Version 2 .0. Effective April 1, 202 2

Overview

​​ This document explains what data is collected in connection with our games and services. This privacy notice aims at giving you information on how your personal data are processed, collected, stored and used as well as how we protect it by Kosmos Games (Cyprus) LTD Address: 28 Oktovriou str. 367, Office A5, 1st floor, Mediterranean Court, 3107, Limassol, Cyprus. In this notice, we refer to ourselves as 'we', 'us', and 'our'.

In short:

At  Kosmos Games we handle your data so that neither we nor anyone else can use them to harm your interests and rights, such as your right to privacy.

H ow can you contact us?

If this Policy doesn’t contain the information you need or if you encounter issues related to your personal data, please do not hesitate to contact us.

The fastest way to do so is to use the in-game support menu “Help” . In the “Personal data”  section you can select an item you are interested in and make a request.

In case you have trouble in finding this section, make a general request about the problem, and include “personal data request” in the description.

Our Support team uses Zendesk ( Zendesk Privacy Policy ) services to ensure that your request is promptly processed.

The policy extends to:

  1. Our games published in App Store  and Google Play
  2. Our website
  3. Our activities on social media

Where did we get your data from?

Directly from you

We may obtain personal data directly from you.

Advertisers and promotional partners

We receive information from our advertisers and promotional partners that we work with to help us deliver ads and personalized content to you and recognize you across browsers and devices. This may include pseudonymous advertiser identifiers that some advertisers or other third-party ad platforms choose to share with us.

Social media networks

If you access or log through a social media service, the information we collect may include your user ID and/or user name associated with that social media service, any information or content you have permitted the social media service to share with us, such as your profile picture, email address or friends lists, and any information you have made public in connection with that social media service.

Device Information

We may collect information about your mobile device , such as a unique device identifier , to understand how you use the Service.

Authentication partners

If you register for or log in to our services using third-party credentials, we will import your information from that third party to help create your account with us.

Publishing platforms

We also receive information from the marketplaces (app stores) where our applications are published. For example, we receive information about your in-app purchases from Apple.

Analytics

We receive technical information on the performance of our apps from mobile analytics software applications. It allows us to better understand the functionality of our mobile software on your device.

1. Our games published in App Store and Google Play

What data, for what purposes, and based on what grounds do we process?

Purpose

Legal ground

Data

To create user accounts and allow you to play our games (to save your score, send you notifications related to the game, enable you with full functionality of the game, allow you to communicate with other users and give an access to other game activities)

Contract

Platform advertising ID (IDFA, GAID)

Platform ID (unique ID from platform that you use for authorization, it may also contest profile information (photo or friends list)

Game ID

Game experience (Nickname and history of its changes, Game Profile, Registration date, Consent to the ToU/Privacy Policy, Game progress, Last Active, Status (online/offline), Last exit, Ban in the game, Score and game results, Logs for the previous and current game sessions, Interaction with other users, History of support requests, Screen clicks)

Technical data (Device configuration, Device model, Operational memory device (RAM), Operating system (and its version), Language of the device, Device ID, Device token, Video card, Time zone, Amount of free internal memory, Total internal memory capacity, Type of connection (mobile internet/wifi), Country code, Game version)

Payments data (History of accruals of bonuses/compensation, History of campaigns and offers that were available in the profile, Payments (In-app purchases), Date of payment, Amount of payment)

Email  (when you register via Facebook account)

To enable in-app purchases

Contract

Game ID

Payments data

Game experience

Technical data

Platform ID

To improve our applications and user experience by analysing users' behavior

Legitimate interest to improve our services and customer experiences

Game ID

Payments data

Game experience

Technical data

Platform ID

To prov ide technical support to the users

Contract

Payments data

Game experience

Technical data

Additional information provided by the user

To maintain the security of our applications

Legitimate interest to safeguard the quality of our services

Game experience

Technical data

Payments data

Platform game ID

Additional information provided by the user

To display advertising of our services to users based on their interests in social media, other websites, and applications

Consent

Platform Advertising ID

User’s email

To display advertising from our partners

Legitimate interest to provide you with relevant ads in our games and to fund our services so that we can keep providing them to you

Platform Advertising ID

Game experience

Technical data

To communicate our special offers, future events, promotions, or news on request via email

Consent

Email

Full name

2. Our activities on social media

What data, for what purposes, and based on what grounds do we process?

Purpose

Legal ground

Data

To conduct activities of the gaming community in social media

Contract

Additional information from the user

To manage relationships with members of the community, visitors of our pages in social media (to answer comments, requests)

Legitimate interest to improve our services and customer experiences

Social media profile

Additional information from the user

How long do we process your data?

We process your data for as long as required to satisfy the purpose for which they were collected and used, or as long as is needed for us to be able to provide the services.

When the processing of your personal data is based on your consent, we process your data until you withdraw your permission for us to process your personal details at any time.

The possible consequences of failure to provide personal data

Personal data that we process to enter into a contract are necessary to provide you with our services. So, you may face the following consequences if you choose not to give your data:

When the data is processed t o create user accounts and allow you to play our games , you would not be able to authorise and use our application.

When the data is processed to enable in-app purchases , we would not be able to provide you with the paid service

When the data is processed to provide technical support to the users , we would not be able to solve technical problems.

When the data is processed t o conduct activities of the gaming community in social media , you would not be able to take part in the activities

Who do we share your personal data with?

In this section, we will provide you with information about the categories of companies to which your data is committed, as well as their data protection practices. In addition, some of the companies to which we provide data are listed as examples:

Our developers

In order to operate the services, your personal information may be transferred to other entities outside the EU. We share your personal information with the developers’ company when it is necessary to give you access to our services ,  provide technical support and make  decisions about improving our services. Standard Contractual Clauses are used to transfer your data to ensure that they are properly protected.

Payment services

We may share payment data with banks and other entities that process payment transactions or provide other financial services and for fraud prevention and credit risk reduction.

The service is used when the application is installed from the App Store. The services are provided by Apple Inc. Address: One Apple Park Way, Cupertino, California, USA, 95014. Relevant privacy policy  of Apple. Standard Contractual Clauses are used to transfer your data to Apple to ensure that they are properly protected.

The service is used when the application is installed from Google Play. The service is provided by Google LLC. Address: Google LLC, Google Data Protection Office, 1600 Amphitheatre Parkway, Mountain View, California 94043, USA. Relevant privacy policy  of Google. Standard Contractual Clauses are used to transfer your data to Google to ensure that they are properly protected. For more information: click on this link .

Social media

We may share the information in your account profile with the social networking service you have linked to your account to provide you with enhanced services.

The services are provided by Meta Platforms, Inc. Address: 1601 South California Avenue, Palo Alto, CA 94304, USA. Relevant privacy policy  of Facebook. Standard Contractual Clauses are used to transfer your data to Facebook to ensure that they are properly protected. For more information: click on this link .

Cloud

Our applications are hosted by Hetzner. .   The service is provided by Hetzner Online GmbH. Address: Industriestr. 25, 91710 Gunzenhausen, Germany. Relevant privacy policy  of Hetzner. Standard Contractual Clauses are used to transfer your data to Hetzner to ensure that they are properly protected. For more information: click on this link .

Analytics  

We use analytics services to evaluate the usage of our applications and frequently improve it. By using generated statistics, we are able to perfect our services and make them more appealing to you as a user.

The service is provided by AppsFlyer Inc. Address: AppsFlyer Inc., 111 New Montgomery Street, San Francisco, California 94105, USA. Various session and interaction data are collected from you and stored for this purpose. We need this information to improve the content and usability of our games and to optimize the user experience for you. The session and interaction data are at no time processed in personalized form. For more information on data processing by AppsFlyer, please refer to the   relevant privacy policy . Standard Contractual Clauses are used to transfer your data to Apple Pay to ensure that they are properly protected.

Managing support and contact requests

This type of service allows us to manage support and contact requests received via email or by other means, such as the contact form. The categories of personal data processed depend on the information provided by the user in the messages and the means used for communication.

We work with Zendesk for customer service. The service is provided by Zendesk, Inc.  Address: 989 Market Street, San Francisco, CA 94103, United States. Relevant privacy policy of Zendesk, Inc .  Standard Contractual Clauses are used to transfer your data to Zendesk, Inc. to ensure that they are properly protected.

Marketing analytics

We use these services to facilitate the sharing of information that may be useful, relevant, or interesting to you, such as allowing you to earn rewards for viewing in-game ads as well as to evaluate the effectiveness of our marketing campaigns. These entities may act as our data processors or, in certain cases, decide for themselves how to process your information.

The service is provided by AppsFlyer Inc. Address: AppsFlyer Inc., 111 New Montgomery Street, San Francisco, California 94105). Various session and interaction data are collected from you and stored for this purpose. We need this information to improve the content and usability of our games and to optimize the user experience for you. The session and interaction data are at no time processed in personalized form. For more information on data processing by AppsFlyer, please refer to the   relevant privacy policy .   Standard Contractual Clauses are used to transfer your data to Apple Pay to ensure that they are properly protected.

Advertising partners

We may feature advertising in our services via showing third party advertisements in our Services, as well as advertise our own services via third parties. We work with advertising partners to enable us to customize the advertising content you may receive on the service. These partners help us deliver ads and promotional messages that are more relevant to you, which may include interest-based advertising (also known as online behavioral advertising), contextual advertising, and generic advertising on the service.

Google Ads (AdWords) remarketing service is provided by Google Inc.Address: Google LLC, Google Data Protection Office, 1600 Amphitheatre Parkway, Mountain View, California 94043, USA. For more information on data processing by Google, please, refer to th e  relevant privacy policy of Google and Google's page   explaining how Google uses data from websites or apps that use one of its platforms. Standard Contractual Clauses are used to transfer your data to Google to ensure that they are properly protected. For more information : click on this link . You can opt out of the Google Ads service by following the instructions  described by Google.

The service is provided by ironSource Ltd. Address: 121 Menachem Begin Rd., Tel Aviv, Israel. The service is also used to mediate advertisements shown by a third party. The session and interaction data are at no time processed in personalized form. For more information on data processing by IronSource, please refer to the   relevant privacy policy . Standard Contractual Clauses are used to transfer your data to IronSource to ensure that they are properly protected.

The service is provided by AppLovin Corporation Address: 1100 Page Mill Road, Palo Alto, CA 94304. The session and interaction data are at no time processed in personalized form. The service also broadcasts ads to users using a mediator IronSource. For more information on data processing by IronSource, please refer to the   relevant privacy policy . Standard Contractual Clauses are used to transfer your data to IronSource to ensure that they are properly protected.

Email services

We may share your data with email services that provide us with tools to send bulk emails and implement email marketing.

The service is provided by Google LLC. Address: Google LLC, Google Data Protection Office, 1600 Amphitheatre Parkway, Mountain View, California 94043, USA. Relevant privacy policy  of Google. Standard Contractual Clauses are used to transfer your data to Google to ensure that they are properly protected. For more information: click on this link .

Tasks and project management tools

We use tasks and project management tools that help us effectively organize work and manage projects and tasks.

Compliance with laws

We may share your personal data when we believe in good faith that it is necessary for us to do so in order to comply with a legal obligation under applicable laws.

Automated decisions

We neither use automated decision-making nor your personal data to automatically assess aspects of your personality (automated profiling).

Your rights

Any user of our services can:

  1. obtain information about the processing of your personal data
  2. obtain access to the personal data held about you

Under Article 15  of the GDPR, individuals have a right of access that gives them the right to obtain a copy of their personal data, as well as other supplementary information. It helps individuals to understand how and why companies are using their data, and check the lawfulness of the processing.

  1. ask for incorrect, inaccurate, or incomplete personal data to be corrected

Under Article 16  of the GDPR, individuals have the right to have inaccurate personal data rectified. An individual may also be able to have incomplete personal data completed – although this will depend on the purposes for the processing.

  1. request that personal data be erased when they are no longer needed or if processing is unlawful

Under Article 17  of the GDPR, individuals have the right to have personal data erased. This is also known as the 'right to be forgotten'. The right is not absolute and only applies in certain circumstances.

  1. request the restriction of the processing of your personal data in specific cases

Article 18  of the GDPR gives individuals the right to restrict the processing of their personal data in certain circumstances. This means that an individual can limit the way that an organisation uses their data. This is an alternative to requesting the erasure of their data.

  1. receive your personal data in a machine-readable format and send them to another controller ('data portability')

Under Article 20  of the GDPR, individuals have the right to data portability that gives individuals the right to receive personal data they have provided to a controller in a structured, commonly used and machine readable format. It also gives them the right to request that a controller transmits those data directly to another controller.

  1. object to the processing of your personal data for marketing purposes or on grounds relating to your particular situation

Article 21  of the GDPR gives individuals the right to object to the processing of their personal data at any time. This effectively allows individuals to stop or prevent you from processing their personal data.

  1. withdraw your consent at any time
  2. lodge a complaint with a supervisory authority

In accordance with Article 77  of the GDPR, you, as a data subject, have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or where an alleged infringement of the GDPR has taken place.


Exercise your rights

If this Policy doesn’t contain the information you need or if you encounter issues related to your personal data, please do not hesitate to contact us.

The fastest way to do so is to use the in-game support menu “Help” . In the “Personal data” section you can select an item you are interested in and make a request.

In case you have trouble in finding this section, make a general request about the problem, and include “personal data request” in the description.

Our Support team uses Zendesk ( Zendesk Privacy Policy )  services to ensure that your request is promptly processed.

How we can delete your data

We can delete your data in several cases:

  1. Whenever data is no longer necessary to provide an app experience or service to users (if the user has not accessed the profile for more than 3 years, we assume that the data is no longer needed and delete it)
  2. When requested by a user (you can learn more about it in the section “Exercise your rights”),
  3. When a user deletes their account associated with your app,
  4. When it is requested by platform where our app is published,
  5. When required by law or regulation.

Requests to delete personal data are resolved in up to 30 calendar days.

Children

We recognize that we have a special obligation to protect children's data. We will not knowingly collect or process children's data without parental consent. By providing consent to this Policy, the User certifies that he or she is of sufficient age to give such consent. If you are a parent or guardian and you believe that we have collected your child's data in violation of the law, contact us at  support@kosmos.games .  We will delete this data in accordance with applicable law.

Cookie files

We, our marketing partners, analytics service providers use cookies (text files placed on your computer to analyze your use of our Products) and similar technologies (such as pixels, tags and device identifiers) to recognize you and/or your devices and our products and to enhance the products, marketing, analytics or website features we offer. The use of cookies is standard on the Internet.

How to delete cookies and opt out of targeted advertising and analytics

You can configure your browser settings to refuse cookies or to notify you when a cookie is sent. You may refuse the use of cookies by adjusting the appropriate settings on your browser. However, please note that this may limit your access to the full functionality of our website and portal supercitygame.com and solitairesocial.com.

Do Not Track: Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals.

Privacy Policy in Other Languages

This Policy was originally written in English and may be translated to other languages. In the event of an inconsistency, the English version has the precedence.

Contact us


For official requests, please use email - support@kosmos.games

Company name:  Kosmos Games (Cyprus) LTD

Address: 28 Oktovriou str. 367, Office A5, Mediterranean Court, 3107, Limassol, Cyprus