Last updated: April 16, 2019
How we store your data
We do not store any data, any information, either personally identifiable or non-personally identifiable. All data is stored within third-parties with compliance to data protection regulations and laws. We do not have any physical access to data centers or computer hard-drives.
What information we collect and how we use it
When you use our Services, we may collect information automatically from your device. This information may be considered as personal information under applicable data protection laws. Specifically, the information we process includes information about the IP address of your device, device type, unique device identification numbers, broad geographic location (e.g. country or city-level location) and any other technical non-personal identifiable information. The information processed is used only for business purposes, such as advertising customization, analytical and statistical information to enhance the gaming experience and track incidents and errors to provide a correct fault free service.
This information is not shared with individuals or companies not associated with us, it is only processed by our third-party partners.
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:
• Log-, device-, usage-, and consumption information are being processed:
• to provide and deliver the products and services you request and send you related information as requested by you / as agreed with you;
• to provide and maintain the App and the game experience; and
• 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.
• to provide news and information about the App that we think will be of interest to you;
• to personalize and improve the App and provide tailored content and features;
• to monitor and analyze trends, usage and activities in connection with the App; and
• 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 balancing-of-interest rule").
• to provide non-child users that have given us consent to share their advertising IDs with our ad network partners (as further specified under Sharing of Information) for the purpose of serving them with personalized advertisement in the App (behavioral advertising).
Our processing for the above purpose is justified by our legitimate interests in providing advertisements and content of interest to you in accordance with Article 6(1)(f) of the GDPR. The disclosure of your advertising ID to third parties for the purposes of behavioral advertising is based on your consent in accordance with Article 6(1)(a) of the GDPR (see more below under Sharing of Information).
We only process your information to the extent that is necessary to achieve the purposes for which the information has been collected.
To improve your experience in using our Services, we collect statistical user data to improve your experience while using our services. For this purpose, we use Analytics technologies from third-party partners to collect anonymous information such as user number of sessions, location information, device information (such as: operating system version, screen resolution, device model and etc). We will ask your consent in cases when we are legally obliged to ask for it.
For more information about the privacy policies on these partners, you can access the following links:
• Unity Analytics: https://unity3d.com/legal/privacy-policy
Sharing of information
We disclose information about you to the following categories of recipients based on the legal bases in Sections 6(1)(b), 6(1)(c) and 6(1)(f) of the GDPR (see a description of the legal bases above):
• Social networks, see more under "Social Sharing features";
• Third parties if we are required to disclose your personal data by applicable law, rule, regulation, legal process or in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
• The authorities if we believe your actions are inconsistent with the spirit or language of our policies or if the disclosure is necessary to protect the rights, property and safety of Kiloo or others;
• Other players in order to provide certain in-app features, such as leaderboards, if you log into the App using a third-party service, such as Facebook or Apple Game Center;
• Advertising network companies in order to serve contextual advertisements (the data include your IP-address, Device ID and advertising ID).
Furthermore, if you have given your consent in accordance with Section 6(1)(a) of the GDPR, we share your advertising ID to advertising network companies for the purpose of them serving behavioral advertisements to you within the App. We use or may use the following advertising network companies:
• Unity https://unity3d.com/legal/privacy-policy
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, Appiolla 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 Appiolla's knowledge, Appiolla will, after having become aware of the incident, immediately take reasonable measures to stop such processing and promptly delete any such data from Appiolla's records.
If you have additional questions about Appiolla’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 Appiolla).
Appiolla 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-ofinterest 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
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
Contact and complaints