Privacy Policy

1. Data Controller

The data controller is Kunifish Game, a game company, having its registered office at Office No.6, 12/F, Wealth Commercial Centre, 48 Kwong Wa Street, Kowloon, Hong Kong.

Protection of your personal data is fundamental to us. This confidentiality policy outlines the manner in which we collect and process your data.

Personal data shall mean any information relating to an identified or identifiable natural person. Data controller shall mean the person that determines the purposes and means of the processing.

2. Remit of the personal data protection policy

This personal data protection policy is applicable to all of our applications and services.

3. What data is collected?

With your prior consent, we are likely to collect and process the following data in whole or in part when you use our applications:

• Identity-related data: for some of our applications, we may collect data from your Facebook account when you log in using Facebook Connect: public profile (surname, forename, age, gender, email address, profile photos, hobbies), friend list.
• IDFA publicity identifiers (for iOS devices) and GAID (for Android devices).
• Data pertaining to your activities on our applications and notably the way in which you interact with our applications and with the advertising we display (time spent, potential clicks).
• Data pertaining to your geographical position (IP address).

We are also likely to use cookies — small files containing letters and figures downloaded onto your device when you access our applications.

This data is collected via external tools (Software Development Kit or SDK) implemented by our partners, which are an integral part of the application. You will find below the list of our partners implementing SDKs through our applications:

• Analytical SDKs: Games Analytics, MixPanel
• Advertising SDKs: Oath, Ogury, MoPub, InMobi, Admob, AppLovin, Vidcoin, Vungle, UnityAds, Ironsource, Tapjoy, Facebook Audience Network, Mobvista, Fractionnal, Apponboard, Fyber

4. Purposes and legal basis of processing

Data collected by Kunifish Game is used to:

• Provide our applications.
• Guarantee use and improvement of our applications.
• Develop new applications.
• Understand your centers of interest and, thanks to this profiling, propose targeted and relevant advertisements (advertising SDK).
• Make statistics on your use of the games, including the number of games played, your duration of use or the advertisements you are watching, which allows us to improve your gaming experience (analytical SDK).
• Communicate with you, notably when you contact us by any means whatsoever.

We collect the data listed hereinabove, in whole or in part, only once we have your express consent for the purposes for which they are to be processed, through a pop-up in our applications. At any time you can withdraw your consent from the "Settings" page in our various applications.

5. Term of data storage

Kunifish Game stores your personal data for a maximum duration of 13 months after collection. Beyond this term, data may be rendered anonymous and stored solely for statistical use and will not be exploited in any nature whatsoever.

6. Categories of recipients of data collected

The recipients of the Data are the teams of Kunifish Game that need access as well as the partners mentioned above in section 3. We may share Data collected with our technical service providers for the aforementioned purposes. We stringently request that our partners always act in compliance with applicable data protection legislation and grant special attention to confidentiality of this Data.

Kunifish Game may also disclose/transfer your personal data to third parties in the following circumstances:

• By virtue of legislation, as part of legal proceedings, a dispute and/or request issued by the public authorities in your country of residence or otherwise.
• If disclosure is necessary for national security, application of legislation or any other matter of public interest.
• In the event of restructuring, transfer, merger or sale to the third party concerned.

7. Data transfer

In such instance as your Data is transferred outside of the European Union, we ensure that:

• The personal data is transferred to countries recognised as offering an equivalent level of protection.
• Personal data is transferred via certified entities under the Privacy Shield.
• For personal data transferred outside of countries recognised by the relevant National Data Protection Authority as having a sufficient level of protection, any of the mechanisms offering appropriate guarantees is used, for which provision is made by applicable regulations, and in particular the adoption of template contractual clauses.

8. Personal data concerning children

Kunifish Game does not knowingly collect any personal data concerning children under 15 years old.

9. Your rights concerning data collected

You have all of the following rights concerning the data we collect:

• Right to confirmation: You are entitled to obtain from the controller confirmation as to whether or not data related to you are being processed.
• Right to access your Data: You are entitled to receive confirmation that your personal data is or is not processed and, when processed, you are entitled to access said data, including a copy of the data processed.
• Right to rectification: You are entitled to request rectification of your Data if incorrect.
• Right to restriction of processing: You are entitled to request that the data controller limit the use of your data solely on those grounds for which provision is made by applicable regulation, in particular when you object to the accuracy of your Data or consider that processing is illicit.
• Right to object to processing: You may withdraw your consent at any time (withdrawal does not harm the legality of processing based on consent granted prior to its withdrawal).
• Right to data portability: You are entitled to reclaim your data provided to Kunifish Game in a structured, commonly used and machine-readable format, and to transfer this data to another data controller.
• Post-mortem guidelines: You have the right to provide specific or general guidelines for the retention, erasure and disclosure of your personal data after your death.
• Right to make a complaint: You have the right to make a complaint to the relevant National Data Protection Authority.

Due to the obligation of security and confidentiality in data processing incumbent upon Kunifish Game, you are hereby informed that your request will be processed subject to your providing proof of your identity, notably by producing a scanned copy of a valid identity document.

Kunifish Game will determine whether this is admissible or not within one month following receipt of the claim. If, given the complexity of the claim, the aforementioned deadline cannot be respected, Kunifish Game will notify you prior to expiry of this deadline of a postponement by a maximum of two months.

To exercise any of these rights, please email us at support@kunifish.com or use our Data Deletion Request page.

10. Personal data security

We take all necessary security measures to prevent, as far as practically possible, any alteration or loss of your data or any unauthorised access thereunto. In the event we become aware of illegal access to personal data concerning you and corresponding to processing for which we are responsible, we undertake to notify you of the incident as soon as possible if this fulfils a legal requirement.

11. Updating the present policy

The present policy may be updated at any time, notably pursuant to legal and/or regulatory provisions and/or any recommendations of relevant authorities. We hereby invite you to consult this page regularly.