Last Update: 27th of June 2019
The App is a free to play game (with optional in-game-purchases), and in order to maintain the high quality and a great game experience we process information from and about you in particular to improve the entire experience in the App and to support internal operations.
Collection of information
Information you provide to us
When you access or use the App, we need to get and collect specific information about you, including:
• Email: Your email adress will be used for the login and for the invitation and recommendation system.
• Password: The password is used for the login on your or your new device and increases the level of safety of your playing data.
• Playername: Your playername will be saved and used for displaying it in the global highscore table.
Information we collect automatically through the app
When you access or use the App, we automatically collect general information about you, including:
• Age: we log your age as indicated by you in the age gate upon downloading the App.
• Contacts: we read your contact list for a better usage of the invitation system (name and email address).
• Log Information: We log information about your use of the App, including the type of device you use, the features you use, access times and your IP address.
• Device Informationen: We collect information about the device you use to access the App, including information about the device’s software and hardware, unique device identifiers (i.e. Device ID and advertising ID), device tokens for push-messages, mobile network information and time zone.
• Usage Information: We collect information relating to your use of the App, including your game progress, scores, achievements and interactions with other players.
• Consumption Information: We collect information about your consumption habits relating to your use of the App, including which purchases you make with both virtual and real currencies and the reception of virtual goods in-game.
Use of information – purpose and legal basis
We use information about you for the following purposes in accordance with the legal bases for each type of personal data as described below:
– is being processed:
a. to identify whether you are a child or adult for data protection purposes to determine the legal requirements for our processing of your data.
– is being processed:
a. to list your contacts inside the app; and
b. to send an email to your selected contact to invite him to install the app: and
c. to connect a new user with your invitation and grant a special feature for it.
Log-, device-, usage-, and consumption information
– are being processed:
b. to provide and deliver the products and services you request and send you related information as requested by you / as agreed with you;
c. to provide and maintain the App and the game experience; and
d. to send you technical notices, updates, security alerts, and support and administrative messages;
Our processing for the above purposes is necessary for the performance of a contract to which you are party in order to support the operation of the App, facilitate the delivery of requested products and services and enable maintenance and update of the App, see Article 6(1)(b) of the GDPR.
e. to provide news and information about the App that we think will be of interest to you;
f. to personalize and improve the App and provide tailored content and features;
g. to monitor and analyze trends, usage and activities in connection with the App; and
h. to provide children (as this term is construed under GDPR in EU, COPPA in the US and relevant applicable legislation in other jurisdictions) with reasonable contextual advertisements in the App.
Our processing for the above purposes is justified by our legitimate interests in
providing advertisements and content of interest to you and improving our services in accordance with Article 6(1)(f) of the GDPR (also known as “the balancingof-interest rule”).
Storage of information
VHO will store your personal data for as long as necessary in order to provide you with the App or otherwise fulfil the purposes as described above, unless further storage is required in order to establish, exercise or defend a legal claim or to comply with applicable law, including accounting rules.
Your personal data are deleted or anonymized as soon as it no longer serves one of the above mentioned purposes and in any event no later than three (3) years after your interaction with VHO has ceased.
The App offers social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take in the App with other media. You must be over the minimum age limit that is prescribed by the legislation in the individual jurisdictions to use any social sharing features integrated in the App. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature.
The App has social features from the following providers:
For more information about the processing carried out by the respective third parties in connection with social sharing features, please visit the privacy policies of the entities that provide these features, which can be found here:
• Facebook: https://www.facebook.com/about/privacy/
The App is for a general audience. In order to comply with the legislation, you will be presented to an age screen, when launching the App. When presented with this age screen, it is important that you state the correct age.
Based on your age information and your device settings, VHO does not process personal
data of children under the minimum age limit that is prescribed by the legislation in the individual jurisdictions for behavioral advertisement. If such personal data have been processed without VHO’s knowledge, VHO will, after having become aware of the incident, immediately take reasonable measures to stop such processing and promptly delete any such data from VHO’s records.
If you have additional questions about VHO’s privacy practices related to children under the applicable minimum age, please contact us at email@example.com.
Transfer to third countries
In connection with the processing, we will in certain circumstances transfer your personal data to recipients in the U.S which has been declared an unsafe third country by the European Commission.
Consequently, the transfers will only occur based on the following safeguards:
• If the entity is certified to comply with the principles for data protection under the US-EU Privacy Shield Framework (“Privacy Shield”) (you can view the entities certified under Privacy Shield at www.privacyshield.gov), or
• If we have entered into standard data protection clauses adopted by the Commission with the entity, which is deemed to offer sufficient safeguards with respect to the protection of the privacy and fundamental rights and freedoms of individuals (you can obtain a copy of the clauses by contacting VHO).
VHO takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.
If you wish to use any of the rights described below, you may contact us at any time by emailing us at firstname.lastname@example.org.
We process and answer your requests without undue delay and in any event within one month of our receipt of the request unless a longer period is required due to the complexity of the request. In this case, our response time can be up to three months in total as permitted by Article 12 of the GDPR.
Right to request access
You have the right to request access into the data that we are processing on you, see Article 15 of the GDPR, including information about:
• the purposes of the processing
• the categories of personal data concerned
• the recipients or categories of recipient to whom the personal data have been or will be disclosed
• the envisaged period for which the personal data will be stored
Furthermore, you have the right to obtain a copy of the personal data undergoing processing. Please note that the access may be restricted due to intellectual property or trade secrets.
The right to object
You have the right to object to our processing of your personal data on grounds relating to your particular situation when the data are processed based on the balancing-of-interest rule in Section 6(1)(f) of the GDPR, see Article 21 of the GDPR. In this case, we will cease the processing unless there are compelling legitimate grounds for the processing which override your interests, rights and freedoms or if the processing is necessary for the establishment, exercise or defense of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes at any time. We will cease the processing of your personal data for this purpose after the objection. Please note that if you exercise this right, your user license to use the App will cease automatically.
Right to rectification and erasure
You have the right to have inaccurate personal data rectified, see Article 16 of the GDPR.
Furthermore, you have the right to have your personal data erased where one of the following grounds applies, see Article 17 of the GDPR:
• the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed,
• if you have withdrawn your consent and there are no other legal grounds for the processing,
• if you have objected to the processing and there are no overriding legitimate grounds for the processing,
• the personal data have to be erased for compliance with a legal obligation in Union or Member State law,
• the personal data have been unlawfully processed or
• the personal data have been collected in relation to the offer of information society services.
Please note that your right to erasure may be limited if the data are necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims.
The right to restriction
You have the right to obtain restriction of processing in certain circumstances, see Article 18 of the GDPR. If you have the right to restriction, we will only process your data with your consent or for the establishment, exercise or defense of a legal claim or to protect a person or important grounds of public interest
The right to withdraw consent
If we have asked for your consent to our processing of your data, you have the right to withdraw your consent at any time, see Article 7 of the GDPR.
If you withdraw your consent, we will cease processing of the data for which you have withdrawn consent, unless we have a legal obligation to keep some or parts of your data.
Please note that if you withdraw your consent, your user license to use the App will cease automatically.
The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal.
The right to data portability
You have the right to receive the personal data you have provided us with which we process in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller if the processing is based on consent or contract performance, see Article 20 of the GDPR.
Contact and complaints
Kiloo has the following contact information:
Villa Hirschberg Online GmbH
Address: Boxhagener Straße 18, 10245 Berlin, Deutschland
If you wish to make a complaint over the processing of your personal data, you have the right to lodge a complaint to the relevant supervisory authority.