Privacy and Cookie Notice for Players


We are Lucky Kat BV. We are based at Binckhorstlaan 36 M214, 2516 BE Den Haag, The Netherlands.

We are based in The Netherlands and you can reach us at support@lucky-kat.com if you have questions about data protection, or if you have any requests for resolving issues with your personal data. You can also write to the above address.

In this privacy notice we describe:

* The ways we collect personal data about you when you play one of our games and why we do so

* How we use your personal data, and

* The choices you have about your personal data.

Our games are ad-supported, and when you play our games we process personal data to be able to show you ads. We are committed to a lawful, fair and transparent processing of personal data.

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

When you play our games we process the following personal data:

·       Your IP address, and the country based on the IP address.

·       Your device type (for example, iPhone 12, Samsung Galaxy S21) and operating system version.

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

·       For analytics, 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 or personally identifiable data.

·       For advertizing, our third-party ad partners receive from us your IP address and advertizing identifier (IDFA for iOS devices and GAID for Android devices). What information we collect and share depends on the permissions you grant in the game. [OO1]

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.  

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[OO2]  of Lucky Kat Studios and that of our partner.


- 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.

Some third-parties choose to rely on consent, in which case they will ask for your consent before processing your personal data.[OO3]

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 analytics and A/B testing data for up to 5 years

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. We use 2FA (two-factor authentication) whenever possible.

·       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[OO6] . These are either controllers, or processors[OO7]  acting on our behalf. We have linked to their respective policies:


Analytics:

Advertizing:

Apple and Google also collect certain data when you use their app stores to install our games. You received that information when you first used your phone and each time you update it.

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 EEA or UK 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.          If you are in California (USA) - do not track and do not sell my data (opt-out)

For players from California (USA), we do sell your data. You can opt-out from this, this is described under Your Rights.

For website visitors from California (USA), our website does not respond to Do Not Track (DNT) signals.

10.        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).

Where we process data based on your consent, you also have the right to withdraw your consent at any time but we would like to point out that this does not affect the lawfulness of the processing before the date that you withdrew your consent. [OO9]

If you wish to exercise any of the above rights, please write us at support@lucky-kat.com. We will respond to all requests within a reasonable timeframe, but at least within 4 weeks.

If you are based in an EU Member State, you also have the right to lodge a complaint with your local EU data protection authority for unresolved complaints.

11.        Version information

We last updated this notice in September 2021.  

You can view it at http://www.lucky-kat.com/games-privacy-notice