This Privacy Policy will be effective from 31st July 2020.
Introduction
In this Privacy Policy, “Wooga” refers to Wooga GmbH, a developer and publisher of games and mobile game applications based in Berlin (Germany). We may also refer to Wooga as "We" or "Us".
Wooga is committed to protecting the privacy of its users and providing them with a better social gaming experience ("Users" or "You").
This Privacy Policy applies whenever You play Our games or otherwise access any of Our other products, services, content, wooga.com and/or the other domains provided by Wooga, together referred to as “Services.” This Privacy Policy describes:
By using the Service, You understand and do not object to the collection, disclosure, storage and use of Your information as outlined in this Privacy Policy. If You do not want Wooga to collect, store, use or share Your information in the ways described in this Privacy Policy, You should not play Wooga’s games or use Our Services. Wooga may amend the Privacy Policy from time to time, and Wooga encourages You to consult the Privacy Policy regularly for changes.
Users in certain jurisdictions have a right to access Personal Information held about themselves. Your right of access can be exercised in accordance with applicable law.
1. Data Controller / Who You Can Contact
Wooga as the data controller is responsible for its Services and protection of Your personal data. If You have specific questions about Your personal data, deletion of Your personal data or similar matters, You can contact Our Data Protection Officer via e-mail at privacy@wooga.net.
You can also reach Us via the support section inside Our games and at:
Wooga GmbH
Saarbruecker Strasse 38
10405 Berlin, Germany
2. Information We Collect, How We Collect It and the Legal Basis for It
“Personal Information” (also “Personal Data”) in this Privacy Policy is individual information about personal or objective circumstances of a specific or identifiable person, e.g. Your name, address or e-mail address, but also IP addresses and device-related identifiers.
Wooga only collects Personal Information to the extent necessary to fulfill one or more of its functions and activities; and will do so only by fair and reasonable means. Generally, We will collect Personal Information directly from the Users, but in some circumstances (including as outlined below) it may be necessary for Us to collect information from a third-party source.
The legal basis for collecting and using the information depends on what the information is and the context in which We collect it.
We’ll generally process Your Personal Information for the purposes of Wooga’s legitimate interests of ensuring smooth and secure provision, optimization and improvement of Our Services (Art. 6(1)(f) GDPR), and for efficiently fulfilling Our contractual obligations (Art. 6(1)(b) GDPR). In some cases, the processing is necessary to fulfill legal obligations (Art. 6(1)(c) GDPR), or to protect Your vital interests or those of another person (for example, another User) (Art. 6(1)(d) GDPR). Moreover, when We process Your personal data based on Your consent (Art. 6(1)(a) GDPR), We will provide all required information for You to give or withhold Your consent freely.
We will also make clear whether providing information is mandatory.
Every correspondence with You is logged and stored within Our systems. When You provide Us additional information other than the information mentioned in this Privacy Policy (such as information revealing financial data), You give Us Your explicit consent to process it for the intended purpose.
We do not sell Personal Information of Our Users and have not done so in the preceding 12 months.
If You are a User residing in California, a list of the categories of Personal Information collected about You, and disclosed for a business purpose, generally and in the preceding 12 months, is detailed in Our California Privacy Notice and Annex 1 to this Privacy Policy, along with the purposes of collection, categories of sources and categories of third-party disclosures.
A. Information About You That We Get from Third-Party Applications, Including Social Networks (Like Facebook)
If You play Wooga’s games or access any of Our other Services on connected third-party applications or connect Our Services to any third-party applications, including social networks like Facebook, Wooga may receive certain information about You from the provider of the third-party application. The information We receive depends on the Wooga game You’re playing, the third-party application, Your privacy settings and, if applicable, Your friends’ privacy settings on that third-party application.
For example, Wooga may process some or all of the following information shared by the provider of the connected third-party application:
If You access Our Services from a third-party application or connect Our Services to a third-party application, You should also read that third-party application’s terms of service and privacy policy.
If You are unclear about what information a third-party application is sharing with Us, please also contact the provider of the third-party application to find out more about their privacy practices.
B. Cookies
We use cookies on Our website(s). Cookies are small text files that are usually stored in a folder from Your browser. Cookies contain information about the current or last visit to Our website:
If cookies do not contain an exact expiration date, they are stored only temporarily and are automatically deleted as soon as You close Your browser or restart Your device. Cookies with an expiration date will still be stored even when You close Your browser or restart Your device. Such cookies will not be deleted until the specified date or if You delete them manually.
We use the following three types of cookies on Our website:
You can configure, block and delete cookies in Your browser settings. If You delete all cookies from Our website, some functions of the website may not be displayed correctly. Further information on cookies and how to configure them can be found here in German https://www.bsi-fuer-buerger.de or here in English https://ico.org.uk/for-the-public/online/cookies/.
Google Analytics
We use Google Analytics, a web analytics service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Google Analytics uses the advertising and analytics cookies described above to analyze Our website with regard to Your usage behavior. The information generated by these cookies is transferred to a Google server in the USA and stored there. However, Your IP address is shortened before the usage statistics are evaluated, so that no direct connection to You as a person can be made. For this purpose, We use the "anonymizeIp" function to ensure anonymous collection of IP addresses. Google will use the anonymous information collected by the cookies to evaluate the usage of the website and to compile reports on website activity. Google may also transfer this information to third parties if this is required by law or if third parties process this data on behalf of Google.
You can also configure Your browser to refuse cookies, or You can prevent Google from collecting and analyzing the data by downloading and installing a browser plug-in (https://tools.google.com/dlpage/gaoptout?hl=en) from Google. As an alternative to the browser add-on or within browsers on mobile devices, You can set an opt-out cookie to prevent future collection by Google Analytics within this website (the opt-out only works in the browser and only for this domain). If You delete Your cookies in this browser, You must click this link again.
As a safeguard to protect Your privacy, We use the anonymization feature offered by Google as mentioned above, whereas analytics are not based on You as a person, but only on a statistical basis. In addition, the high security standards of the Google platform and its data privacy policy apply (http://www.google.com/intl/de-DE/privacy). We have also concluded a special data protection agreement with Google, which ensures to protect Your data through technical and organizational security measures. Since Google is based in the USA and thus in a third country, further safeguards are required to ensure that Your data is protected in accordance with a European level of data protection. Google has been certified under the EU-US Privacy Shield and has thus demonstrated a sufficient level of data protection (https://www.google.de/policies/privacy/frameworks/). The purpose of the use of Google Analytics is to (anonymously) analyze usage behavior of Our websites. The information collected helps Us to improve Our websites and games. The legal basis is the legitimate interest in accordance with the European data protection requirements under Art. 6(1)(f) GDPR, which We evaluated together with Our data protection officer. In addition, a data processing agreement was concluded in accordance with the requirements of Art. 28 GDPR.
For more information on how to limit the types of cookies You allow, please see Opting out of Cookie Tracking section.
C. Information About You That You Share with Us Directly
When You use Our Services (whether via a social network or Our applications), You may give Us information directly (like when You’re setting up Your account) and We will store that on Our systems and use it for the purposes described in this Privacy Policy. These may include:
We may also let You create a User profile inside Our games, different from Your social network site profile (for example, Your Facebook profile), that other Wooga Users can see. Your User profile may include information like:
D. Information You Generate Using Our Communications Features
You may be able to take part in certain activities on Our Services that let You communicate or share information not just with Wooga, but also with other Wooga Users. These include:
We may access in real-time, record and/or store archives of these communications, comments, photos and drawings on Wooga's servers to make use of them to protect the safety and well-being of Our Users and Wooga’s rights and property in connection with Our Services; to conduct research; to operate, improve, personalize and optimize Our Services and Our Users’ experiences, including through the use of analytics; and to manage and deliver contextual advertising.
E. Payment Information
Wooga does not collect or store Your financial information, like credit card numbers.
F. Clubs, Message Boards and Chats
You may be able to take part in certain activities in Our Services that give You the opportunity to communicate or share information not just with Wooga, but also with other Users of Our Service. Note that information You post and communicate through a Service or a third-party site or service is public information for which You have no expectation of privacy.
You may choose to disclose information about Yourself in the course of contributing user-generated content to Wooga sites or Services or in its clubs, chats, blogs, message boards, User “profiles” for public view or in similar forums on its sites through mobile services and/or through third-party sites or services, posting public comments to other Users' profiles or gameboards, sending private messages or invitations to other Users, either directly on Our websites or to their e-mail accounts and posting photos. Information that You disclose in any of these forums is public information, and there is no expectation of privacy or confidentiality.
You should be aware that any Personal Information You submit in the course of these activities can be read, collected or used by other users of these forums, and could be used to send You unsolicited messages. Wooga is not responsible for the Personal Information You choose to make public in any of these forums. We may also record and store archives of these communications on Wooga's servers to protect the safety and wellbeing of Our Users and Wooga's rights and property in connection with the Service. You acknowledge and consent to the recording and storage of such communications for these purposes.
If You post a video, image or photo through a Service for public view, You should be aware that these may be viewed, collected, copied and/or used by other Users even without Your consent. Wooga is not responsible for the videos, images or photos that You choose to post through a Service. Please see Wooga’s Terms of Service on this point and for other guidelines about posting content through any Service.
G. Customer Support Correspondence
Except as provided herein, when You ask for help from Our customer care team, We will collect and store the contact information You give them (e.g. Your e-mail address), information about Your game play or activity on Our Services, and Your Wooga User and/or social network game-specific ID number. We will also store the communications You have with the Customer Service team and any information in those communications in order to provide support and improve the Services. Should We detect that a User is younger than 13 years (or than 16, depending on the country You are from), We will use Your contact information for the sole purpose of providing a one-time response to Your question. We will then delete or pseudonymize Your information (based on Our retention policy) from Our servers.
3. How We Use the Information We Collect and With Whom We Share It
A. How We Use Your Information
The main use of the information We collect and store is to provide Our Services and a better gaming experience, but there are other uses as well. The uses for which We collect and store Your information may include:
B. How We Share Your Information
We may disclose or publish aggregated and analytical information (information about You and other Users collectively that is not intended to specifically identify You, for example, Users between the ages of 25 and 30 who live Chicago) and other non-Personal Information about Our Users for industry analysis, demographic profiling, marketing, analytics, advertising and other business purposes.
In addition, We may share Your information (which may include Personal Information) with third parties (in other words, parties other than Wooga) or allow third parties to collect this information from Our Services in the following circumstances:
B(1) Friends and Other Wooga Users
In most Wooga games, if You play through a social network or register through a social network (like Facebook), Your social network friends will see Your social network profile name, profile photo and Your game activity. Correspondingly, in many Wooga games, other Users, regardless of whether they are Your social network friends or not, will be able to see descriptions of Your game activity (including the identification of any Wooga games You have played), communicate with You within Our Services, and view Your game profile, which may include Your social network name or a chosen game profile name and Your profile photo. Other Users may also be able to send You game requests or even friend requests through the related social networks or Wooga’s communication channels.
B(2) Third-Party Advertising Including Tailored Advertising and Analytics
We may include advertising in Our Services which help Us to continue to offer many of Our Services for free. We may also show Our own ads outside of Our Services for Our own marketing activities.
When We, advertisers, publishers or ad networks place ads in and outside of Our Services, they may collect, or We may share the following types of information from within Our Services through ad identifiers, cookies or other technical means:
The information collected may be used to:
We recommend that You also review Our advertising partners’ privacy policies for more information. A list of Our advertising partners and their privacy policies can be found here.
Please note, after clicking on a third-party advertisement, You may no longer be on a Service provided by Wooga or the social network through which You are playing Wooga’s games.
Receiving personalized in-application advertisements from third parties is subject to Your consent. If You consent, You can always opt out from these in the game’s settings or follow the steps explained below.
B(3) Third-Party Service Providers
Wooga uses third-party companies to perform its services, like analyzing data, optimizing game play, e-mail delivery, hosting services, managing and delivering contextual and tailored advertisements, etc.. We contractually require these third-party service providers to maintain the confidentiality of the information We share with them, and We contractually require them to not use Your Personal Information for anything other than to provide services on Our behalf.
B(4) Sale or Merger
In the event that Wooga undergoes a business transition (including proposed transactions), like a merger, acquisition by another company, or sale of all or part of its assets (like selling a game), We may disclose or transfer all of Your information, including Personal Information, to the successor organization in the transition while always considering Your individual interests. We will make reasonable efforts to let You and other Users know (in the way described in Changes to Our Privacy Policy) of the business transition before transferring Your Personal Information.
4. How to Access, Update and Manage Your Information and Means of Communication
A. Accessing and Updating Your Information Held by Wooga
If You want to review, delete or change the Personal Information Wooga has about You or have additional questions, You can submit a request to privacy@wooga.net or through the support section inside the game You play.
B. Deletion of Your Personal Information
If You no longer want Wooga to make active use of Your Personal Information, You can submit a request for deletion of Your personally identifiable information to privacy@wooga.net or through the customer care section inside the game You play.
Following such request, We are required to authenticate Your identity and ask for Your confirmation.
We will respond to Your request within thirty days of Your verification. Please note that certain records, in some cases will be maintained in Wooga archived databases in order to:
If You have sent content through or posted content on the Service, We may not be able to delete it.
C. Manage Information We Get From Third Parties
To manage the information Wooga receives about You from a third-party platform where You play Our games, like Facebook, Apple, Google, Amazon etc. You will need to follow the instructions for each such third-party application for updating Your information and changing Your privacy settings. Once Wooga receives Your information from a third-party application or Your mobile device, that information is stored and used by Wooga in accordance with this Privacy Policy.
D. Opting out of Promotional Emails From Wooga
If You want to stop receiving promotional e-mails from Wooga, click on the "Unsubscribe" link in any promotional e-mail from Wooga or submit such request to privacy@wooga.net. Please note that once We receive Your request, it may take a few days to process Your opt-out.
E. Opting out From FB messages
If You want to stop receiving messages through Our game pages, You may click on the “Settings” icon on the top of such message, and by clicking ”manage messages” You may turn off all messages from such game.
F. Opting out of Push Notifications
When You install Our apps on Your mobile device You can choose to receive push notifications, which are messages an app sends You on Your mobile device even when the app is not opened. You can turn off notifications by visiting Your mobile device’s “Settings” page.
G. Opting out of Personalized Advertising
In some games (that serve third-party ads) We have a toggle button allowing You to disable personalized ads.
If You are interested in more information about tailored advertising and Your choices to prevent third parties from delivering tailored web and mobile web advertising You may visit the following websites:
Network Advertising Initiative Consumer Opt-Out Page or the Digital Advertising Alliance Opt-Out Page for U.S.-based advertising;
Your Online Choices UK website for EU-based advertising.
These opt-out tools are provided by third parties, not Wooga. Wooga does not control, operate or endorse these tools or the choices that advertisers and others provide through these tools. They are listed here only as a convenience for Users.
In addition, if You do not want to receive tailored in-application advertisements from third parties that relate to Your interests in apps on Your mobile device, You may opt out by adjusting the ad tracking settings on Your device. You can also reset the “Advertising Identifier” (like an IDFA, GAID/AAID) from Your mobile device’s “Settings” page, which will prevent continued use of existing behavioral data tied to the previous “Advertising Identifier.” Further, depending on the platform provider (such as Apple or Google), You may be able to download apps, such as the Digital Advertising Alliance’s “AppChoices” app, that offer to provide You with control regarding the collection and use of cross-app data for personalized advertising. Like the opt-out tools mentioned above for web, these mobile opt-out tools are provided by third parties, not Wooga. Wooga does not control, operate or endorse these tools or the choices that advertisers and others provide through these tools.
Please note that You may still receive advertisements from third parties within Wooga’s games even if You opt out of personalized advertising, but they will not be based on Your activity across unrelated web sites or apps.
H. Opting out of Cookie Tracking
You can set Your web browser to warn You about attempts to place cookies on Your computer or limit the type of cookies You allow. Flash cookies operate differently than browser cookies and cookie management tools available in a web browser may not remove flash cookies. To learn more about and manage flash cookies You can visit the Adobe website and make changes at the Global Privacy Settings Panel.
I. Users From California
Please review Our California Privacy Notice, available here.
Note that Wooga does not currently respond to Do Not Track signals, whether that signal is received on a computer or on a mobile device.
5. Children Policy
Unless written otherwise, Our games are intended for use by those 18 or older for amusement purposes only. Without derogating from the foregoing, Wooga does not knowingly collect Personal Information from minors under the age of 13 years (or under 16, depending on the country You are from). If Wooga learns that a person who is under the age of 13 years (or under 16, depending on the country the User is from) has provided Us with Personal Information, Wooga will take reasonable steps to delete such information as soon as possible.
Since Our Services are designed for Users who are at least 18 years of age, Our Services generally do not knowingly collect or make use of "Personal Information" as defined in the Children’s Online Privacy Protection Act ("COPPA") from children under 13, except as consistent with applicable law.
We do not knowingly allow children under the age of 13 years (or under 16, depending on the country You are from) to set up an account or otherwise provide any Personal Information to Us, and We do not knowingly collect or use Personal Information from children under 13 years (or under 16, depending on the country You are from) for targeted advertising purposes.
If We learn that We have inadvertently gathered Personal Data that is not subject to a COPPA exception from a child, We will take reasonable measures promptly to remove that information from Our records.
Wooga respects the privacy of parents and children and is committed to complying with COPPA. If a parent believes that their child has submitted Personal Information to Wooga, they can contact Us via e-mail at privacy@wooga.net. We will take steps to promptly delete the information upon learning that it relates to a child under the age of 13 years (or under 16, depending on the country You are from). We recognize the importance of safeguarding the privacy of children and encourage parents to check and monitor their children's use of online activities regularly.
6. How We Protect the Information We Store and Share About You
A. Security of Your Information
Wooga has undertaken reasonable technical and organizational measures designed to secure Your information both online and offline from accidental loss and from unauthorized access, use, alteration or disclosure, and We are committed to the protection of customer information. We will take reasonable steps to ensure that Your data is treated securely and in accordance with this Privacy Policy.
While We take reasonable precautions against possible security breaches of Our Services and Our customer databases and records, no Website or Internet transmission is completely secure, and Wooga cannot guarantee that unauthorized access, hacking, data loss or other breaches will never occur and that third parties will never be able to overcome those measures or use Your Personal Information for improper purposes.
Also please note that e-mail and messaging systems are not considered secure, so Wooga discourages You from sending Wooga Personal Information through these media. If You access Our Services through a social network and Your social network account is hacked, this may lead to unauthorized play of Your Wooga games without Your permission. So, be careful to keep Your account information secure.
Although We strive to protect Your personal data, We cannot guarantee the security of Your data while it is being transmitted to Our site; any transmission is at Your own risk. Once We have received Your information, We have procedures and security features in place to try to prevent unauthorized access. If You have questions about the security of Our Websites, please submit a ticket to Our customer care team.
B. Safety, Security and Compliance with Law
Your information, and the contents of all of Your online communications in Our Services and between You and Wooga may be accessed and monitored as needed to provide Our Service and may be disclosed:
C. International Operations and Transfers Out of the EEA
When You use Our Services, Your personal data may be sent outside of the European Countries, for example, to the United States, Israel and possibly other countries. When We transfer, store, and use personal data collected in the EEA outside of the EEA, We comply with Our legal obligations and ensure that Your personal data is subject to suitable safeguards (such as encrypting communication) or transferred to “approved” territories.
As a global company, We may transfer Your personal data to affiliated entities located in European Countries and outside like United States and Israel.
When We transfer Your personal data internationally, We will ensure that there is an adequate level of protection, or the transfer is supported by the European Commission’s standard contractual clauses for the transfer of personal data to a country outside the European Countries. These standard contractual clauses are available here.
When We transfer personal data to Our parent company (Playtika), which is based in Israel, We rely on data transfer agreements and the adequacy decisions by the European Commission. The European Commission has determined that Israel has an adequate level of data protection similar to the one in the European Union.
D. How Long We Keep Your Information
We will only retain Your Personal Information for as long as necessary to fulfill the purposes for which it was collected, or as necessary to comply with Our business requirements and applicable laws; to comply with any legal, accounting or reporting obligations; to resolve disputes; to protect Our assets; to efficiently run Our business; and to enforce Our agreements.
To determine the appropriate retention period for Personal Information, We consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of Your Personal Information, the purposes for which We collect or process Your Personal Information and whether We can achieve reasonably those purposes through other means, and the applicable legal requirements.
We may retain some information for a few years after You have stopped playing Wooga games if this is necessary to meet Our legal obligations or to exercise, defend or establish legal rights.
7. Your Rights
You can contact Us at any time if You have any questions about Your rights regarding data protection or if You wish to exercise any of the following rights:
Right to withdraw Your consent in accordance with Art. 7(3) GDPR (e.g. You can contact Us if You wish to cancel a previously given consent to a newsletter)
Right to access Your data in accordance with Art. 15 GDPR (e.g. You can contact Us if You would like to know what data We have stored about You)
Right to correct Your data in accordance with Art. 16 GDPR (e.g. You can contact Us if Your e-mail address has changed and We should replace Your old e-mail address)
Right to have Your data deleted in accordance with Art. 17 GDPR (e.g. You can contact Us if You want Us to delete certain data that We have stored about You)
Right to limit data collection in accordance with Art. 18 GDPR (e.g. You can contact Us if You do not want Us to use Your e-mail address for newsletters, but only to send absolutely necessary e-mails)
Right to take Your data with You in accordance with Art. 20 GDPR (e.g. You can contact Us to receive Your data, if You want to upload it to another website)
Right to object how Your data is handled in accordance with Art. 21 GDPR (e.g. You can contact Us if You do not agree with any User analytics procedures as described within this Privacy Policy)
Right to send complaints to the supervisory authority in accordance with Art. 77 para. 1 GDPR (e.g. You can contact the data protection supervisory authority directly)
For exercising Your Privacy rights or any other questions, comments or concerns about Our Privacy Policy or any other issue You can contact Us via Our customer care section inside Our games.
You can also get in touch with Our Data Protection Officer via privacy@wooga.net
8. Changes to Our Privacy Policy
If We decide to make material changes to Our Privacy Policy, We will tell You and other Users by placing a notice on www.wooga.com or its equivalent in-game or other appropriate channels prior to the change becoming effective. We recommend checking www.wooga.com and this privacy page for updates every now and then.
Annex 1
Categories of Data We Collect pursuant to the California Consumer Privacy Act (CCPA)
1. Identifiers such as a picture, real name, in-game alias/account name, unique personal identifier, online identifier, Internet Protocol address, e-mail address.
a. Categories of sources from which the information is collected: from You directly and from third-party online services such as Facebook.
b. The categories of third parties with whom We share the Personal Information: Your social network friends and other Wooga Users, advertising networks, and successor organization in the transition of Wooga’s sale or merger.
2. Commercial information, including products or services purchased, obtained or considered from us.
a. Categories of sources from which the information is collected: from You directly and from third-party online services such as Facebook.
b. The categories of third parties with whom We share the Personal Information: Wooga affiliates, and successor organization in the transition of Wooga’s sale or merger.
3. Internet or other electronic network activity information, including, but not limited to, browsing history, search history and information regarding a consumer’s interaction with an Internet Web site, application or advertisement.
a. Categories of sources from which the information is collected: from You directly when You use a computer or smartphone to access Our Services, and from third-party online services such as Facebook.
b. The categories of third parties with whom We share the Personal Information: Wooga affiliates, advertising networks, and successor organization in the transition of Wooga’s sale or merger.
4. Geolocation data.
a. Categories of sources from which the information is collected: from You directly through when You use a computer or smartphone to access Our Services.
b. The categories of third parties with whom We share the Personal Information: Wooga affiliates, advertising networks, and successor organization in the transition of Wooga’s sale or merger.
5. Inferences drawn from any of the information above, to create a profile about You reflecting Your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
a. Categories of sources from which the information is collected: data analysis of the Personal Information mentioned previously.
b. The categories of third parties with whom We share Personal Information: Wooga affiliates, advertising networks, and successor organization in the transition of Wooga’s sale or merger.
The business or commercial purpose for which We collect all of the above categories of information:
1. Auditing related to a current interaction with the User;
2. Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
3. Debugging to identify and repair errors that impair existing intended functionality;
4. Undertaking internal research for technological development and demonstration;
5. The commercial purposes indicated in Section 3(A) above (“How We Use Your Information”).