Acceptance and Consent
1. Information Collection
Our main goals in collecting and using information are to provide and improve the Service, to administer and assist you in administering your Account on the Service, and to provide you with a better experience with the Service.
The personal information we may collect about you through the Services falls into the following categories:
1.1 Voluntarily information provided by user
Certain sections of our Services may ask you to provide personal information voluntarily. For example, we may ask for specific information to begin playing Games, to subscribe to marketing communications from us, and/or to submit enquiries to us, such as:
your name/ email address or other contact details.
Any information you submit to our customer service team in the game or via email
The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be explained to you when we ask you to provide your personal information.
1.2 Automatic information collected
When you use our Services, we may also collect certain information automatically from you and/or your device which may be considered personal information under applicable data protection laws, such as:
your service communications such as in-game chats and messages with other players.
Data and analytics about your use of our Services for example in-game play progress,
levels, games played, session length, preferred settings, which in-game adverts you may have viewed, in-game preferences or just game preferences, which friends you connect with, the means by which you were referred to our Services
your device type and operating system that you use
general geographic location based on your IP address
We may share aggregate or anonymous information about you with advertisers, publishers, sponsors and other third parties.
1.3 Special categories of information
We do not request or intend to collect any “special categories of information” such as any information on race, religion, health, political opinions or philosophical beliefs, sexual orientation or preferences. Please be cautious when sharing such information about yourself or others in our forums.
1.4 Social Media
If you use one of our applications and connect to your Facebook account or Gmail within such application, you will be providing us with basic account information i.e., user ID, name, email, profile picture URL. In addition, we will cache data we receive from the Facebook APIs to improve our user experience. If you want us to delete the data we receive from Facebook about you, please contact us via the contact form.
1.5 Profile information
When using some of our Services, you may be able to add information to your profile, such as an avatar or profile picture, birthday, nickname or username, or country. You voluntarily provide this information to us.
1.6 Offer wall
We may display an “offer wall” in our applications that is hosted by an offer wall provider. The offer wall allows third party advertisers to provide virtual currency to users in exchange for interacting with an advertisement or for completing a marketing offer that may include signing up for an account with one of those advertisers. These are not offers made by Kroy Games. These offers may be displayed to you based on certain technical information, such as your geographic area or anonymous demographic information. After clicking on one of these advertisements, you will no longer be on a site hosted by Kroy Games. To properly credit user accounts and to prevent fraud, a unique identifier, will be shared with the offer wall provider.
1.7 Friend invitation
You may decide to provide us with another party’s email address to allow us to contact and invite that party to visit or join the Service or so that Kroy Games may facilitate your communication with such other party through methods of communication enabled by the Service (such as when you upload an address book). Such email addresses will be used only for the purpose of sending email communications to the addressee.
2. How we use the information we collect?
We use the personal information we gather through the Services for the purposes described below. If we use your personal information in any other ways, we will disclose this to you. You can choose not to share your information with third parties for marketing purposes, or from allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your consent. If you choose to limit the ways we can use your personal information, some or all of the Services may not be available to you.
(a)To provide the Services to you. We require certain information from you in order to provide you with the Services you requested. Such information may include your contact and device information. We share this information with our service providers or partners to the extent necessary to continue to provide you with the Services. We cannot provide you with Services without such information.
(b)To provide customer service. We process your personal information when you contact us to help you with any questions, concerns, disputes or issues, or to provide us with your feedback. Without your personal information, we cannot respond to you or ensure your continued use and enjoyment of the Services.
(c)To enforce terms, agreements or policies. To ensure your safety and adherence to our terms, agreements or policies, we may process your personal information to: actively monitor, investigate, prevent and mitigate any alleged or actual prohibited, illicit or illegal activities on our Services; investigate, prevent, or mitigate violations of our terms and policies; enforce our agreements with third parties and partners; and, collect fees based on your use of our Services. We cannot perform our Services in accordance with our terms, agreements or policies without processing your personal information for such purposes.
(d)To send you Service-related communications. We use your contact information to send you administrative or account-related information to you to keep you updated about our Services, inform you of relevant security issues or updates, or provide other transaction-related information to you. Service-related communications are not promotional in nature. You cannot unsubscribe from such communications because you could miss important developments relating to your account or the Services that may affect how you can use our Services.
(e)For security purposes. We process your personal information to: improve and enforce our security measures; combat spam, malware, malicious activities or security risks; and to monitor and verify your identity so that unauthorized users do not access your account with us. We cannot ensure the security of our Services if we do not process your personal information for security purposes. Designated Countries: For all purposes listed above, pursuant to the EU General Data Protection Regulation (“GDPR”) or any equivalent legislation (collectively “Data Protection Laws”), we process the personal information of users located in the European Economic Area (“EEA”), United Kingdom and Switzerland (collectively, the “Designated Countries”) based on our contract with you.
(f)To maintain legal and regulatory compliance. We process your personal information to pay our taxes or fulfill our other business obligations, and/or to manage risk as required under applicable law. We cannot perform the Services in accordance with our legal and regulatory requirements without processing your personal information for such purposes. Designated Countries: Pursuant to the Data Protection Laws, we process the personal information of users located in the Designated Countries to comply with our legal obligations.
(g)To personalize your experience on the Services. We allow you to personalize your experience on our Services via social media plugins on our Services (e.g., Facebook and, or Google.), by keeping track of your preferences (e.g., nickname or display name, time zone, language preference, etc.), and more. Without such processing, you may not be able to access or personalize part or all of our Services. Designated Countries: Pursuant to the Data Protection Laws, we process the personal information of users located in the Designated Countries to satisfy our legitimate interests as described above.
(h)To conduct research and development. We process information about the way you use and interact with our Services to help us improve our Services; build new Services; and build customized features or Services. Such processing ensures your continued enjoyment of part or all of our Services. Designated Countries: Pursuant to the Data Protection Laws, we process the personal information of users located in the Designated Countries to satisfy our legitimate interests as described above.
(i)To engage in marketing activities. We may process your contact information or information about your interactions on our Services to: send you marketing communications; deliver targeted marketing; inform you about events, webinars, or other materials, including those of our partners; and, keep you up-to-date with our relevant products and Services. Transactional communications about your account or our Services are not considered “marketing” communications. In addition, when you share your friends’ contact information with us, we may reach out to them to invite them to our Services and to continue receiving our communications. You can opt-out of our marketing activities at any time.
Designated Countries: For users located in the Designated Countries, please see section 9.C. below.
Unless you opt out as explained below, we and our third-party partners use information collected about you to send you marketing communications about other games and related Services based on your interests. For instance, we may send emails, serve ads within our Services or place ads on third party websites, apps and Internet-connected devices.
5. Cookies and similar technologies
We collect information about your device and how you use our games including cookies and similar technologies. This section describes our use of these technologies and how you can manage your preferences.
Ad identifiers, cookies and similar technologies are used to provide our Services to you and in order to collect data from your device. These technologies allow us and our third-party advertising partners to:
- recognize you and your device
- provide internet-based advertising to you
- allow our Services to interact with third party social network or platform (where you
have chosen to allow such interactions)
- allow us to understand how you interact with our websites (for instance, where we use
cookies such as in the Google Analytics cookie on our Websites)
- allow our payment processors to process your payment instructions, and
- enable us and third parties to provide you with more customized services, for example
to provide our Services in the correct language.
5.1 How do ad identifiers, cookies and similar technologies work?
Ad identifiers are non-permanent, non-personal identifiers such as the Android advertisingID and/or Apple’s ID for advertising (the IDFA), which are uniquely associated with your device. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognize your device when you use websites and applications.
Cookies are small text files that are stored by your browser on your desktop computer or mobile device. You can withdraw your consent to cookies by updating within your browser.
5.2 How to adjust your preferences for your interest-based advertising?
You can choose to prevent your device’s ad identifier being used for interest-based advertising, or you can reset your device’s ad identifier, by changing the settings of your device. Settings usually vary from device to device, but you will usually find the ad identifier settings under “privacy” or “ads” in your device’s settings.
If you choose to adjust your preferences in order to prevent these technologies, you may find out that you cannot enjoy the full use of our services.
Note that adjusting your preferences as described in this section does not mean you will no longer receive adverts, it only means the adverts you do see will be less relevant to your-interests. We will also still use your device’s ad identifier to serve you with ads, for instance, we may use this for frequency capping (meaning, to control the maximum number of times you see the same ad from us).
6. Legal basis for data processing
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only where (i) we need the personal information to perform a contract with you, (ii) the processing is in our legitimate interests and not superseded by your rights, or (iii) we have your consent to do so.
(a) Under our terms of service, “performance of contract” as a legal basis for processing your information refers to when we make the Game and Services available to you, provide customer support, integrate Games with technology and distribution platforms such as Apple iOS and Google Android, and inform you of service-related changes and Game progress.
(b) We process your personal data on the basis of our legitimate interests for example when we provide you the Game and Game events, serve interest based advertisements to you (both in-game and on third-party properties), carry out marketing, keep our games secure, for engineering purposes, analyzing the users’ behavior across our Games, moderating chat discussion.
(c) We have a “legal obligation” to process your personal data when complying with a legal obligation, such as the preventing a crime or fraud or maintaining tax records.
(d) If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
If you have questions about, or require, further information concerning the legal basis for collecting and using your personal information, please contact us using the contact information provided in the " Contact Us" section below.
7. How does Kroy Games share personal information with third-parties?
We may share your personal information with third parties in the following circumstances:
Employees, Third-Party Processors and Third-Party Service Providers.
We disclose your personal information to our employees, contractors, affiliates, distributors, dealers, vendors and suppliers (“Service Providers”) who provide certain services to us or on our behalf, such as operating and supporting the Services, analyzing data, or performing marketing or consulting services. These Service Providers will only have access to the personal information needed to perform these limited functions on our behalf.
Designated Countries: Pursuant to the Data Protection Laws, we process the personal information of users located in the Designated Countries based on our contract with you.
Response to Subpoenas or Court Orders or to Protect Rights and to Comply with Our Policies
To the extent permitted by law, we will disclose your personal information if:
Required to do so by law, or in response to a subpoena or court order or similar request from judicial authority, law enforcement authorities or other competent public authorities.
We believe, in our sole discretion, that disclosure is reasonably necessary to protect against fraud, to protect the property or other rights of us or other users, third parties or the public at large; or
We believe that you have abused the Services by using it to attack our systems or to gain unauthorized access to our system, to engage in spamming or otherwise to violate applicable laws.
Designated Countries: Pursuant to the Data Protection Laws, we process the personal information of users located in the Designated Countries based on our legal obligations, in the public interest, or protect your vital interests.
With any other person, with your consent for such discloser.
Kroy Games takes reasonable measures to protect your information from unauthorized access or against loss, misuse or alteration by third parties.
Although we make good faith efforts to store the information collected on the Service in a secure operating environment that is not available to the public, we cannot guarantee the absolute security of that information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining access to this information. We do not warrant or represent that your Account or any of Your Information will be protected against, loss, misuse, or alteration by third parties.
9. International data transfers
Your information may be transferred to and processed in countries other than the country of which you are a resident. These countries may have data protection laws that are different from the laws of your country.
Specifically, our Game servers are currently located in the United States, and our business members, and third-party service providers operate around the world. This means that when we collect your personal information we may process it in any of these countries. However, we ensure appropriate safeguards are in place so that your personal information will remain protected in accordance with this Privacy Notice.
10. Data retention
We retain personal information we collect from you where we have an ongoing legitimate business need to do so. For example, to provide you with a Service you have requested, or to comply with applicable legal, tax or accounting requirements. For example, we periodically de-identify unused Game accounts and regularly review and de-identify unnecessary personal information.
When we have no ongoing legitimate business need to process your personal information, we will either delete or de-identify it, or, if this is not possible – for example, because your personal information has been stored on a backup server – then we will securely store your personal information and isolate it from any further processing until deletion is possible.
11. Your rights
You have certain rights in connection with your personal information and how we handle it. You can exercise these rights at any time by contacting us via any of the methods set out in the Contact Us section.
You have the following rights:
(a) Right of access: You have a right to know what information we hold about you and in some cases to have the information communicated to you. If you wish to exercise this right please contact us letting us know that you wish to exercise your right of access and what information in particular you would like to receive. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information. Please note that we may not be able to provide all the information you ask for, for instance if the information includes personal information about another person. Where we are not able to provide you with information that you have asked for, we will endeavor to tell you why. We will try to respond to any request for a right of access as soon as possible, but we will always do so within 1 month of receipt of your request and verification of your identity.
(b) Right to correct personal information: We try to keep the information that we hold about you accurate and up to date. Should you realize that any of the information that we hold about you is incorrect, please let us know at firstname.lastname@example.org and we will correct it as soon as we can.
(c) Data deletion: In some circumstances you have a right to have some of the personal information that we hold about you deleted. Should you wish to have any information about you deleted, please Contact Us using the information below. Please note that in order to process your request you must delete our games from your mobile devices and clear our cookies from any device where you have played our games in a web browser. Where we delete personal information about you, we may still retain some or all of that information for other purposes such as maintaining financial records, protecting or enforcing legal rights, maintaining marketing suppression lists or for technical reasons such as maintaining technical security or our database integrity. We may also retain your information in an anonymized form. In some instances, personal information about you that is visible through gameplay such as username, avatar, your high scores and any chat messages may be cached on other players’ devices and we may not be able to remove or update that data from those devices, for example if that device is not connected to a wifi network.
(d) Account deactivation: If you have created an account with us, you can ask us to deactivate that account by contacting us using the information below. We may ask you for other information before we are able to deactivate your account. That information might include information about your mobile device. Other steps you should take should you wish to completely deactivate your account include disassociating your Facebook account from our mobile games and deleting our games from your mobile devices. Please note that if you completely deactivate your account all your progress in our games and any unspent virtual items, such as Coins or Gems will be lost and we may not be able to restore them in the future.
(e) Data portability: In some circumstances, you may have the right to request that data which you have provided to us is provided to you, so you can transfer this to another data controller.
(f) Restriction of processing: In some cases, you may have the right to request a restriction of the processing of your personal data, such as when you are disputing the accuracy of your data held by us.
(g) Right to object: You have the right to object to the processing of personal data about you which is processed on the grounds of legitimate interests (see Legal Bases below).
(h) Direct marketing opt out: If you have elected to receive direct marketing communications from us, you can change your mind at any time by following the opt out link in any marketing communication that is sent to you. If you have elected to receive more than one type of marketing communications from us, you may need to opt out of all of them individually. It may take a few days for us to update our records before any opt out is effective.
When we collect personal information, we do not know the age of our players. If a player has a Facebook account and has logged into a game, we obtain the age information from the player’s Facebook profile. If we discover we has inadvertently gathered personal information from a minor under 13 years of age, we will take reasonable measures to promptly delete such personal information from our records.
14. Contact us
Support team: Use the contact form
In writing to Kroy Games of 6/F., Teda Building, 87 Wing Lok Street, Sheung Wan, Hong Kong