Data:
2.1 Personal Data provided by you
When you use our Services, you provide or be asked to give us certain information,
including:
Information provided in relation to our customer service: When you contact support
via our Website, we collect information about your request (subject and content of your
request) and your name and contact details.
Account information: For social games, you have the option to sign up for an account.
If you choose to create an account, we collect your log-in data (your email address,
username and password)
Information provided in relation to transaction and payment: When you make a
transaction in games (e.g. purchased items or memberships, your order details) we
collect information which is related to your transaction, for example the payment
method, status and date. We do not collect any card data, you will be redirected to an
external payment provider for the transaction of your payment, we receive payment
confirmation details from our payment provider. For more information please see the
service specific information below.
2.2 Personal Data we receive or generate from your use of our Services
When you use our Services, we also process device-related information and information
about how you interact with our Services, including:
Technical information: We collect information about your device/device settings you
use for the purposes described below. The information we obtain from your devices
includes the type of your device, online identifiers (your IP address), game/site ID,
geolocation data (based on your IP address), browser settings, screen resolution and
other technical information.
Cookie data: As further described in our Cookie Notice (“Cookie Notice”), we use
cookies and similar technology such as pixels, SDK or local storage and allow third
parties to use cookies and similar technology for the purposes described below. The
exact process of placing cookies, and the scope of the data that may subsequently be
processed is set out in our Cookie Notice.
Your usage: We collect and aggregately process information about how you use our
Services. This information includes your preferences, such as your interests in certain
categories of games, the actions you take, the time and duration of your activity, the
time that you spend while playing the games, your in-game purchases, your interaction
with advertisements (clicks, installs and creative views). Furthermore, we collect
information about the websites that led you to our Services.
2.3 Personal Data we collect from other third parties
In certain scenarios, we will also obtain your Personal Data from third parties, in strict
compliance with applicable data protection laws and regulations. Your Personal Data be
provided by the following third parties:
Your Consent String: When you play our games in Third Party Platforms, that Third Party
Platform obtains your consent for our processing activities as well. If you provide your
consent to that Third Party Platform we will receive your consent string which shall
provide us your preferences on our processing activity, from Third Party Platform.
Google Analytics: Google Analytics employs cookies that are stored to your computer
in order to facilitate an analysis of your use of the site. The information generated by
these cookies, such as time, place and frequency of your visits to our site, including your
IP address.
In using Google Analytics our website employs the extension “anonymizeIp”. In doing
so, Google abbreviates and thereby anonymizes your IP address before transferring it
from EU/EEA member states. Google uses this information to analyze your use of our
site and in game events, to compile reports for us on internet activity.
Social Networks and connected third-party platforms: If you choose to connect our
Services with your Facebook account by using your credentials with our log-in process,
we receive certain information about you from Social Networks such as your public
profile, first and last name, your profile picture, your email address, and your
authentication token.
If you choose to connect our Services with Azerion Connect, it offers a single platform
from where users can obtain the necessary login data for all participating. After
registration, the SSO authentications service is available to the participating portals and
to users as a single tool for logging in to the various participating specialist portals. We
receive your name, surname, your email address and your authentication token.
To learn more about which data is processed, please see the section with service specific
information below.
3. Do we collect data from minors?
Our services are intended to be appropriate for general audiences. Therefore we do not
intentionally collect and/or categorize personal information from children . In the event
that we learn that we have collected personal data from a user under 16 years of age within
the scope of the Services explained in this Privacy Notice, we will delete that data as quickly
as possible. If you believe that a user might be under the age of 16, please contact our
support team at Game Distribution Support.
4. For what purpose do we process your data?
Depending on which Services you are using and which privacy settings you have selected,
we process your Personal Data for the following purposes:
Provision and improvement of our Services
to allow you to play the games on our Website and Third Party Platforms
to allow you to use our Services
to identify and correct any bugs/errors
to gain insights into the popularity of our Services
to assess the quality of our Services
to analyze the performance of our Services
to understand and improve your online experience
to aggregate financial reports to pay our business partners
to pay our business partners for the promotion of our Services
to provide you with customer support based on your questions, requests, or
complaints
to facilitate your purchase, to verify and confirm your payment
Personalization of your game experience
to recommend games you may like based on your preferences
to remember you next time you visit our Services
Marketing and analytics
to deliver (targeted and non-targeted) advertising in our Services
to measure the effectiveness of advertising
to acquire new users
to understand usage of our Services across all our group companies to support
strategy and growth
Prevention of fraud and illegal activity
to investigate fraud and illegal behaviour
Compliance with our legal or regulatory obligations
to determine the legal requirements for processing of your Personal Data (based on
your location such as your country)
to respond to your requests related to your data subject rights
to comply with our legal obligations (e.g. tax and accounting obligations)
to inform you about any changes to this Privacy Notice
Please see the section with service specific information below for a more detailed
description of the purposes for which we process your Personal Data.
5. Do we engage in profiling activities?
If you consent to this via the cookie consent pop-up, we use tracking mechanisms to track
your activities in the games and while using our Services. We receive aggregated data from
our tracking mechanism. We do not use this data for profiling purposes. This data allows us
to analyze performance of our services and improve our services. You have the right to
object to this type of processing. You can also go to your privacy settings to review and
amend your privacy choices related to this type of processing at any time.
6. On which legal basis do we process your Personal Data?
We process your Personal Data for the purposes described in this Privacy Notice, based on
the following legal grounds:
Your consent: We process your Personal Data if you have provided your consent for a
specific purpose. For example, when you use our Services for the first time, your consent
is asked for the data processing in the context of personalized advertising and analytics.
We also show you just-in-time contextual notifications and consent pop-ups to obtain
your consent for further processing activities. You have the right to withdraw your
consent at any time, for example by changing your privacy settings. Please note that
this will not affect any processing carried out before you withdraw your consent.
As it is explained above when you play our games on Third Party Platforms, the Third
Party Platform that you play our games shall ask for your consent on behalf of us, we
shall only process your personal data that we rely on your consent for processing if you
provide your consent to that Third Party Platform.
Performance of a contract: We process your Personal Data for the performance of a
contract to which you are a party, for example, in the context of customer service, to
support the operation of our games or facilitate the delivery of requested services.
Compliance with legal obligations to which we are subject: We process your Personal
Data to comply with legal obligations. for example, for tax and accounting purposes or
legal disputes.
Legitimate interests: We also process your Personal Data to the extent that the
processing is necessary for our legitimate interests or those of third parties while
applying appropriate safeguards that protect your privacy. For example, we process
your Personal Data for improvement of the service provided to you or to provide you
with a better user experience and we transfer your personal data across all our group
companies for administrative transfers as well as to identify/determine the size of the
user base of our Services. We kindly remind you that you have the right to object to
processing of personal data.We kindly remind you that you have the right to object to
processing of personal data.
Please see for additional information the section with service specific information below.
7. With whom do we share your Personal Data?
We will not disclose your Personal Data to any party who is not authorised to process them.
To manage our services, we will share your Personal Data internally with members of our
responsible departments and technical support involved in the gaming process and in each
case only if access to your Personal Data is necessary for the performance of their roles.
Moreover, and only when necessary to fulfil the purposes mentioned above, we disclose
your Personal Data to the following recipients or categories of recipients or allow the
following third parties to collect your Personal Data in connection with your use of our
Services:
External service providers: We share your Personal Data with external service providers
who perform services on our behalf, like IT services, hosting and content delivery
services, data management services, video hosting service, and user notification
services. Where we share your Personal Data with external service providers, we have
appropriate agreements in place to ensure that your Personal Data is processed in
compliance with applicable data protection laws.
Third Party Platforms: As GameDistribution we distribute games to third-party
Publishers. We only provide anonymized statistics and revenue reports to third-party
Publishers. We therefore advise you to check the privacy policies of any such Publisher
before starting the game. Furthermore, you can find the third parties your Personal
Data may be processed by playing our games or use our Services in the following link:
https://static.gamedistribution.com/policy/third-party-list.html.
External advertising companies: With your consent, we share your Personal Data with
third-party advertising companies or allow third-party advertising companies to collect
your Personal Data when you use our Services. If you choose not to receive personalised
ads at all, we will still show you ads, but they may not reflect your interests as those ads
will be content specific and not user specific. Please note that by clicking on a third-
party advertisement, you are redirected to the third-party advertiser’s environment
over which we have no control.
In-Game Event Analytics Platform: With your consent, we share your Personal Data
with our affiliate in-game event analytics platform to receive standardized tracking for
business intelligence teams who use the data for analytics & reporting.
Payment providers: If you make in-app or website payments, the transaction will be
processed by a third-party payment provider and will be subject to the third-party
payment providers’ privacy policies.
Law enforcement, government authorities or courts: We disclose your Personal Data
in response to lawful requests to public authorities, including law enforcement,
government authorities, or courts.
Group companies: We share your personal data with our group companies which are
responsible for internal analytics for the purposes of cross-product audience
measurement. Where we share your personal data with our group company, we have
appropriate agreements (an intra-company data sharing agreement) in place to ensure
that your personal data is processed in compliance.
Other third parties: We also disclose your Personal Data in the event of any
contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer
or other disposition of all or any portion of our business or assets (including in any
insolvency or similar proceedings).
Please see the section with service specific information below for more information about
the third parties we may share your data with. Furthermore, you can find the third parties
your Personal Data may be shared with by clicking on the following link:
https://static.gamedistribution.com/policy/third-party-list.html
8. Where will my Personal Data be processed?
In general, if you are accessing our Services from the European Union (EU) / the European
Economic Area (EEA) your data is stored on servers within the EU / EEA. However, with
regard to certain activities described in this Privacy Notice, your data may also be shared
outside the EU / EEA. We have implemented appropriate safeguards to protect your
Personal Data when it is transferred outside the EU/EEA, including the execution of the
European Commission’s standard data protection clauses (also known as Model Clauses) to
provide safeguards for your Personal Data.
9. How do we protect your Personal Data
We have implemented appropriate technical and organizational security measures
designed to protect your Personal Data against accidental, unlawful or unauthorized
destruction, loss, alteration, access, disclosure or use. We update and test our security
standards on an ongoing basis. In addition, we take reasonable steps to assure that third
parties to whom we transfer your Personal Data provide sufficient protection of Personal
Data.
10. How long do we store your Personal Data?
We will not retain your Personal Data longer than necessary to fulfil the purposes for which
the data was collected or to fulfil our legal obligations or necessary for the establishment,
exercise of defence of legal claims or resolving disputes. Afterwards, we will delete or
anonymize your Personal Data. Please see below for information about how long we will
retain your Personal Data. Additional information on how long your Personal Data is stored
by our service partners can be found in the respective third-party list available here.
11. What are your rights in respect of your Personal Data?
To the extent permitted by applicable data protection laws and regulations, you have the
following rights in relation to your Personal Data:
Access the Personal Data we hold about you, including information such as the source
and categories of data, the processing purposes, the recipients (or categories thereof),
and the respective retention period.
Request an update or correction of your Personal Data so that it is always accurate.
Receive your Personal Data in a structured, commonly used and machine-readable
format, including the right to transfer your Personal Data to another data controller.
Request the deletion of your Personal Data if you believe that retention is no longer
necessary for the purposes indicated above.
Restrict the processing of your Personal Data, for example, if you have contested the
accuracy of your Personal Data, and for a period of time that is sufficient to allow us to
verify its accuracy.
Withdraw your consent at any time if your Personal Data is processed with your
consent. Please note that this will not affect the lawfulness of data processing based on
consent granted prior to its withdrawal.
Object to the processing on specific grounds relating to your particular situation, in the
event and to the extent that we process your Personal Data based on our legitimate
interests. In such cases we will no longer process your Personal Data unless we have
compelling legitimate grounds for the processing which override your interests, rights
and freedoms, or for the establishment, exercise or defence of legal claims. You also have
the right to object where we are processing your Personal Data for direct marketing
purposes (including profiling). In such a case, we will stop processing your Personal Data
for marketing purposes.
You can exercise these rights by sending a request to the contact details set out below,
providing your name, your email address as well as a description of your request. If you
believe we have not complied with our obligations under applicable data protection
laws and regulations, you can lodge a complaint with a competent data protection
authority, for example, the Autoriteit Persoonsgegevens in the Netherlands.
12. How can you contact us?
If you have any queries about this Privacy Notice or how we use your Personal Data, please
contact our customer support via our Website or our Data Protection Officer via e-mail to
dpo@azerion.com.
13. How often do we update this Privacy Notice?
We regularly review and update this Privacy Notice. When there is an important change
that will have a relevant impact on the processing of your Personal Data, we will inform you
by email if we have your email address. If we do not have your email address, for example
because you did not create an account, we will inform you with a banner on our Website.
This Privacy Notice was last updated on:12/08/2021
Additional Information for California Residents
This section for California residents supplements the information provided in this Privacy
Notice and applies solely to players, and others who reside in the State of California. We
provide this section to comply with the California Consumer Privacy Act of 2018 (CCPA) and
the regulations issued under it; accordingly, this section addresses the specific requirements
of the CCPA and should be read together with this Privacy Notice.
We do not sell your Personal Data. However, we may share or provide access to each of the
categories of Personal Data we collect as necessary for our business purposes. We collect
information that identifies, relates to, describes, references, is capable of being associated
with, or could reasonably be linked, directly or indirectly, with a particular consumer or
device. In particular, we have collected the following categories of personal information
(envisaged by the CCPA) from consumers within the last twelve (12) months:
Category A Identifiers (such as your device identifier, demographic information -such as
your country, your username, email address, any information you may choose to provide -
such as your age or your language-)
Category B- Personal information categories listed in the California Customer Records
statute (Cal. Civ. Code § 1798.80(e))
Category D Commercial information (such as purchase history)
Category F Internet or other similar network activity (such as your interaction with our ads,
your IP address)
Category G Geolocation data
Category H Audio, electronic, visual, thermal, olfactory, or similar information.
The CCPA provides consumers (California residents) with specific rights regarding their
personal information.
You have the right to access specific information i.e. you may request that we disclose
certain information to you about our collection and use of your personal information over
the past 12 months.
You have the right to know. Under the CCPA you have the right to request that we disclose
to you what Personal Data we process about you.
You have the right to deletion which means that you may request that we delete any of your
personal information we collected from you and retained, subject to certain exceptions.
Under the CCPA, you have the right to opt out of any sale of your personal data. Please note
that your right to opt out does not apply to our sharing of personal data with service
providers, who are parties we engage to perform a function on our behalf and are
contractually obligated to use the personal data only for that function.
Finally, you have a right to not be discriminated against for exercising your rights under the
CCPA.
You can exercise these rights by sending a request to the contact details set out above,
providing your name, your email address as well as a description of your request.
Additional Information for Brazil Residents
Under the Brazilian General Data Protection Law (the “LGPD”), you have the right to access,
rectify, port, erase, and confirm that we process your data. If you have given consent about
processing your data, you have the right to withdraw consent anytime.
SERVICE SPECIFIC INFORMATION
In this part of our Privacy Notice, you will find specific information on how your Personal
Data is processed. For general information about data processes that apply, please see
above.
Hosting and content delivery
GameDistribution is hosted by external companies providing web servers and web content
delivery. Every time you make a request, for example by clicking on a link on our platform,
the information allowing this request (e.g. device information and information on
requested content) as well as online identifiers (your IP address) will be sent to the external
servers. This data is used to show you the content you requested in a faster way. We process
this data on the basis of our legitimate interest, to provide and improve our service and
ensure its functionality.
Facebook Connect
We are offering you the opportunity to sign up for our Services through Facebook Connect.
In order to do this, you will be redirected to Facebook where you can log in using your
Facebook user data. Your Facebook account will then be linked to our Services.
Depending on your Facebook settings, linking your account will allow the following data to
be transmitted to us and/or retrieved by us: email address, name, and other data that you
have set to the public on your Facebook profile.
We shall only use this information for identification purposes and contract processing. For
more information on Facebook Connect and the privacy settings, please refer to the Privacy
Policy and Terms of Use of Facebook Inc: https://www.facebook.com/policy.php.
If you use Facebook Connect to register for and log into an account, your Personal Data will
be transmitted to Facebook, Inc. 1601 Willow Road Menlo Park, California 94025 in the
United States.
You can unlink the accounts at any time and revoke the transfer of data with future effect
by changing your settings on Facebook and through your Account Settings .
Customer service
If you contact us for customer support by using our email address, we will process your
email address, and the content of your request in order to provide you with support. The
request history helps us to solve a newer request and is stored to defend possible future
legal claims. We process this data on the basis of performance of contract to provide you
with customer support, and store this data on the basis of our legitimate interest, to
improve our services, and to be able to defend possible future legal claims.
Analytics
We use analytics services to understand which features you like in our Services and how
popular our games are on social media and to monitor traffic of our Games and our
Website, for example following changes to the website. For this purpose, we process
information about your device, request data (including the URL of the current webpage and
the website visited before) . We also process your full IP address to allow us to better
understand how you use our Services and to improve our games and websites.
By activating IP anonymisation on this Website, the IP address is shortened prior to
transmission within the EEA or in other states party to the Agreement on the EEA.
We process this information based on your consent, provided in the consent pop-up which
will be shown to you when you access GameDistribution for the first time.
We also process your IP address and user id to determine the number of unique users of
our Services within our group companies. We process your personal data in connection with
this activity based on legitimate interest.
Video player
We use an ad supported video player to provide you with walkthrough videos of our games.
In order to show you the appropriate video, your request data including your IP address,
the URL you visited, and device information will be processed by the third-party video
provider based on our legitimate interests. the ads that will be shown via the video player
will only be personalised if you have given your consent for personalised advertising.
Payments
If you make in-app purchases, you will be redirected to an external payment provider for the
transaction of your payment.
The transactions will be processed by the third-party payment provider. While we do not
collect and do not receive any financial data (such as your bank account data), we collect or
receive from third-party payment providers the following information related to your
transaction: the purchased amount, the purchased item, the price and currency, your IP
address, country, device information (user agent), time stamp payment/transaction id, and
the status of your payment
Advertising
On our Games, we show advertising from different advertising companies. These adverts
can be targeted or non-targeted content related ads. In order to show you personalized ads
and only if you have provided your consent, we will share your Personal Data (your IP
address, advertising identifiers and the information that you have provided your consent
for personalized ads) through our advertising platform provider with third-party advertisers
and ad networks.
We also use this information to measure how effective these ads are. In our consent pop-
up which will be shown to you the first time you enter our Website, you can choose from
which advertising company you would like to receive personalised ads or choose not to
accept receiving personalised ads at all. You can adjust your preferences at any time in your
privacy settings. If you choose not to receive personalised ads at all, we will still show you
ads, but they may not reflect your interests as those ads will be content specific and not
user specific.