Last Revised: October 2020
Cogscoding ("Cogscoding", "we", "our" or "us") develops, publishes and operates social games for web and mobile environments "Games"), as well as web and mobile applications (each, an "App") for playing our Games across multiple devices and platforms (such as mobile devices and Facebook).
We also operate the website caseroyale.com, its subdomains and its related features ("Site", and together with the Games and App, collectively - the "Services").
Specifically, it describes our policy regarding -
You are not legally required to provide us with any Personal Data, but without it we will not be able to provide you with the full range or with the best experience of using our Services (for instance, you may still play our Games without connecting your Facebook account, but you will not be able to enjoy their social features).
We collect four main categories of data (and to the extent it may enable the identification of a specific person, or is linked to such potentially identifying data, we will deem it as "Personal Data"):
Our legal basis for collecting and using your Personal Data will depend on the particular purpose for which your data is being processed, however, we generally use the following:
The purposes for which we use Personal Data are described in more detail below:
Our Games include advertising for third party services and products. We and our advertising partners use certain data about you in order to improve our advertising practices and make the ads we deliver more effective, relevant and enjoyable, including by deploying interest-based advertising, as well as targeting and ad measurement and attribution systems.
Such data includes your device advertising identifiers (e.g. IDFA or Advertising ID), to the extent available), data related to your connected Facebook or Apple profile (if any, such as your gender, region or country), and other demographic and interests-based information that we or our advertising partners may have received from or about you, based on your consent or another legal basis (i.e., as required in order to provide you with our respective services, or based on the legitimate interests that we described in Section 3 above).
The ads we or our advertising partners deliver may be shown within our Games, our Services, or through other channels, such as third party websites and applications.
How to adjust your preferences regarding interest-based advertising
If you wish to prevent the use of your device’s advertising ID or other identifiers for interest-based advertising, you may change your device settings to reset such advertising ID or opt-out of such advertising (typically, this is available under the “Privacy” or “Ads” section in your device settings).
If you live in the USA, Canada or Europe, you can also opt-out from the collection of your data by our advertising partners who participate in the Digital Advertising Alliance, by visiting www.aboutads.info/choices (for US users), www.youradchoices.ca/choices (for Canadian users).
Please note that if you reset your advertising ID or opt-out of interest based advertising, you may still see advertisements in our Games, or on any other channels, but those ads will not be targeted based on the above mentioned identifiers. For example, such ads may be instead based on context, such as your progress and actions in the Game, or your language preferences. Please note that such actions may result in a less enjoyable user experience.
Your Personal Data may be maintained, processed, accessed and stored by Cogscoding and our authorized affiliates, Service Providers and business partners in and from the United States of America and other jurisdictions, as necessary for the proper delivery of our Services, or as may be required by law. Cogscoding is based in a jurisdiction which is considered by the European Commission to be offering an adequate level of protection for the Personal Data of EU Member State residents.
While privacy laws may vary between jurisdictions, Cogscoding has taken reasonable steps to ensure that your Personal Data is treated by its affiliates and Service Providers in a secure and lawful manner, and in accordance with common industry practices, regardless of any lesser legal requirements that may apply in their jurisdiction. Where we transfer Personal Data of EEA users to countries outside the EEA which are not considered by the European Commission to offer adequate protection, we generally make such transfers subject to approved data transfer agreements, such as the Standard Contractual Clauses. You can contact us using the details in section 12 to find out more about these safeguards.
We retain your Personal Data in order to maintain and expand our relationship, and to provide you with our Services. In other words, we will retain your Personal Data for as long as you remain our user and have not notified us otherwise. We will take reasonable measures to delete your Personal Data if you delete your account. We may also retain your Personal Data for legal and accounting purposes (i.e., as required by laws applicable to record and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), in accordance with our Data Retention Policy. If you have any questions about our Data Retention Policy, please contact us at firstname.lastname@example.org.
Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and are free to securely delete it for any reason and at any time, with or without notice to you.
We may share your data with certain third parties, including law enforcement agencies, our service providers and our affiliates - but only in accordance with this policy:
For the removal of doubt, Cogscoding may share your Personal Data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data in our sole discretion and without the need for further approval.
6. Cookies and Tracking Technologies
Our Services and some of our Service Providers utilize “cookies”, anonymous identifiers and other tracking technologies (collectively, “Tracking Technologies”) which help us provide and improve our Services, personalize your experience and monitor the performance of our activities and campaigns, as well as the usage of our Apps, Games and Services as a whole.
Service Communications: we may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, billing issues, etc. You will not be able to opt-out of receiving such service communications.
Promotional Communications: we may also notify you about new services, events and special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone, mobile or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.
If you wish not to receive such promotional communications, you may notify Cogscoding at any time by e-mailing us at email@example.com or by following the "unsubscribe", "stop" or "change e-mail preferences" instructions in the promotional communications you receive..
In order to protect your Personal Data held with us and our Service Providers, we are using industry-standard physical, procedural and electronic security measures, including encryption where deemed appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties as described in Section 6 above.
In case we process Personal Data about you and if you are an EU resident or the resident of another jurisdiction that affords you with the below rights you:
If you wish to exercise your rights under applicable law (e.g. the EU GDPR) please contact us at firstname.lastname@example.org. If you reside in the EU you may also contact our EU representative at email@example.com.
Please note that your request must:
We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you. We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Please note that the abovementioned rights are not absolute, and requests are subject to any applicable legal requirements, including legal and ethical reporting or document retention obligations.
If you wish to manage the information we receive about you from a third-party application or platform where you play our Games, such as Facebook, Apple or Google, please follow the third-party application’s instructions for updating your information and changing your privacy settings.
You have the right to file complaints with a data protection supervisory authority. You can find details of your national supervisory authority via this link https://edpb.europa.eu/about-edpb/board/members_en
The Games and Services are available only to individuals who are the greater of sixteen years of age or the age of legal majority in your jurisdiction. We reserve the right to request proof of age at any stage. We may block Users whom we suspect are under the applicable age. We do not knowingly collect Personal Data from minors and do not wish to do so. If we learn that a minor is using the Services or playing any of our Games, we may prohibit and block such use and will make all efforts to promptly delete any Personal Data stored with us with regard to such minor.
If you believe that we might have any such data, please contact us at firstname.lastname@example.org.
11. Notice for California residents
If you reside in the state of California please visit here to learn more about the rights available to you.
12. Updates; How to Contact Us
13. Controlling Version
Last modified: October 2020
Processing Personal Data
We may have collected and discloses for a business purpose the following categories of Personal Data:
Category of Personal Data Collected
Personal Data Collected
Categories of service providers to whom Personal Data was disclosed
Business Purpose for Collection
Name, username, email address, social media identifier, IP address, username, advertising ID, device an operating system information
· Advertising networks
· Social media services
· Data analytics vendors
· Quality assurance vendors
· Cloud storage Providers
· Service providers
· App distribution platforms
· Operate our business and game
· Product development/improvement
· Customer service
· Detecting/Protecting against security event
· Internal analytics and reporting
· Internal research
· Game mechanics or functionality
· Facilitate players' social interaction
· Maintaining and enhancing service, debugging
· Advertising and direct marketing
· Detecting/protecting against security events, preventing fraud and abuse of our policies
· User acquisition
· Compliance purposes and meeting legal/regulatory requirements
B. Personal Data Categories listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e))
D. Commercial Information
Transaction information, purchase history. This does not include any payment information, which is collected directly by the mobile app distribution platform.
E. Internet or Other Electronic Network Activity Information
Interaction with our App
F. Geolocation Data
Country, State, City
Sources of Personal Data
In accordance with the CCPA, you have the right to request: (i) that we disclose what Personal Data we collect, use or disclose, (ii) the deletion of your Personal Data as collected or maintained by us; (iii) to not be discriminated against in pricing and services because you exercise any of your rights under the CCPA – in accordance with the CCPA, using the methods we made available herein.
You can designate an authorized agent to make a request under the CCPA on your behalf, in accordance with the CCPA, using the methods we made available herein.
Selling Personal Data