Privacy policy

1. Introduction

This Privacy Policy explains who we are, how we collect, share and use personal data about you, and how you can exercise your privacy rights. This Privacy Policy applies to CoolGames' games, websites and related services, which we here collectively call the Service. We may periodically update this Privacy Policy by posting a new version on www.coolgames.com. If we make any material changes, we will notify you by posting a notice in the Service prior to the change becoming effective. Your continued use of the Service after the effective date will be subject to the new Privacy Policy.

If you have questions about data protection, or if you have any requests concerning your personal data, we encourage you to primarily contact us through the game, so we can reply to you more quickly.

Name of the data controller: CoolGames b.v.
Address: Herengracht 433, 1017 BR Amsterdam, the Netherlands
E-mail: [email protected]

2. Legal basis for data processing

The legal basis for data processing including use of cookies is Art. 6(1)(f) of the GDPR. If the e-mail contact is aimed to conclude a contract or serves the contract execution, additional legal basis for the processing is Art. 6(1)(b) GDPR.

3. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer various kinds of personal data about you which we have grouped together as follows:

3.1 Data you provide us

• Contact information (such as name and email address)
• Player name and password
• Profile information (such as profile photo, friends)
• Your messages to the Service (such as chat logs and player support tickets)
• Other data you choose to give us

3.2 Data we collect automatically

• Data about your account and game progress
• Your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI)
• Data about your device, such as device name and operating system, browser type and language
• Data we collect with cookies and similar technologies
• General location data
• Precise geo-location data (GPS, with your consent)
• Data about your use of the Service, such as gameplay data and your interactions with other players inside the Service

In most cases, we also create a CoolGames-specific ID for you when you use the Service.

3.3 Data we collect from our partners

• Data we receive if you link a third-party tool with the Service (such as Facebook, Apple, KakaoTalk, LINE or Google)
• Demographic data (such as to determine the coarse location of your IP address)
• Data to fight fraud (such as refund abuse in games or click fraud in advertising)
• Data from platforms that the games run on (such as to verify payment)
• Data for advertising and analytics purposes, so we can provide you a better Service

4. Purpose of data collection

4.1 To make the Service work

To perform the contract, we process data necessary to create accounts and allow you to play our games and use our Service, operate the Service, verify and confirm payments, provide and deliver products and services you request, and send you Service-related communications.

4.2 To make the Service more suitable for our players

To provide a great Service, we have a legitimate interest to collect and process data to update and develop player profiles, develop and improve the Service and player experience, manage our relationship with you, provide social features, customize your Service experience, respond to your comments and questions, provide offers in the Service and by email, send related information such as updates and security alerts, and enable you to communicate with other players.

4.3 To show personalised advertisements

To show you personalised advertisements in the Service as well as in other websites and services (including email) we have a legitimate interest to track the content you access and your online behaviour, and to deliver, target and improve our advertising and the Service. For information on how to opt out, see "Opting out of cookie tracking" below.

4.4 To keep the Service safe and fair

Ensuring a level playing field is a top priority for us. For more information, see the CoolGames Terms of Service. In order to keep the Service safe and fair and to fight fraud, we have a legitimate interest to analyse and monitor use of the Service, moderate chats, and take action against fraudulent or misbehaving players.

4.5 To analyse, profile, and segment

In all of the above cases and purposes, we may analyse, profile and segment all collected data.

4.6 With your consent

With your consent, we may process your data for additional purposes, such as using your GPS location to show you local events.

5. Cookies and automated information collection

5.1 Like many websites, CoolGames and service providers acting on our behalf, like Google Analytics, store log files and use tracking technologies such as "cookies" to collect information. A cookie is a small data file transferred to your computer's hard disk or mobile device for record-keeping purposes.

5.2 Third party advertisers on the Services may also use, place or read cookies or other technologies on your browser, subject to their own policies. Cookies can be disabled at any time by changing your browser's options. If you do not accept cookies, you may not be able to use all features of the Service.

5.3 We and our service providers may also employ web beacons, tracking pixels and local shared objects (flash cookies) to know if a page was visited, advertise more efficiently, and reduce fraud.

5.4 We and our service providers use these technologies to collect technical information including: device type; operating system version; device identifiers (MAC address, IDFA, IMEI); browser type and language; referring and exit pages and URLs; platform type; number of clicks; domain names; landing pages; pages viewed and their order; time spent on pages; and game state and activity timestamps. In some cases, we connect this information with your social network ID or CoolGames user ID.

5.5 Opting out of cookie tracking: most browsers are initially set to accept cookies, but you can reset your browser to refuse them. You may also use the Network Advertising Initiative or European Interactive Digital Advertising Alliance (EDAA) opt-out pages. Some features may not function properly if cookies are disabled.

6. Who can see your data

6.1 Other players and users: social features are a core component of our games — other players may see your profile data, in-game activities and messages you have posted.

6.2 Partners working for CoolGames: partners process your data only according to CoolGames' instructions, for hosting, player support, advertising, analytics and fraud prevention.

6.3 Other companies and public authorities: to combat fraud and illegal activity, we may exchange data with other companies and provide it to public authorities in response to lawful requests.

6.4 We may also disclose your data to comply with the law or to protect the rights, property or safety of us, our players or others.

7. How we protect your data

We are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorised access, loss, misuse or alteration.

7.1 Data retention

We retain your data for as long as your account is active or as needed to provide the Service. We periodically de-identify unused game accounts and regularly review and de-identify unnecessary data. If you ask us to remove your personal data, we will retain data as necessary for legitimate business interests, such as complying with legal obligations, resolving disputes, and enforcing agreements.

7.2 Age limit

We do not knowingly collect or solicit personal data about anyone under the age of 13, or knowingly allow such persons to use our Services. If you are under 13, please do not send us any data about yourself. If we learn we have collected personal data about a child under 13, we will delete it as quickly as possible.

7.3 International transfers outside of the EEA

Our Service is global by nature and your data can therefore be transferred anywhere in the world. Because different countries may have different data protection laws, we take steps to ensure adequate safeguards, including standard contractual clauses approved by the EU Commission and Privacy Shield certification for transfers to the USA.

8. Legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

• 8.1 Right to access — receive a copy of the personal data we hold about you and check we are lawfully processing it.
• 8.2 Right to correct — have incomplete or inaccurate data corrected.
• 8.3 Right to erase — ask us to delete data where there is no good reason for us to keep processing it.
• 8.4 Right to object — object to processing based on legitimate interest or for direct marketing purposes.
• 8.5 Right to restrict processing — ask us to suspend processing in certain scenarios.
• 8.6 Right to data portability — receive your data in a structured, machine-readable format.
• 8.7 Right to withdraw consent — at any time, without affecting prior lawful processing.

8.8 Costs: you will not have to pay a fee, unless your request is clearly unfounded, repetitive or excessive.

8.9 Information required: we may need to request specific information to confirm your identity before responding to a rights request.

8.10 Response time: we try to respond to all legitimate requests within one month.

8.11 To exercise any of the rights above, email [email protected] with your name, the name of the game, and your game ID (found in the settings menu).

9. United States of America

9.1 Residents of certain US states are granted specific legal rights regarding their personal information, defined per the California Consumer Privacy Act of 2018 (CCPA) as information that identifies, relates to, or could reasonably be linked with a particular consumer or household.

9.2 If you reside in these states, you have enhanced rights concerning your Personal Information, including the ability to access, confirm, correct, obtain a copy of, delete, and opt out of the sale or sharing of your Personal Information, and to opt out of profiling for targeted advertising.

9.3 We may collect or process the same categories of personal information mentioned in Section 3, for the business purposes described in Sections 4 and 5. We do not collect or process sensitive personal information for the purpose of inferring characteristics about a user.

9.4 While we do not generally sell personal information in the traditional sense, certain state laws such as the CCPA may interpret sharing or disclosure as a "sale." To the extent that applies, we will comply with all legal requirements regarding such activities.

9.5 Our retention practices are detailed in Section 7.1.

9.6 Depending on your state of residence, your rights may include the Right to Know and Delete, the Right to Opt Out of sale/sharing and targeted advertising, the Right to Limit Use and Disclosure of Sensitive Personal Information, the Right to Obtain Consent, the Right to Confirm and Obtain a Copy, the Right to Correct, and the Right to Non-Discrimination for exercising your privacy rights. To exercise any of these rights, contact us via [email protected] with your name, the name of the game and your game ID.

10. Policy updates

We may update our Privacy Policy from time to time to reflect changes in technology, legislation, our operations, or as we otherwise determine is necessary or appropriate. Any such changes will become effective when we make the revised policy available on our website. We encourage you to review this page periodically.

This document has been updated on December 17, 2024.