Privacy Policy

Who We Are

Kometa.Games is a professional game development studio. We design, develop, publish and operate mobile games for players worldwide, managing the full lifecycle of Our products — from concept and design through to release, live operation and ongoing support. Our activities are focused on delivering high-quality, engaging and polished casual gaming experiences.

1. Data Controller

By “Data Controller” We mean the entity that determines how and why personal data is processed. With regard to the activities described in this Privacy Policy, We are the Data Controller.

To provide and operate the Services, it is sometimes necessary to share Your Data with Our associates or partners. Some of these associates or partners are data controllers operating independently, and thus independently determine how and why they process Your Data. For more information, please refer to the section “Who Do We Share Your Data With?” below.

2. Contact Information

For matters related to this Privacy Policy, or to exercise any of Your rights, You may reach Us by email at privacy@kometagames.zendesk.com.

3. Why Do We Collect and Process Personal Data, and What Is Our Legal Basis for Doing So?

We collect and process Your personal data to perform Our contractual obligations with You, in order to:

• create, maintain and allow the use of an account for You, in Our Games or other Services where applicable;
• enable You to play Our Games or use Our other Services;
• provide the appropriate version of Our Games or other Services to You (for example, selecting a suitable language version);
• notify You of Game updates, new products or promotional offers; or
• verify Your purchases or other transactions in Our Games or other Services.

Pursuant to Our legitimate interest in making Our Services the best they can be, We process Your Data to:

• operate and maintain Our Services (for example, keeping them secure and functioning as intended);
• troubleshoot or debug bugs, errors or other issues in Our Services;
• measure and analyse the use of Our Services (for example, to discover trends or other insights, or to inform Our operations);
• create data that is not identifiable to You (for instance, aggregate data), which We then use and share freely;
• store information so that You do not have to re-enter it during future use of the Game;
• conduct surveys or other research to learn more about Our users;
• solicit feedback from You about how We can improve the Game;
• monitor the effectiveness of Our Games;
• customise and personalise the user experience; or
• improve Our current Services or develop new Services.

Pursuant to Our legitimate interest in safeguarding Our operations, We process Your Data to:

• detect, prevent or investigate fraud, fraudulent activity or otherwise unauthorised behaviour;
• conduct audit checks of Our operations or processes; or
• establish, defend and exercise Our legal rights to the extent allowed by applicable laws and regulations.

Where You provide Your consent, We process Your Data:

• to send You newsletters or similar communications where You have subscribed to them; or
• for other purposes explained to You at the time Your consent is requested.

Finally, We process Your Data where necessary to comply with legal obligations that apply to Us (including accounting and tax requirements, and requirements to provide information to competent authorities upon request), or to protect Your interests or the interests of others. We do not use Your Data to make automated decisions that significantly affect You.

3.1 Advertising and Marketing

Advertising helps fund Our Services and allows Us to make Our Games available without charge. Within Our Games or Services We may display Our own ads along with ads from third parties, and We may also advertise outside of Our Games and Services, on third-party websites and applications.

When ads are displayed within Our Games and/or Services, We may disclose Your Advertising ID and IP address to Our advertising partners. Those partners may also collect information directly from Our Games through technologies such as software development kits (SDKs). They may use Your Data for purposes such as limiting the number of times an ad is displayed to You or personalising the ads You see. When Our ads are displayed to You outside of Our Services, the ad network involved may, based on activity previously associated with Your Advertising ID, conclude that Our Services may be of interest to You. Advertising IDs and other identifiers are also used for ad measurement (for example, total views, clicks or installs generated by a particular ad), which may be collected by parties involved in ad delivery, including Us and Our advertising partners. For more information, please refer to the privacy policies of Our advertising partners.

3.2 Cookies and Similar Technologies on Our Websites

As with most websites today, Our Websites may use cookies or similar technologies (for instance, local shared objects or web beacons). A “cookie” is a small piece of data sent from a website and stored on Your device by Your web browser. Cookies may be set by the website You visit (first-party cookies) or by third parties involved in providing content, functionality or services such as analytics or advertising (third-party cookies). A cookie is typically used to recognise Your device, for instance to enable functionality, facilitate audience measurement, improve performance or store Your preferences.

3.3 How to Manage Cookies

Through Your device or browser settings You can control the use of cookies, for instance by disabling some or all cookies, or by configuring Your browser to notify You when cookies are being installed. Please note that by disabling cookies You may affect Your ability to use the Services.

4. What Data Do We Collect?

We collect the following data in relation to You:

• Your name, email address or other contact information, where You have provided them when registering an account or subscribing to Our communications;
• online identifiers, for example Your gaming alias, IP address, identifiers We assign to Your account, and hardware or operating system identifiers, including Your Advertising ID;
• technical information about the device You use, such as type, model, maker, operating system, language, display, processor or memory;
• Your coarse location, such as country, province or city, deduced from Your IP address;
• data relating to Your use of the Services, such as Your progress in Our Games, Your visits to Our Websites or Your interactions with ads in Our Games;
• data relating to Your interactions with Our ads outside of the Services, including information on how You were referred to Our Games or Services;
• crash logs and other information related to bugs, errors or other issues in Our Services;
• assumptions We have deduced based on Your activity in Our Services;
• messages or other communications You send to Us or through the Services, such as in-game chat messages or emails to Our support team;
• where You choose to connect a third-party account (such as a social media account), the information We receive from that provider, such as account name, identifier, email address, profile name, picture or friends’ information used to provide social features;
• where You make purchases in Our Games, the information We receive from third-party payment service providers to validate those purchases;
• where You subscribe to Our communications, Your content preferences or other information You submit when subscribing;
• where You participate in Our surveys or research, any comments, feedback or responses You provide; and
• any additional information You decide to provide to Us through Our Services or otherwise, including, following Your permission, any information described to You when asking for Your consent.

We do not intend to collect or otherwise process any special categories of data relating to You. Special categories of data mean genetic, biometric or health information, information revealing racial or ethnic origin, sex life or sexual orientation, political opinions, religious or philosophical beliefs, trade union membership, or information about Your criminal offences or convictions. Please do not provide this kind of information to Us, or use the Services to present such information to others.

5. From What Sources Do We Collect Your Personal Data?

We collect Your Data from the following sources:

• from information You provide to Us, for instance during account registration, subscription to Our communications, survey responses or support enquiries;
• directly from Your device and/or You by automatic means, through the use of Our Services or Your interaction with Our ads, for instance through cookies, similar technologies or SDKs;
• from Our advertising affiliates involved in the delivery and measurement of ads, when You interact with ads within Our Games or Our ads outside of Our Services;
• from the third-party account provider, when You choose to link a third-party account (such as a social media account) with Our Services;
• from the third-party payment service provider, when You make purchases within Our Services; or
• following Your consent, from additional sources described to You when asking for Your consent.

You are not obliged to provide data to Us. However, We may not be able to provide You with the Services, or some parts of them, without the collection and processing of Your Data. We provide a number of options that allow You to limit or control the extent to which Your Data is processed. For instance, You may choose not to connect Your third-party accounts, change Your device settings to reset or limit the use of Your Advertising ID, or disable some or all cookies in Your browser settings.

5.1 Data Collected from Third Parties

Most of the information We collect comes directly from You when You play Our Games or interact with Our Services. However, when You allow third-party companies access to Your personal data (for example, by downloading Our applications through the App Store or Google Play, or by linking a social media account), We may also collect information from such third parties:

• Social media: when You interact with Our Services through social media networks (for example, by liking or following Us, or sharing Our content), We may receive information that You permit the network to share. The data We receive depends on Your privacy settings with that network. We recommend that You review and adjust those settings before sharing information or linking accounts.
• Payment service providers: when You install or purchase items related to Our apps, Kometa.Games does not have access to Your credit card or bank account data. Third-party payment processors may share non-financial information with Us relating to Your purchases, such as the items purchased, in order to fulfil Your order.
• Authentication services: some parts of Our Services may allow You to log in through a third-party authentication service. These services authenticate Your identity and give You the option to share certain personal data with Us, which could include Your name, email address, user ID and profile picture. The data We receive depends on that third party’s policies and Your privacy settings.

6. Who Do We Share Your Data With?

We may share Your Data with third parties to accomplish the purposes described in this Privacy Policy. These third parties include:

• affiliate companies or associates of the Kometa.Games group, for instance where they assist in the development or operation of Our Services;
• individuals or companies outside of the group that provide services to Us and process data on Our behalf, for instance providers of hosting, analytics or services that add functionality;
• other affiliates We cooperate with in providing the Services, who process Your Data independently of Us, including advertising partners;
• potential or actual buyers, including their advisors, in the context of an acquisition, merger or other corporate restructuring;
• legal advisors, law enforcement agencies, competent courts or other governmental authorities, where disclosure is necessary as a matter of applicable law or regulation;
• any person or entity where We believe disclosure is necessary to exercise, establish or defend Our legal rights, or to protect Your vital interests or those of others; or
• any other individual or entity with Your consent.

Please note that certain data You submit or make available through Our Services may be visible to other users — for instance, Your public profile information such as Your in-game username or alias, chat messages, or information disclosed to provide social features such as groups or leaderboards.

In the context of a sale of assets, corporate restructuring or a change of control of Kometa.Games, any third party to which Kometa.Games transfers or sells its assets will have the right to continue to use the information You provide to Us in the manner set out in this Privacy Policy.

In relation to the activities described in this Privacy Policy, Your Data may be transferred to and/or processed in countries outside of the European Union (EU) and the European Economic Area (EEA), where some of Our group companies or service providers may be located. These countries may have data protection laws that differ from those of Your country. In such cases, We incorporate appropriate safeguards to protect Your personal data, including the European Commission’s Standard Contractual Clauses. Upon request, We can provide further details on the applicable safeguards.

7. How Long Do We Keep Your Data?

Your Data will be kept for as long as necessary to achieve the purpose for which it was collected — for instance, to enable Us to provide You with the Services, or to comply with legal, reporting or accounting requirements. We periodically review the data We hold and delete or de-identify inactive accounts or other data.

Following the appropriate retention period, We will either de-identify or delete Your Data or, where neither is possible (for instance because data is stored on a backup server), We will isolate Your Data and halt further processing until de-identification or deletion becomes possible. We may continue to use data that is not identifiable to You, such as aggregate data.

7.1 How to Delete Your Data

If You no longer wish to use Our Games and want to delete Your account and all associated personal data, You may request this at any time by contacting Us at privacy@kometagames.zendesk.com. Upon receipt of Your request We will comply promptly, though please allow some time for processing.

When Your account is permanently deleted, all saved in-game progress — including characters, items and virtual currencies — and all other data saved on Your account will be lost. Deletion is irreversible. We also reserve the right to retain a copy of any information that We are required by applicable law to retain.

8. How Do We Keep Your Data Secure?

We employ appropriate security procedures and measures to provide Your Data with a level of security suitable to the level of risk. These measures aim to protect Your Data against unlawful or accidental destruction, loss, alteration, unauthorised disclosure or access, and typically include encryption in transit, pseudonymisation of identifying data where possible, controls limiting access to systems that contain personal data, and procedures to handle suspected security incidents. However, no method of transmission over the internet or method of electronic storage is completely secure, and We cannot guarantee absolute security.

9. Your Rights

Where We are processing Your Data, You have the right to:

• access, rectify or request the erasure of Your Data;
• request Us to restrict Our processing of Your Data;
• object to Our processing of Your Data to the extent it is based on Our legitimate interests or those of a third party; or
• where technically feasible, request a copy of the personal data You have provided to Us in a machine-readable format.

Where Our processing is based on Your consent, You may withdraw Your consent at any time. Processing will continue where We have another lawful basis to do so.

To exercise any of Your rights, please contact Us at privacy@kometagames.zendesk.com. In order to fulfil requests submitted by email, We may need to confirm Your identity to verify Your right to make the request, which may involve requesting additional information from You.

You always have the right to lodge a complaint with Your local data protection authority regarding Our processing of Your Data, for instance the Office of the Commissioner for Personal Data Protection of the Republic of Cyprus.

10. Note for California Residents

If You are a California resident, under the California Consumer Privacy Act of 2018, as amended (“CCPA”), You are entitled to receive specific information on how We process Your data and You have specific rights over Your data, including the right to opt out of the “sale” of personal information, which is defined broadly to include the transfer of data to third parties to personalise ads for You. If You opt out of the “sale” of Your information, We will not sell Your information, including to Our advertising partners, but You may still see ads in the Services and some of Our advertising partners may still deliver ads to You based on information they already hold. To exercise Your rights under the CCPA, please contact Us at privacy@kometagames.zendesk.com.

11. Age Limit

Pursuant to Our Terms of Service, You declare that You are at least 14 years of age. We generally direct Our Services to a broad audience and do not knowingly collect personal information from children under the age of 14 (or older, where applicable law provides for different protections). If You are under 14 years of age, please do not provide Us with Your personal data or use the Services to make Your personal data available to others. If We discover that We hold personal data relating to a user under the applicable age, We will take appropriate measures to process that data according to applicable laws or promptly delete it.

The table below sets out the minimum age at which You can provide Your consent for the processing of Your Data in order to use Our Services, depending on the country You are in while using Our Services. Regardless of the legal provisions of each jurisdiction, You should in no case use Our Services if You are under the age of 14, unless prior parental or guardian approval is provided.

If You have reason to believe that We might hold information from or about a child under the relevant age, please contact Us at privacy@kometagames.zendesk.com. Where We determine that We have collected personal information from a child under the relevant age, We will delete that information without undue delay.

12. International Transfer

Data collected or stored by Kometa.Games may be stored or processed in various locations, including, but not limited to, the European Union, the EEA and the United Kingdom. Where We transfer Your Data internationally, We rely on appropriate safeguards recognised under applicable law, including adequacy decisions and standard contractual clauses. Please note that the privacy laws applicable to the places where Your personal data is transferred to, stored, used or processed may differ from, and may not provide the same level of protection as, the laws applicable to the place where You are resident.

13. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy from time to time, for example due to changes in Our operations or the legal obligations that apply to Us. Updates will be made available here. We encourage You to review this Privacy Policy on a regular basis, and in particular before You submit additional information through Our Services.

14. Contact Us

If You have any questions or concerns about this Privacy Policy, or wish to proceed with the erasure of Your account, please contact Us at privacy@kometagames.zendesk.com.