Privacy Policy

This Privacy Policy was last updated on Jan 1 2022.

OOOGAME is committed to protecting the privacy of all visitors who use

our site and applications, including older users above the age of 13

(“General Users”) and younger users under the age of 13 (“Children

Users”), together the “Users”. This privacy policy (“Privacy Policy” or

“Policy”) is designed to provide transparency into OOOGAME¡¯s privacy

practices and principles for information that we collect from General

Users through our OOOGAME.com web platform, mobile applications, our

OOOGAME Publishing services, and other general-audience sites and

applications (“OOOGAME General Site”), as well as information that we

may collect from Children Users through our separate Kids.OOOGAME.com

site (“OOOGAME Kids Site”). The OOOGAME General Site and OOOGAME Kids

Site (together, the “OOOGAME Site”) are owned and operated by OOOGAME

B.V. (referred to in this Policy as “OOOGAME”, ¡°we”, “our”, or “us”).

OOOGAME B.V. (“OOOGAME”) is an entity incorporated under the laws of the

Netherlands. By using the OOOGAME General Site, you agree to observe and

be bound by this Privacy Policy and you consent to the processing,

collection, use, and disclosure of your information and data in

accordance with the terms of this Privacy Policy. Please do not use the

OOOGAME Site if you do not agree to this Privacy Policy. If you are a

parent or legal guardian, by allowing your child(ren) to use the OOOGAME

Kids Site, you are agreeing to the terms of this Privacy Policy on your

child¡¯s behalf. To view our privacy practices specific to the OOOGAME

Kids Site and Children Users, please click here. If you have any

questions concerning this Privacy Policy, please contact us with e-mail

[email protected]

1. General information

All features on the OOOGAME Site are available without the need for

registration by Users. No personal data (such as email addresses and

phone numbers) are requested from users. OOOGAME may collect certain

electronic data (such as the User¡¯s IP address, cookies or device ID).

When a User clicks to leave the OOOGAME Kids Site, OOOGAME may try to

inform the User that they are leaving the OOOGAME Kids Site and that this

Privacy Policy will no longer apply. When a User provides personal data

on any third party website or application, the processing of such

personal data will be governed by any privacy statement applicable to

that site/application. In any event, OOOGAME shall not act as the Data

Controller or the Processor of such personal data. 2. Data collection and

its purposes Our servers automatically recognize visitors¡¯ domain names

and IP addresses (the number assigned to computers on the Internet). The

OOOGAME Site may gather anonymous “traffic data” that does not

personally identify you, but that data may be helpful for marketing

purposes or for improving the services we offer. When your computer or

mobile device contacts our web servers (for example, when you visit the

OOOGAME Site), our web servers automatically collect usage information.

Such usage information includes information about how our visitors use

and navigate the OOOGAME Site. It can include the number and frequency of

visitors to each web page and the length of their stays, browser type,

and referrer data that identifies the web page visited prior and

subsequent to visiting our Site. Traffic information may also be shared

with business partners and advertisers on an aggregate and anonymous

basis. More information about sharing information will follow in part 7.

In addition, Advertisers on the OOOGAME General Site might receive

advertising and capping the frequency of ads.

8. International Data Transfers

OOOGAME may work with third parties that are based outside of the

European Economic Area (EEA), and may transfer data about you to the

countries in which these parties reside. Whenever we share personal data

originating in the EU with an entity outside of the EEA, we will do so on

the basis of the EU standard contractual clauses, with your consent, or

because such transfer is necessary performance of a contract. If you have

any questions about our policy regarding international data transfers,

please contact us with e-mail [email protected]

9. Children Users

We recognize the importance of safeguarding the privacy of children and

encourage parents to check and monitor their children¡¯s use of online

activities regularly. This is why we created a separate age-appropriate

experience for Children Users through the OOOGAME Kids Site, or through

an age-gate in certain games on the OOOGAME General Site: in order to

comply with the legislation, you could be presented to an age screen when

starting the game. When presented with this age screen, it is important

that you state the correct age. Based on your age information and your

device settings, OOOGAME does not process personal data of children under

the minimum age limit (Children Users) that is prescribed by the

legislation in the individual jurisdictions for behavioral advertisement.

The Children Users¡¯ experience of games with an age-gate on the OOOGAME

General Site, and the OOOGAME Kids Site supports and complies with the

Children¡¯s Online Privacy Protection Act (“COPPA”). The Children

Users¡¯ experience of games with an age-gate on the OOOGAME General Site

and the OOOGAME Kids site will not request any personal information from

Children Users. There is no registration required for the OOOGAME Kids

Site and any advertising shown on the OOOGAME Kids Site, or in the the

Children Users¡¯ experience of games with an age-gate on the OOOGAME

General Site, is age-appropriate. The OOOGAME Kids Site and the Children

Users¡¯ experience of games with an age-gate on the OOOGAME General Site

will not show behaviorally targeted ads or allow third parties to track

the activity of Children Users for that purpose. The OOOGAME Kids Site

and the the Children Users¡¯ experience of games with an age-gate on the

OOOGAME General Site may collect and use IP addresses and other

persistent identifiers, including cookies, from Children Users, but only

for purposes of supporting our internal operations, such as to help us:

Identify whether you are a child or adult for data protection purposes to

determine the legal requirements for our processing of your data Maintain

or analyze the functioning of the OOOGAME Kids Site Perform network

communications Authenticate users of, or personalize the content on, the

OOOGAME Kids Site Serve contextual advertising on the OOOGAME Kids Site

and cap the frequency of advertising We have separated our platform into

a few sections. OOOGAME Kids was created for our youngest audience and is

fully COPPA compliant. If you are a Child User, you should only use the

OOOGAME Kids Site and only with the permission of a parent or legal

guardian. On OOOGAME.com, you¡¯ll find games that are intended at users

that are over 13. OOOGAME.com is not targeted towards children under the

age of 13 and it will not knowingly collect personal information from

children under 13. To learn more about COPPA, please reference this

simple one-page informational guide from the kidSAFE Seal Program:

https://www.kidsafeseal.com/knowaboutcoppa.html.

10. Lawful Bases for Processing Personal Data

If you are an individual in the European Union (EU), we collect and

process data about you only where we have legal bases for doing so under

applicable EU laws. This means we collect and process your data only

when: It is necessary for a legitimate interest (which is not overridden

by your individual privacy interests), such as preventing fraud,

improving the Service, and increasing the security of the Service and

network infrastructure; You have consented to this collection and

processing for a specific purpose; It is necessary to fulfil our

contractual obligations; or It is necessary to comply with a legal

obligation. Where we rely on our legitimate interests to process your

personal data, you have the right to object. More information on

exercising this right can be found in section 11 addressing Individual

Rights. Some examples of our legitimate interests and the data being

processed include: Network and information security (IP address,

user/device ID) Customer Support and fraud prevention (email address)

Improving our products and services (activity logs) Where we rely on your

consent to process your personal data, you have the right to withdraw or

decline consent at any time. If you wish to withdraw your consent, please

contact us using the information in section 12 regarding the Contacts for

Individual Rights Requests. If you have any questions about or need

further information concerning the legal basis on which we collect and

use your personal data, please contact us with e-mail

[email protected]

11. Individual Rights

OOOGAME makes certain choices available to you when it comes to your

personal data. Please review the below information outlining your choices

and how to exercise them. We will respond to all requests within a

reasonable timeframe. If our full response will ever take more than a

month due to complexity or scope, we will notify you of this and keep you

updated. We may request more information to confirm your identity before

acting on any request. Review and update your data: You have the right to

access and update any personal data that we have collected. To review or

update this data, please submit a request using the contact information

at the end of this section. Delete your data: You also hold the right to

have your personal data deleted. This is sometimes known as the ¡®right

to be forgotten¡¯. To request that we delete all personal data about you,

please submit a request using the contact information at the end of this

section. After you delete your personal data from our services, we may

not immediately delete residual copies from our active servers and may

not immediately remove data from our backup systems for archiving,

prevention of fraud and abuse, analytics, satisfaction of legal

obligations, or where we otherwise reasonably believe that we have a

legitimate reason to do so. We may also decline to honor this request in

certain specific situations, such as if the data is necessary to comply

with a legal obligation or to exercise/defend a legal claim. Restrict

Processing: You have the right to restrict how we process your personal

data in certain circumstances. This is an alternative to requesting the

deletion of your data. Rather than requesting we delete all of your

personal data, you may request that we limit our uses of your personal

data to specific purposes. You may wish to request we restrict our

processing if you contest the accuracy of your personal data and we are

working to verify this information, or if you want us to retain your

personal data in connection to a legal claim but cease processing it.

Data Portability: You have the right to obtain copies of your information

in a structured, commonly used format that you can move your data between

our service and the services of others. We may request more information

to confirm your identity before providing any personal data. Right to

Object: You have the right to object to the processing of your personal

data for direct marketing purposes or when our processing of your data is

based on legitimate interests. You may request that we stop processing

your personal data for direct marketing purposes. This is an absolute

right and we cannot refuse this request. Beyond direct marketing, if you

wish to exercise this right, you must give specific reasons why you

object to our processing of your data, based on your particular

situation. Even after receiving such a request, we may continue

processing if it is necessary for the exercise/defense of a legal claim

or if we can demonstrate a compelling legitimate ground for the

processing. If any request made under this section is clearly unfounded

or excessive, we may reject the request or require a reasonable fee to

honor the request. If we decide to reject your request, we will inform

you of the reasons for not taking action and provide information on other

possible remedies. If we decide that a reasonable fee is necessary, we

will promptly inform you and will comply with the request upon receipt of

this fee.