🛡️ Privacy Policy
Koyuton Technologies (referred to as "Company," "we," "us," or "our") is committed to protecting the privacy of our users. This Privacy Policy applies to the personal data we collect through our website, our mobile games, our mobile applications, and our custom-developed web applications (collectively, the "Services").
We are the Data Controller for the personal data processed in accordance with this Policy.
- Effective Date: 03-12-2025
- Last Updated: 03-12-2025
1. Company and Contact Details​
| Details | Information |
|---|---|
| Legal Entity Name | Koyuton |
| Registered Address | Gaickingalaan 3, 9801 EA Zuidhorn The Netherlands |
| Email Address for Privacy Questions | privacy@koyuton.com |
2. Personal Data We Collect​
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user or device ("Personal Data").
A. Data You Provide to Us Directly​
This data is collected when you: register an account, make a purchase, contact customer support, or participate in surveys.
| Category of Data | Examples of Data | Purpose of Processing |
|---|---|---|
| Account/Contact Data | Name, email address, username, password. | To create and manage your account, provide access to Services. |
| Transaction Data | Payment information (e.g., last four digits of card, PayPal email), purchase history. | To process payments, fulfill orders, and manage subscriptions. |
| Correspondence Data | Information provided in emails, support tickets, or chat messages. | To provide customer support and improve our Services. |
B. Data Collected Automatically​
This data is collected when you use our Services.
| Category of Data | Examples of Data | Purpose of Processing |
|---|---|---|
| Device Data | IP address, device ID, device type, operating system, browser type. | To maintain the security of our Services and troubleshoot bugs. |
| Usage Data | Pages viewed, features used, games played, time spent in the app/game, clicks, session duration. | To analyze and improve the performance and user experience of our Services. |
| Location Data | General location based on IP address (country/city). | To comply with regional laws and analyze market reach. |
| Advertising IDs | Apple ID for Advertising (IDFA) or Google Advertising ID (GAID). | For third-party advertising, analytics, and personalization (with consent). |
3. Legal Basis for Processing (GDPR)​
Under the GDPR, we must have a legal basis to process your Personal Data. Our legal bases are:
| Legal Basis | Explanation & Use Case |
|---|---|
| Contractual Necessity | Processing is necessary to provide the Service you have requested, such as managing your account or processing a game purchase. |
| Legitimate Interest | Processing is necessary for our business operations, provided your rights are not overridden. This includes improving our Services, fraud prevention, and network security. |
| Consent | Where required, we will ask for your explicit consent for specific activities, such as sending direct marketing emails or using non-essential cookies/tracking. You may withdraw this consent at any time. |
| Legal Obligation | Processing is necessary to comply with legal requirements, such as tax and accounting laws. |
4. How and Why We Share Your Data​
We do not sell your personal data. We only share it with third parties in the following circumstances:
- Service Providers (Data Processors): We use third-party companies and individuals to facilitate our Services, such as cloud hosting (e.g., AWS), payment processing (e.g., Stripe), and customer support platforms. These processors are contractually bound to process data only on our instructions and to implement appropriate security measures.
- Advertising and Analytics Partners: For our mobile games/apps, we may share non-personally identifiable identifiers (like Advertising IDs) with advertising and analytics partners (e.g., Google Analytics, Facebook SDK) to measure campaign performance and personalize ads, only where consent is provided.
- Legal Compliance: We may disclose your data if required to do so by law, or in response to valid requests by public authorities (e.g., a court order or government agency).
- Business Transfers: In connection with a merger, sale of company assets, or acquisition of all or a portion of our business by another company, your data may be transferred.
5. International Data Transfers​
As an EU-based company, we primarily store and process data within the European Economic Area (EEA).
However, some of our third-party service providers are located outside of the EEA (e.g., in the United States). In such cases, we ensure that transfers are protected by using one of the following safeguards:
- Standard Contractual Clauses (SCCs): Contractual agreements approved by the European Commission.
- Adequacy Decisions: Transfers to countries deemed by the European Commission to have an adequate level of data protection.
6. Data Retention​
We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy, including for the purposes of satisfying any legal, accounting, or reporting requirements.
- Account Data: Retained as long as your account is active or as needed to provide you with Services.
- Transaction Data: Retained for a minimum of [e.g., seven years] to satisfy financial and legal obligations.
- Usage/Analytics Data: Retained for [e.g., 26 months] before being anonymized or deleted.
7. Your Data Protection Rights (GDPR)​
Under the GDPR, you have the following rights regarding your personal data. To exercise any of these rights, please contact us at [Dedicated Privacy Email].
- The Right to Be Informed: To be informed about how your personal data is being used (which is the purpose of this policy).
- The Right of Access: To request copies of your personal data we hold.
- The Right to Rectification: To request that we correct any information you believe is inaccurate or complete information you believe is incomplete.
- The Right to Erasure ("Right to be Forgotten"): To request that we erase your personal data, under certain conditions.
- The Right to Restrict Processing: To request that we restrict the processing of your personal data, under certain conditions.
- The Right to Object to Processing: To object to our processing of your personal data, under certain conditions (e.g., for direct marketing).
- The Right to Data Portability: To request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
- The Right to Withdraw Consent: Where we rely on consent to process your data, you have the right to withdraw that consent at any time.
8. Children’s Privacy​
Our Services are not intended for use by children under the age of [e.g., 16]. We do not knowingly collect personally identifiable information from children under [e.g., 16]. If you become aware that a child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from a child without verification of parental consent, we take steps to remove that information from our servers.
9. Changes to This Privacy Policy​
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date at the top of this Policy. Where required by law, we will also notify you via email or through a prominent notice on our Service prior to the change becoming effective.
10. How to Complain​
If you have a complaint about how we handle your data, please contact us first so we can try to resolve it. However, you also have the right to lodge a complaint with a supervisory authority, particularly in the Member State of your habitual residence, place of work, or place of the alleged infringement.
- The Dutch Data Protection Authority (Autoriteit Persoonsgegevens) is the supervisory authority in the Netherlands.
- Website: autoriteitpersoonsgegevens.nl