CRAZY COW STUDIO Privacy Policy

Last Updated: August 18, 2024

CrazyCowGames develops and publishes games for the web and mobile devices. This Privacy Notice describes the ways CrazyCowGames (“Studio,” “us”, “our” or “we”) collects, stores, uses, discloses or otherwise processes personal information of our users in connection with their use of our products or services, provided on various platforms. Additionally, this Notice describes the rights and choices concerning your information that may apply to you.  

This Privacy Notice covers the following topics:

If you have questions regarding this Notice or our collection and use of personal information, please contact us as described in the “Contact Us” Section.

PERSONAL INFORMATION WE COLLECT

When you interact with or use our Services, we are collecting personal information about you. Sometimes we collect personal information automatically when you interact with our Services (e.g., information about how you interact with our Services) and sometimes we collect the personal information directly from you when you use our Services (e.g., information you give us when setting up your account or user profile).  At times, we may collect personal information about you from other sources and third parties, including other players.

We will collect and use the following Information about you:

1.      Information you provide to us.

2.      Information collected via our customer support channels: For example, when you contact us by email, we will receive information you provide to us such as (a) your full name and, and (b) any information you choose to provide to allow us to assist you.

3. Information we automatically collect or is generated about you when you play the Game:

   1. Identifiers: Such as your IP address, device and app ID, unique Game ID and device information (such as model, brand and operating system).

   2. Information regarding your use of the Games: Such as date and time stamps of game events, interactions with our teams and ad engagement, and transaction records, or evidence of you using cheating software or using of modified versions of the Games.

   3. Information received from third parties:

      1. Information from payment processors: When you make payments in our Game, we receive information from our payment processors about your transactions, including your Apple ID number for Apple, your postcode and state for Google.

      2. Analytics information: We integrate analytics software from Google, and Unity Technologies (a US and Finnish company), third party analytics providers. They provide reports that help us optimise our in-game features and events to each user of our Game, which include your user ID and information on your in-game activity.

      3. Information collected from advertising partners: We receive information from Unity Technologies. This includes user ID and information on your interactions with advertising shown in on our Games.

      4. Information from mobile measurement partners: We receive information from third parties to allow us to track performance of our marketing campaigns and to detect fraud in such campaigns. This includes advertising ID, IP address, location and transaction information.

HOW WE USE YOUR PERSONAL INFORMATION

The information that we collect from users is used as below:

1.      Provide you with the Game: In particular, we will use your Information to perform our contractual obligation towards you to allow you to create an account, play the Game and remember your progress, allowing you to play the Game with others and to allow you to make purchases via Google Play or IOS App Store and maintain a record of such purchases. The Information we process when doing so includes your registration information, information you provide to us when playing the Game, identifiers, information you generate and display when playing the Game, and information regarding your use of the Game such as transaction records.

2.      Improve and monitor Game use: It is in our legitimate interests to improve our Games for our customers. When doing so, we may collect information we automatically collect or is generated about you when you play the Games, as well as non-personal information about your device such as battery, Wi-Fi strength, device manufacturer, model and operating system, and the amount of free space on your device.

3.      Provide you with support and to respond to your requests or complaints: If you reach out to us for support, we will use your Information to create a support account for you, respond and resolve your queries and complaints, facilitate support (e.g. retrieval of a forgotten password). When doing so, we perform our contractual obligation towards you. The Information we process when doing so includes your registration information, your identifiers, non-personal information about your device such as your Wi-Fi strength and the amount of free space on your device, and any other information about you collected via our customer support channels.

4.      Conduct analytics: It is in our legitimate interests to analyse the use of and inform, our Games, newsletters and advertising campaigns, and any other interaction or interest in the same. When doing so we will process information we automatically collect or is generated about you when you play the Games or interact with our newsletters and advertising campaigns to (a) create anonymised and aggregated data; (b) create segments of users who show particular characteristics or interests; and (c) conduct predictive analytics about your interests.

5.      Send you updates about in-Game offers and our other products and services that may be of interest to you: We will send you promotional offers, and information about other products and services that may be of interest to you. Where it is required, we will only do so where we have your consent. We do so via email, push notification or in Game. When doing so, we process your registration information and the analytics information above. Your consent can be withdrawn at any time by following the unsubscribe mechanism at the bottom of each communication for emails or by adjusting your device settings for push notifications.

6.      Provide you with advertising: We will present you with ads and suggestions in our Game and elsewhere. These may be ads relating to our own games or other services you may be interested in. Depending on your consent, or device settings, these ads and suggestions may be tailored.

SHARING OF YOUR INFORMATION

We share your Information with selected third parties, including:

1.      Vendors and service providers we rely on for the provision of the Games, for example:

a.      Cloud service providers who rely on for data storage, including Amazon Web Services and Google Cloud that are based in the U.S.

b.      Customer support solution providers, who help us manage and respond to our customer questions and complaints.

c.       Analytics providers, we work with a number of analytics, segmentation and mobile measurement service providers who help us understand our userbase.

d.      User acquisition, we work with a variety of user acquisition partners to help us report on the success of our marketing campaigns.

2.      Advertising partners. We are an ad-supported service. Subject to your settings, we provide certain Information to advertisers who will use them to serve you with ads in our Games, and we measure who sees and clicks on their ads. We also share advertising identifiers, along with the interests or other characteristics of a device or the person using it, to help partners decide whether to serve an ad to that device or to enable them to conduct marketing, brand analysis, personalise advertising, or similar activities.

3.      Payment processors. We use our platforms as payment processors, i.e. Google (if you run Android on your mobile device), and Apple App Store payments (if you run IOS on your mobile device). These payment processors are responsible for the processing of your Information, and may use your Information for their own purposes in accordance with their privacy policies.

4.      Law enforcement agencies, public authorities or other judicial bodies and organisations. We disclose Information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to comply with a legal obligation, process or request; enforce our terms of service and other agreements, policies, and standards, including investigation of any potential violation thereof; detect, prevent or otherwise address security, fraud or technical issues; or protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organisations for the purposes of fraud protection).

Third Party Privacy Practices

If you access the Game through a third-party platform such as Facebook (“Third Party Services”), you must understand that those Third Party Services may collect other information about you (including information you share with them directly or about your use of the Game) in accordance with their own terms and privacy policies. The privacy practices described in this Policy do not apply to Third Party Services. Any links in the Game to Third Party Services do not imply that we endorse or have reviewed the Third Party Services.

SECURITY OF YOUR INFORMATION

We implement reasonable and appropriate technical and organizational measures to protect the security of your personal information against accidental or unlawful destruction, loss, change or damage.

However, no security system is impenetrable, and we cannot guarantee the security of your personal information.  Any transmission is at your own risk.

DATA RETENTION

We retain your personal information for as long as needed to provide you Services, unless we are required by law to delete or if we accept your request to delete the information pursuant to applicable law. We will also retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

When we no longer require your personal information, we will look to delete, destroy, or anonymize it pursuant to our typical procedures.  If this is not possible (for example, because your personal information has been stored in backup archives), then we will apply security measures to your personal information and isolate it from any further processing until deletion or destruction can occur pursuant to our typical procedures. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

CHILDREN’S PRIVACY

The Services are not intended for use by children (aged 16 or such higher age as required by applicable law). We do not knowingly collect personal information from children through the Services or knowingly allow them to use our Services.   If we learn that we have unintentionally collected personal information from a child, we will delete that information.  If you believe that we might have collected personal information from or about a child, please contact us at support@crazycowstudio.com

MANAGING YOUR INFORMATION

Subject to certain exemptions, you can manage information we receive about you, and you may have additional rights as explained in the “Specific Provisions for Certain Non-U.S. Users” and the “Specific Provisions for Certain U.S. Multistate Users.”

Information-Related Requests — If you wish to review, change, or correct the information we have about you, or to withdraw your consent to the processing of your personal information, you may send an e-mail to support@crazycowstudio.com making this request.  

Deleting Your Account — If you would like us to delete your information, you may send an e-mail to support@crazycowstudio.com and place “Delete My Account” in the subject line [or request to delete your information inside the app you are using].   Please note that, if you proceed with the deletion of your account, you will no longer have access to the game account or services associated with your account.  Other steps you should take should you wish to delete your account include disassociating your Facebook account from our mobile games, if applicable, and deleting the game from your mobile device.  Please note that if you ask us to delete your account, all your progress in the game and any unused virtual items will be lost and we may not be able to restore them in the future.  Please note that your information, for example records pertaining to payments or customer service matters, may be retained for legal and accounting purposes. If you have sent or posted content on the Service, we may not be able to delete it.

We will need to verify your identity before processing your request. In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems. In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

Acting through an Authorized Agent or Representative — In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf where (i) you provide sufficient evidence to show that the requestor is an authorized agent with written permission to act on your behalf and (ii) you successfully verify your own identity with us.

Response Time — In accordance with applicable law, we aim to respond to a consumer request as soon as possible after receiving that request and any necessary verification. If we require more time, we will inform you of the reason and extension period in writing.

SPECIFIC PROVISIONS FOR CERTAIN NON-U.S. USERS

These additional provisions apply to individual residents of those countries outside of the United States that have enacted comprehensive consumer privacy laws, including the European Union General Data Protection Regulation, the United Kingdom Data Protection Act, and each of their associated regulations, as well as amendments to those laws or additional consumer privacy laws that have been enacted or may be enacted in the future.

This section addresses the specific disclosure requirements under those laws and provides additional information about how we collect, use, share, and otherwise process personal information, the rights of covered consumers in relation to that personal information, and the ways to exercise those rights.

CrazyCowGames, is the “data controller” responsible for the processing of personal data in connection with our Services. This means that we determine and are responsible for how your personal information is used.

Your Privacy Rights

Depending upon applicable law, you, your legal representative, and/or your next of kin have certain legal rights in connection with your personal information that we hold.  However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.  Subject to certain exemptions, you have the right to:

·        Access and Correct Your Personal Information.  At any time, you may request to access the personal data that we hold about you. We may need to ask you to provide certain information to make sure you are who you claim to be. If you find the information on your account is not accurate, complete, or updated, then please provide us with the necessary information to correct it.

·        Erase or Restrict Access to Your Information.  You may request to delete or restrict access to your personal data under certain conditions.  To the extent permitted by applicable law, we may postpone or deny your request if your personal data is in current use for providing Services or for other legitimate purposes, in which case we will let you know if we are unable to do so and why.

·        Transfer Your Personal Data (Otherwise Known as Your Right to Data Portability).  You have the right to receive your personal data that you have provided us in a structured, commonly used and machine-readable format and the right to transmit that data to another party of your choice, where technically feasible. However, this right shall not apply where it would adversely affect the rights and freedoms of others.

·        Right to Object and/or Restrict Processing of Your Personal Data.  Under certain conditions, you have the right to object to our processing of your personal data as outlined in Sections 2, 3, and 4, above.

·        Right Not to be Subject to Automated Decision-Making.  Under certain conditions, you have the right not to be subject to automated decision-making, if applicable.

·        Withdrawing Your Consent. Contact us if you would like to withdraw your consent to the processing of your personal data based on that consent. Exercising this right will not affect the lawfulness of processing based on consent before withdrawal.

·        Right to Make a Complaint.  In accordance with applicable law, you have the right to lodge a complaint with an appropriate regulator.  The Global Privacy Assembly provides a publicly-available list of privacy authorities.  If you have a complaint about how we process your personal data, we encourage you to contact us at support@crazycowstudio.com and we will endeavor to address your request.

How to Exercise Your Privacy Rights

If you wish to exercise any of these rights or any other rights that you may have under applicable law, please contact us at support@crazycowstudio.com

We will need to verify your identity before processing your request.  In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems.  In certain circumstances, you may also appoint an authorized agent to exercise any rights that you may have on your behalf.  If you choose to exercise any rights through an authorized agent, you will need to verify your identity directly with us before we can process any requests.  In addition, we will need written documentation demonstrating the authorized agent’s authority to act on your behalf.

If you make a request, we will typically look to respond within one month, although a longer period may be permitted.  In certain circumstances, we may decline a request, particularly where we are unable to verify your identity or locate your information in our systems.  If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

Lawful Basis for Processing

With respect to each of the purposes for which we use your personal information (see Sections 2, 3, and 4, above), the lawful basis that we may rely upon will vary based on the nature of, and reason for, the particular use to which we are putting your personal information. However, typically we will use your personal information:

1. Where we need to do so to perform a contract we are about to enter into with you or have entered into with you – for example, this will be relevant where we use your personal information to provide you with the Services, to operate the Services, and to create and maintain your Account.

2. Where it is necessary for our legitimate interests, and/or those of a third party, and your interests and fundamental rights do not override those interests – for example, this will be relevant where we share your personal information in the context of an actual or prospective corporate event, in these cases we and any relevant third parties have a legitimate interest in enabling those parties to investigate and, where relevant, to continue to operate, all or relevant part(s) of our operations.  

3. Where we need to comply with a legal or regulatory obligation – for example, this will be relevant where we are legally obliged to provide your personal information to authorities to comply with lawful governmental or regulatory requests.

4. Where we have your specific consent to carry out the processing for the purpose in question  – for example, this may be relevant where we use your personal information to show you targeted online advertising, where required by law.

For questions about the lawful basis we rely on for data processing, please contact us at support@crazycowstudio.com

Marketing and Advertising

From time to time, we may contact you with information about our services, including sending you marketing messages and asking for your feedback on our services. Most marketing messages we send will be by email or push notifications. For some marketing messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.

Where we rely on consent to send you marketing communications, we will only send you such messages if you have given us your consent to do so. You can withdraw your consent at a later date by clicking on the “unsubscribe” link at the bottom of our marketing emails or by updating your preferences in the settings page of the App or Service.

Data Transfers and Processing Outside Europe

If you are located in the EEA, the UK, or Switzerland, your personal information may be processed outside of those regions, including in the United States.  In the event of such a transfer, we typically try to ensure a degree of protection similar to that applied in your home country is afforded to it by employing one of the following mechanisms:

1. Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the relevant authorities (e.g., by the European Commission, UK Government, and/or Swiss Federal Council).

2. Transfers to territories without an adequacy decision. 

   1. We may transfer your personal information to countries or territories whose laws have not been deemed to provide an adequate level of protection for personal information by those relevant authorities (e.g., the United States).  

   2. However, in these cases, we may look to use specific appropriate safeguards approved by the relevant authorities, which are designed to give personal information the same protection it has in the EEA, UK, or Switzerland – for example, standard-form contracts approved by relevant authorities for this purpose.

In limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to recipients in such countries despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.  

If you want further information on the specific mechanism(s) used by us when transferring your personal information, please contact us at support@crazycowstudio.com.

SPECIFIC PROVISIONS FOR CERTAIN U.S. MULTISTATE USERS

These additional provisions apply to individual residents of those U.S. States that have enacted comprehensive consumer privacy laws, including the California Consumer Privacy Act of 2018 and the California Privacy Rights Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, the Virginia Consumer Data Protection Act, the Utah Consumer Privacy Act, and each of their associated regulations, as well as amendments to those laws or additional consumer privacy laws that may be enacted in the future.  

This section addresses the specific disclosure requirements under those laws and provides additional information about how we collect, use, share, and otherwise process personal information, the rights of covered consumers in relation to that personal information, and the ways to exercise those rights.

Your Privacy Rights.  To the extent permitted under applicable law, you may be able to exercise the following rights in relation to the personal information that we may have collected about you, subject to certain limitations and requirements, including the verification of your identity and our right to retain information to comply with our legal obligations, among other circumstances.