Your privacy is important to us. We strive to ensure that our use of your personal information or personal data is lawful, reasonable and relevant to our business activities with the ultimate goal of improving our services and your experience.
2. Application of this policy
3. What is personal information?
Personal information refers to information about an identifiable person such as your name and surname, gender, age, date of birth, contact details (phone number and email) and address, physical location, ID number and your image.
Other information which might be “personal” information could include:
- Device and device event information: IP address, unique device identifier, the nature of the device you used to access our site, the geographic location of your device, hardware model and settings, operating system details, browser type and version, browser language, system activity and crashes;
- Log information: This includes details of how, when and for how long you accessed and used our site and other site traffic and use information, landing pages, which pages you accessed and viewed, the amount of time spent and what you did on those pages, details about the games you played, how you interacted with other site users, and exit pages;
- Location information: We might use various technologies to determine your actual location such as geographical data from your device (which is usually based on the GPS or IP location); and
- Unique application numbers: Certain services include a unique application number. This number and information about your installation (for example, the operating system type and application version number) could be sent to us when you install or uninstall such a service or when that service periodically contacts our servers, such as for automatic updates.
4. How we collect your personal information
We collect your personal information using four methods:
- Actively from you;
- Passively from your device when you use our site;
- Passively from social networking sites (subject to your privacy settings); and
- Passively from third-party service providers.
5. Active collection of personal information
Some areas of our site might require you to submit specific information for you to register for certain services or to benefit from specified features such as when you register on our platforms, ask to receive any newsletters or similar subscriptions or tips/pointers or participate in a particular activity (collectively referred to as the “value-added services”). If you contact us, we may keep a record of that correspondence.
Our site may also collect personal information from you by asking you specific questions and by permitting you to communicate directly with us, for example, via email, feedback forms, site comments and forums.
In these situations, we will:
- Ask you for particular information;
- Inform you at each information point what information is required and what information is optional; and
- Indicate the consequences if you don't give us the relevant information. (You will generally need to provide us with the relevant information to take full advantage of our platform features.)
The information we might actively collect from you could include your:
- Identifying information (e.g. your name, surname, gender, date of birth, profile picture and physical location);
- Contact details (e.g. email address and phone number); and
- Other information which we might request from you from time to time.
6. Passive collection of personal information from your device
We passively collect some of your personal information from the device you use to access and navigate through our site using various technological means.
One of the key ways in which we collect information passively is by using server logs to manage and maintain log information.
7. Why we collect your personal information and how we use it
We use the information we collect to provide, maintain and improve our services, to develop new ones and to protect us, our services and our users. We constantly strive to improve our user experience, so we also use the information we collect to offer you information and content, which is more appropriately tailored for you.
We may collect and use your personal information to:
- Establish and verify your identity;
- Maintain and update our databases;
- Communicate with you in various ways (determined by you in your privacy settings) such as email, post, telephonically, SMS notifications, instant messaging or other notifications to your device (e.g. on-screen pop-up messages);
- Request feedback on our site, products and servers, address any issues and liaise with users in that regard;
- Keep a record of our communications with you and your communications with us;
- Fulfil any contractual obligations we might have to you or any third party;
- Provide you with value-added services;
- Improve the content of our site, products and services;
- Allow you to participate in any interactive features and share features that might be active on our site;
- Improve your user experience and the overall quality of our services;
- Customise our site to your preferences and tailor information and content for you to ensure that it is presented in the most effective manner for you and your device;
- Inform you of facts relating to your access to and use of our site;
- Inform you about our products and services which we think might interest you (as long as you have consented to this);
- Inform you about competitions, promotions and special offers from us (as long as you have consented to this);
- Carry out marketing, product research and development;
- Tailor general advertising on our platforms more appropriately for particular user groups;
- Compile and use statistical information about you, other users and their access to and use of our site, browsing habits, click patterns, preferences, demographics, etc. which we might use to develop, provide and improve our platforms, products and services, including recommendations to users and tailoring information and content for users;
- Compile, use, disclose and trade with non-personal statistical information about our users and their access to and use of our site, browsing habits, click patterns, preferences, demographics etc. which we and our advertisers may use to develop, provide and improve our platforms, products and services, including targeted advertising to user groups. Please note that the information referred to in this paragraph is aggregate information about our users which has de-identified users' personal information so that it cannot be linked back to identify you. We will not disclose your identifiable personal information to anyone without your express permission;
- Diagnose and deal with technical issues and customer support queries and other user queries such as problems with our server, determine the optimal and fastest route for your device to use in connecting with our site and administer, maintain and secure our platforms;
- Comply with the law or with any legal process; and
- Other activities not specifically mentioned which are lawful, reasonable, relevant to our business activities and which are the minimum necessary and adequate for us to provide our platforms, our products and services.
We will get your permission before collecting or using your personal information for any other purpose.
8. Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
- Right of access – you have the right to request a copy of the information we hold about you. Access to this information might be subject to an administrative fee if your request is manifestly unfounded, excessive or repetitive.
- Right of accuracy – you have a right to insist that we correct data we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances, you can ask for the data we hold about you to be erased from our records. Access to this information might be subject to an administrative fee if your request is manifestly unfounded, excessive or repetitive.
- Right to restriction of processing – where certain conditions apply, you have a right to restrict the processing of your data.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation or provided to you in a machine-readable format.
- Right to object – you have the right to object or remove your consent for certain types of processing such as direct marketing.
- Right to object to automated processing, including automated profiling, unless such profiling is necessary to conclude a contract or the performance required by a contract between you and us – and we apply suitable measures to safeguard your personal information.
- Right to complain if you have cause to be concerned about the way we capture, treat or process your personal information.
To verify your identity if you request a copy of your data or information about your data, we might ask for a copy of your passport, driving licence, national identity card or birth certificate.
9. Retention of your personal information
We retain all personal information which we collect from you (except for the information referred to below) unless there is a valid technical, legal or business reason for us to delete, destroy or de-identify it (“retained information”).
10. Disclosure of your personal information
We may disclose or share your personal information to or with:
- Our affiliates;
- Our employees, contractors and agents if and to the extent that they need to know that information to process it for us and to provide services for or to us such as site hosting, development and administration, technical support, financial services such as processing of payments, delivery services, marketing services (only in respect of our site, products and services) and other support services;
- To protect our rights, property or safety or that of our customers, employees, contractors, agents and any other third party;
- To mitigate any actual or reasonably perceived risk to us, our customers, employees, contractors, agents or any other third party;
- Any third party that acquires (or proposes to acquire) ownership or control of our assets, shares or management, or that of our affiliates, and our site, whether by sale, merger, acquisition or otherwise, and to any third party from whom we acquire (or propose to acquire) ownership or control of assets, shares or management, either by purchase, merger, acquisition or otherwise;
- Government agencies, exchanges and other regulatory or self-regulatory bodies if we are required to do so by law or if we reasonably believe that such action is necessary to comply with the law or with any legal process;
- Protect and defend our rights, property or safety, and that of our affiliates, customers, employees, contractors and agents or any third party;
- Protect the rights, property or safety of members of the public (if you provide false or deceptive information about yourself or misrepresent yourself as being someone else, we may proactively disclose such information to the appropriate regulatory bodies and/or commercial entities).
We may use your personal information to compile profiles for statistical purposes and may freely trade with such profiles and statistical data, provided that the profiles or statistical data cannot be linked back to you by a third party.
We will get your permission before disclosing your personal information to any third party for any other purpose.
11. Direct marketing
When you register on our platforms, you can choose to receive marketing communications from us.
You may refuse to accept, require us to discontinue, or pre-emptively block any approach or communications from us if that approach or communications are primarily for the purpose of direct marketing (“direct marketing communications”).
You may opt out of receiving direct marketing communications from us:
- At the time of registering on our platforms by ticking the relevant “opt-out” box; and
- At any time by requesting us (in any manner, either telephonically, electronically, in writing or in person) to desist from initiating any direct marketing to you.
If you have opted out in accordance with the above, we will:
- Send you written (which might include electronic writing) confirmation of receipt of your opt-out request; and
- Not send you any further direct marketing communications.
You may (in terms of the Consumer Protection Act, 2008) register a pre-emptive block against direct marketing communications. If you do so, we will not send you direct marketing communications unless you have expressly consented to receive direct marketing communications from us.
We will not send you direct marketing communications at home at any period during which it is prohibited by law to do so unless you have expressly or implicitly requested or agreed otherwise.
All information you provide to us is stored on our secure servers or those of our trusted partner services.
We implement appropriate, generally accepted technical and organisational measures to protect your data against unauthorised or unlawful processing, accidental loss, destruction or damage, including encryption where appropriate.
Unfortunately, the transmission of information via the internet is not completely secure. We will do our best to protect your personal information, but we cannot guarantee 100% security of your data transmitted to our servers using the internet and any transmission is at your own risk.
We take reasonable technical and organisational measures to secure the integrity of the information we collect about you, using accepted technological standards to:
- Prevent unauthorised access to or disclosure of your personal information; and
- Protect your personal information from misuse, loss, alteration or destruction, in particular:
- From time to time, we review our information collection, storage and processing practices, including physical security measures, to keep up to date with best practice.
- We create a secure backup for operational and safety purposes.
13. Linking to third-party sites
We are not responsible for the privacy practices of a third-party site to which there might be a link on our site or to which you could log in from our site (e.g. integrated social networking services).
In certain instances, we might give you the option to manage some of your privacy settings on integrated social networking sites from our sites (e.g. to enable you to determine which of your personal information you would like to share via our site).
14. Changes to this policy
15. Queries and complaints
If you have a concern about the way we are handling your information, for example, if you feel we:
- Are unlawfully processing your personal information;
- Are not keeping your personal information secure;
Are misusing your personal information;
- Are keeping personal information about you for longer than is necessary;
- Hold inaccurate personal information about you;
- Have disclosed personal information about you;
- Have collected personal information for one reason and are using it for something else; or
- Have accessed your personal information without your authorisation.
If you want to complain about how we have processed your personal information, or how your complaint has been handled, please contact us with the following information by sending an email to email@example.com
- Full name of the person lodging the complaint
- Contact details such as email address and telephone number
- How the personal data was collected (if known)
- All necessary information
- The timeframe over which the suspected wrongdoing occurred (if known)
- Any evidence in support of the complaint
While we try to respond as promptly as possible, resolution times will vary depending on the nature of the complaint. You will be notified of the outcome of your complaint and of any action taken.
Abusive, persistent or vexatious correspondence and complaints
For lodging complaints, it is the complaint which must be vexatious and not the individual making the complaint.
While we differentiate between people who make numerous complaints because they think things have gone wrong and people who are simply being difficult, we do understand that sometimes complainants act in distress, and we will make reasonable allowance for that.
We may decide not to attend to the complaint based on one or more of the following reasons:
- Persisting in a complaint after being advised that there are insufficient or no grounds for your complaint or that we are not the appropriate body.
- Refusing to cooperate with the complaints process, without good reason, but still wanting your complaint to be resolved, including failure or refusal to specify the grounds of a complaint despite offers of assistance, changing the basis of the complaint as inquiries of a complaint despite offers of assistance, changing the basis of the complaint as inquiries are made and introducing trivial or irrelevant new information and expecting this to be taken into account and commented on.
- Submitting repeat complaints after the complaint procedure has been completed, essentially about the same issues, with additions/variations which the complainant then insists on being treated as new complaints and put through the full complaint procedure again.
- Refusing to accept the outcome of the procedure after its conclusion, repeatedly arguing the point, complaining about the outcome, and/or denying that an adequate response has been given.
We hope this notice has helped you to understand how and why we collect and process your personal data to enable you to use our site and our services.
If you are a customer of Koola Digital and would like to know more about how your personal data is being processed by us (or any of our third parties), please contact us on firstname.lastname@example.org. This email address is actively monitored and we endeavour to respond to all requests within 20 business days.
2. About cookies
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies might be "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you might be linked to the information stored in and obtained from cookies.
Authentication – we use them to identify you when you visit our online platform and as you navigate our online platform;
Status – we use them to help us determine if you are logged into our online platform;
Personalisation – we make use of them to store information about your preferences and to personalise our online platform for you;
Advertising – we make use of them to help us display advertisements that will be relevant to you;
The information which we may passively collect from your device might include your identifying information, contact details, device and device event information, site activity information, log information, telephony log information, location information and any other information which you permit us, from time to time, to passively collect from your device.
The names of these cookies change from time to time and sometimes from session to session. If you have a query about a specific cookie, please contact us with the name and value of the cookie so we can identify its purpose.
4. Managing cookies
Most browsers allow you to refuse to accept cookies and to delete them. The methods for doing so vary from browser to browser, and version to version. However, you can obtain up-to-date information about blocking and deleting cookies via these links:
For Google Chrome (https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=en)
For other browsers and operating systems (https://www.avast.com/c-enable-disable-cookies)
16. Contact us
Need more information or have a question? You can contact us by sending an email to email@example.com