Last updated: May 22, 2018
If you are based in Europe for the purposes of Europe’s General Data Protection Regulation (GDPR), the Controller of your personal information is Cloud Games BV (hereinafter referred to as “Cloud Games”, “we”, “us” or “our”), having its office at Stationsplein 116, 2011 LN, Haarlem, The Netherlands. It’s important to note that we are not always considered the Controller of your information, but sometimes act as a Processor of data on behalf of our customers and partners. In those cases, we do everything in our power to make sure that our customers and partners are GDPR-compliant Controllers as well.
Information we collect and how we use it
It’s important to understand that Cloud Games offers a variety of services that handle personal information differently.
Game development and distribution
One line of services consists of creating games and distributing these to trusted, third party publishers. Sometimes, this means that we actually host and serve these games from our servers, and sometimes this means that third party publishers have total control over the games that we develop. Usually, our games contain advertisements served by AdSense, Tunnl and Superawesome. Either way, after explicitly asking our users for consent, in both scenarios we collect and store personally non-identifiable information for purposes of analyzing game usage and user demographics, by using Google Analytics in a GDPR-compliant manner. In case of the third party publisher having total control over games we’ve developed, we do our best to make sure that the third party also complies with these same GDPR regulations.
Cloud Games requires you to give consent before playing our games, without giving consent our games don’t work.
The other line of services consists of facilitating mobile advertising campaigns for our game developer and advertising network customers, which means that Cloud Games bids actual money on advertising positions within games in order to serve ads to end users. Sometimes we simply facilitate the technical parts of bidding on advertising positions to serve ads to end users, and sometimes we automatically make decisions whether to bid on advertising positions or not, based on data. In all cases, we target iOS and Android devices only.
In order to serve relevant advertisements to end users, we collect, store and aggregate personal data such as advertising ID, IP address, browser type, network carrier, operating system, country and geo location. We collect this data for the sole purpose of targeting segments of users to serve relevant advertisements. We do not attempt to identify individual people, but we do attempt to identify unique device advertisement identifiers (ID) so that we can optimize our advertising bidding process. These unique identifiers are can be reset in the general settings menu of your Android and iOS devices, or disabled all together by following your phone operating system’s default way of doing this. If you need help with this, feel free to reach out to email@example.com. Once you reset your advertising ID, we won’t be able to identify you or your device in any way after that. If you want us to actually delete all your advertising ID-based data, please share your advertising ID with us before resetting it. We can’t delete your data if you don’t provide this identifier, because we’ll simply not be able to identify you.
Providing your data is not mandatory, and disabling your advertising ID on iOS or Android will not lead to Cloud Games blocking any service for you. However, it’s up to the actual apps that you use to device whether they provide the same app experience to you or not. We don’t influence this decision in any way.
This personal information is sent to us via our advertising infrastructure partner, who in turn gets the data from advertising platforms like AdX and Mopub, which in turn get their data from iOS and Android apps that serve ads. These apps, which is where data originates from, follow iTunes Store and Google Play store terms and conditions, which also provide GDPR provisions to protect your privacy.
Sharing personal information
Cloud Games does not share personally identifiable data with any third parties. We do, however, share personally non-identifiable information such as usage data, campaign results and demographics with our customers, so that they know how games or ads are performing.
Storage and processing
All our data infrastructure is hosted on Amazon Web Services (AWS) in both Europe and the United States. This means that your personal data may be stored on servers in the United States. Since advertising networks may be hosted anywhere around the world, it’s possible that your personal data was originally transferred anywhere around the world before getting to Cloud Games, which is something the app developers, app stores and advertising networks are responsible for. We do not directly transfer your personally identifiable information to any country that doesn’t provide the legal provisions necessary to protect your data and privacy.
How we protect your data
Your personally identifiable data is only directly transferred from our infrastructure partner’s AWS infrastructure to our own AWS infrastructure using secured connections and industry standard security practices. All other data is collected using third party services that use secure connections to prevent malicious users from intercepting that data. For technical reasons, we (and most other companies) cannot guarantee absolute security of your data, so feel free to reach out to firstname.lastname@example.org if you have any questions or concerns regarding the protection of your data.
We retain data indefinitely for the purpose of optimizing our advertisement bidding process, but anonymize all data after a period of 12 months.
As you can read in this great article, as an individual, you have a variety of rights that we intend to fully respect:
- The right of rectification – you have the right to have your personal data rectified if it is inaccurate or incomplete. You can contact us if you feel like we need to rectify anything.
- The right to erasure – you may contact us with your iOS or Android advertising identifier as described above and we’ll delete all data we have on you. Be aware that we do not save names, email addresses, payment information or other contact information.
- The right to restrict processing – as described above, you can reject consent on our games, and you can disable advertising identifiers on your iOS and Android devices to prevent data to be stored for advertising purposes.
- The right to data portability – you may contact us to get a copy of data that we have on your device. You’ll have to provide your advertising identifier because we’re otherwise not able to identify you.
- The right to object – we don’t believe this is relevant to our services, but feel free to contact us if you object against any of our practices and we’ll take your objection very seriously.
- Rights of automated decision making and profiling – Cloud Games does automatically make decisions based on data, for the purpose of serving interesting advertisements within third party apps that you use. More information can be found above.
The best way to contact us is by sending an email to email@example.com or going to the contact page on our website.