Privacy Notice for Kooply Universe Games

Last updated: January 2024

About this Privacy Notice

This Privacy Notice is meant to give you information about what personal data we collect about you, how we use it, why we use it, and how you control the data processing.

Table of Co ntents  

1. The Basics: Who We Are, Our Role, and Definitions

2. Personal Data We Collect, How  We Use it, and Why

1. Website Visitors
2. Users
3. Job Applicants
4. Event Participants
5. Visitors to Our Social Media Pages

3. Our Marketing Activities
4. Sharing the Personal Data We Collect
5. International Transfers
6. Security
7. Your Rights - How to Control Our Use of Your Personal Data
8. Data Retention
9. Cookies and Similar Technologies
10. Third-Party Services
11. Children
12. Changes to the Privacy Notice

Kids who are using our apps might find it easier to read our Privacy Summary for Kids  at the end of this page.

1. The Basics

1. Who We Are

1. Kooply ZYP, sometimes doing business as K-Creative, offers mobile games through our mobile apps and manages Branching Factor’s games. Our offices are located at 12 Hatzofim Rishon Lezion IL and our registration number is 516471851 .

2. If you have questions about our company or your privacy, or want to exercise your rights, or you just want to say hello, you can contact us at hello@kooply.com .

3. If you have specific requests under European law, you can also contact us, by way of our representative in the European Union (EU), PrighterGDPR-Rep
4. by Maetzler Rechtsanwalts GmbH &Co KG, using the information available at: https://prighter.com/q/15243526173 .

2. Our Role: Controller and Processor . Certain data protection laws, including the laws in the EU, differentiate between a party that determines why and how personal data is processed (called a "controller ") and a party that processes personal data solely on the controller 's behalf and according to the controller 's instructions (called a "processor "). We are the controller in respect of the processing described in this Privacy Notice. Additional entities who may be serving as separate, independent controllers are listed below.

3. Definitions and Recommendations  

1. When we refer to " services ", we mean the Kooply Universe, through which users can access a suite of connected games that are available through our linked mobile apps.

2. When we refer to " personal   data ", we mean information that is defined as personal data under law. This includes information that identifies you directly or indirectly, including unique identifiers like IP addresses or cookie IDs.

3. When we refer to " you ", we mean users of the mobile apps that are part of the Kooply Universe.

4. This Privacy Notice is meant to be read together with our Terms of Service, which you can find at www.kooply.com/terms_and_conditions.html . In general, we recommend that you routinely review this Privacy Notice and your preferences on our apps.

4. A Note on Legal Bases.  Certain jurisdictions only allow the processing of personal data where a legal basis has been established. Under the EU 's General Data Protection Regulation ("GDPR "), the possible legal bases include (but are not limited): your consent, the processing is necessary to perform a contract with you, the processing is necessary to fulfill our legal obligations, or a company has a legitimate business interest to process your personal data. Where we are a controller, we only collect and process data where we have established a legal basis. Below you can find more details about specific legal bases.

2. Personal Data We Collect, How We Use It, and Why . Below is a description of the types of personal data we collect, how we use it, and the reason why we consider each use lawful. You have no legal obligation to provide us with personal data, but if you don 't provide us with certain information, we may not be able to provide you with the associated services.

5. Contact Information  –When you send us a, we collect any data you provide, such as your name, company, email, and the content of your message.

How We Use this Data : To respond to your message.

Legal Basis : We process this personal data based on the performance of a contract with you.

6. Third-Party Login Account Data  –If you access our apps through a third-party login account, such as your Gmail account or your Google Play Login, we may have access to a certain identifier as provided by such third-party service.

How We Use this Data : We collect third-party account data in order to allow you to access to the services and to save your preferences for use of the Kooply Universe.

Legal Basis : When we process your third-party account data to provide you with our services, we do so for performance of our contract with you, specifically our Terms of Service.

7. Activity and System Data –  When you use our apps, we automatically assign a unique identifying number to you, and we will collect data about your mobile device, including personal data such as your IP address (which will be hashed), whether you have other Kooply apps installed, and your advertising identifier (AAID/IDFA). We also collect recordings of your activity within the apps of the Kooply Universe so that we can see what screens you 've viewed, for how long, and what links you clicked on. For more information about the cookies and similar technologies we use and how to adjust your preferences, see the Cookies and Similar Technologies  section below.

How We Use this Data : We use this data for a number of purposes: (1) this data allows us to recognize our users and connect between users in order to provide them with the cross-functionality of the Kooply Universe. (2) We also use this data to generate aggregated, non-specific, analytics data about the use of our apps so we can maintain and improve the apps and develop new products or services. Recordings enable us to understand how users use our apps and how we can improve their experience. (3) In certain cases, we use this data in order to customize the ads that we display and show content that will be more relevant to specific users.

Legal Basis : (1) When we process this data in order to provide the functionality of the Kooply Universe, we do based on performance of our contract with you, specifically our Terms of Service. (2) We also process this personal data based on our legitimate interests to develop and improve our products and services, and to prevent fraud. (3) Where permitted by applicable law and subject to your consent, if required, we may also use this personal data in order to provide you with targeted marketing.

8. Purchase History  –If you make a purchase through the app, we retain a record of such purchase.

How We Use this Data : To provide you with the in-app items or services that you have purchased.

Legal Basis : We process this data in order to provide you with services and for performance of our contract with you, specifically our Terms of Service.

9. Input Data  –We collect any personal data that you input to the apps, including a username that you choose, the year of your birth, and any personal data you may choose to include in a comments section within an app.

How We Use this Data : To provide you with our services and to enable us to comply with regulations relating to children 's data.

Legal Basis : We process the input you provide for performance of our contract with you, specifically our Terms of Service and to comply with our legal obligations.

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3. Our Marketing Activities . As described above, we may use certain personal data we collect for advertising and marketing purposes. We try to limit the marketing material we send to a reasonable and proportionate level.

10. Mobile Ads . Where permitted by applicable law, and subject to your consent where required by applicable law, we collect certain device identifiers in order to serve you with targeted ads on our apps. By collecting this information, we get insights into your preferences and interests and we are better able to serve you with ads that we believe will appeal to you.

11. Marketing Campaigns.  In addition, we do run marketing campaigns on other platforms in order to let people know about our Services. As part of these campaigns, we may receive a hashed ID relating to your device. This can help us track the success of our campaigns.

4. Sharing the Personal Data We Collect . We share your personal data as follows:

12. Service Providers . Below is a list of the types of service providers we use, the service each provides, and the types of data shared with each. All service providers have agreed to confidentiality restrictions and have undertaken to use your personal data solely as we direct.

13. Data Controllers for Marketing . As part of our marketing campaigns, other companies may be collecting data about the individuals being targeted. These companies serve as separate, independent controllers of your personal data. For further details regarding our arrangement with such controllers, please contact us at hello@kooply.com  or contact such controllers directly as follows:

In addition, data may be shared with certain programmatic partners through the IronSource networks as listed at: https://developers.is.com/ironsource-mobile/general/ironsource-exchange-programmatic-partners/ .

When you link a Freecash account, we share your device identifier (IDFA/GAID) with Almedia GmbH (Freecash.com) for reward attribution and fraud-prevention. The legal basis for this is Art. 6 (1)(b) GDPR. .

14. Change of Ownership . If we are looking to sell our company, liquidate assets, or merge with another, we may share your personal data with other interested parties as part of negotiations toward that transaction. In such case, or where we do sell our company, your personal data shall continue to be subject to the provisions of this Privacy Notice .

15. Law Enforcement Related Disclosure . We may share your personal data with government agencies or other relevant parties, such as a law office or independent auditor: (i) if we believe that such disclosure is appropriate to protect our rights, property or safety (including the enforcement of the Terms and this Privacy Notice) or those of a third party; (ii) if required by law or court order; or (iii) as is necessary to comply with any legal and/or regulatory obligations, such as audit requirements.

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5. International Transfers . Some of our service providers and additional controllers are located in countries other than your own. When we transfer your personal data internationally, we will do so safely and securely and in accordance with applicable law.

16. If you are located in the EU, when we share your personal data with third parties based outside of the European Economic Area (" EEA "), we will ensure that they sign on agreements that require them to comply with applicable law, keep your data secure at similar levels to the level described in this Privacy Notice, and make sure that your data protection rights are protected. We will also implement the following safeguards:

5. When we transfer your personal data to certain approved countries, we rely on the decision by the European Commission that says that those countries are considered to provide an adequate level of data protection.

6. Where we transfer your personal data to other countries, we (i) take additional security measures to protect the data and (ii) use specific contracts approved by the European Commission, known as the Standard Contractual Clauses, to give your personal data the same protection it has in the EEA.

7. Please contact us at hello@kooply.com  if you would like further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.

6. Security . The security of your personal data is our highest priority. We work hard to make sure that your personal data will be held securely and that it will not be shared or lost accidentally. However, it is impossible to guarantee absolute security. The security of your data also depends on the security of the devices you use and the way in which you protect your user IDs and passwords. The measures we take include:

17. Technical Measures . The electronic safeguards we employ to protect your personal data include secure servers, firewalls, and antivirus protections. We encrypt data in transit using secure HTTPS (HTTP over TLS) protocols.

18. Access Control.  We limit access to your personal data only to authorized personnel who have a need to know, including customer support staff, and software developers. We review these permissions regularly and revoke an employee 's access immediately after his/her termination.

19. Internal Policies.  We maintain and regularly review and update our privacy related and information security policies.

20. Personnel.  We require employees to sign non-disclosure agreements according to applicable law and industry customary practice.

21. Database  security . Our data is encrypted in transit and in rest, meaning that when our apps communicate with the database they do so over an encrypted channel (SSL) and when it is stored in the database it is encrypted as well.

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7. Your Rights - How to Control Our Use of Your Personal Data . Depending on which laws apply, you have certain legal rights over your data. Below is some general information about rights that may apply to you, but we recommend checking the law or consulting with a lawyer to understand what applies in your specific case. To exercise your rights, please contact us at hello@kooply.com . If you want to exercise your rights regarding your personal data held by other controllers you can contact the applicable controller directly. We may ask for reasonable evidence to verify your identity before we can comply with any request.

22. Right of Access . You may have a right to know what personal data we collect about you. We may charge you with a fee to provide you with this information, if permitted by law. If we are unable to provide you with all the information you request, we will do our best to explain why. See Article 15  of the GDPR for more details, if your personal data is subject to GDPR.

23. Right to Correct Personal Data . You may request that we update, complete, correct or delete inaccurate, incomplete, or outdated Personal Data. See Article 16  of the GDPR for more details, if your personal data is subject to GDPR.

24. Deletion of Personal Data ("Right to Be Forgotten ") . If you are located in the EU, you may have the right to request that we delete your personal data. Note that we cannot restore information once it has been deleted. Even after you ask us to delete your personal data, we may be allowed to keep certain data for specific purposes under applicable law. See Article 17  of the GDPR for more details, if your personal data is subject to GDPR. T o exercise your right please visit: https://www.kooply.com/deletion-request.html  

25. Right to Restrict Processing . If you are located in the EU, you may have the right to ask us to stop processing your personal data. See Article 18  of the GDPR for more details, if your personal data is subject to GDPR.

26. Right to Data Portability . If you are located in the EU, you may have the right to request that we provide you with a copy of the personal data you provided to us in a structured, commonly-used, and machine-readable format. See Article 20  of the GDPR for more details, if your personal data is subject to GDPR.

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27. Right to Object . If you are located in the EU, you may have the right object to certain processing activities. See Article 21  of the GDPR for more details, if your personal data is subject to GDPR.

28. Withdrawal of Consent . If we are processing your data based on your consent, you are always free to withdraw your consent, however, this won 't affect processing we have done from before you withdrew your consent.

29. Right to Lodge a Complaint with Your Local Data Protection Authority . If you are located in the EU, you have the right to submit a complaint to the relevant data protection authority if you have any concerns about how we are processing your personal data, though we ask that as a courtesy you please attempt to resolve any issues with us first.

8. Data Retention .

30. We retain your personal data as long as necessary to fulfill each of the purposes we described above. Once we 're done with your data, we delete it.

31. When deciding how long to store personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized access, the purposes for which the personal data was collected, as well as applicable legal requirements. Please note that we may delete information from our systems without notifying you first. Retention by any of our service providers or subcontractors may vary in accordance with each business 's retention policy.

32. Please contact us at hello@kooply.com  if you would like details about the retention periods for each type of personal data we process.

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9. Cookies, Web Beacons, and Other Tracking Technologies .

33. We use certain technologies that store data in your device or that collect information or help us identify you. This piece of text acts as a sort of tag, letting us know that it 's you (really, your device) that 's visiting. There are other technologies that act similarly, like web beacons, pixel tags, server calls, clear GIFs, and Device IDs for apps, but for simplicity 's sake we 'll refer to them all as "cookies ".

34. How We Use Cookies . While the specific names and types of cookies we use may change from time to time, they generally fall into one of the categories listed below.

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35. Third Party Cookies : In addition to our first-party cookies, we place cookies from the following third parties:

• Unity Technologies
• Google
• Meta
• Firebase
• Singular
• App Lovin
• Bid Machine
• Fyber
• InMobi
• Liftoff
• Pangle
• IronSource –more information about IronSource 's collection of data can be found in IronSource 's privacy policy .

36. How to Ad just Your Preferences . By changing your device settings, you can prevent your device 's ad identifier being used for interest-based advertising, or you can reset your device 's ad identifier. This means that you won 't be shown ads that relate to your browsing activities. Typically, you can find the ad identifier settings under "privacy "or "ads "in your device 's settings, although settings may vary from device to device. Adjusting your preferences does not mean you will no longer receive ads, it only means the ads that you do see can be less relevant to your interests.

10. Third-Party Services . You may have access to third-party services through our services. Please note that all use of third-party services is at your own risk and subject to such third party 's terms and privacy policies. We do not take any responsibility for the performance of other services.

11. Children . We do not knowingly target children under the age at which targeting is legal without parental consent, nor do we use any data collected from children using our apps for purposes of targeted advertising. In the event that a user chooses to access our apps through a third-party login account, we rely on the age restrictions imposed by such third party. In the event that you become aware that an individual under the legal age has registered without parental permission, please advise us immediately.

12. Changes to the Privacy Notice . We may update this Privacy Notice from time to time to keep it up to date with legal requirements and the way we operate our business. We will place any updates on this page. Please come back to this page every now and then to make sure you are familiar with the latest version.

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Privacy Summary for Kids

We think your privacy is important. That 's why we wrote this summary so that you will know what we do with the information we have about you without having to read the boring adult Privacy Notice above. We also want you to know how your information is protected and we want you to know how you can make decisions about how we treat your information.

It 's probably best if you read this together with a responsible grown-up, like a parent. If you have any questions, you should speak with a grown-up, or you can always talk to us.

If you use our apps, we 're responsible for information about you that gets collected through the apps. This means that we have a special role, called a 'Controller ', in the law.

Who can use our App?

When you open our app, we will ask you for some information that will allow us to understand how old you are. Please answer truthfully so that we can make sure that we use your information in an appropriate way. The way we handle your information will depend on your age and the laws that apply in the country where you live.

What kind of information do we have about you and how do we use it?  

There is some information that you provide to us and some information that we collect automatically.

For example, when you answer our question about what year you were born, we can figure out how old you are. If you sign in with your Google or Play login account, we 'll get some data from Google.

We also collect some identifying numbers that help us recognize your device so that we 'll be able to know who you are when you enter the app again or when you enter other apps in the Kooply Universe. If we 're able to recognize you, we can make the games more fun for you, and can allow you to share things like avatars or points between different games. This information also helps us understand how you use our games so that we can make them better and more fun for all of the other players.

We might keep a record of how you play the games so that we can see which screens you visit and how long it takes you to complete a level. This also helps us understand your experience so that we can make our games better.

You might see ads in the games. These ads are shown to lots of people playing our games and we won 't use any of your information to try to figure out which ads you might like if you 're considered a kid in the country where you live and/or if we 're not allowed to according to the law.

You have no legal obligation to provide us with any information about you and can always decide that you don 't want us to have any information about you. If you decide that, then we may not be able to let you use all or part of our services since they won 't work without this information.

How do we share your information with others?

We work with a bunch of other businesses and people who help us build and fix our games. Some might help us make sure the games are working and others might help us understand how it works. We have to share your information with them so that they can help us provide you with our apps. These other businesses might not be in the country where you live. When we send them the information in the country where they are, we make sure that they are just as careful to protect your information as we are.

If we sell our whole company, we 'll have to share your information with the new owner. If that happens, we 'll make sure that the new owner treats your information in the same way that we do.

If a law says that we have to use your information in a certain way, we 'll do what the law says to do. If the law says that we have to share information with someone else, we 'll also do that.

How can you decide what we do with your information?  

You can ask us to do any of the things on this list, but you will have to get permission from your parent or guardian first:

• You can find out what information we have and ask us to send you a copy.

• If you find that we have some wrong information, you can ask us to correct it.

• You can ask us to erase any information we have. If we do, then we won 't be able to bring it back.

• You can sometimes ask us to stop using your information.

• If you live in the European Union, you can tell a supervisory authority if you think we did something wrong. You will definitely need to ask a parent or guardian before you do this.

Cookies!

No, not that kind of cookies! Cookies are a kind of technology that helps our website work. It helps remember things that you do in our apps and gives us information that can help us make it work better. We need some of the cookies to help the apps work properly and keep it safe.

How long do we keep information?

We only keep information as long as we need it in order to do the things we said we were going to do with it. If we don 't need it, we 'll erase it.

How is it protected?

We looked around to see what security measures are currently available to protect your information and what other companies like us do to protect their information and made sure that we 're doing at least as good a job as they are. That doesn 't mean everything is 100% safe but we do our best!

What if we change our mind about how we use your information?

If we do, we 'll make sure to let you and your parent or guardian know (by email or by posting an updated Privacy Notice on the website).

How can you reach us?

If you have any questions or want to tell us something about how we use and collect your information, or if you want us to delete or fix your information, you can email us at hello@kooply.com . Please remember to speak with your parent or guardian before you do.