PRIVACY POLICY

Last Updated: December 11, 2024 

Kooapps LLC (“we,” “our,” and/or “us”) value the privacy of individuals who use our website, mobile applications (“Apps”), and related services (collectively, our “Services”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and share information from users of our Services (“Users”) to improve the gaming experience. If you reside in California, Colorado, Connecticut, Oregon, Texas, Utah, or Virginia, please refer to our U.S. Privacy Addendum below for supplemental information about the types of personal information we collect and disclose, as well as how to exercise your rights under state law.

For users of our Apps that are part of Apple Arcade, please refer to the “Apple Arcade” section below.

By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond this Privacy Policy, your use of our Services is subject to our Terms of Service.

INFORMATION WE COLLECT

We may collect a variety of information from or about you or your devices from various sources, as described below. If you do not provide your information as requested, you may not be able to use our Services if that information is necessary to provide our Services or we are legally required to collect it.

Information You Provide Us.

Registration and Profile Information. If you link our Services to a third party account, such as a Game Center, Google Play, or Facebook account, we may receive information about you from these third party services such as your email address, profile information, and friends list. If you wish to limit the information these third parties make available to us, we encourage you to visit the privacy settings for those third party accounts to learn about your options.

Payment Information. All purchases, including all in-app purchases, are handled by App store platforms such as Apple and Google. Outside of a payment receipt, which we receive for refund purposes and includes the date of purchase, the item purchased, and an anonymous identification number, we do not collect any payment information.

Communications. If you contact us directly, we may receive additional information about you. For example, if you contact our customer support team, we will receive your name, email address, device identifiers, phone manufacturer, operating system version (e.g., iOS or Android) the contents of the message and any attachments you may send to us, and any other information you choose to provide. If you subscribe to our newsletter, we will collect certain information from you such as your email address. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and improve our Services.

Careers. If you decide that you wish to apply for a job with us, you may submit your contact information and your resume online. We will collect the information you choose to provide on your resume, such as your education and employment experience.

Information We Collect When You Use Our Services.

Location Information. When you use our Services, we infer your general location information based on technical information such as your internet protocol (IP) address, which may indicate your more general geographic region.

Device Information. We automatically collect certain technical information about the device and software you use to access our Services, including your IP address, operating system version (e.g., iOS, Android), web browser type, phone manufacturer, device identifiers, media access control (MAC) address, and push notification tokens.

Your Contacts.  If you give us permission to import your contacts from a third party account you link to our Services, such as your Game Center, Google Play, or Facebook account, we may access and store names and contact information from your address book to facilitate invitations and social interactions that you initiate through our Services and for other purposes described in this Privacy Policy or at the time of consent or collection. We also collect your contacts if you invite them to use our Services or share information or content with them from our Services.

Information from Cookies and Other Tracking Technologies.  We and our third-party partners collect information using cookies, pixel tags, SDKs, or other tracking technologies. Our third-party partners, such as analytics and advertising partners, may use these technologies to collect information about your online activities over time and across different services.

Messages Between Users. When you communicate with other Users on our Services through text chat, we and our third-party partners may receive the content of the messages you send and receive and information about those messages, such as when they were sent or received.

Information We Receive from Third Parties.

Other Third Parties. We may receive additional information about you, such as demographic data, from third parties such as data or marketing partners and combine it with other information we have about you.

HOW WE USE THE INFORMATION WE COLLECT

We use the information we collect:

HOW WE SHARE THE INFORMATION WE COLLECT

Affiliates. We may share any information we receive with our affiliates for any of the purposes described in this Privacy Policy.

Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of our Services.

User Content. Our Services are social services in which you can find, enjoy, and share content. If you choose to share content, like the games you’re playing, with other Users, your username will be viewable by those Users. We are not responsible for the other Users’ use of available information, so you should carefully consider whether and what to post or how you identify yourself on the Service.

Third Party App Integrations.  If you connect a third party application to our Services, we may share information such as your device identifier with that third party.

Social Networks and Other Online Services. The Service allows you to, upon your direction, share information with social networking services, such as X, Facebook and Instagram. You understand and agree that the use of your information by any social networking websites will be governed by the privacy policies of these third party platforms and your settings on that platform. We encourage you to review their privacy policies.

Marketing. We may share information about you with third parties that is in an aggregate or de-identified form that cannot reasonably be used to identify you.

Analytics Partners. We use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect information regarding your use of other websites, apps, and online resources. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout .

Advertising Partners. We work with third party advertising partners to show you ads that we think may interest you. These advertising partners may set and access their own cookies, pixel tags and similar technologies on our Services and they may otherwise collect or have access to information about you which they may collect over time and across different online services. Some of our advertising partners are members of the Network Advertising Initiative (http://optout.networkadvertising.org/?c=1#!/) or the Digital Advertising Alliance (http://optout.aboutads.info/?c=2&lang=EN). If you do not wish to receive personalized ads, please visit their opt-out pages to learn about how you may opt out of receiving web-based personalized ads from member companies. You can access any settings offered by your mobile operating system to limit ad tracking, or you can install the AppChoices mobile app to learn more about how you may opt out of personalized ads in mobile apps.

As Required By Law and Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through our Services.

Merger, Sale, or Other Asset Transfers. We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets. The use of your information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable information was collected.

Consent. We may also disclose your information with your permission.

THIRD PARTIES

Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your interaction with these third parties and any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

SECURITY

We make reasonable efforts to protect your information by using physical and electronic safeguards designed to improve the security of the information we maintain. However, because our Services are hosted electronically, and no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.

CHILDREN

No part of our Services is directed to children, and we do not knowingly collect, maintain, or use personal information from children under 13 years of age. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at [email protected].

INTERNATIONAL VISITORS

Our Services are hosted in the United States and intended for visitors located within the United States. If you choose to use our Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, please note that you are transferring your personal information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating our Services. By providing any information, including personal information, on or to our Services, you consent to such transfer, storage, and processing.

ACCESSING/UPDATING INFORMATION

You can update your account and profile information through your profile settings. If you have any questions about your privacy on our Services or as described in this Privacy Policy, please contact us at [email protected]

DELETING/RESTRICTING INFORMATION

You can request the deletion of your personal information by submitting a request to [email protected]. You can ask us to restrict the processing of your personal information by submitting a request to [email protected]. If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time by submitting a request to [email protected].

INFORMATION RETENTION

We retain your personal information where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements) and for a period of time consistent with the original purpose as described in this Privacy Policy. We determine the appropriate retention period for personal information on the basis of the amount, nature, and sensitivity of your personal information processed, the potential risk of harm from unauthorized use or disclosure of your personal information, and whether we can achieve the purposes of the processing through other means, as well as on the basis of applicable legal requirements (such as applicable statutes of limitation).

After expiration of the applicable retention periods, we will either delete or anonymize your personal information or, if this is not possible, then we will securely store your personal information and isolate it from any further processing until deletion is possible.

APPLE ARCADE

This section applies if you are playing one of our Apps that is offered through Apple Arcade (“Apple Arcade Apps”).

Your Apple Arcade App Information. We do not collect, use, disclose or retain any of your personal information as part of the standard operation of our Apple Arcade Apps. You can use and enjoy our Apple Arcade Apps without supplying us with your personal information. We collect some anonymized information (including your Player Name and game score) as part of your gameplay. All other information from your use of the Apple Arcade Apps is sent directly to Apple, and is subject to the terms, conditions, and policies between you and Apple.

iCloud. Our Apple Arcade Apps provide full support for Apple’s iCloud service, which means that they automatically save some of your game information (such as progress and current game state) and allow iCloud access to that information. If you have iCloud enabled on your device, iCloud will upload that data to the cloud on your behalf. This process never involves our servers or storage. You can enable or disable iCloud through your device settings.

Customer Support. If you contact us for customer support from within one of our Apple Arcade Apps, we will receive your email address and the contents of whatever message you send us. As this message is outside of the standard operation of our Apple Arcade games, any information you send to us is covered by the terms of the Privacy Policy.

Anonymized Data. As part of the Apple Arcade service, we may periodically receive data from Apple about the usage of our Apple Arcade Apps. This data is anonymized, which means it cannot be connected to individuals.

Children. We do not collect, use, disclose or retain the personal information of children under 13 as part of the standard operation of our Apple Arcade Apps. As a guardian, you can provide additional protection by changing the access settings on your devices. Please see the “Children” section in our Privacy Policy for more information.

CONTACT INFORMATION

Kooapps LLC is responsible for processing your information. If you have any questions, comments, or concerns about our processing activities, please email us at [email protected] or write to us at PO Box 50625 Bellevue, WA 98015.

We also work with third party service providers who may also collect persistent identifiers through the Services. A list of third parties is provided below.

List of Third Party Sites:

Tenjin

Kooapps U.S. State Privacy Notice Addendum

This U.S. State Privacy Notice Addendum (this “Notice”) supplements the information and disclosures contained in our Privacy Policy. It applies to the residents of California, Colorado, Connecticut, Oregon, Texas, Utah, and Virginia, and explains how we collect and process information about you as a business or controller and how you can exercise your privacy rights under the aforementioned States’ comprehensive data privacy and security laws (the “U.S. State Privacy Laws”).

Personal Information means information that the U.S. State Privacy Laws in this Notice defines as “Personal Information” or “Personal Data.” Personal Information does not include information that is deidentified or aggregated or otherwise excluded from the scope of the U.S. State Privacy Laws.

  1. Sources of Personal Information We Collect

    We collect Personal Information from you when you provide it to us or automatically through our services. We may also obtain information about you from other sources, such as our data or marketing partners.

  2. Categories of Personal Information We Collect, Process, and Disclose to Third Parties; and the Purposes of Processing

    The information we collect, use, and disclose about you will vary depending on how you interact with our Services. Over the past 12 months, we may have collected, used, and disclosed each of the categories of Personal Information about you, as described below.

    Categories of Personal Information We Collect Categories of Third Parties to Whom We May Disclose Personal Information for Business Purposes
    Identifiers, including name, online identifiers, internet protocol address, email address, or other similar identifiers
    • Service providers and vendors
    • Analytics partners
    • Advertising partners
    • Law enforcement or other third parties in connection with legal requests, to comply with applicable law or to prevent harm
    Categories of information listed in the California Customer Records statute (Cal. Civ. Code Section 1798.80(e)), including name
    • Service providers and vendors
    • Law enforcement or other third parties in connection with legal requests, to comply with applicable law or to prevent harm
    General (Non-Precise) Geolocation Data
    • Service providers and vendors
    • Analytics partners
    • Advertising partners
    • Law enforcement or other third parties in connection with legal requests, to comply with applicable law or to prevent harm
    Professional or Employment-Related Information, such as job application or resume information
    • Service providers and vendors
    • Law enforcement or other third parties in connection with legal requests, to comply with applicable law or to prevent harm
    Sensitive Personal Information, including contents of communications
    • Service providers and vendors
    • Law enforcement or other third parties in connection with legal requests, to comply with applicable law or to prevent harm

    Over the past 12 months, we have disclosed Identifiers to Advertising and Analytics Partners. Under the U.S. State Privacy Laws, some of these data disclosures may broadly be considered a “sale” of Personal Information, processing of Personal Information for targeted advertising, and “sharing” of Personal Information for cross-context behavioral advertising.

    We do not use or disclose Sensitive Personal Information as defined in the CCPA for purposes other than those set forth in that law.

    We do not knowingly “share” Personal Information about consumers under the age of 16 for cross-context behavioral advertising. We do not knowingly process Personal Information about consumers under the age of 13.

  3. Our Purposes for Processing Personal Information

    We use the information we collect:

    Purpose Categories of Personal Information Used for This Purpose
    • To provide, maintain, improve, and enhance our Services;
    Identifiers, Geolocation Information, and Sensitive Personal Information
    • To personalize your experience on our Services such as by providing tailored content and recommendations;
    Identifiers, Geolocation Information
    • To understand and analyze how you use our Services and develop new products, services, features, and functionality;
    Identifiers, Geolocation Information
    • To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;
    Identifiers, Categories of information listed in the California Customer Records statute
    • To facilitate the connection of third party services or applications, such as social networks and gaming apps;
    Identifiers
    • For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable or otherwise of interest to you;
    Identifiers
    • To send you push notifications;
    Identifiers
    • To facilitate transactions and payments;
    Identifiers, Geolocation Information
    • To process your job application;
    Identifiers, Categories of information listed in the California Consumer Records statute, Professional or Employment Data
    • To find and prevent fraud and abuse, and respond to trust and safety issues that may arise; and
    Identifiers, Categories of information listed in the California Customer Records statute, Geolocation Information, Professional or Employment Data, Sensitive Personal Information
    • For compliance purposes, including enforcing our TOS or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
    Identifiers, Categories of information listed in the California Customer Records statute, Geolocation Information, Professional or Employment Data, Sensitive Personal Information
  4. Retention

    We will retain Personal Information for a time period required or allowed by applicable regulations or laws and as needed to fulfill business purposes outlined in Section 3, including providing you products and services, complying with our legal obligations, resolving disputes, and enforcing our agreements, or for other purposes described in this U.S. State Privacy Notice Addendum. Our retention of information is based on many factors such as your relationship with Kooapps, the nature of the information, compliance with our legal obligations, and defending or resolving actual or anticipated legal claims.

  5. Your U.S. State Privacy Rights

    Some states provide consumers certain rights regarding their Personal Information. Depending on where you live and subject to certain exceptions, you may exercise the following rights:

    • The right to confirm whether we process your personal information and to know the categories of personal information we have collected or disclosed about you, as well as the sources of such personal information, the purposes, and the third parties or categories of third parties to whom such personal information is disclosed.
    • The right to request that we disclose to you the categories of personal information we have collected or disclosed about you, as well as the sources of such personal information, the purposes, and third parties or categories of third parties to whom such personal information is disclosed.
    • The right to access, correct, or delete the specific pieces of Personal Information we have collected about you.
    • The right to opt out of the “sale” of your Personal Information, the “sharing” of your Personal information for cross-context behavioral advertising, and the processing of your Personal Information for targeted advertising.
    • The right to limit our collection, use or disclosure of your sensitive Personal Information, where permitted by law.
    • The right to be free from discriminatory treatment for the exercise of your privacy rights.
    • The right to appeal any decision with regard to your privacy request.
    • The right to opt-out of profiling in furtherance of producing legal or significant decisions concerning a consumer. We do not engage in such profiling.
  6. Exercising Your U.S. State Privacy Rights

    Submitting Requests. You can submit access, correction, deletion, and appeal requests by sending us an email to [email protected]. You may also submit requests to access or delete your personal information by visiting https://kooapps.com/datadeletionrequest.php. You can exercise your right to opt out of the processing of your Personal Information for targeted advertising, the “sharing” of your Personal Information for cross-context behavioral advertising, or the “sale” or your Personal Information by visiting kooapps.com/privacyoptout.php.

    Verification. Requests for access to, deletion, or correction of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant U.S. State Privacy Laws’ requirements, limitations, and regulations. To verify your access, deletion, or correction request, please email us at [email protected]. In order to verify a request, we may ask you for certain information, including your device ID.

    Authorizing an Agent. If you are acting as an authorized agent to make a request to know, delete, or correct on behalf of a California resident, please send an email to [email protected], and attach a written authorization signed by the resident. We may still require the California resident to directly verify their identity and confirm that they have provided you permission to submit the request.

  7. Contact Information If you have any questions, comments, or concerns about this notice, please email us at [email protected].

Last Reviewed and Updated: December 11, 2024