GDPR – Privacy-By-Design and Record of Processing Activities


We are committed to a lawful, fair and transparent processing of personal data, adhering to the EU General Data Protection Regulation (GDPR). This file documents our general privacy-by-design considerations (articles 5, 25 and 26 GDPR) and records our processing activities.(article 30(1) GDPR)


Company name:                                          Lucky Kat Studios

Address:                                      Binckhorstlaan 36 M219, 2516BE The Hague

Personal Data Processings:      Player data

Creation date / last update:       1 May 2018

Contact persons:*                      Herdjie Zhou,  

* Not formally a DPO under the GDPR.


Note that the below uses the “you” and “us” pronouns in paragraphs nrs. 1 o 11 to allow inclusion without modification in our information notices provided to data subjects.


1.                     We process the following (categories of) personal data

When you play our games, connect to a social networking site through our games, register an account, enter a promo code, or place an order, we process the following personal data when you consent:

·              Your IP address, and the country,

·              Your device type (for example, iPhone 7, Samsung Galaxy S7) and operating system version.

·              Your Game Center ID (for iOS games) or Google Play ID (for Android games).

·              When you connect to Facebook or Game Center, or other social platforms, we access your profile, including your username and friends list.

·              For analytics, most, when you installed and played the game, your progress throughout the game, and events that are connected to your game-play. We generally cannot identify you with this data, but treat it the same as personal data.

·              For advertising, We may use collected IDFAs to (re)target users on advertising platforms. 

·              Your e-mail address, if you subscribe to our newsletter. Note that if at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.


Apps using ARKit, Camera APIs, Photo APIs, or other software for depth of facial mapping information, TrueDepth API, HomeKit, Keyboard extensions, Apple Pay, Stickers and iMessage extensions


We do not collect, store or share data used by ARKit, Camera APIs, Photo APIs, or other software for depth of facial mapping information, TrueDepth API, HomeKit, Keyboard extensions, Apple Pay, Stickers and iMessage extensions.


Extra information regarding Wacky Face's use of Apple's Truedepth API


Wacky Face uses the device's TrueDepth camera system to track the movement of your eyes and mouth. This allows for a unique user experience — a game you can play with your face. In order for this functionality to be possible, the app requires access to your device's camera. This access can be toggled on or off at any time in your device's settings. 

The camera images and resulting depth data are only used for gameplay purposes. The live video feed is never used, and its data is never stored locally or remotely. Camera access is required to get depth data from Apple's API's. 

This data is stored on the device only for the duration of your current game session. Every time the home screen is presented or the app is closed, the data is deleted. This data is used to make your gameplay experience more enjoyable and prevent accidental jumps. 

Face data is never stored remotely, given to third parties, or used for any non-gameplay purposes. The face data only remains on your device, and never leaves your device at any time.


2.                     What (purposes) do we use the data for

We use this personal data to perform analytics for our games and allow third-parties to sell, buy and deliver advertizing in those games that display advertizing.  

We use social network data to show you personalized content. For example, we might show a high score list with only your friends in it, or show your name or avatar on an in-game object.

We use your email address that you provided when you signed up for our newsletter to send you the newsletter.


3.                     What is our legal basis for the processing

For both analytics and advertizing we base the processing of personal data on the legitimate interest of Lucky Kat Studios. For analytics, this is our ability to analyze how players progress through our games to make them better, and to know our player-base on an aggregate level. For advertizing, this is our ability to be able to off-set development costs and risk with advertizing income.


For the third-parties we use, their legitimate interest is to be able to offer us their services, and for advertizing third-parties and advertizers to be able to show you advertizing.


4.                     Where do we obtain the data from (sources)

We obtain the data from our third-party services providers:



5.                     How long and where do we store data

We store the personal data that we collect for up to a year, and only aggregate data after that time, except for email addresses for our newsletter. Aggregation data means that we can no longer look at data for individual players.


When a third-party service provider is a controller, they may keep data as well, either for a shorter or longer period.


6.                     What safeguards have we taken to protect data

Taking into account the nature, scope, context and purpose of the processing, we have taken the following technical and organizational measures:

·              Access to our database and user accounts with third-party service providers is protected with access control.

·              Access to the database is limited, not all staff in our organization have full access.

·              Data sent from our games is encrypted in transit where technically possible.


We do not actively monitor the security of our databases and need to rely on our processors to notify us of any data breaches.


7.                     Who we share data with

We share data with the following third-parties. These are either controllers, or processors acting on our behalf. We have linked to their respective policies and given a basic description of what they do:



Apple and Google may also collect data when you use their app stores to install our games.


8.                     Transfer of your personal data

You should also know that your personal data may be transferred from your home country to third parties. If you are an EU resident, this could imply that we also transfer data to countries that do not offer an adequate level of protection for your personal data. When we transfer this data, we will do so only when we have put in place appropriate safeguards to protect your personal data. Please contact us to get a copy of the safeguards that we have put in place. Our contact details are at the bottom of this text.


9.                Your Rights

You have the right to request access to your personal data that we process. You also have the right to:

·                 Rectify incorrect personal data or erase it in certain circumstances.

·                 Restrict or object to the processing of your personal data.

·                 Receive your data so that you can use it elsewhere (data portability).

·                 Request to be reviewed manually if a decision has been based on automated processing and profiling.


If you wish to exercise any of the above rights, please write us at We shall act on the data subject access request without undue delay and at the latest within one month of receipt. Finally, you have the right to lodge a complaint with a supervisory authority. If you do not know who your supervisory authority is, please contact us and we will tell you.


10.                How to contact us

You can contact us with any questions you may have about the processing of your personal data, or to exercise the above rights:

Address: Binckhorstlaan 36 M219, 2516 BE Den Haag, The Netherlands

11.                Version information

We last updated this notice on 1 May 2018. 

You can view it at