KOGEI PRIVACY POLICY

Applicable from: June 12, 2015

KOGEI Software Developer Limited Liability Company including its affiliates (“KOGEI”), collects, stores, and uses your personal information as a data controller in connection with and in order to provide and develop KOGEI’s products, mobile applications, services and websites (together “KOGEI Services”) according to this privacy policy (“Privacy Policy”).

For questions and information about Privacy Policy and data subject's rights, please contact us at info@kogei.com.

For information about our privacy practices related to data from children, please see “Special Note About Children’s Privacy” below.

ALL KOGEI SERVICES ARE GOVERNED BY THIS PRIVACY POLICY AND BY USING OR ACCESSING ANY OF KOGEI SERVICES YOU GIVE CONSENT TO THE PROCESSING, USE AND DISCLOSURE OF YOUR DATA. PLEASE DO NOT INSTALL OR USE THE KOGEI SERVICES IF YOU DO NOT AGREE TO THIS PRIVACY POLICY.

KOGEI reserves the right to modify this Privacy Policy. Your continued use of KOGEI Services will signify your acceptance of the changes to this Privacy Policy.

1. HOW WE COLLECT YOUR DATA

Likely situations when you make personal data available to KOGEI include, but are not limited to: (i) by using KOGEI’s mobile apps or visiting our websites, (ii) registration for KOGEI Services, contests and special events; (iii) accessing KOGEI Services using a third party ID, such as social networking sites or gaming services; (iv) subscribing to newsletters; (v) purchasing a product or services through KOGEI’s online stores or within the app (or in-app purchase); (vi) using “tell a friend,” "email this page," or other similar features; (vii) opening a KOGEI Account; (viii) requesting technical support; and (ix) otherwise through use of KOGEI Services where personal data is required for use and/or participation.

The data we process on you may include, but is not limited to: email address, device ID, and IP-address.

KOGEI may supplement your data with data received from third parties in connection with demographic, advertisement, market and other analytics surveys or services.

2. AD-SERVING TECHNOLOGY

KOGEI reserves the right to use and disclose the collected, non-personal data for purposes of advertising by KOGEI or KOGEI’s partners and contractors. KOGEI may employ third party ad-serving technologies that use certain methods to collect information as a result of ad serving through KOGEI Services.

When you use the KOGEI Services, we or third parties operating the advertisement serving technology may use demographic or other information collected directly from you and/or from third parties such as age and gender as well as information logged and/or collected from your device using cookies, web beacons and other technologies to ensure that appropriate advertising is presented within the KOGEI Services and to calculate the number of unique and repeat views of advertising. This technology also controls the number of times you see a given ad, delivers ads that relate to your interests and measures the effectiveness of ad campaigns. KOGEI or third parties operating the ad-serving technology may use demographic and geo-location information (for more information regarding use of Location Data see below Section 3) as well as information logged from your hardware or device to ensure that relevant advertising is presented within the KOGEI Service. KOGEI or third parties may collect and use data, for such purposes, including but not limited to, data such as IP address, Device ID, MAC address, installed software, application usage data, hardware type, Operating System information, browser information, unique identifiers in browser cookies, Flash cookies, and HTML5 local storage, Internet and on-line usage information and in-game information. The foregoing data may be collected, used, stored and disclosed pursuant to this Privacy Policy providing the foregoing data may be disclosed to third parties participating in ad-serving technology in a form that does not personally identify you.

KOGEI may display to you behaviorally targeted advertising. If you wish to “opt out” of certain targeted advertising, please visit http://www.youradchoices.com and/or www.networkadvertising.org. Please note that the links above may not reach all KOGEI’s advertising partners and certain behaviorally targeted advertising may still be displayed to you. If you want to be certain that no behaviorally targeted advertisements are displayed to you, please do not use or access the KOGEI Services.

Please note that if you “opt out” it does not mean that you will no longer receive advertising. It just means that the advertising you see displayed will not be customized to you and your interests and may be less relevant to you.

Some services may include the use of in-game advertisements or brand placement. Such ads or sponsorships will be noted as such within the services.

3. LOCATION DATA

To the extent KOGEI makes location enabled KOGEI Services available and you use such KOGEI Services, KOGEI may collect and process your location data to provide location related KOGEI Services and advertisements. For example, some add-ons or offers may be available at dedicated locations. The location data is processed and stored only for the duration that is required for the provision of the location related KOGEI Services.

KOGEI may use, depending on the service (1)IP-based location based on the IP address presented by the end-user, (2) fine geo-location data based on coordinates obtained from a mobile device’s GPS radio, or (3) coarse, network-based geo-location data based on proximity of network towers or the location of Wi-Fi networks.

GPS-based geo-location is not accessed without your consent. Notwithstanding KOGEI’s partners who are providing location related parts of the KOGEI Service, KOGEI will not share your GPS geo-location with third parties without your consent. To the extent KOGEI makes available GPS geo-location to third parties in accordance with this Privacy Policy, it will be provided anonymously.

4. ANALYTICS

KOGEI uses your information to perform its own analytics and to enable analytics provided by third parties. We use analytical information for supporting business analysis and operations, business intelligence, product development, improving products and services, personalizing content, providing advertising, and making recommendations. KOGEI may also use third-parties in order to develop and analyze use of the KOGEI Services.

5. FRIENDS

If you choose to use KOGEI’s “tell a friend” or a similar service about KOGEI Services or order a gift certificate for your friend, KOGEI may store your friend's name and contact details that you provide to KOGEI.

Please note that certain features of the KOGEI Services may be able to connect to your social networking sites to obtain additional information about you. In such cases, KOGEI may be able to collect certain information from your social networking profile when your social networking site permits it, and when you consent to allow your social networking site to make that information available to KOGEI. This information may include, but is not limited to, your name, profile picture, gender, user ID, email address, your country, your language, your time zone, the organizations and links on your profile page, the names and profile pictures of your social networking site “friends” and other information you have included in your social networking site profile. KOGEI may associate and/or combine as well as use information collected by KOGEI and/or obtained through such social networking sites.

6. DISCLOSURE AND TRANSFER OF PERSONAL DATA

Personal data may be disclosed to third parties including third parties located outside the European Union or the European Economic Area in accordance with applicable legislation and this Privacy Policy.

KOGEI may use third parties to collect and process personal data on KOGEI’s behalf and in according to KOGEI’s instructions. KOGEI is not liable for the acts and omissions of these third parties, except as provided by mandatory law.

7. DATA RETENTION AND CORRECTNESS

KOGEI retains the collected data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Thereafter KOGEI deletes all aforementioned data in its possession within a reasonable timeframe. KOGEI does not verify the correctness of personal data.

Please note that some data may be further retained if necessary to resolve disputes, enforce KOGEI user agreements, and comply with technical and legal requirements and constraints related to the security, integrity and operation of KOGEI Services.

8. COOKIES, BEACONS AND TRACKING

The KOGEI Services may use “cookies” and other technologies such as pixel tags, local shared objects, hardware-based device identifiers, Operating System-based identifiers, clear GIFs and web beacons. KOGEI treats information collected by cookies and similar technologies as non-personal data.

Cookies: A “cookie” is a small file stored by your browser when told to do so by a website. Typically websites place a number of different cookies on an end-user’s machine. Some of the cookies are “1st Party”, from the website itself, and others are “3rd party”, belonging to advertising and analytics entities or social networks. KOGEI’s cookies typically do not include personal data and are used to quickly identify your device and to “remember” your browser during subsequent visits for purposes of functionality, preferences, and website performance. You can disable cookies or set your browser to alert you when cookies are being sent to your device; however, disabling cookies may affect your ability to use the KOGEI Services.

Flash cookies & HTML5: KOGEI may also use Flash cookies (local shared objects) and HTML5 local storage. Flash cookies are small files similar to browser cookies, but which are not stored in the browser and can also be used to remember your settings, to personalize the look and feel of the KOGEI Services, or for advertising and analytics. You may prevent Flash cookies from being stored by following the instructions provided by Adobe at http://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html.

Web Beacons and pixel tags: A “web beacon” or a “pixel tag” is an electronic image (often not visible to the end-user) that allows KOGEI to count users who have visited certain pages or viewed certain advertisements. Additionally, e-mails and other electronic communications KOGEI sends to you may contain pixel tags that enable KOGEI to track your usage of the communication, including whether the communication was opened and/or what links were followed, if any.

9. THIRD PARTY TERMS AND CONDITIONS

Please note that your access to and use of the KOGEI Services may be subject to certain third party terms and conditions and KOGEI is not liable for any such third parties’ use of your personal data.

Please note that in accordance with the valid license agreements concluded by KOGEI in some cases KOGEI may be obliged to share with its licensors all and any user data (including personal data) that KOGEI collects through any of the KOGEI Services using the license provided by the licensor in the same form and format as such user data is actually collected.

Certain KOGEI Services that KOGEI may offer, such as multiplayer gaming, social networking and gaming console services, may use third party services to provide authentication for the KOGEI Services with a gaming console ID, social networking ID, or gaming network account. In connection with such use, certain personally identifiable user and/or membership data may be transferred automatically to and from KOGEI.

KOGEI may disclose your personal data to third parties in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of KOGEI’s stock and/or assets or other corporate change, including, without limitation, during the course of any due diligence process provided, however, that this Privacy Policy shall continue to govern such personal data.

10. SAFEGUARDS

KOGEI follows generally accepted industry standards and maintains reasonable safeguards to attempt to ensure the security, integrity and privacy of the information in KOGEI’s possession.

11. OTHER

You may choose to disclose data about yourself in the course of contributing user generated content to the KOGEI Services.

Any data that you disclose in any of these forums, blogs, chats or the like will become public information, and there is no expectation of privacy or confidentiality with respect to that data.

KOGEI may store and/or transfer your personal data to its affiliates and partners in and outside of EU/EEA member states and the United States in accordance with mandatory legislation and this Privacy Policy.

12. SPECIAL NOTE ABOUT CHILDREN’S PRIVACY

KOGEI does not knowingly collect personal information from children under 13 years of age. If KOGEI learns that KOGEI has inadvertently gathered personal data from children under 13 years of age, KOGEI will take reasonable measures to promptly delete such personal data from KOGEI’s records.

KOGEI understands the need to provide extra privacy protections to users who are children. To that end, features and services such as social networking plug-ins, behaviorally targeted advertising, and collection of data for the purpose of building user profiles are not available to users under 13. KOGEI also does not allow our third party partners who engage in such practices to access personally identifiable data from users under 13.

KOGEI and its partners do collect non-personally identifiable data from children. This includes, for example, collection of IP-based geolocation data to ensure that the product, service or features served comply with applicable laws of that nation.

KOGEI and its partners also collect data to assess general information about the use of products, such as the number of visitors to our sites and services and which sections of a site or service are popular. KOGEI also uses this data to provide contextually-relevant advertising to users, to prevent users from seeing the same ad repeatedly, and to allow users to personalize their experience on the site or service (for example, to save a high score in a game). KOGEI and its partners may also use cookies, pixels, hardware-based identifiers, Operating System-based identifiers, and software-set identifiers, to manage and measure the performance of advertising.

Please note that KOGEI’s partners may have their own policies related to tracking technologies for analytics and ad-serving purposes. KOGEI persuades that companies comply with KOGEI’s privacy policy, nevertheless KOGEI does not actually control third-party data collection and use. KOGEI encourages parents to review the list of operators below and to become familiar with those parties policies and practices. Please note that the list of operators below is not fully comprehensive.

http://www.adcolony.com/legal/privacy/

https://www.tapjoy.com/privacy.html

http://www.supersonicads.com/about-us/privacy-policy

http://www.flurry.com/privacy-policy.html

http://skillz.com/blog/privacy-policy/

13. FURTHER INFORMATION

This Privacy Policy is governed by the laws of the State of California without regard to its conflict of laws provisions.

KOGEI makes good faith efforts to enable you to review, update or correct your personal data in KOGEI’s possession.

KOGEI will need sufficient information from you to establish your identity and to verify your access request, and also to assist us in handling your request.