Global Privacy Statement

Version May 2024

1. General information

Pokii is committed to protecting the privacy of everyone who uses our websites and applications. The Pokii websites and applications can be used all over the world. The privacy and data protection requirements vary per country. Regardless of where your personal data is processed, we believe it is important to provide the same high level of protection as described in this privacy statement, which now applies in all countries outside the EU and UK. This privacy statement – the “Global Privacy Statement”, or just in short “Privacy Statement” – is designed to provide transparency into Pokii’s privacy practices and principles. It provides information on the data that we collect from our website visitors through our pokii.games web platform, our Pokii for Developers platform, and other general audience sites and applications (hereafter referred to together as the “Pokii Website”).

The Pokii Website is dedicated to website visitors of 16 years and older (“Website Visitors”). If you are under the age of 16, this website is not meant for you. If you have any questions concerning this Privacy Statement, please contact us at privacy@pokii.games.

The Pokii Website is owned and operated by Pokii Gamess (referred to in this Privacy Statement as “Pokii", “we", “our", or “us").

*Please note that we determine from which region you visit our website based on your IP-address, thus if you use a VPN-connection, you may not be shown the Privacy Statement applicable to you.

2. Which data is used and for what purposes?

All features on the Pokii Website are available without the need for registration by Website Visitors. No contact details such as your name, email address and phone number are requested from or processed about Website Visitors, unless they actively contact us.

Nonetheless, Pokii does collect certain electronic data. We can process this data in various ways. Please find directly below some general information about our processing of your data and further below, you find an overview of various topics on which you can click for more detailed information about the processing of your data in a specific context.

General processing purposes

In general, we may always process your data for the following purposes:

▪️ For maintenance, administration and network and security purposes;
▪️ For internal control and business operations;
▪️ For analyzing and improving our products;
▪️ For handling any requests, complaints and disputes;
▪️ For determining, exercising and defending our rights; and
▪️ For complying with legal obligations (incl. fraud prevention) and requests of authorized governmental institutions.

General processing grounds

In general, we may process your data based on a legal obligation. This means that we will process your data for as far as we are legally obliged to do so, for instance to comply with statutory minimum retention periods.

Legitimate interest

Sometimes we indicate that we process your data based on the legal ground "legitimate interest". This means that a balance of interests is performed between the interests that are served by the processing on the one hand and your privacy interests on the other hand, and that the interests in favor of the processing prevail. The related legitimate interests are included below per topic. If you want more information about this, you can contact us directly via our contact details stated below.

Minors and other persons with a legal representative

The Pokii Website is not meant for persons younger than 16 years. We also do not focus on persons who are placed under a legal relationship, such as guardianship or persons who are supervised or administered by someone else. If, in exceptional cases, we could focus on such persons, Pokii will take into account the vulnerable position of these persons and take extra precautions.

i. The General Pokii Website
We process your data for providing, maintaining and improving the Pokii Website, our apps and for our social media activities. For more specific information on the cookies and similar technologies used in this respect, please refer to our Cookie Statement.

The persons involved. Our Website Visitors: people who visit the Pokii Website.

The purpose of the processing. When you visit the Pokii Website, your data may be processed for the following purposes:

Functioning of the Pokii Website (incl. remembering your settings and consent choices);
Advertising and marketing to you, targeted advertising, and presenting you with relevant advertisements;
Showing you the privacy information relevant to your region (which data we process exactly will depend on from which region you access the Pokii Website).

The data that is processed. When you visit the Pokii Website, we may process the following information about you which is collected automatically:

▪️ IP address;
▪️ Device ID;
▪️ Browser type ;
▪️ Global geographic location (e.g. location on national or city level);
▪️ Advertisements displayed to you and your interaction with these (e.g. whether you clicked on an advertisement or not);
▪️ Other technical information (e.g. regarding the interaction between your device and the Pokii Website, the web pages that were visited, the links clicked and the log data).

Sensitive information:

In the context of the Pokii Website we do not, in principle, process sensitive information such as information about your health. If we in certain cases would decide to process sensitive information, you will be separately informed about this processing and where necessary, we will request explicit consent.

Legal grounds for the processing. We base the use of your data in the context of the Pokii Website on one of the following legal grounds:

▪️ Consent. Based on local law requirements, we sometimes base the processing of your data on the (explicit) consent of the relevant person. Depending on the circumstances, consent may be expressed or implied from your actions and the context. In other situations, you can opt out of the processing of personal data. This is for example applicable for certain cookies and similar technologies. For further information on this, please refer to our Cookie Statement.
▪️ Legitimate interest. Our legitimate interest in offering and using the Pokii Website, apps and social media; and pursuing the other processing purposes listed above.

Social media platforms. Pokii uses different social media platforms, for example in the context of recruitment and selection and for marketing purposes. Pokii is not responsible for the management of the social media platforms, but is responsible for example for content of the Pokii Website that is shared by Pokii via a social media platform. For more information about how your data will be used by such social media platforms, we refer to the information already available on the websites of the suppliers of these platforms. Below we have included links to the privacy policies of various suppliers of social media platforms, which we could use:

ii. About Pokii
On our “about Pokii” webpage you can find additional information about us. On this webpage we do not process any additional data about you. On this webpage we do link to some of the above-mentioned webpages, such as Global Privacy Statement, Global Cookie Statement, Terms Of Use, FAQ or Contact Us.

iii. Pokii Support
The persons involved. People who send an email to customer support, e.g. via support@pokii.games, hello@pokii.games, privacy@pokii.games.

The purpose of the processing. When you contact Pokii customer support or contact Pokii otherwise, we will process your data for the following purposes:

▪️ To provide you with support;
▪️ To answer any question you may have for us.

The data that is processed. When you contact Pokii customer support or contact Pokii otherwise, we will process the following information about you:

▪️ Email address;
▪️ Name (if you provide one);
▪️ The information you sent us and related metadata you shared with us; as well as the information and related metadata we may share with you in reply.

Legal grounds for the processing. In principle, we base the use of your data in the context of the Pokii customer service on the legitimate interest ground. It concerns our legitimate interest to provide you with support and answer any questions you have for us.

3. How do we obtain your data?

We obtain your data in various ways:

▪️ Provided by you. Some data about you, we receive straight from you. Examples include information in your messages to us and information you enter in our application form.
▪️ Obtained internally. It is possible that we obtain your data via other Pokii systems. An example for game developers is the data which is included into our CRM system.
▪️ Obtained from third parties. We could also obtain data about you from other persons or external parties. Specifically, we make use of this possibility in two scenarios:
- ▪️ Website Visitors: we may receive information about you from privately held third parties, such as for the advertisements that are shown on the Pokii Website. Further information on this is included in our Cookie Statement.
- ▪️ Applicants: we may obtain information from a referral included by you in your application.
▪️ Automatically obtained. Some data we obtain automatically, for example by using cookies and similar techniques. When your computer or mobile device contacts our web servers (e.g. when you visit the Pokii Website), our web servers automatically collect usage information. Such usage information includes information about how our Website Visitors use and navigate the Pokii Website. It can include the number and frequency of Website Visitors to each web page and the length of their stays, browser type, and referrer data that identifies the web page visited prior and subsequent to visiting the Pokii Website. Further information on this is included in our Cookie Statement.
▪️ Derived. Certain data we do not receive directly, but can be derived from the information already in our possession. For example, information about your language preferences.
In principle you are under no obligation to provide any information about yourself to us. However, refusal to supply certain information could have a negative influence on, for example, the functionality of the Pokii Website. If the provision of certain personal data is a legal or contractual obligation or an essential requirement for concluding an agreement with us, we will separately provide additional information about this for as far as this is not clear in advance. In such case we will also inform you about the possible consequences if this information is not provided.

4. Who do we share your data with?

We only share your data with third parties if:

▪️ This is necessary for the provision of a service or the involvement of the third party. Sub-contractors, for example, will in principle only get access to the data that they require for their part of the service provision.
▪️ The persons within the third party that have access to the data are under an obligation to treat your data confidentially. Where necessary this is also contractually agreed on.
▪️ The third party is obliged to comply with the applicable regulations for the protection of personal data, for instance because we have concluded an agreement with this party or because our Terms of Use apply. This includes that the party is obliged to ensure appropriate technical and organizational security measures.

We could share your data on a need-to-know basis with the parties mentioned below. In this context, "need-to-know" means that a party only gets access to your data if and insofar as this is required for the professional services provided by this party.

▪️ Authorized persons, employed by Pokii, who are involved with the processing activity concerned. Such as, the members of the support team you are in contact with.
Authorized persons, employed by service providers / sub-contractors engaged by Pokii, who are involved with the processing activity concerned. Such as, the service provider for the Pokii web shop.
▪️ Authorized persons, employed by parties in the private sector with whom we may share certain data, such as our game developers and advertising partners. Traffic information may be shared with game developers and advertisers on an aggregate and anonymous basis. In addition, advertisers on the Pokii Website may receive information gathered by cookies for targeted advertising purposes. Further information regarding the use of cookies can be found in our Cookie Statement.
▪️ Authorized government institutions. Such as, courts, police, and law enforcement agencies. We may release information about our Website Visitors, when legally required to do so, at the request of governmental institutions conducting an investigation or to verify or enforce compliance with the policies governing the Pokii Website and applicable law. We may also disclose such user information whenever we believe disclosure is necessary to protect the rights, property or safety of Pokii, or any of our respective business partners, customers or others.
▪️ Aggregate Information. We may also disclose non-identifying, aggregated user statistics to third parties for a variety of purposes, including describing our services to prospective partners and other third parties. Examples of such non-personal information include the number of users who visited this Pokii Website during a specific time period or played a specific game.

5. How do we secure your data?

Protecting your privacy and data is very important to us. Therefore, Pokii has implemented appropriate technical and organizational measures to protect and secure personal data, in order to prevent violations of the confidentiality, integrity and availability of the data. All Pokii employees and other persons engaged by Pokii for the processing of data are obliged to respect the confidentiality of personal data.

6. To which countries will we transfer your data?

Parties involved with the processing of your data may be located in a different country than you are. No matter where you are located, we are securing your personal data as much as reasonably possible.

If your data is transferred from the EU to a party located outside the EU, we call this an 'EU transfer' (see this link for an overview of the EU countries). If your data is transferred from the UK to a party located outside the UK, we call this a 'UK transfer'. EU transfers and UK transfers are legitimized in the manner described below. You may contact us for information on the legitimization of other data transfers.

EU transfers. An EU transfer EUcan in the first place be legitimized based on an adequacy decision of the European Commission, in which it is decided that the (part within the) third country in question ensures an adequate level of data protection. See this link for a summary of the applicable adequacy decisions.

UK transfers. A UK transfer can in the first place be legitimized based on an adequacy regulation of the UK government. See this link for an overview of the applicable adequacy regulations.

If an EU transfer and/or UK transfer takes place for which there is no adequacy decision or adequacy regulation in place, we agree on the applicability of the relevant version of the Standard Contractual Clauses with the relevant party. This is a standard contract to safeguard the protection of your data, which is approved by the European Commission in which the parties fill out the appendices. See this link for the various versions of the Standard Contractual Clauses for the EU. Where appropriate, additional safeguards should be taken. Where the UK GDPR is applicable, a UK Addendum will be added to the Standard Contractual Clauses mentioned above, as required by UK law and regulations (see this link).

In specific situations we can also rely on the derogations as specified in applicable law to legitimize the EU transfer and/or UK data transfer. This could mean that we may transfer your data: (i) with your explicit consent, (ii) if this is necessary for the performance of a contract that has been concluded with you or has been concluded in your interest, or (iii) if this is necessary for the establishment, exercise or defense of legal claims. Lastly, in exceptional cases we may also transfer your data if the data transfer is necessary for our compelling legitimate interests and is not overridden by your interests or rights and freedoms.

You can contact us if you want additional information via our contact details as stated at the bottom of this Privacy Statement.

Google Analytics, Pokii.games uses Google Analytics, a web analysis service of Google Inc. ( "Google''). Google Analytics uses "cookies'', text files that are stored on your computer and allow an analysis of the use made of the web. The information generated by cookies on your use of this website is transmitted and stored on a Google server in the US If the anonymous IP is activated on this website, Google shortens your IP address within member states of the European Union or other states which have ratified the agreement on the European Economic Area previously. Only in exceptional cases the full IP address will be transmitted to a Google server in the US and it is shortened there. By order of the operator of this website, Google will use this information to analyze your use of it, in order to compile reports on the activities of the website and provide other services related to the use of the web and the use of Internet operators. The IP address transmitted by your browser through Google Analytics is not associated with other data from Google. You can prevent the installation of cookies if configured in your browser, but please note that in this case, you might be able to not use all features of this website. Visitors can disable the use we make of Analytics by visiting Google Analytics Opt-out page. More about Google Analytics here.

Google Adsense. These third-party ad servers or ad networks use technology to the advertisements and links that appear on pokii.games sent directly to your browsers. They automatically receive your IP address when this occurs. Other technologies ( such as cookies, JavaScript, or Web Beacons ) may also be used by the third-party ad networks to measure the effectiveness of their advertisements and / or to personalize the advertising content that you see. pokii.games has no access to or control over these cookies that are used by third-party advertisers. You should consult the respective privacy policies of these third-party ad servers for more detailed information on their practices as well as for instructions about how to opt-out of certain practices. pokii.games privacy policy does not apply to, and we cannot control the activities of, such other advertisers or web sites. If you wish to disable cookies, you may do so through your individual browser options. More detailed information about cookie management with specific web browsers can be found at the browsers respective websites. More about Google Adsense here.

7. How do we determine how long we retain your data?

In general, we do not keep your data for longer than what is necessary in relation to the purposes for which we process the data. There could however be exceptions applicable to the general retention terms.

Exception: shorter retention period. If you exercise certain privacy rights, it is possible that Pokii will remove your data earlier than the general applicable retention period or – oppositely – retain it for a longer period of time. For more information about this, please refer to the header "What are your privacy rights (incl. right to object)?"

Exception: longer retention period. In certain situations, we process your data for a longer period of time than what is necessary for the purpose of the processing. This is for instance the case when we have to process your data for a longer period of time:

▪️ Retention obligation. To comply with a minimum retention period or other legal obligation to which we are subject based on the applicable law;
▪️ Procedure. Your personal data is necessary in relation to a legal procedure;
▪️ Freedom of expression. When further processing of your personal data is necessary in order to exercise the right to freedom of expression and information.

8. What are your privacy rights (incl. right to object)?

You have various privacy rights. Which privacy rights you have, depends on the applicable law. To what extent you can exercise these rights may depend on the circumstances of the processing, such as the manner in which Pokii processes the personal data and the legal ground for the processing. Below, we included a summary of the privacy rights you may have. The applicable law may allow or require us to refuse your request, because these rights are not absolute or may not be applicable in your region.

For more information about your privacy rights in other jurisdictions, such as the Member States of the EU or the UK, go to this webpage or this webpage of the European Commission or this webpage of the UK Information Commissioner’s Office. In case you are visiting the Pokii Website from another jurisdiction, please refer to 12. Local Law Addenda to see which privacy rights you might have.

8.1 Your privacy rights.
In relation to our processing of your personal data, you may have the below privacy rights.

▪️ Right to withdraw consent. In so far as our processing of your data is based on your consent, you have the right to withdraw your consent at any time via our contact details stated below. Withdrawal of consent does not influence the legitimacy of the processing before you withdraw your consent. If you withdraw your consent, Pokii will no longer process your data for the purpose that you consented to. It can however be possible that we still process the personal data for another purpose, such as to comply with a minimum retention period. In that case you will be informed about this.
▪️ Right of access. You may have the right to request access to your data. This enables you to receive a copy of the data we hold about you (but not necessarily the documents themselves). We will then also provide you with further information on our processing of your personal data. For example, the purposes for which we process your data, where we got it from, and with whom we share it. Where applicable, we may refer to this Privacy Statement.
▪️ Right to rectification. You may have the right to request rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected. You have this right in case we process personal data about you that: (i) is factually incorrect; (ii) is incomplete or not related to the purpose it was collected for; or (iii) is in any other way used in a manner that is in conflict with an applicable law.
The right of rectification is not intended for the correction of professional opinions, findings or conclusions that you do not agree with. However, Pokii could in such a case consider adding your opinion about this to your data.
▪️ Right to erasure. You may have the right to request erasure of your personal data. This enables you to ask us to delete or remove your data where: (i) the data is no longer necessary, (ii) you have withdrawn your consent, (iii) you have objected to the processing activities, (iv) the data has been unlawfully processed, (v) the data has to be erased on the basis of a legal requirement, or (vi) where the data has been collected in relation to the offer of information society services.
However, we do not have to honor your request to the extent that the processing is necessary: (i) for exercising the right of freedom of expression and information, (ii) for compliance with a legal obligation which requires processing, (iii) for reasons of public interest in the area of public health, (iv) for archiving purposes, or (v) for the establishment, exercise or defense of legal claims.
▪️ Right to object. You may have the right to object to the processing of your data where we are relying on legitimate interest as processing ground (see above). Insofar as the processing of your data takes place for direct marketing purposes, we will always honor your request. For processing for other purposes, we will also cease and desist processing, unless we have compelling legitimate grounds which override your interests, rights and freedoms or that are related to the institution, exercise or substantiation of a legal claim. If such is the case, we will inform you on our compelling grounds and the balance of interests made.
▪️ Right to restriction. If applicable, the right to restriction of processing means that Pokii will continue to store personal data at your request but may in principle not do anything further with it. In short, you have this right when Pokii does not have (or no longer has) any legal ground for the processing of your data or if this is under discussion. This right is specifically applicable in the following situations:
▪️ Unlawful processing. We may not (or no longer) process certain personal data, but you do not want us to erase the data. For example, because you still want to request the data at a later stage.
▪️ Data no longer required. Pokii no longer needs your data for our processing purposes, but you still require the personal data for a legal claim. For example, in case of a dispute.
▪️ Pending an appeal. You objected against the processing of your data by Pokii (see the right to object above). Pending the verification of your appeal we will no longer process this personal data at your request.
▪️ Contesting the accuracy of data. You contest the accuracy of certain data that we process about you (e.g. via your right to rectification; see above). During the period in which we assess your contest we will no longer process this personal data at your request.
▪️ Right to data portability. You may have the right to request the transfer of your data to you or to a third party of your choice (right to data portability). We will provide you, or such third party, with your data in a structured, commonly used, machine-readable format. Please note that this right only applies if it concerns processing that is carried out by us by automated means, and only if our processing ground for such processing is your consent or the performance of a contract to which you are a party (see above).
▪️ Automated decision-making. You may have the right not to be subject to a decision based solely on automated processing, which significantly impacts you (“which produces legal effects concerning you or similarly significantly affects you”). In this respect, please be informed that when processing your personal data, we do not make use of automated decision-making which significantly impacts you.
▪️ Right to complaint. In addition to the above-mentioned rights, you may have the right to lodge a complaint with a supervisory authority, in particular in the country of your habitual residence, place of work or where an alleged infringement took place. However, we would appreciate the chance to deal with your concerns before you approach them, so please contact us beforehand.

8.2 How to exercise your rights.
You can exercise your privacy rights free of charge, by phone or by e-mail via the contact details displayed below. If requests are manifestly unfounded or excessive, in particular because of the repetitive character, we may either charge you a reasonable fee or refuse to comply with the request.

8.3 Verification of your identity.
We may request specific information from you to help us confirm your identity before we further respond to your privacy request.

8.4 Follow-up of your requests.
We will provide you with information about the follow-up of the request without undue delay and in principle within one month of receipt of the request. Depending on the complexity of the request, the number of requests and the applicable law, this period can be extended. We will notify you of such an extension within one month of receipt of the request. The applicable law may allow or require us to refuse your request. If we cannot comply with your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

9. Who is responsible for the processing of your data?

Pokii is in principle responsible for the processing of your data in the context of the Pokii Website, but other parties may also be involved and responsible themselves, as specified below.

9.1 Developers.
The developers of the games on the Pokii Website are in principle required to remove all outgoing links and branding/advertisements (e.g. splash-screens, social links and app-store links) from their game(s). If developers do gather personal data for their own purposes, Pokii is not responsible for this processing: only the developer decides what (personal) data is processed and for what purpose. * For further information on developers cookies, please refer to our Cookie Statement. Furthermore, if you notice any possible undue processing by a developer of your data, please inform us so that we can investigate.

9.2 Advertisement partners.
Pokii uses the services of several advertising parties. These parties provide us with advertisements for the Pokii Website and are responsible for their part of the processing of your data in this context. To nevertheless safeguard your privacy in this respect as much as possible, Pokii has, amongst other things, ensured that suitable contractual measures are in place. Further information regarding the use of cookies, also in the context of advertising partners, can be found in our Cookie Statement.

9.3 Externally hosted games, third party games and other websites.
This Privacy Statement does not apply to usage of your data by other parties that are themselves responsible for such usage of your data, such as providers of third-party games available on the Pokii Website. The relevant provider of such third-party games is responsible for ensuring that any processing of your data by them in the context of a game complies with the applicable law. In principle, Pokii does not permit third party content providers to collect personal data about Website Visitors. However, if any personal data will be collected by a third-party content provider, Pokii will require that the processing of such data by them complies with the applicable law.

*Please note that this list may not be complete, since randomized cookies that are placed with less than 100 Website Visitors are not included in the list. Furthermore, the cookies used by developers may change over time. Therefore, we automatically update this list daily.

10. How can you contact us?

If you have any questions concerning this Privacy Statement, or our usage of your data, please contact us at privacy@pokii.games or support@pokii.games

11. Changes

We may change this Privacy Statement from time to time to accommodate new technologies, industry practices, regulatory requirements or for other purposes. The latest version can always be consulted via the Pokii Website. Important changes will also be communicated to you.

12. Local Law Addenda

12.1 Local Law Addendum (Canada)

If you are currently visiting the Pokii Website from within the Canada region, the following applies:

A. Privacy Rights
You have certain privacy rights, which you may contact us at privacy@pokii.games to exercise your rights. These include:

▪️ Withdrawing Consent: If you have given consent to the processing of your personal information for one or more purposes, you are entitled to withdraw your consent at any time (without affecting the lawfulness of any information processing that took place before the withdrawal of consent). If you withdraw consent for processing that is necessary for us to provide our services, we may not be able to provide those services to you.
▪️ Accessing and Correcting your Personal Information: You may access personal information which we hold about you, correct any inaccurate personal information about you and/or complete any incomplete personal information about you. You are entitled to access your personal information, subject to the restrictions on access that are set out in relevant laws. We reserve the right not to change personal information if we disagree that it is incorrect, but we will append your requested alternative information.
▪️ Additional Rights: Under certain circumstances and subject to applicable local data protection laws, you may also be entitled to request additional information regarding our data governance practices, including details regarding what information is collected about you, the categories of persons who have access to your information, the right to be informed of and submit observations regarding automated decision-making, and information regarding how long your information will be retained for. You may also be entitled to request that we cease communicating your information, or de-index any hyperlink attached to your name that provides access to your personal information by technological means.

*Please note, we may require you to verify your identity before we allow you to access or correct your personal information, or exercise your other rights.

B. Cookies
In Canada, we use advertising cookies, analytical cookies, and marketing cookies unless you opt out of these cookies via our Privacy Center. Please note that even if you opt out of cookies for personalized advertisements and analytical cookies, we may still use certain cookies. These include cookies used for the proper functioning of our Website and to remember your cookie choices. For more detailed information, please see our Privacy Statement and our Cookie Statement.

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