Kudo Privacy Policy

Protecting your privacy is really important to Kudo Network Technology Co., Ltd ("Kudo", "our", "us" or "we"). We provide this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of information we receive from users of our game applications for mobile devices and tablet computers (the “Apps”). This Privacy Policy applies only to information that you provide to us through the Apps. Kudo is dedicated to transparency, data privacy, and security, and follows the strict regulations required by the CCPA (California Consumer Privacy Act), LGPD(Lei Geral de Proteção de Dados) and GDPR (General Data Protection Regulation), as detailed in this privacy policy. If you have any concerns, please contact us using the methods provided in the Contact Us section of this document. If you disagree with your information being used as described in this Privacy Policy, please do not install or use the Services.

Reference Definition

Apple – means Apple, Inc., any parent or group company or any successor thereof which operates the Apple mobile platform currently called “App Store”.

Apps – means Our mobile applications and any services provided through the Apps. It is a part of the Services which We provide to You.

Content – means all kinds of content, including, but not limited to information, data, text, articles, links, software, sound, music, photographs, graphic or video messages, tags or other materials uploaded, communicated, transmitted, created, generated or otherwise made available or accessible via Our Services, whether publicly available or privately transmitted by a Third-Party Supplier, or contributed, submitted, displayed or otherwise provided by You when using the Services, or as a result of Your interaction with other user of the Services.

Device – means an authorized smart phone or a tablet or other mobile device, which You own or otherwise legally control solely for Your lawful, personal, and non-commercial use.

EEA – means the European Economic Area.

Policy – means the privacy policy, which describes how We collect, use, process, store and share information that We collect about You.

Representative – means a parent, or a legal guardian, or other representative under the applicable law of a person between 16 and 18 years of age.

Services – means Apps and Our related services/products and websites, which You download, install, use and/or visit.

How do we collect and use information?

Our primary goals in collecting information are to provide and improve our Apps and related services (collectively, the “Services”), to administer your use of the Services (including your account, if you choose to create an account for your use of the Services), and to enable you to enjoy our Services. We may also collect information from advertising platforms and partners and other third-parties such as information about purchases and interests.

Account Information

In connection with your use of the Services, we do not collect any information that can be used to contact or identify you directly, such as your full name, email address, postal address or phone number (“Personally Identifiable Information” or “PII”). However, we may collect certain other information that you provide us, such as your nickname, if you use our Services as a guest. If you choose to create an account for your use of the Services through one of your third-party social networking accounts (such as Facebook,) (“SNS Accounts”), you may have to provide us with your username (or User ID) so that your identity can be authenticated by the SNS Account. When the authentication is complete, we’ll be able to link your account with the SNS Account and access certain information, such as your first name, SNS Account profile picture and SNS Account identification number. We don’t receive or store passwords for any of your SNS Accounts. Some details of orders (amount spent, date, time, vouchers or offers used) might be involved in case there is any questions about the order you make. We keep a record of these communications to provide customer service by answering your questions and providing you with a better experience using our app.

Payment Information

We’ll collect information related to any purchases you make. When you play Kudo’s games or access any of our other Services on connected third-party applications or platforms (like Facebook, Apple, Google, or Amazon), any purchases you make will be processed by that third-party application and subject to that third-party application’s terms of service and privacy policy. For these purchases, Kudo does not receive your financial information, but may receive non-financial information related to your purchases, like your name, approximate physical location, and the items purchased. The information Kudo receives depends on the Kudo game you’re playing and the third-party application. Kudo’s Terms of Service explain our policies and terms related to charges, billing, third-party credits, and virtual currencies. Please note that purchases of third-party credits or currencies are also subject to those parties’ terms of service and privacy policies.

Profile Information

If you register via Facebook accounts, we shall get your Facebook or Google ID for authentication purposes, as well as your name. In addition, your Facebook profile picture might appear within the game or our social media features.

Information Related to Use of the Services

Our servers automatically record certain information about how a person uses our Services (we refer to this information as “Log Data”), including both account holders and non-account holders (either, a “User”). Log Data may include information such as a User’s Internet Protocol (IP) address, device type, operating system, the links and advertisements on our Services that a User clicked on, the amount of time you interact with the Services and other statistics. We use this information to administer the Services and we analyze (and may engage third-parties to analyze) this information to improve and enhance the Services by expanding their features and functionality and tailoring them to our Users’ needs and preferences. We also use the IP Address to generate aggregate, non-identifying information about how our Services are used. We use Thinkingdata to collect, monitor and analyze Log Data in order to increase our Services’ functionality and user-friendliness, and to better tailor our Services to our visitors’ needs. We also use this information to verify that visitors to the Services meet the criteria required to process their requests. Accordingly, Log Data is shared with Thinkingdata, which has its own privacy policy (accessible at https://doc.thinkingdata.cn/tdamanual/installation/privacy.html) addressing how Thinkingdata uses such information.

Location Information and Other Information

In some case we collect and store information about where you are located, such as by converting your IP address into a rough geolocation. We may use location information to improve and personalize our Services for you. Similarly, we may ask for access to your camera in case you want to use certain features of our Services.

Mobile Device Information

When you access the Services via a mobile device, we will collect information related to the mobile device like your unique device ID(persistent/non-persistent), your device operating system, version, model, CPU, amount of RAM and disk space, hardware type, Identifier For Advertising (IDFA), Advertising ID, the version of your operating system ("OS"), your device name, Game Center ID, and your location based on your Internet Protocol ("IP") address, when communicating between you and us, whether via email, or through social media channels. We may use this information to improve and personalize our Services for you.

Advertising & Third-Party Products and Services

The Services are supported via advertising, and we collect certain data to help the Services serve ads. We may work with analytics companies to help us understand how the Services are being used, such as the frequency and duration of usage. We work with advertisers and third-party advertising networks, who need to know how you interact with advertising provided in the Services which helps us keep the cost of the Services low. Advertisers and advertising networks use some of the information collected by the Services, including the unique identification ID of your mobile device. To protect the anonymity of this information, we use an encryption technology to help ensure that these third-parties can’t identify you personally. These third-parties may also obtain information about other services you’ve downloaded to your mobile device, the mobile websites you visit, your non-precise location information (e.g., your zip code), and other non-precise location information in order to help analyze and serve anonymous targeted advertising on the Services and elsewhere. We may also share encrypted versions of information you have provided in order to enable our partners to append other available information about you for analysis or advertising related use.

How We May Share or Disclose Your Information with Third-Parties?

Third-party Websites, Social Media Platforms, and Software Development Kits.

We may share your information as described in this Privacy Policy (to provide the Services with our Third-party Service Providers; to comply with legal obligations; to protect and defend our rights and property) or with your consent.

Account holders

If you choose to connect your SNS Account to the Services, other Users of the Services will be able to see your SNS Account first name and profile picture and information related to your use of the Services, such as the number of times you have accessed or used the Services. For more information about the processing driven by the third-parties regarding social sharing features, please visit the privacy policies of the providers found here:

·         Facebook: https://www.facebook.com/about/privacy

·         Game Center: https://www.apple.com/legal/privacy/en-ww

·         Google Play Games: https://www.google.com/policies/privacy

Guest Users

If you choose to use the Services without connecting to an SNS Account, your nickname and information related to your use of the Services, such as the number of times you have accessed or used the Services, will be viewable by other Users.

Information Shared with Our Services Providers

We may engage third-party service providers to work with us to administer and provide the Services. These third-party services providers have access to your information only for the purpose of performing services on our behalf and are expressly obligated not to disclose or use your information for any other purpose.

Information Shared with Third-Parties

We may share aggregated information and non-identifying information with third-parties for industry analysis, demographic profiling and other similar purposes.

Information Disclosed in Connection with Business Transactions

Information that we collect from our users, including PII, is considered to be a business asset. As a result, if we go out of business or enter bankruptcy or if we are acquired as a result of a transaction such as a merger, acquisition or asset sale, your information may be disclosed or transferred to the third-party acquirer in connection with the transaction.

Information Disclosed for Our Protection and the Protection of Others

It is our policy to protect you from having your privacy violated through abuse of the legal systems, whether by individuals, entities or government, and to contest claims that we believe to be invalid under applicable law. However, it is also our policy to cooperate with government and law enforcement officials and private parties. Accordingly, we reserve the right to disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary: (i) to satisfy or comply with any applicable law, regulation or legal process or to respond to lawful requests, including subpoenas, warrants or court orders; (ii) to protect our property, rights and safety and the rights, property and safety of third-parties or the public in general; and (iv) to prevent or stop activity we consider to be illegal or unethical.

Information We Disclose With Your Consent or at Your Request

We will share your information with third-party sites or platforms, such as social networking sites, if you have expressly requested that we do so via the Services.

Law enforcement or government bodies

We may disclose your personal data as permitted by law in order to investigate, prevent or take action regarding illegal activities, suspected fraud, violation of our intellectual property rights, situations involving potential threats to the physical safety of any person, violation of our Terms and Conditions or other agreements, or as required by law.

The Security of Your Information

We take reasonable measures to protect the information that we collect from or about you (including your information) from unauthorized access, use or disclosure. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.

Links to Other Sites

Our Services may contain links to other websites and services. Any information that you provide on or to a third-party website or service is provided directly to the owner of the website or service and is subject to that party’s privacy policy. Our Privacy Policy does not apply to such websites or services and we’re not responsible for the content, privacy or security practices and policies of those websites or services. To protect your information we recommend that you carefully review the privacy policies of other websites and services that you access.

Modifying Your Information

You can access and modify the information associated with your account in the “Settings” section of the Services. If you want us to delete your information and your account, please contact us at support@kudo.games with your request. We’ll take steps to delete your information as soon as is practicable, but some information may remain in archived/backup copies for our records or as otherwise required by law.

International Transfer

All Personal Information collected via or by Kudo may be stored anywhere in the world, including, but not limited to, in China, the United States, the European Union, in the cloud, on our servers and on the servers of our affiliates or the servers of our Service Providers. When we transfer your Personal Information internationally, we will take reasonable steps to ensure that it is treated securely, lawfully and in the manner, we describe here. Please note that laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to the places where your information is transferred to or stored, used or processed in may be different from the privacy laws applicable to the place where you are resident. Your information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you’re located outside the United States and choose to provide information to us, we may transfer your information to the United States and China and process it there.

By providing information to Kudo, you consent to the storage of your Personal Information in these locations.

If you are using our Services from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to China and the United States and to Processing of your data globally. We share your personal data with our affiliates in the EU and outside the EU. International transfers with PLR affiliates outside the EEA, are governed by EU Commission-approved Standard Contractual Clauses for Controllers and, where relevant, for Processors. We share personal data with external vendors or service providers or suppliers that we engage to perform services or functions on our behalf and under our instructions. Where these vendors are located within the EU, we ensure that they are contractually obligated to comply with the EU data protection rules. We also ensure in our contracts with these organizations that they only Process Personal Data in accordance with our instructions and in order to provide the agreed services and protect the integrity and confidentiality of your personal data entrusted to them.

Our Policy Toward Children

Our Services are not directed to children under 13 and we do not knowingly collect PII from children under 13. If you are a parent or legal representative of a child under the age of 13 (or under 16 in certain jurisdictions in the European Union) who uses our games, please contact us at support@kudo.games and if we learn that we have collected PII of a child under 13, we will take steps to delete such information from our files as soon as possible.

Changes to Privacy Policy

This Privacy Policy may be updated from time to time for any reason. We might notify you of any changes to our Privacy Policy by way of notification or pop-up. Your continued use of our Services signifies your acceptance of changes to this Privacy Policy. You are advised to consult this Privacy Policy regularly for any changes.

California Privacy Rights

According to the California Consumer Privacy Act (CCPA), users who are California residents may request and obtain a list of the Third-Parties to whom we have disclosed their personal information (if any) and the type of personal information disclosed to those parties during the prior calendar year.

USER RIGHTS

Right to correct personal information

We try to keep the information that we hold about you accurate and up to date. Should you realize that any of the information that we hold about you is incorrect, please let us know at support@kudo.games and we will correct it as soon as we can.

Right To Delete

You have the right to request the deletion of the personal information we have collected from you and retained, subject to certain exceptions. If you wish to have your data deleted sooner, please contact us at support@kudo.games Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records.

Right to opt-out

You have the right to opt out of the sale of personal information, which is defined in a way that may include the transfer of data to third parties to personalize ads for you. If you opt-out of the sale or share of your information, we will not sell or share your information, including to our advertising partners, but you may still see ads in the game and some of our partners may deliver ads to you, based on information they hold on you. About how to adjust your preferences for interest-based advertising for more information:
1. Disconnect your social media or network account from our games;
2. Reset your mobile advertising identifier or limit ad tracking altogether using the settings on your phone.
3. Limit or prevent the use of cookies in your web browsers.

Advertising Partners

When you play our games or use our Services, the advertising networks and their partners, that are listed below, and would like your consent, may collect or receive device information from our apps and other apps that include personal and non-personal information, such as advertising (or ad) identifiers, IP address, or other information regarding the delivery of advertisements and your interaction with them non-personal identifiers and other information from your device is collected and shared with advertising partners to enable the technical delivery of ads to your device If you consent to or are opted into, the collection and use of your data for targeted advertising purposes by our advertising partners. We recommend that you review our advertising partners’ privacy policies for more information. You can refuse or withdraw your consent to such use at any time.

AdColony

Privacy Policy: https://www.adcolony.com/privacy-policy/

Amazon Developer

Privacy Policy: https://aws.amazon.com/privacy/
Manage your personalized ad preferences in relation to Amazon directly from your Amazon account here: https://aws.amazon.com/privacy/

AppLovin and Applovin MAX

Privacy Policy:https://www.applovin.com/privacy

BidMachine

Privacy Policy:https://bidmachine.io/privacy-policy/

ChartBoost

Privacy Policy: https://answers.chartboost.com/en-us/articles/200780269

Meta Audience Network

Privacy Policy:https://www.facebook.com/about/privacy/
You can manage your personalized ad preferences in relation to Facebook directly from your Facebook account.

Fyber

Privacy Policy:https://www.fyber.com/services-privacy-statement/

Google AdMob and their partners

Privacy Policy of Google:https://www.google.com/policies/privacy/
AdMob
Partners:https://support.google.com/admob/answer/9012903
You can opt-out from AdMob by Google service by following the instructions:
https://support.google.com/ads/answer/2662922?hl=en

Google AdSense

Google Ads Settings web page:https://www.google.com/ads/preferences/

Index Exchange

Privacy Policy:https://www.indexexchange.com/privacy/

InMobi

Privacy Policy:https://www.inmobi.com/privacy-policy/
Opt-out:https://www.inmobi.com/page/opt-out/

ironSource

Privacy Policy:https://developers.is.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/

Mintegral

Privacy Policy:https://www.mintegral.com/en/privacy/

MobileFuse

Privacy Policy:https://mobilefuse.com/privacy-policy/

MyTarget

Privacy Policy:https://legal.my.com/us/mytarget/privacy/

Pangle

Privacy Policy:https://www.pangleglobal.com/privacy

PubMatic

Privacy Policy:https://pubmatic.com/legal/privacy-policy/
Opt-out:https://pubmatic.com/legal/opt-out/

PubNative

Privacy Policy:https://pubnative.net/privacy-notice/

Smaato and their vendors

Privacy Policy:https://www.smaato.com/privacy/
For more information on the Smaato Vendors, please visit:https://www.smaato.com/partner-list/

Tapjoy

Privacy Policy:https://www.tapjoy.com/legal/#privacy-policy

Unity Ads

Privacy Policy:https://unity3d.com/legal/privacy-policy

Verve

Privacy Policy:https://www.verve.com/privacy-policy/

Vungle

Privacy Policy:https://vungle.com/privacy/

Yahoo and partners

Privacy Policy:https://legal.yahoo.com/ie/en/yahoo/privacy/index.html
For more information on Yahoo partners, please visit:
https://legal.yahoo.com/ie/en/yahoo/privacy/topic/ourpartners/index.htm Analytics and other service providers

Analytics and other service providers

We use your information to perform our own analytics and to enable analytics provided by third parties and other essential functions. We use analytical information for supporting business analysis and operations, business intelligence, product development, improving the Services, personalizing content, providing advertising, and making recommendations. In order to learn about how your information is used by our analytics service providers, you can follow the hyperlinks in the list below to each provider’s privacy notice.

AppsFlyer

Privacy Policy: https://www.appsflyer.com/legal/privacy-policy/

AWS

Privacy Policy: https://aws.amazon.com/privacy/

Facebook Ads conversion

Privacy Policy: https://www.facebook.com/about/privacy/

Facebook Analytics

Privacy Policy: https://www.facebook.com/about/privacy/

Firebase

Instructions provided by Google in their Privacy Policy: https://www.google.com/intl/en/policies/privacy/

Google Analytics

Google Analytics is an analytics service provided by Google Inc.
Privacy Policy: https://policies.google.com/privacy
For more information visit the site “How Google uses data when you use our partners' sites or apps” available at:https://policies.google.com/technologies/partner-sites

Yandex

Privacy Policy: https://yandex.com/legal/confidential/?lang=en

Thinking Data

Privacy Policy: https://doc.thinkingdata.cn/tdamanual/installation/privacy.html

Tenjin

Privacy Policy: https://www.tenjin.io/privacy


Questions?

Please contact us at support@kudo.games if you have any questions about our Privacy Policy.