Privacy Notice


We at Key Games Network B.V. (“Key Games”, “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.

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”) when you play our games and visit the gaming websites that are part of our gaming platform. 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 access or play a game from the following gaming websites (“Gaming Websites”):

  • www.zigiz.com/nl/

  • www.gembly.com/


In this Privacy Notice, we will give you general information about how we process your Personal Data. We will furthermore give you more detailed information on the processes within our Services.

GENERAL INFORMATION

In this part of our Privacy Notice, you will find general information about how we process your Personal Data when you access or play a game from one of our Gaming Websites. For specific information with more details about our processing activities on the respective Gaming Website, please see the service specific information below.

Who is responsible for the processing of your Personal Data

Beechavenue 137, 1119RB Schiphol-Rijk Netherlands is responsible (“the data controller”) for the processing of your Personal Data.

You can reach our data protection officer under dpo@azerion.com.

What types of Personal Data do we process and how do we collect it?

When you access or play a game from one of our Gaming Websites, 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 depends on which of our games or Gaming Websites you use and how you use them. We process the following types of your Personal Data:

Personal Data provided by you

You can visit and play our games without registering or logging into our websites. When you access or play a game from one of our Gaming Websites, you provide or be asked to give us certain information, including:

  • Data provided in relation to our customer service: When you contact support, we collect information about your request (subject and content of your request) and your contact details (e-mail address).

  • Game ratings: We collect rating information if you use the voting button on our Gaming Websites (like and dislike buttons).

  • Your account information: On our Gaming Websites, you have the option to sign up for an account. If you choose to create an account, we collect your log-in data (your email address, username, and password).

Personal Data we receive or generate from your use of our Services

When you access our Gaming Websites or play a game from our Gaming Websites, we also process device-related information and information about how you interact with our games or Gaming Websites, including:

  • Technical information: We collect information about your device/device settings and may combine this information across different devices you use for the purposes described below. The information we obtain from these devices includes the type of your device, browser information online identifiers (your IP address), device IDs, game/site ID, geolocation data (based on your IP address), 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 usage: We collect information about how you use our Gaming Websites or play the games available on our Gaming Websites. This information includes your preferences, such as your interests in certain categories of Games, the actions you take, the time and duration of your activity. Furthermore, we collect information about the websites that led you to our Gaming Website.

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 may be provided by the following third parties:

  • Payment Providers: If you make in-game purchases, the transaction will be processed by a third-party payment provider and will be subject to third-party payment providers’ privacy policies. For these transactions, we do not receive any specific financial information (such as the payment method or your credit card information), but may receive information which is related to your transaction, for example, the item you bought, payment status and payment date.

  • Social Networks and connected third-party platforms: If you access our Gaming Websites or play a game from our Gaming Websites by logging-in via a third-party platform (Facebook), and you have created an account on the third-party platform, the authentication token is shared with us.

  • User acquisition companies: If you click on our advertisements shown to you in a third-party network, we will receive campaign information (the campaign ID, clicks on our ads, creative views), information about the which game or Gaming Website you visited, your country and language, and technical identifiers from our user acquisition partners.

  • We also receive information about your approximate geolocation (the country you are located in) from third parties (e.g. Google). We use this information to comply with our legal obligations applying to the processing of your Personal Data, customize certain services to your location, and for fraud or abuse prevention purposes.

To learn more about which data is processed on the respective Gaming Website from a specific Gaming Website, please see the section with service specific information below.

For What Purpose do we process your data?

Depending on which Gaming Website you are using and which privacy settings you have selected, we may process your Personal Data for the following purposes:

Provision and improvement of our games and services

  • to allow you to play our games, including third-party games available on our Gaming Websites

  • to create and manage your account

  • 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 indicate the popularity of our games

  • to assess the quality of our services

  • to understand and improve your online experience

  • to aggregate financial reports to pay our business partners

Personalization of your game experience

  • to remember your preferred game settings

  • to show you your preferred games

  • to recommend games you may like based on your preferences

  • to personalize advertising for you

  • to remember you next time you visit one of our Gaming Websites

Marketing and analytics

  • to deliver (targeted and non-targeted) advertising in our games or on our Gaming Websites

  • to measure the effectiveness of advertising

  • to send you marketing communications, informing your about new content and in-game offers

  • to understand usage of our Services across all our group companies to support strategy and growth

Prevention of fraud and illegal activity

  • to investigate fraud and illegal behaviour on our Gaming Website and reporting it to relevant authorities

  • to enforce our policies and terms of use

Compliance with our legal or regulatory obligations

  • to determine the legal requirements for processing of your Personal Data (based on your location and your age)

  • to obtain a valid (parental) consent, if necessary

  • 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 per Gaming Website.

Do we engage in profiling activities?

If you consent to this via the cookie consent pop-up, We use tracking mechanisms to track your Personal Data for profiling purposes. This allows us to serve relevant content to you and adjust our services and ads to your interests. You have the right to object to this type of processing. You can also go to your privacy settings to review and amend your privacy choices related to this type of processing at any time.

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:

  • Your consent: We process your Personal Data if you have provided your consent for a specific purpose. For example, when you enter our Gaming Website for the first time, we ask for your consent for the data processing in context of personalized advertising, analytics, profiling, social media and games from external publishers. We also show you just-in-time contextual notifications and consent pop-ups to obtain your consent for further processing activities. You have the right to withdraw your consent at any time, for example by changing your privacy settings. Please note that this will not affect any processing carried out before you withdraw your consent.

  • Performance of a contract: We process your Personal Data for the performance of a contract to which you are a party , for example, where it is necessary for the creation and administration of your account, to support the operation of our games or facilitate the delivery of requested services.

  • Compliance with legal obligations to which we are subject: We process your Personal Data to comply with legal obligations, for example, in order to verify your age,for tax and accounting purposes or legal disputes as well as any requests or claims from legal authorities

  • Legitimate interests: We also process your Personal Data to the extent that the processing is necessary for our legitimate interests or those of third parties while applying appropriate safeguards that protect your privacy. For example, we process your Personal Data for improvement of the service provided to you or to provide you with a better user experience or we transfer your personal data across all our group companies for administrative transfers as well as to determine the size of the user base of our Services.

Please see for additional information the section with service specific information below.



With whom do we share your Personal Data?

We will not disclose your Personal Data to any party who is not authorised to process them. To manage our services, we will share your Personal Data internally with members of our responsible departments and technical support involved in the gaming process and in each case only if access to your Personal Data is necessary for the performance of their roles.

Moreover, and only when necessary to fulfil the purposes mentioned above, we disclose your Personal Data to the following recipients or categories of recipients or allow the following third parties to collect your Personal Data in connection with your use of our games or Gaming Websites:

  • Group companies: We share your personal data with our group companies which are responsible for internal analytics for the purposes of cross-product audience measurement. Where we share your personal data with our group company, we have appropriate agreements (an intra-company data sharing agreement) in place to ensure that your personal data is processed in compliance.

  • External service providers: We share your Personal Data with external service providers who perform services on our behalf, like customer support service, IT services, hosting and content delivery services, web/social analytics services, data management services, social media sharing service, video hosting service, and user notification services. Where we share your Personal Data with external service providers, we have appropriate agreements in place to ensure that your Personal Data is processed in compliance with applicable data protection laws.

  • Payment providers: If you make in-game purchases, the transaction will be processed by a third-party payment provider and will be subject to the third-party payment provider’s privacy policy.

  • Third-party game Distributors: On our Gaming Websites, we offer games from third-party game distributors. By playing a third-party game, your Personal Data will be processed by the third-party game distributors (directly or through the use of cookies or similar technology). Please note that by choosing a third-party game, you will be able to play the game in the third-party game developer’s environment over which we have no control. We only receive anonymized statistics and revenue reports from third-party game distributors. We therefore advise you to check the privacy policies of any such game distributor before starting the game. Furthermore, you can find the third parties your Personal Data may be processed by playing our games or Gaming Websites in the following link: 3rd Party list.

  • External advertising companies: With your consent, we share your Personal Data with third-party advertising companies or allow third-party advertising companies to collect your Personal Data when you access or play a game from our Gaming Website. If you choose not to receive personalised ads at all, we will still show you ads, but they may not reflect your interests as those ads will be content specific and not user specific. Please note that by clicking on a third-party advertisement, you will be redirected to the third-party advertiser’s environment over which we have no control.

  • Law enforcement, government authorities or courts: We disclose your Personal Data in response to lawful requests to public authorities, including law enforcement, government authorities, or courts. We may also disclose your Personal Data to legal authorities where we believe such disclosure is necessary for prevention of a crime, facilitation of an investigation related to public safety, protect the security or integrity of our Service, or enable us to take precautions against liability or to protect our rights.

  • Other third parties: We also disclose your Personal Data in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in any insolvency or similar proceedings).

Please see the section with service specific information below for more information about the third parties we may share your data with.

How do we protect minors?

The data we collect from minors and our communication with parents

We offer our users a range of games and Gaming Websites. Some of our games are liked and played by minors. When we refer to minors, we mean persons under the age of 16. Protecting the privacy of minors is extremely important to us. When you identify yourself as being a minor, we generally do not process your Personal Data.

Where will my Personal Data be processed?

In general, your data is stored on servers within the European Union (EU) / the European Economic Area (EEA). However, your data may also be shared outside the EU / EEA. We have implemented appropriate safeguards to protect your Personal Data when it is transferred outside the EU/EEA, including the execution of the European Commission’s Standard Contractual Clauses (also known as Model Clauses) to provide safeguards for your Personal Data.

How do we protect your Personal Data

We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental, unlawful or unauthorized destruction, loss alteration, access, disclosure or use. We update and test our security standards on an ongoing basis. In addition, we take reasonable steps to assure that third parties to whom we transfer your Personal Data provide sufficient protection of Personal Data.

How long do we store your Personal Data?

We will not retain your Personal Data longer than necessary to fulfil the purposes for which the data was collected or to fulfil our legal obligations. Afterwards, we will delete or anonymize your Personal Data. Please see below for game specific information about how long we will retain your Personal Data. Additional information on how long your Personal Data is stored by our service partners can be found in the respective third-party list available here.



What are your rights in respect of your Personal Data?

To the extent permitted by applicable data protection laws and regulations, you have the following rights in relation to your Personal Data:


  • Access the Personal Data we hold about you, including information such as, for example, the source and the categories of the data, the purposes of the processing, the recipients (or categories thereof) and the respective retention period.

  • Request the update or correction of your Personal Data so that it is always accurate.

  • Receive your Personal Data in a structured, commonly used and machine-readable format, including the right to transmit your Personal Data to another controller.

  • Request the deletion of your Personal Data if you think that it is no longer needed for the purposes indicated above. To submit this request, contact our support team or our Data Protection Officer.

  • Restrict the processing of your Personal Data in certain circumstances, for example, where you have contested the accuracy of your Personal Data, for the period enabling us to verify its accuracy.

  • Withdraw your consent at any time if your Personal Data is processed with your consent. Please note that this will not affect the lawfulness of the processing based on consent before its withdrawal.


Right to object

In the event and to the extent that we process your Personal Data based on our legitimate interests, you have the right to object to the processing on specific grounds relating to your particular situation. In such case we will no longer process your Personal Data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.

You also have the right to object where we are processing your Personal Data for direct marketing purposes (including profiling). In such a case, we will stop processing your Personal Data for marketing purposes.

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You can exercise these rights by sending a request to the contact details set out below, providing your name, your email address as well as a description of your request.

If you believe we have not complied with our obligations under applicable data protection laws and regulations, you can lodge a complaint with a competent data protection authority, for example, the Autoriteit Persoonsgegevens in the Netherlands.

How can you contact us?

If you have any queries about this Privacy Notice or how we use your Personal Data, please contact our Data Protection Officer via e-mail to dpo@azerion.com.



How often do we update this Privacy Notice?

We regularly review this Privacy Notice. When there is an important change that will have a relevant impact on the processing of your Personal Data, we will inform you by email if we have your email address. If we do not have your email address, for example because you did not create an account, we will inform you with a banner on our Gaming Website.

This Privacy Notice was last updated on:

Version

Last updated

1.0

September 27, 2022







Additional Information for California Residents

This section for California residents supplements the information provided in this Privacy Notice and applies solely to players, and others who reside in the State of California. We provide this section to comply with the California Consumer Privacy Act of 2018 (CCPA) and the regulations issued under it; accordingly, this section addresses the specific requirements of the CCPA and should be read together with this Privacy Notice.

We do not sell your Personal Data. However, we may share or provide access to each of the categories of Personal Data we collect as necessary for our business purposes. We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. In particular, we have collected the following categories of personal information (envisaged by the CCPA) from consumers within the last twelve (12) months:

Category A – Identifiers (such as your device identifier, demographic information -such as your country, your username, email address, any information you may choose to provide -such as your age or your language-)

Category B- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Category D – Commercial information (such as purchase history)

Category F – Internet or other similar network activity (such as your interaction with our ads, your IP address)

Category G – Geolocation data


The CCPA provides consumers (California residents) with specific rights regarding their personal information.

You have the right to access specific information i.e. you may request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.

You have the right to know. Under the CCPA you have the right to request that we disclose to you what Personal Data we process about you.

You have the right to deletion which means that you may request that we delete any of your personal information we collected from you and retained, subject to certain exceptions.

You have the right to data portability which enables you to request to transfer your personal data to another data controller.

Under the CCPA, you have the right to opt out of any sale of your personal data. Please note that your right to opt out does not apply to our sharing of personal data with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the personal data only for that function.

Finally, you have a right to not be discriminated against for exercising your rights under the CCPA.

You can exercise these rights by sending a request to the contact details set out above, providing your name, your email address as well as a description of your request.


Additional Information for Brazil Residents

Under the Brazilian General Data Protection Law (the “LGPD”), you have the right to access, rectify, port, erase, and confirm that we process your data. If you have given consent about processing your data, you have the right to withdraw consent anytime.


SERVICE SPECIFIC INFORMATION

In this part of our Privacy Notice, you will find specific information on how your Personal Data is processed in our Website. For general information about data processes that apply to Games/Walkthrough Videos and Website, please see above.

Account: On our Gaming Website, you have the option to sign up for an account. If you choose to create an account, we collect your log-in data (your email address, username and password).

Hosting and content delivery: Gaming Websites are hosted by external companies providing web servers and web content delivery. Every time you make a request, for example by clicking on a link on our platform, the information allowing this request (e.g. device information and information on requested content) will be sent to the external servers. This data is used to show you the content you requested in a faster way. We process this data on the basis of our legitimate interest, to provide and improve our service and ensure its functionality.


Customer service: If you contact us for customer support by using our email address, an external customer service company will process your email address, and the content of your request in order to provide you with support. The request history helps us to solve a newer request and is stored to defend possible future legal claims. We process this data on the basis of performance of a contract to provide you with customer support, and store this data on the basis of our legitimate interest, to improve our services, and to be able to defend possible future legal claims.

Analytics: We use web and social media analytics companies to understand how popular our games are on social media and to monitor traffic on Gaming Websites, for example following changes to the website. For this purpose, we process information about your device, request data (including the URL of the current webpage and the website visited before) and special event data (for example if you share a link with your friends in the social media platform). We also process your full IP address to allow us to better understand how you use our games or our website and to improve our games and websites. We process this information based on your consent, provided in the consent pop-up which will be shown to you when you access Gaming Websites for the first time. We also process your IP address and user id to determine the number of unique users of our Services within our group companies. We process your personal data in connection with this activity based on legitimate interest.

Game distributors: On Gaming Websites, we offer Games from third-party game distributors which process your Personal Data. As also explained in the general information part, in case that you will play the game, it will be played in the third-party game developer’s environment over which we have no control. It is the third-party game distributors that processes your data when you play their game and who should therefore obtain your valid consent. We only receive anonymized statistics and revenue reports from third-party game distributors.

We therefore advise you to check the privacy policies of any such game distributor before starting the game. Furthermore, you can find the third parties your Personal Data may be processed by playing our games in the following link: 3rd Party list.

Last played games: To make your game experience more convenient, we will show you games you last played. This information will be stored locally on your device and will be deleted when the browser cache is cleared manually or automatically. We process this information based on our legitimate interest to provide you with a convenient user experience.

Facebook Connect

We’re offering you the opportunity to sign up for our services through Facebook Connect. In order to do this, you will be redirected to Facebook where you can log in using your Facebook user data. Your Facebook account will then be linked to our services. Depending on your Facebook settings, linking your account will allow the following data to be transmitted to us and/or retrieved by us: name, date of birth and email address.

We shall only use this information for identification purposes and contract processing. For more information on Facebook Connect and the privacy settings, please refer to the Privacy Policy and Terms of Use of Facebook Inc.

https://www.facebook.com/policy.php.

Advertising: On Gaming Websites, we show advertising from different advertising companies. These adverts can be personalized or non-personal content related ads. In order to show you personalized ads and only if you have provided your consent, we will share your Personal Data (your IP address, advertising identifiers and the information that you have provided your consent for personalized ads) through our advertising platform provider with third-party advertisers and ad networks. We also use this information to measure how effective these ads are. In our consent pop-up which will be shown to you the first time you enter our Gaming Website, you can choose from which advertising company you would like to receive personalised ads or choose not to accept receiving personalised ads at all. You can adjust your preferences at any time in your privacy settings. If you choose not to receive personalised ads at all, we will still show you ads, but they may not reflect your interests as those ads will be content specific and not user specific.

Rating function: You can rate the games on Gaming Websites, by choosing a thumbs up or thumbs down icon. It is in our legitimate interest to provide our users an overview which games are most popular and best rated. When you click on a rating button, we will store the aggregated voting data. The result of all the submitted ratings is used to generate a score between 1 and 5 for each game. In addition, a local text file will be stored to prevent multiple ratings for the same game. We will store this data in your browser’s local storage and we will not share this data with other partners.