Effective date: September 07, 2018
WELCOME TO COMET STUDIO! THIS WEBSITE IS OWNED BY COMET STUDIO. AT COMET STUDIO, WE TAKE YOUR PRIVACY SERIOUSLY AND WE ARE COMPLIANT WITH THE EU GENERAL DATA PROTECTION REGULATION (GDPR)’S PRIVACY NOTICE.
Please read this Policy carefully and contact us with any questions or concerns about your privacy matters.
B. WHO WE ARE?
COMET Studio, hereafter known as "COMET Studio,” “COMET," "we," "us," “we’re,” “we've, or “our”) is a online source that offers fun and exciting games. Our data protection officer is Christian Seebach. He can be contacted at email@example.com.
C. WHAT INFORMATION DO WE COLLECT?
The following are the types of information we may collect.
1. Information You Provide Us
Personal information that you provide to us, such as your name, email address, telephone number, physical address, birth date, gender, zip code, financial information, payment information, and content you submit or make available through the social media platform (e.g., Facebook, Twitter, Instagram etc, collectively, “Third Party Platform”) used to access our website or apps, or other information that can be collected via the website or apps. Accordingly, if an in-app purchase is made, we may also collect your payment information (e.g., credit card information, billing name and address).
2. Website and App Usage Information
We may receive and store certain types of information whenever you visit and download our games at our website or at either the iOS App Store and Google Play Store, or when you make an in-app purchase. For example, we may collect click-stream data, your IP address and information shared on these third party platforms.
3. Email Communications
When you open emails from the website, we may receive a confirmation noting you opened an email from us, if your computer supports such capabilities. We also may keep track of what emails we send you and what emails you may be receiving from us and our subsidiaries and affiliates. Additionally, we keep a record of what types of emails you have opted to and not to receive.
4. Information from Other Sources
We may receive information about you from other sources, including without limitation, third party platforms, and add it to your personal information. These platforms are for remarketing purposes and may include:
- Google Analytics
- Pinterest, other social platforms and marketing tools
If you choose to log into our services through Facebook Connect, we will request your permission to collect the following information about you: your e-mail address, name, profile picture, cover photo, friends, gender, networks (e.g., school), age range, language, country, and other information that you have chosen to make public. We may append this information to other information that we collect about you. If you “like” us on Facebook, we also may collect your email address.
D. HOW DO WE USE YOUR PERSONAL INFORMATION?
We use the information that we collect from and about you, including your personal and financial information, for the following purposes:
- Providing Our Services.To provide our services to you; for order fulfillment purposes; to communicate with you, including via email, about your use of our services; to respond to your inquires; and for other customer service purposes.
- Marketing/Advertising.To provide you with news and newsletters, special offers, and promotions, including via email; to contact you about products or information we think may interest you; and for other marketing, advertising, and promotional purposes.
- Analyzing Use of Our Services.To better understand how users access and use our Website and services, both on an aggregated and individualized basis; to respond to user desires and preferences; and for other research and analytical purposes.
- Posting to your Wall.If you log in through Facebook Connect or “like” us, we may post to your wall.
- Complying with the Law.To comply with applicable legal obligations.
- Protecting Our Rights and Interests.We may use your information to protect our rights and interests and the rights and interests of other users of our website and apps, as well as to enforce this Policy.
- provide you access to the COMET Studio website and apps
- inform you about relevant products or services from COMET Studio, or carefully selected third parties. You may stop receiving these at any time by contacting us;
- personalization of content, personal information or user experience
- account set up and administration
- delivering marketing and events communication
- carrying out polls and surveys
- internal research and development purpose
- providing goods and services
- legal obligations (eg prevention of fraud)
- meeting internal audit requirements
- contact you about the website;
- contact you relating to your status;
- confirm or fulfill an order you may have made;
- monitor or improve the use of the website;
- customize the advertising and content you see;
- monitor compliance with our terms and conditions of use of the website;
- send you promotional material on behalf of our business partners;
E. WHAT LEGAL BASIS DO WE HAVE FOR PROCESSING YOUR PERSONAL DATA?
Pursuant to the GDPR, COMET Studio has two relevant processing conditions as the legal basis to process your personal data. This includes:
You, as the Customer, acknowledge that by purchasing a in-app product or downloading one of our games, you consent to COMET Studio to allow us to retrieve your personal and financial information.
Per the purchase agreement between you, the Customer, and COMET Studio, you contractually agree to allow COMET Studio to retrieve and have access to your personal and financial information.
F. WHEN DO WE SHARE PERSONAL DATA?
We will treat all of your personal data confidentially and will only disclose your information under the following circumstances:
- Affiliates.To our parent company, affiliates, or subsidiaries for research and marketing, including marketing our product as well as their own products and services, and other purposes consistent with this Policy.
- Partners.From time to time, we may offer promotions with other entities, and we may share your contact information with the other entity for the purpose of the joint promotion.
- Service Providers.To companies that provide services to help us with our business activities such as shipping your order or offering customer service, performing website analytics, assisting us with marketing and advertising, evaluating the success of our marketing/advertising campaigns. For example, we may share information (such as the number of daily visitors to a particular web page, or the size of an order placed on a certain date) with advertising partners and other third parties to assist us in determining relevant advertising.
- Unaffiliated Third Parties.We also may share your information with non-affiliated third parties, including for their own marketing purposes (please see our Special Information for California Consumers section below with regard to such disclosures).
We also may share your information, including your personal information, for the following reasons:
- Business Transfers.If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the acquiring company.
- In Response to Legal Process.We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order or other legal process, such as in response to a subpoena.
- To Protect Us and Others.We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our Terms of Service or this Policy.
- Aggregate and Anonymized Information.We may share aggregate or anonymized information about users with third parties for marketing, advertising, research or similar purposes. For example, if we display advertisements on behalf of a third party, we may share aggregate, demographic information with that third party about the users to whom we displayed the advertisements.
G. HOW DO WE SECURE PERSONAL DATA?
We have taken steps to help protect the information we collect about you from loss, misuse, unauthorized access, disclosure, alteration, and destruction. No method of transmission over the Internet, or method of electronic storage, is 100% secure however. Therefore, we cannot guarantee its absolute security.
You should take steps to protect against unauthorized access to your Google or App Store account by, among other things, choosing a robust password that nobody else knows or can easily guess and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
H. HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?
Per the GDPR, we retain our data for no longer than reasonably necessary and adhere to the local laws governed in Germany to determine how long to keep the data for. Once we determine that the data is no longer reasonably necessary, we securely dispose of data after we no longer need it by permanently deleting it from our data banks and files.
I. YOUR RIGHTS IN RELATION TO PERSONAL DATA
Pursuant to the GDPR, we respect your right as the Customer to access and control their personal data. Accordingly, we shall honor a Customer’s right in respect to:
- Access to personal information
- Correction and deletion
- Withdrawal of consent (if processing data on condition of consent)
- Data portability
- Restriction of processing and objection
- Lodging a complaint with the Information Commissioner’s Office
You, as the Customer, can exercise your rights by making a request for such information. However, such requests will not be honored in regards to a Customer asking for such personal data about another person, or if a Customer is asking to delete data whereby we are required to keep by law.
J. COOKIES AND OTHER TRACKING TECHNOLOGIES
- Session Cookies.Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. This allows us to process your online transactions and requests and verify your identity as you move through our Website.
- Persistent cookies.Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. This allows us to process your online transactions and requests and verify your identity as you move through our Website.
- Log Files. Like many websites, we automatically gather certain information about our website and store it in log files. This information includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual Users, to analyze trends, to administer the website, to track Users’ movements around the web website and to gather demographic information about our User base.
- We may use Google Anyalytics and Hotjar for tracking purposes for the Website, and Gameanalytics located at https://gameanalytics.com, for our apps analysis.
- We do not link this automatically collected data to your personally identifiable information.
K. DO NOT TRACK
Our Site does not respond to Do Not Track signals and we (either directly or through third party service providers) may track your activities once you leave our Website. You may disable certain tracking as discussed in this Policy (e.g., by disabling cookies).
L. HOW TO CONTACT US?
If you have questions or concerns about your privacy practices, your personal information, or if you wish to file a complaint, you can contact us at firstname.lastname@example.org