PRIVACY POLICY

This Privacy Policy is used to inform our users, especially parents and guardians, regarding Kivicom Oy’s (hereinafter “us”, “our” or “we”) policies with the collection, use, and disclosure of information for our offline mobile games (hereinafter “our Services”).

This policy is designed to be fully transparent and compliant with the European General Data Protection Regulation (GDPR) 2016/679, particularly in relation to data concerning children (GDPR-K), as well as the Children’s Online Privacy Protection Act (COPPA) and other applicable international laws.

We recommend that you read this Privacy Policy in full to ensure you are fully informed.

🛡️ Children's Privacy and Our Commitment

Our Services are primarily directed to and designed for children aged 6 and up. Protecting the privacy of young users is our highest priority.

• No Personal Information Collection: Our games are designed to be played offline and do not require or collect any personal information that could be used to identify a child or any user (e.g., full name, email address, phone number, specific geolocation).

• No Targeted Advertising: Our Services do not use or share any data for the purpose of serving targeted or behavioral advertising.

• No Social Features: Our games do not contain social media links, chat features, or other tools that would allow children to share personal information publicly.

🗂️ Information We Collect

Our Services operate on a principle of Data Minimisation, collecting only the essential data needed for the game to function and for internal analysis.

1. Information Provided by the User (None)

Our Services do not require you to provide us with any personally identifiable information, registration details (like usernames, passwords), contact information, or payment information to play the games.

2. Automatically Collected Information (Anonymized Game Data)

While using our Services, we automatically collect strictly anonymized, non-personal data via our third-party analytics provider. This data is aggregated and cannot be used to identify an individual player.

Data Type

Specific Examples

Purpose

Device/Technical Data

Device type, operating system version, the configuration of the app, time and date of use, Internet Protocol (“IP”) address (only used for regional aggregation and is not persistent).

Used for analyzing crash reports and obtaining broad, country-specific/device-specific usage statistics to improve game stability.

Internal Game Data

Player progression (e.g., level completed, puzzle solved), Death/Failure events, Session length.

Used exclusively to analyze and improve game design, balance, and quality (e.g., identifying difficult levels or bugs).

This Anonymized Data is explicitly not considered “Personal Information” under COPPA, GDPR, and other laws, as it is only used for internal operations and cannot be traced back to an individual user.

🎯 Purpose of the Information We Collect

We collect only the anonymized, non-personal data described above for the following internal purposes:

• To analyze and improve the stability, performance, and design of the games we provide.

• To analyze anonymized crash reports to ensure technical quality.

• To meet legal obligations related to operating a software service.

🧩 Third-Party Service Providers

We employ one third-party company to assist us in analyzing how our Service is used, exclusively using the anonymized, non-personal data listed above.

• Unity Analytics (via the Unity Engine): Used to collect anonymized game-related metrics (e.g., progression, deaths) for internal improvement. We configure Unity Analytics to comply with all child-directed app standards, ensuring no personal data is collected or shared for targeted advertising.

We do not use Facebook or Game Analytics as previously stated.

🌍 Information Transfer outside of the EU or the European Economic Area

Information may be transferred and stored to a server outside of the EU or the European Economic Area to be processed by the Controller or Controller’s affiliate on Controller’s behalf in accordance with the Personal Data Act. We ensure any such transfers are protected by appropriate safeguards (such as standard contractual clauses) to maintain the required level of privacy protection.

🛠️ Access, Correction, and Deletion of Information

As we do not collect personal information, there is generally no personal data to access, correct, or delete. However, in the event that any potentially personal or persistent identifier (like an IP address or device ID used for analytics) is collected:

• Deletion: To stop all collection and delete any data we or our service provider may hold related to your device, please contact us at contact@kivicom.net using the subject “REMOVE”.

• Opt-Out: You can stop all data collection done by our games easily by uninstalling the game. You may use the standard uninstall processes as available on your mobile device.

🔒 Security

We value your trust in our commitment to privacy. We limit access to this non-personal information to authorized employees and contractors who need to know that information to operate, develop or improve our services. While we strive to use commercially acceptable means of protecting the information we process and maintain, no security system can prevent all potential security breaches.

🔄 Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any significant changes by posting the new Privacy Policy on this page. These changes are effective immediately after they are posted on this page.

🤝 Data Controller and Contact Information

If you have any questions, suggestions, or concerns about our Privacy Policy, especially regarding children’s data, do not hesitate to contact us.

Role/Information

Details

Data Controller:

Kivicom OY

Address:

Luotsikatu 3A 6 

Business ID:

3322979-2

Email (Privacy Inquiries):

contact@kivicom.net