Privacy Policy

Last updated November 22nd, 2022.

Kinoa Labs Limited (registered number 516498342) (“us”, “our”, “we”, “Kinoa”) is the controller of personal data collected through https://kinoa.io (the “Website”) and a processor of personal data on behalf of games developers, publishers and other rights owners. Kinoa is committed to protecting and respecting privacy. Kinoa is a subsidiary of Apliko Limited. This privacy policy is issued on behalf of both of those entities. Kinoa is an Israeli company and is supervised by the Privacy Protection Authority.

This privacy policy (the “Policy” or “Privacy Policy”) sets out the types of personal data we collect and use when users access and visit the Website (including prospective customers and mere browsers of the Website) and when our customers share personal data with us. The Policy sets out how we may use that data.

1. Introduction

This Privacy Policy explains who we are, why and how we process personal data collected through use of the Website and, if you are the subject of any of the personal data concerned, what rights you have and how to get in touch with us if you need to.

When you supply any personal data to us, we have legal obligations towards you in the way we use that data. This is also true for personal data that is passed to us for processing under agreements with our customers. For ease of reading, we have divided this Policy into several sections:

Introduction
What information can we collect?
Sensitive Data and Special Category Data
How is your personal information collected?
How and why do we use and share your personal information?
For how long do we keep your personal information?
Security
International Data Transfers
Your Privacy Rights
Contact Details

It is important that you read this Policy together with any other privacy notice or fair processing notices that we may provide on the Website at or around the time that we collect or process personal data about you (for example, fair processing notices that we may display to you at the time that you log onto the Website) so that you are fully aware of how and why we are using that data.

This Policy supplements other notices on the Website and is not intended to override or replace them.

By using the Website, you agree to its terms (including as amended from time to time) and this Privacy Policy. If, for any reason, you do not agree to the terms of this Policy, please stop using this Website.

We reserve the right to revise or amend this Policy at any time to reflect changes to our business or changes in the law. Where these changes are significant, we will endeavour to let users of the Website know. However, it is your responsibility to check this Policy before each use of the Website – for ease of reference the top of this Policy indicates the date on which it was last updated.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Please note that the Website is not expected to be used by children under the age of 18 (each a "Child" or "Children.")

However, we do process personal data about Children on behalf of our customers. We perform such processing and rely on performance of a contract as the lawful basis for processing Children’s data. We have contractual clauses in place with our customers to ensure that their processing of personal data is lawful and that special attention is given to the processing of Children’s personal data.

2. What information can we collect?

What is personal data?

Where this Policy refers to ‘personal data’ it is referring to data about you from which you could be identified – such as your username, your contact details and even your IP address. When processing personal data on behalf of customers, we process broader categories of personal data, as explained below.

Depending on your location, you have various rights to seek information from those organisations about how they are using your data, and to prevent them from processing it unlawfully. For more information about your data protection rights, please review the guidance from your data protection supervisory authority.

What types of data we collect from you when you use the Website

The personal data we collect directly from you may include:

Identity Data which includes your name and username .
Contact Data which includes your e-mail address
Employment Data which includes the company that employs you and your job title
Transaction Data which includes details about your interactions with the Website, including a history of actions taken
Technical Data which includes your IP address, your login data and browser type and version.
Usage Data which includes information about how you use the Website.

What type of data we process on behalf of our customers

Identity Data which includes your name and username, Apple’s ID for Advertising (IDFA), Google Android ID and Advertising ID for Android (AIFA), carrier user “ID,” geo-location information and social media identifiers.
Contact Data which includes your email address and telephone number
Profile Data which includes your username, social media details, your game preferences, your interests, feedback and survey responses.
Transaction Data which includes details about your interactions with games, including a history of actions taken
Technical Data which includes your IP address, your login data and browser type and version.
Usage Data which includes information about how you play games such as frequency of play, play time, game personalisation, purchasing habits
Marketing and Communications Data which includes your preferences in receiving marketing from games providers and publishers, responses to promotions and responses to advertisements.

What type of data we process on behalf of our customers

Identity Data which includes your name and username, Apple’s ID for Advertising (IDFA), Google Android ID and Advertising ID for Android (AIFA), carrier user “ID,” geo-location information and social media identifiers.
Contact Data which includes your email address and telephone number
Profile Data which includes your username, social media details, your game preferences, your interests, feedback and survey responses.
Transaction Data which includes details about your interactions with games, including a history of actions taken
Technical Data which includes your IP address, your login data and browser type and version.
Usage Data which includes information about how you play games such as frequency of play, play time, game personalisation, purchasing habits
Marketing and Communications Data which includes your preferences in receiving marketing from games providers and publishers, responses to promotions and responses to advertisements.

3.Sensitive and Special Category Data

We do not collect any sensitive or special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.

4.How is your personal information collected?

Direct interactions with the Website

When you use the Website to register as a user, complete a form, contact us by email browse from page to page, we may collect, store and use the personal data that you disclose to us.

Automated technologies or interactions gathered through the Website

We shall also collect information about you when you visit and interact with the Website through the use of technologies such as cookies. The following are examples of information we may collect:

information about your device, browser or operating system;
your IP address;
information about links that you click and pages you view on the Website;
page response times;

We use the data described above for several different reasons. First we use it to ensure that the Website works properly and that you are able to receive the full benefit of it. Secondly, we use the data to understand and refine the functionality of the Website. Thirdly, we use the data to gain insights about user preferences and interests. We undertake these activities because we have a legitimate interest in doing so.

Personal Data shared with us by our customers

Our customers appoint us to process your personal data for them, so they can improve the in-App experience. Our customers have their own legitimate business reasons for understanding your usage habits of Apps too. We undertake these activities to fulfil a contract with our Customers and they will advise you of their lawful basis for collecting and sharing your personal data with us.

Our customers provide us your personal data through a technological interface called an “API.”

Updating your information if you use the Website

If you want to update the information you have previously given to us, you can use the interactive services available on the Website.

5.How and why do we use/share your personal data?

Lawful basis for processing your information

We will only use your personal data when the law allows us to. Most commonly we will use your personal data in the following circumstances:

Where you have asked us to do so, or consented to us doing so (although consent is not necessarily required for us to process your personal data);
Where we need to do so in order to perform a contract we have entered into with you or a third party;
Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests; and
Where we need to comply with a legal or regulatory obligation.

Here are some examples about how we may use the information we collect about you and the lawful basis we rely on to do so.

Activity	Examples of the types of personal data we may collect	Lawful basis for processing
To register you as a user of the Website	Identity, contact and transaction information	Performance of a contract with you.
To manage our relationship with you including notifying you of any changes to the Website or services provided on the Website.	Identity, contact, profile and marketing communications information.	Performance of a contract with you.
To administer, protect and maintain our business and this Website (including troubleshooting, data analysis and system testing.)	Identity, contact, transaction and technical information.	Legitimate interests and/or performance of a contract with you.
On behalf of our customers, to use data analytics to improve the games, functions, content, marketing, customer relationships and experiences for their users	Identity, profile, transactional, technical and usage information.	Legitimate interests
On behalf of our customers to enable them to deliver relevant content, promotions and advertisements to you.	Identity, contact, profile, usage, marketing and communications, technical and technical information.	Legitimate interests

Communications with users of the Website

We may use your personal data to contact you with news and updates that may be of interest to you.

You will receive marketing communications from us if you are a user of the Website and you have not opted out of receiving that marketing.

Sharing your personal data

We may share the personal data of Website users with any member of our company group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

By virtue of our contract with our customers, we share personal data back and forth with the customers.

We may also disclose your personal data to third parties in the following events:

if we were to sell or buy any business or assets, in which case we might disclose your personal data to the prospective seller or buyer of such business or assets as part of that transaction;
if Kinoa Labs Limited or substantially all of its assets are acquired by a third party, in which case personal data held by us about our customers and contacts will be one of the transferred assets;
if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or if we are asked to provide your details to a lawful authority in order to aid in the investigation of crime or disorder; and/or
in order to enforce or apply the Website’s terms of use.

Sharing your personal data with our service providers (Data Processors)

Our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this data and do not use it for any other purpose. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights as a data subject. We do not allow our third-party service providers to use your personal data for their own purposes. The following is a list of our major service providers:

Hetzner online GmbH
Google Inc
Amazon Web Services

Cookies are text files, comprised of small amount of data, that are saved on your computer or other device (e.g. smartphone, tablet, etc.) when you use the internet and visit various websites.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly.

We use cookies for a number of purposes including cookies that are strictly necessary for the functioning of the Website. The Website cannot operate properly without these cookies and for analytics that help us understand how you and other users interact with our Website by collecting data that does not directly identify you.

Change of purpose

Website Users: We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Other personal data: We process this personal data under the terms of a contract with the App publisher. Please refer to their privacy policy in order to understand what purposes they are using personal data for.

6.For how long do we keep your personal data?

We will hold your personal information

in the case of users of the Website: only for as long as required to provide you with the services you have requested from the Website, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.

in the case of personal data that we are processing on behalf of our customers: only for as long as they instruct us to process the personal data.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data,whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances and in accordance with applicable data protection laws, we may anonymise personal data (so that it can no longer be associated with a private individual) for our commercial purposes in which case we may use this information indefinitely without further notice to the data subjects.

Where appropriate and lawful, we may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but will not directly or indirectly reveal your identity. For example, we may aggregate usage data to calculate generalised data about the games industry.

7.Security

Kinoa takes the protection of personal information seriously. We have put in place technologically and organisationally appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

Where you use a password to enable access to the Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

In addition, we limit access to personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8.International Data Transfers

Please note that our service providers are based in territories around the World.

Where we transfer your data to a service provider, we seek to ensure that appropriate safeguards are in place to make sure that personal data is held securely and that data subject rights are upheld. Where we use certain service providers, we may use either specific contractual clauses mandated by regulators or require additional safeguards to be in place in order to give personal data greater protections. Such contractual clauses and/or additional safeguards shall be approved by the UK and EU regulators as compliant with the UK and EU GDPR regulations, respectively.

Where our customers transfer your personal data to us, we enter into contractual clauses with the customers that provide additional safeguards to protect personal data.

9.Your Privacy Rights

You may have the following privacy rights:

If you wish to access, correct, update or request deletion of your personal data, you can do so at any time by contacting us at info@kinoa.io

In addition, if you are a resident of the EEA or the United Kingdom, you can object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects.

Users of our Website have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” link in the marketing communications we send you.

You can manage your cookie preferences by visiting our Cookie Consent Manager.

If we have collected and processed your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.

You have the right to complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local supervisory authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

10.Contact Details

If you have any queries regarding this Privacy Policy or if you wish to exercise any of your rights or if you think that the Privacy Policy has not been followed, please contact us by emailing at privacy@kinoa.io

You may also lodge a complaint to your supervisory authority about the way we process your personal data. We would however, appreciate the chance to address your concerns before you approach the supervisory authority, so please contact us in the first instance.