Game Distribution Platform Privacy Notice We at Key Games Network B.V. (“GameDistribution”, “GD”, “we”, “us” or “our”) respect your privacy and recognise the importance of providing a secure environment for your personal data. Therefore, we are committed to being transparent about how we collect and process your personal data. Game Distribution is a distributor of cross-platform browser games and acts as the link between Developers and Publishers. Developers co-operate with Game Distribution in order to get access to Publishers that can publish Developers’ games on their platforms, as well as to thoroughly analyse and monetize their games. The purpose of this privacy notice (“Privacy Notice”) is to inform you as a user about why and how we process your personal data (that is any information that can be linked or attributed to you, “Personal Data”) while using our platform that you can sign-up from www.gamedistribution.com (“Website”). This includes information regarding with whom we will share your Personal Data, how long we will retain it, and which rights you have in relation to the processing. This Privacy Notice applies whenever you create an account in our Platform or use any of our other services, all of which together we refer to as “Services”. GENERAL INFORMATION In this part of our Privacy Notice, you will find general information about how we process your Personal Data when you use our Services. For specific information with more details about our processing activities, please see the service specific information below. 1. Who is responsible for the processing of your Personal Data? Key Games Network B.V. Beechanvenue 182 1119PX SCHIPHOL-RIJK, Netherlands is responsible (“the data controller”) for the processing of your Personal Data when you use our Services. 2. What types of Personal Data do we process and how do we collect it? When you use our Services, we collect, use, store and transfer different kinds of Personal Data. As a general principle, we do not collect and do not ask you to provide any “special categories of Personal Data”, which is any particularly protected information such as data
concerning health, religion, political opinions or philosophical beliefs, sexual preferences or orientation. The information we collect differs on which of our Services you use and how you use them. We process the following types of your Personal Data: 2.1 Personal Data provided by you When you use our Services, you provide or be asked to give us certain information, including: ● Your account information: On our Website, you have the option to sign up for an account. If you choose to create an account, we collect your log-in data (first name, last name, your email address, country and password) and whether you are Publisher, Developer or both. ● Your company information: When you choose to create an account, we collect information about your company; company name, url of your website and the expected traffic of your website (we collect this information only if you are a Publisher). As further explained below, we share this information with our reporting and billing partner Headerlift. ● Your billing Information: As further explained below, we access your billing information that you provide to Headerlift; payment type, currency, depositor detail (company name, your name and surname if you are private person ), street and house number (street name and house number, postal code, city and country), bank details (bank name, account number/IBAN, swift code, bank address). ● Information provided in relation to our customer service: When you contact support via our Website through contact us or live chat feature we collect information about your request (subject and content of your request) and your name and contact details. Our customer support system and emails are provided by Zendesk. Customers’ email addresses will appear in Zendesk along with all discussion between the customer and ourselves. 2.2 Personal Data we receive or generate from your use of our Services When you use our Services, we also process device-related information and information about how you interact with our Services, including: ● Technical information: We collect information about your device/device settings you use for the purposes described below. The information we obtain from your devices includes the type of your device, online identifiers (your IP address), game/site ID, geolocation data (based on your IP address), browser settings, screen resolution and other technical information.
● Cookie data: As further described in our Cookie Notice (“Cookie Notice”), we use cookies and similar technology such as pixels, or local storage and allow third parties to use cookies and similar technology for the purposes described below. The exact process of placing cookies, and the scope of the data that may subsequently be processed is set out in our Cookie Notice. ● Your revenue share information: As further explained, we also have access to your revenue share information, generated from the ad monetization activities operated by us and revenue share from in game purchases. As further explained you may also see this information via your Headerlift account. 2.3 Personal Data we collect from other third parties In certain scenarios, we will also obtain your Personal Data from third parties, in strict compliance with applicable data protection laws and regulations. Your Personal Data be provided by the following third parties: ● Headerlift: We have access to data you provide to and generated by Headerlift (reporting and billing information), our partner that we use for their reporting and billing services. To learn more about which data is processed, please see the section with service specific information below. 3. Do we collect data from minors? The Services are not targeted towards, nor intended for use by anyone under the age of 18. In the event that we learn that we have collected personal data from a user under 18 years of age within the scope of the Services explained in this Privacy Notice, we will delete that data as quickly as possible. If you believe that a user might be under the age of 18, please contact our support team at Game Distribution Support. 4. For what purpose do we process your data? Depending on which Services you are using and which privacy settings you have selected, we process your Personal Data for the following purposes: Provision and improvement of our Services ● to allow you to publish the games we distribute, ● to allow you to use our Services ● to create and manage your account ● to restore your account if you ever lose access ● to communicate with you in context of account activation, password management ● to simplify the registration process
● to provide technical support and respond to your requests ● to identify and correct any bugs/errors ● to gain insights into the popularity of our Services ● to assess the quality of our Services ● to understand and improve your online experience ● to aggregate financial reports ● to pay you for the promotion of our Services Personalization of your platform experience ● to remember your preferred settings ● to remember you next time you visit our Services Marketing and analytics ● to deliver our newsletter Prevention of fraud and illegal activity ● to investigate fraud and illegal behaviour ● to enforce our policies and Terms and Conditions Communication ● to provide you with customer support based on your questions, requests, or complaints ● to send you service emails, so that you can activate your account, for instance, or in case you forget your password Compliance with our legal or regulatory obligations ● to determine the legal requirements for processing of your Personal Data (based on your location such as your country) ● to respond to your requests related to your data subject rights ● to comply with our legal obligations (e.g. tax and accounting obligations) ● to inform you about any changes to this Privacy Notice Please see the section with service specific information below for a more detailed description of the purposes for which we process your Personal Data. 5. On which legal basis do we process your Personal Data? We process your Personal Data for the purposes described in this Privacy Notice, based on the following legal grounds: