Game Distribution Platform 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.
Game Distribution is a distributor of cross-platform browser games and acts as the link
between Developers and Publishers. Developers co-operate with Game Distribution in
order to get access to Publishers that can publish Developers’ games on their platforms, as
well as to thoroughly analyse and monetize their games.
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”) while using our platform that you can sign-up from
www.gamedistribution.com (“Website”). 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 create an account in our Platform or use any of
our other services, all of which together we refer to as “Services”.
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 use
our Services.
2. What types of Personal Data do we process and how do we
collect it?
When you use our Services, we collect, use, store and transfer different kinds of Personal
Data. 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.
The information we collect differs 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:
Your account information: On our Website, you have the option to sign up for an
account. If you choose to create an account, we collect your log-in data (first name, last
name, your email address, country and password) and whether you are Publisher,
Developer or both.
Your company information: When you choose to create an account, we collect
information about your company; company name, url of your website and the expected
traffic of your website (we collect this information only if you are a Publisher). As further
explained below, we share this information with our reporting and billing partner
Headerlift.
Your billing Information: As further explained below, we access your billing information
that you provide to Headerlift; payment type, currency, depositor detail (company
name, your name and surname if you are private person ), street and house number
(street name and house number, postal code, city and country), bank details (bank
name, account number/IBAN, swift code, bank address).
Information provided in relation to our customer service: When you contact support
via our Website through contact us or live chat feature we collect information about
your request (subject and content of your request) and your name and contact details.
Our customer support system and emails are provided by Zendesk. Customers’ email
addresses will appear in Zendesk along with all discussion between the customer and
ourselves.
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, 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 revenue share information: As further explained, we also have access to your
revenue share information, generated from the ad monetization activities operated by
us and revenue share from in game purchases. As further explained you may also see
this information via your Headerlift account.
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:
Headerlift: We have access to data you provide to and generated by Headerlift
(reporting and billing information), our partner that we use for their reporting and
billing services.
To learn more about which data is processed, please see the section with service specific
information below.
3. Do we collect data from minors?
The Services are not targeted towards, nor intended for use by anyone under the age of 18.
In the event that we learn that we have collected personal data from a user under 18 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 18, 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 publish the games we distribute,
to allow you to use our Services
to create and manage your account
to restore your account if you ever lose access
to communicate with you in context of account activation, password management
to simplify the registration process
to provide technical support and respond to your requests
to identify and correct any bugs/errors
to gain insights into the popularity of our Services
to assess the quality of our Services
to understand and improve your online experience
to aggregate financial reports
to pay you for the promotion of our Services
Personalization of your platform experience
to remember your preferred settings
to remember you next time you visit our Services
Marketing and analytics
to deliver our newsletter
Prevention of fraud and illegal activity
to investigate fraud and illegal behaviour
to enforce our policies and Terms and Conditions
Communication
to provide you with customer support based on your questions, requests, or
complaints
to send you service emails, so that you can activate your account, for instance, or in
case you forget your password
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. 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:
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
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 such as 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.
Please see for additional information the section with service specific information below.
6. 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, web analytics services, billing and invoicing 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.
In Game Event Analytics Platform:, we share your Users Personal Data with in game
event analytics platform to receive standardized tracking for business intelligence team
who use the data for analytics & reporting.
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.
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:
[GameDistribution Third Party Partners List]
7. Where will my Personal Data be processed?
In general, Your personal data is stored on servers within the European Union (EU) / the
European Economic Area (EEA). However, 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.
8. 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.
9. 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 Service Specific 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.
10. 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.
11. 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 email to
dpo@gamedistribution.com.
12. 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 platform.
This Privacy Notice was last updated on:17/08/2021
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.
Creation/administration of your account
In order to use our Services, you have to create an account. We store your account data
(log-in credentials, first-last name, email address and password (encrypted)) to allow you
to log in on different devices, based on the performance of a contract. Your account data
will be stored for as long as your account exists. You can delete your account at any time by
submitting a deletion request to our support team or by contacting our Data Protection
Officer.
Login
The internet portal transmits the data you have provided in your registration form (normally
your email address and password) and a service URL to the authentication server. The
authentication server then uses this data to verify the login request. If the login request is
accepted on that basis, the user ID assigned to you will be transmitted to the server of the
third party platforms concerned. We process this data on the basis of performance of a
contract.
Billing, Reporting, Invoicing and Payment
GameDistribution uses an external service provider for its billing, reporting and invoicing
services. In order to provide these services GameDistribution shares your account
information, your name, surname, email, with our service provider Headerlift. Once you
create your account in order for us to provide our billing and invoicing services you shall
provide your invoice information and payment details (e.g payment type, currency,
depositor detail (company name, your name and surname if you are private person), street
and house number (street name and house number, postal code, city and country). We
process these data based on the performance of a contract.
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 a 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 to
monitor traffic of your Games. 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 users full IP address to allow us to better understand how you use our
Services and to improve your 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.