Game Distribution User Privacy Notice
We at KeyGames 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 GameDistribution 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.
GameDistribution participates in the IAB Europe Transparency & Consent Framework and
complies with its Specifications and Policies. GameDistribution’s identification number within
the framework is 610.
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
KeyGames Network B.V. Boeingavenue 30 1119PE 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 show you in-game promotions
● to facilitate your purchase, to verify and confirm your payment
● to allow you to create accounts to use our Services
● to recognize you when you visit our Services from different devices
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 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. We are also processing your Personal Data to ensure
and verify that users’ privacy choices can be and are respected, to demonstrate compliance with
accountability principles.
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. In addition to this, we determine our retention periods based on
our accountability obligations (to be able to demonstrate that we complied with our obligations, e.g.
preserving records when you exercised one of your data subject rights), statutory requirements in
countries that we are legally present including statute of limitations, the need of Personal Data for any
reference to our future actions (e.g. to be able to justify an action we took or to be able to handle
payments to our partners or clients) and the need of Personal Data for business processes including
but not limited to development of our product. 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 below.
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: 26.04.2024
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.
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.
