| Language: |
By playing Zombie Assault: Resurgence you agree to the following Terms of Service and Privacy Policy:
Latest Updates
For ease of access and understanding, recent revisions are highlighted here, but please take the time to read this full Terms of Service agreement as this is a binding legal agreement between you and Ninja Kiwi Limited.
In compliance with California’s Consumer Privacy Act, we have added clarity in our Privacy Policy about how California residents (or their parents or guardians) can request access to information stored and/or to delete that information via request to privacy@ninjakiwi.com.
In compliance with Europe’s General Data Protection Regulation (GDPR), we have updated our Ninja Kiwi Login to explicitly ask whether players are under 16; in the case that players are under that age limit, no personally identifiable information (PII) will be requested during login and other PII such as IP address will not be stored. Further GDPR information is also located in our Privacy Policy.
This Terms of Service and the Ninja Kiwi Privacy Policy are addressed to players at least 16 years of age. If a player is below the age of 16, they must have a parent or guardian read and accept these Terms of Service and the Ninja Kiwi Privacy Policy on their behalf.
Ninja Kiwi has updated its Fan Content terms to make it clearer and easier for streamers and content creators to work with Ninja Kiwi games.
Ninja Kiwi has updated terms specific to the player creator revenue sharing available within Bloons TD 6.
Introduction/Binding Agreement
These Terms of Service govern your access to and use of the Application and/or Ninja Kiwi Login, including any content, information, products, related communications, or related Services. This is a binding legal agreement between you and Ninja Kiwi Limited. (“Ninja Kiwi”) and applies to you in relation to any interaction with the Application, Ninja Kiwi Login, Services, or any related communications. Your access and use of the Application, Ninja Kiwi Login, or Services or participation in related communications signifies your acceptance of these Terms of Service and agreement to the collection, storage, review, and use of your information; this information will be stored on servers, some of which may be located in the United States. If you do not accept these Terms of Service and the Ninja Kiwi Privacy Policy in their entirety, you may not access, engage, or in any way use the Application, Ninja Kiwi Login, or any related Services. Ninja Kiwi reserves the right at any time to modify, discontinue, or terminate the Application, Ninja Kiwi Login, or Services, or modify these Terms of Service or the Privacy Policy at its sole discretion; when these Terms of Service or the Privacy Policy are updated they will be posted here and updated to the Ninja Kiwi blog and social channels (https://www.facebook.com/ninjakiwigames/ and https://twitter.com/ninjakiwigames). For players under the age of 18, we appreciate you reading these terms to understand your responsibilities as a player and member of the Ninja Kiwi community, but you must review these Terms of Service with your parent or guardian and your parent or guardian must agree to these Terms of Service on your behalf.
Eligibility and Use
By your (or your child’s in the case of a parent or guardian) access and use of the Application, Ninja Kiwi Login, Services, or Application-related communications you signify your agreement to the following:
a. You affirm that you are at least 16 years of age and that you are fully able and competent to comply with and adhere to these Terms of Service. Alternatively or in conjunction, you affirm that you are the parent or guardian of a player under the age of 16 for whom you take full responsibility for their compliance with these Terms of Service;
b. For Ninja Kiwi Login, players under the age of 16, in order to comply with the Children’s Online Privacy Protection Act (COPPA) and Europe’s General Data Protection Regulation (GDPR) standards, must signify their true age by selecting the “No, I am under 16”; c. For Ninja Kiwi Facebook Applications, you verify that you have a legitimate account in accordance with Facebook’s Terms of Service, and you will prevent anyone under the age of consent in your country from using your Account;
d. You shall use the Application, Ninja Kiwi Login, or Services only for non-commercial purposes, and you shall not solicit services, advertise, or send repetitive or spam messages;
e. If you access the Application, Ninja Kiwi Login, or Services from a social networking site or any other website you will comply with the terms of service of that site along with these Terms of Service;
f. You may not enter, submit, or upload player-generated content (including but not limited to Ninja Kiwi Login player names, forum posts, blog posts, chat, character or other in-game names, game editor content, Content Browser content, Map Editor content, or any video or streamed content where a core visual or topical content is Ninja Kiwi or its games) that is defamatory, harassing, threatening, bullying, bigoted, hateful, violent, obscene, pornographic, or that harms or can reasonably be expected to harm any person or property, and you understand that any such activity will lead to suspension of your Ninja Kiwi Account; g. You shall not use the Application, Ninja Kiwi Login, or Services to engage in any illegal activity;
h. You are responsible for safeguarding and maintaining the confidentiality of your Account information, you will not disclose that information, and you will not disclose personally identifiable information unless as part of the setup of your Ninja Kiwi Login account or via Facebook, Google, Apple, or Twitch permissions. You shall not share personally identifiable information or account information with other players or community members. You agree that you are entirely and solely responsible for all access and use of your Account, whether or not you authorised it and whether or not you were aware of it. Please review our Privacy Policy for more information about our collection and limited use of personally and non-personally identifiable information. For players of the Red Reign game on Apple Arcade, please review the Red Reign Privacy Policy. For players of the Bloons TD 6+ game on Apple Arcade, please review the Bloons TD 6+ Privacy Policy;
i. You shall not share, copy, clone, gift, trade, barter, sell, or in any other way exchange your Ninja Kiwi Login or game data with any other person or entity, and you understand that any such activity will lead to segregation and/or suspension of your Ninja Kiwi account;
j. You shall not use alternative Ninja Kiwi Login accounts in any way that enables or supports tampering with other players’ multiplayer experiences, specifically multiplayer leaderboard competitions, for instance joining other Clans, Parties, or Teams for the purpose of blocking other players from joining and/or to weaken that Clan’s, Party’s, or Team’s scoring; and
k. You will only connect to the Application, Ninja Kiwi Login, and Services through legitimate, unmodified clients for the purposes of any multiplayer or competitive play and rewards, including public co-op game sessions, all leaderboards, and all player vs player game sessions, and you understand that any such modified activity will lead to the automated or manual segregation and/or suspension of your Ninja Kiwi account. For clarity use of modified clients is tolerated for private single player use and private co-op games but you understand that such use may also lead to automated segregation and/or suspension of your Ninja Kiwi account, which you may appeal by contacting the community management team at https://support.ninjakiwi.com/hc/en-us/requests/new.
Limited License; Content; Ownership
Subject to your agreement to and compliance with these Terms of Service, Ninja Kiwi grants you a non-exclusive, non-transferable, non-sublicensable, revocable limited license to access, play, and otherwise use the Ninja Kiwi Applications and Services provided such access, play, customise characters, create in-game content using in-game editors and tools, and use is for your own entertainment and not for commercial purposes. Ninja Kiwi makes special provisions for commercial performance play on popular platforms such as YouTube and Twitch as covered under Fan Content below.
Except where otherwise noted, the Application, Ninja Kiwi Login, Services, related communications, and all content including but not limited to graphics, audio, text, user interface, characters, animations, buttons, icons, thumbnails, reward systems, quest systems, downloads, game data, game design, events, content editors and their components, and player created content using content editors such as but not limited to the Bloons TD 6 Content Browser Challenge Creator, Odyssey Creator, and Map Editor, are the property of Ninja Kiwi and are protected by United States, New Zealand, and international copyright, trademark, and intellectual property laws. You may access, engage, and use the Application, Ninja Kiwi Login, or Services as they are presented to you and in accordance with these Terms of Service. Without express written consent from Ninja Kiwi, any attempts to modify, hack, cheat, autoplay, bot, datasniff, data capture, interfere with, disrupt, reproduce, frame, copy, post, sell, scrape, transmit, clone accounts, clone characters, or create related or derivative works is expressly prohibited and immediately terminates the limited license granted and will lead to the automated or manual segregation and/or suspension of your account; any attempts to promote such proscribed usage through video, stream, social network, public display, digital communications, or any other mass audience channel is expressly prohibited and immediately terminates the limited license granted and will lead to the segregation and/or suspension of your account.
Any and all content including but not limited to bloons, monkeys, buildings, towers, characters, environments, maps, worlds, creatures, items, pets, homes, robots, tools, weapons, powers, powerups, upgrades, equipment, display areas, user interface, virtual currency, or any other virtual items or organised display or use of any such items remains the sole and exclusive property of Ninja Kiwi. No amount of customization, stat changes, item changes, configuration, levelling up, decorating, or in any other way modifying game elements through use of the Application, Ninja Kiwi Login, Ninja Kiwi Services, or any other means conveys any ownership or alteration of the limited license to use; all elements remain the sole and exclusive property of Ninja Kiwi.
Where Ninja Kiwi games provide in-game tools such as but not limited to the Bloons TD 6 Content Browser Challenge Creator, Odyssey Creator, and Map Editor that allow players to modify, customise, and otherwise manipulate game content to create player-generated content for display and play within or outside Ninja Kiwi games whether private or public, all such content remains the exclusive property of Ninja Kiwi Limited, and any use of such tools to create and display content is done on a voluntary basis without any right, claim, or interest to compensation of any kind, except as defined specifically for content creator and player creator revenue sharing as detailed in the Fan Content and Player Creator Content and Revenue Sharing sections below.
Ninja Kiwi reserves the right at its sole discretion and without notice to make changes, modifications, additions, deletions, copies, or any other alterations and edits to any and all content elements, including but not limited to their appearance, animation, statistics, behaviour, performance, cost, component parts, display, visibility, or in-game value. Ninja Kiwi reserves the right at its sole discretion and without notice to delete, suspend, or modify any item, feature, account or the entire Application, Ninja Kiwi Login, or Services. In the event that access to the Application, Ninja Kiwi Login, or Services is terminated, all virtual items, virtual currency, and player’s game progress is forfeited and you will not receive any compensation, monetary or otherwise, for any of these elements forfeited. Any suspension or termination of your access to the Application, Ninja Kiwi Login, or Services will not waive or diminish your obligations under these Terms of Service (including but not limited to ownership, indemnification, and limitation of liability).
Fan Content
Ninja Kiwi supports the maintenance and growth of healthy, non-sponsored communities, fan-art channels, and content creator/streamer ecosystems and seeks to encourage and support fan creations that use or perform our IP, as long as they adhere to these Terms.
Fan Content includes but is not limited to art, animation, memes, crafts, game designs, game mechanics, stories, ‘ships, music, videos, merchandise, printed material, and any other creation that uses Ninja Kiwi IP, as well as any performance of Ninja Kiwi IP, including but not limited to video content creation and streaming as appears on platforms like Twitch and YouTube. Fan Content must comply with each of the following requirements; any fan content that violates the following requirements is prohibited : a. Streamers and content creators may monetize their performances of Ninja Kiwi IP through platform (e.g. Twitch or YouTube) ads, platform currencies, and other standard platform methods provided the performance of the Ninja Kiwi IP must adhere to all other conditions of these Terms; b. Fan Content other than streamer and content creator performances on major platforms as described at (a) above must have no commercial and/or monetary objective or implementation; c. Fan Content must not be posted as stand alone products whether free or for purchase to commercial platforms such as app stores (e.g. Apple App Store, Google Play Store, Steam) or content stores (e.g. Spotify, Bandcamp, Printful, Redbubble, Zazzle, Etsy). For clarity, this does not restrict streamers and content creators from posting their Fan Content to content creator platforms available on app stores (e.g. Twitch, Youtube, and Facebook); d. Fan Content must not use the Ninja Kiwi company or game logos or trademarks and must not be presented in any way that could cause people or search algorithms to react as if it was an official Ninja Kiwi production or post; e. Fan Content must not derogate Ninja Kiwi, Ninja Kiwi games or services, or Ninja Kiwi staff or otherwise cause damage to the reputation, public perception, or goodwill of Ninja Kiwi or its games or brands, as determined solely by Ninja Kiwi; f. Fan Content must not be used to communicate, link, distribute, or promote cheats or hacks to any Ninja Kiwi games; g. Fan Content must not be obscene, sexually explicit, defamatory, hateful, or harmful to others, as determined solely by Ninja Kiwi; h. You acknowledge that Ninja Kiwi games appeal to broad audiences that may include children and as such Fan Content should be appropriate for broad audiences or gated behind sufficient warning for mature content as provided by performance platforms, and you further acknowledge your understanding that Ninja Kiwi will not promote any Fan Content that is not appropriate for broad audiences.
If you have a channel on YouTube, Twitch, Facebook, or another platform and have any questions about media kits, game information, or just want to say hello, please get in touch with us at streamers@ninjakiwi.com; there is no obligation or requirement to contact Ninja Kiwi, but we do like to hear from people finding fun and value creating content with Ninja Kiwi IP in accordance with these Terms.
Content creators and streamers can also participate in a revenue share exchange managed by Nexus.gg and subject to their terms: https://www.nexus.gg/legal/terms-of-use.
As a standard practice, Ninja Kiwi does not accept Fan Content submitted directly to Ninja Kiwi for the Application, Ninja Kiwi Login, and/or Services of any other Ninja Kiwi game or property. From time to time, Ninja Kiwi may run promotions based on Fan Content for the purpose of community engagement. Whether part of a promotion or unsolicited, if you make any Fan Content submissions to Ninja Kiwi via any delivery mechanism including but not limited to blogs, forums, emails, letters, videos, community sites, or social networking posts and comments, you acknowledge your understanding that Ninja Kiwi is in the business of making games and is constantly creating game ideas, features, concepts, technologies, designs, mechanics, and all other elements for Applications or Services and likely has ideas that are similar to or identical to your submissions. In addition, you acknowledge that you will receive no compensation or credit and that your submission is not confidential. By communicating the submission, you warrant that you are the originator of the idea and that it does not infringe on the rights of any other person or entity, and you grant Ninja Kiwi a worldwide, royalty-free, non-exclusive perpetual right and license to use, modify, translate, publish, perform, produce derivative works, and in any other way manifest the submission without any liability, payment, or expense. Ninja Kiwi at its sole discretion and where possible will make efforts to acknowledge promotional Fan Content submissions that are reinterpreted and/or reauthored by Ninja Kiwi and subsequently incorporated into any Applications or Services.
Player Creator Content and Revenue Sharing
Player Creator Content is defined as any content created within any Ninja Kiwi game or service that can then be shared with other players for their use, performance, and enjoyment. The main examples of Player Created Content are the Challenge, Odyssey, and Map creations within Bloons TD 6. All such Player Created Content is bound by these Terms.
While all Player Creator Content creation is voluntary and is done without any right, claim, or interest in compensation of any kind, Ninja Kiwi is facilitating a platform-specific revenue share from In App Purchases made from players who are actively playing a Player Creator’s Challenge, Odyssey, and/or Map creations; this revenue share is conditional on the Player Creator: a) creating a Nexus.gg account; b) linking that Nexus account to their Ninja Kiwi player account, and; c) accepting the Nexus.gg terms: https://www.nexus.gg/legal/terms-of-use. For additional visibility, the Nexus.gg terms restrict revenue share participation to players 18 years of age and older.
Because IAPs and/or IAP validation are not available on all platforms where Bloons TD 6 is distributed, players on Apple Arcade, Netflix, Amazon App Store, and Windows Store cannot give Accolades. Because of platform specific data constraints, player creators on Apple Arcade and Netflix cannot receive revenue sharing.
Revenue share amounts are subject to change at Ninja Kiwi’s sole discretion and without notice, but reasonable efforts will be made to update the current revenue share percentage within the Accolades Store information panel when playing Bloons TD 6 while connected to the internet.
Player creator data related to revenue sharing will be stored for six months from the time of content creation to allow players to take their time to register with Nexus.gg and link their accounts. Potential revenue share older than six months before Nexus.gg registration will not be stored or claimable.
Merchandise
Ninja Kiwi provides IP related merchandise for sale at https://store.ninjakiwi.com, and this merchandise is sold in accordance with Store Policies available at https://store.ninjakiwi.com/pages/store-policies.
Ninja Kiwi supports and encourages fan creativity in the creation of Fan Content merchandise provided it adheres to all of the requirements of Fan Content. Making limited-run (50 or less) hand-authored prints, t-shirts, stickers, and other merchandise for non-commercial distribution to friends and other fans is permitted so long as they adhere to all of the requirements of Fan Content and are not similar to any items listed at https://store.ninjakiwi.com.
Virtual Currency and Premium Items
Through use of the Application, Ninja Kiwi Login, or Services you may accumulate virtual currency and virtual items whose sole use is within the Application, Ninja Kiwi Login, or Services where they were obtained. Ninja Kiwi engages with industry leading platform storefronts, including but not limited to Apple’s App Store, Google Play, Amazon’s App Store, and Steam, and with reputable third party services to allow purchase of virtual currency with real world currency, and Ninja Kiwi reserves the right to enable or disable any in-game acquisition of or real world purchase of virtual currency. Ninja Kiwi reserves the right at its sole discretion and without notice to change the rate of exchange for in-game or purchased virtual currency or the cost of any in-game item. Use of the platform storefront or third party service for purchase of virtual currency is governed by the terms of use of that service and any issues with that transaction are to be resolved with that platform storefront or third party service according to their support procedures. Ninja Kiwi will offer support assistance in contacting and attempting to resolve such platform storefront or third party service issues if you email support@ninjakiwi.com. You understand and acknowledge that Ninja Kiwi is not required to provide a refund for any currency or other item for any reason. Further, you understand and acknowledge that you will receive no money or other compensation for unused virtual currency, premium items, or any other game resources when an account is closed, when an account is suspended, when an Application or Service is under maintenance, offline, closed, or otherwise unavailable, or when your data has been lost, corrupted, deleted, or otherwise made unavailable. Ninja Kiwi reserves the right at its sole discretion and without notice to remove, suspend, or close any Application or Service without any compensation to you.
Parents and guardians acknowledge that your children and wards may purchase virtual currency only with your supervision and authorization. We encourage all players, regardless of age, to understand their device settings and limit or restrict in-app purchasing on their device if they do not wish to engage with in-app purchase features. Additional information on restricting in-app purchases is available here: https://support.google.com/googleplay/answer/1626831 https://support.apple.com/HT204396 https://www.amazon.com/gp/help/customer/display.html
Virtual currency and items are non-transferrable to any other Application, Service, website, or anywhere else. Virtual currency, virtual items, and player progress are not redeemable for any monetary value from Ninja Kiwi, any third party service, or any other entity. You agree not to sell, exchange, or attempt to transfer virtual currency, virtual items, or player progress, and any such actions will not be tolerated by Ninja Kiwi and will lead to suspension of your Ninja Kiwi account.
Whether you obtained virtual currency and virtual items through use of the Application, Ninja Kiwi Login, and Services, by purchase via a third party service, or by interacting with advertisements, you have no right or title to any virtual currency, virtual items, or any other game assets. You agree to pay all fees and related taxes incurred by you or anyone using an account that is registered to you. You agree to pay all internet, carrier, device, power, repair, replacement, data, bandwidth and any other fees and related taxes related to the operation of any equipment or devices required to access any Application or Service.
Bloons TD 5 Deluxe Terms of Sale
The downloadable PC desktop Application, “Bloons TD 5 Deluxe,” is no longer for sale but these Terms still apply for players of the game. There are no physical goods comprising or associated with the Bloons TD 5 Deluxe Application. Customers must have access to the internet to download and to validate their serial key and complete the installation; customers are solely responsible for their internet access and any related fees. The Bloons TD 5 Deluxe Application may only be used according to the Ninja Kiwi End User License Agreement that must be accepted during the installation process.
Third Party Links
The Application and Services may link to or rely on third party websites or resources. Ninja Kiwi is not responsible or liable for the availability or accuracy of such websites or resources. You acknowledge sole responsibility for and assume all risk arising from your use of any such websites or resources.
Electronic Communications
You consent to receive email communications from the Ninja Kiwi community management team if you create a support ticket via an Application or via support@ninjakiwi.com. Ninja Kiwi endeavours to respond to customer support tickets, app store reviews, and community posts in a timely and appropriate manner, but any such or other communications contact with Ninja Kiwi does not guarantee a reply or in any way impact the Disclaimer of Warranties or any other aspect of these Terms of Service.
Ninja Kiwi reserves the right to use, and you consent to receive, emails for critical communications such as legal notices or announcements. Any marketing or game status emails would be opt-in only, and your opt in or out will not affect your access to the Application, Ninja Kiwi Login, Services, or related communications. You can opt out at any time from your in game profile or through the unsubscribe link at the bottom of any marketing email.
Ninja Kiwi Competitions
By submitting a Fan Content entry for any competition run by, or in association with Ninja Kiwi, you fully and unconditionally agree to and accept these additional rules, terms, and conditions: a. You grant Ninja Kiwi a worldwide, royalty-free, non-exclusive perpetual right and license to use, reproduce, modify, publicly display, perform, produce derivative works of, or otherwise use any entry in any and all media, whether now known or hereafter existing, throughout the world for any and all purposes without compensation to you of any kind; b. You represent and warrant that your entry does not infringe on any copyright, trademark, property rights, or any other rights of any third party and that you have the right to transfer the entry to Ninja Kiwi free of any claims. Ninja Kiwi shall have no liability for any alleged or actual infringement of a third-party's rights in connection with any entry; c. You agree that you have not or will not receive any compensation or other consideration for your entry. Ninja Kiwi may in its sole discretion and without notice choose to award fan merchandise, including but not limited to t-shirts, stickers, badges, mouse pads, and virtual currency. All such items have no cash value and are purely for promotional purposes. Ninja Kiwi is under no obligation to award any fan merchandise regardless of the number or types of entries; d. You further agree to release and hold harmless Ninja Kiwi and its licensors, distributors, agents, shareholders, directors, officers, employees and representatives from and against any and all losses, damages, rights, claims, and actions of any kind arising in connection with your participation in the contest, including, not limited to, claims based on publicity rights, defamation, or invasion of privacy. All federal, state, local, provincial and municipal laws and regulations apply. Void where prohibited by law.
Disclaimer of Warranties
The Application, Ninja Kiwi Login, and/or Services are for use “as available” and “as is” and without any warranty, regardless of the amount of time and/or money you have spent on the Application, Ninja Kiwi Login, and/or Services. Use of the Application, Ninja Kiwi Login, and/or Services are at your sole risk and sole discretion, and you are solely responsible for any damage to your computer system or smart device, for any device performance issues, and for any loss of data. Ninja Kiwi disclaims any warranty express or implied regarding title, merchantability, availability, fitness, freedom from errors, error correction, and timeliness of communication or error correction. Ninja Kiwi does not warrant that the Application, Ninja Kiwi Login, and Services are bug free, error free, or virus free. You are solely responsible for how you spend your time and money. No communication whether written or oral shall supersede this Disclaimer of Warranties.
Limitation of Liability; Indemnification; Force Majeure
In no event will Ninja Kiwi, its directors, or its employees be liable for any damages whatsoever and without limitation, whether they be direct, indirect, punitive, commercial, intangible, or of any other type, arising from the use of the Application, Ninja Kiwi Login, or Services, regardless of whether the damages are foreseeable, even if Ninja Kiwi, its directors, and/or its employees have been advised of the possibility of such damages. To the extent that the above limitation applied to its fullest extent in applicable jurisdiction assigns liability, that cumulative liability shall not exceed US$10.
You agree to indemnify and hold harmless Ninja Kiwi, its directors, employees, partners, and service partners from any claim and demand, including any attorney’s fees, made by any party due to your use of the Application, Ninja Kiwi Login, or Services, your violation of these Terms of Service, or your violation of applicable law or the rights of another party.
Ninja Kiwi shall not be liable for any damages, disruptions, or claims related to its Application, Ninja Kiwi Login, or Services that arise from acts of nature, weather, war, social upheaval, economic upheaval, unavailability of utilities or resources, terrorism, the public enemy, any government or public authorities requirements, or any other event outside of Ninja Kiwi’s control.
Supplemental Terms for PlayStation®
For Purchases in PlayStation™ Store in North America
Purchase and use of items are subject to the Network Terms of Service and User Agreement. This online service has been sublicensed to you by Sony Interactive Entertainment America.
For Purchases in PlayStation™ Store in Europe
Any content purchased in an in-game store will be purchased from Sony Interactive Entertainment Network Europe Limited ("SIENE") and be subject to PlayStation™Network Terms of Service and User Agreement which is available on the PlayStation™Store. Please check usage rights for each purchase as these may differ from item to item. Unless otherwise shown, content available in any in-game store has the same age rating as the game.
General
These Terms of Service shall be governed by and interpreted in accordance with the laws of New Zealand. Any legal action or proceeding will be brought exclusively in courts located in Auckland, New Zealand and you consent to this jurisdiction. If any provision in these Terms of Service is held to be invalid, the remaining provisions shall survive in full effect. These Terms of Service are personal to you and imply no partnership, employment, or any other business relationship between you and Ninja Kiwi, and you may not transfer, assign, or delegate these Terms of Service to any other party with the exception of a parent or guardian taking responsibility for these Terms of Service for their child or ward. No delay, failure to communicate, or failure to take action in relation to any of these Terms of Service shall invalidate any provision of these Terms of Service.
Contact
You may address comments or questions to the following email address: support@ninjakiwi.com.
Hello and Welcome to Ninja Kiwi’s Privacy Policy!
We are committed to making our games both fun and safe to use. In general, our approach is to only collect anonymous data wherever possible and use as little personal data as is necessary to provide the best games and services. We don’t gather or use anonymous data or any personal information to sell these to third parties for commercial purposes; we only want to make our games more awesomer.
Please take a moment and read this Privacy Policy. It will help you understand how we process your personal data. Depending on the specific case it is possible that other privacy policies of ours may apply additionally, in which case we will inform you about this additional application (e.g., by referring to them). If you have any questions regarding our use of your personal data, please feel free to contact us over the channels provided below.
When you or your children or wards use Ninja Kiwi games and services, our Terms of Service and the terms of this Privacy Policy apply. You or your children or wards should not use any Ninja Kiwi games or services unless you agree to this.
The descriptions of how we process your personal data, your rights, and limitations to processing your personal data that are mentioned in this privacy policy apply to you when you use our services. They are based on the rules of the UK General Data Protection Regulation ("UK GDPR") and the General Data Protection Regulation ("GDPR") which applies when you reside in the United Kingdom or European Union and use our services.
If you do not reside in the UK or EU and use our services, the descriptions of this privacy policy may not fully apply to you and other data protection laws might be applicable. If you are a resident of the State of California, please see Section X below for detailed information according to the California Consumer Privacy Act ("CCPA").
When we refer to "you" in this Privacy Policy, we refer to you as data subject (see Sect. III below for more details on what this means). If you are interacting with us on behalf of others, please make sure all affected people receive the information stated in this Privacy Policy.
I. Who Are We?
If we speak of "we" or "us" in this Privacy Policy, we refer to ourselves as controller as defined below. Our contact details are:
Ninja Kiwi Ltd.
PO Box 26
Kumeu 0841
New Zealand
Our group data protection officer ("DPO") is
Kat Small
c/o Ninja Kiwi Europe Ltd.
Unit 13 The Vision Building
20 Greenmarket
Dundee DD1 4QB
Scotland
Ninja Kiwi Europe Ltd. is our representative in the UK (Art. 27 GDPR).
Supervisory Authority (UK)
Information Commissioner’s Office (ICO)
Wycliffe House
Water Lane
Wilmslow SK9 5AF
England
Our representative in the EU is
Modern Times Group MTG AB
Skeppsbron 18, Box 2094
111 30 Stockholm
Sweden
Supervisory Authority (EU)
Integritetsskyddsmyndigheten (IMY)
Box 8114
104 20 Stockholm
Sweden
You can reach out to us regarding any data protection matters by sending an email to privacy@ninjakiwi.com.
II. Joint Controllerships
What does joint controllership mean?
We and our subsidiaries, Ninja Kiwi Europe Ltd and Ninja Kiwi Americas LLC ("Subsidiaries"), cooperate closely together to provide our games and services. This means that we and our Subsidiary jointly determine if and how personal data of yours is processed. Since we and our Subsidiary each are controllers of your data when doing so, the working relationship is called a joint controllership. Our Subsidiaries are:
Ninja Kiwi Europe Ltd.
Unit 13 The Vision Building
20 Greenmarket
Dundee DD1 4QB
Scotland
and
Ninja Kiwi Americas LLC
140 Divisadero Street
San Francisco CA 94117
USA
Our Subsidiaries’ group data protection officer ("DPO") is
Kat Small
c/o Ninja Kiwi Europe Ltd.
Unit 13 The Vision Building
20 Greenmarket
Dundee DD1 4QB
Scotland
You can reach out to our DPO regarding any data protection matters by sending an email to privacy@ninjakiwi.com and noting that you are addressing our Subsidiary.
Is there a contract between us and our Subsidiaries?
Yes. We and our Subsidiaries have concluded a contract that legitimises any data flows between us and our Subsidiary. It contains rules for joint controllerships between us, especially which company is responsible for what when it comes to your personal data.
In which cases do we process your data together with our Subsidiaries and why?
We cooperate with our Subsidiary and jointly process personal data with them in the following cases:
We and our Subsidiary administer HR matters related to data subjects outside of the EU and process personal data related to this (e.g., regarding job applications and performance reviews).
We and our Subsidiary share IT services that are provided and administered by Ninja Kiwi Ltd. and through this process personal data such as personal data of yours when you play Ninja Kiwi games or use our services as well as personal data of employees of partners who cooperate with us and/or our Subsidiary.
We and our Subsidiary jointly market Ninja Kiwi products and services. For this purpose, we and our Subsidiary may process personal data, such as player data (e.g., your name when responding to a post of yours in our social media channels), as joint controllers. Such data is managed separately. However, we and our Subsidiary may jointly decide whether and how personal data is used for marketing purposes.
We and our Subsidiary may share the services of Ninja Kiwi’s external legal consultants (e.g., lawyers) for any legal questions and for administering and cooperating in intercompany matters. Through this we and our Subsidiary may jointly process personal data such as names and other personal data provided in connection with a legal assessment or proceeding.
We and our Subsidiary jointly handle data protection requests that you as data subject might send us (e.g., if you want to have your data deleted). Through this we and our Subsidiary may jointly process personal data such as names and other personal data provided in connection with your request.
We and our Subsidiary jointly process data required for playing our games (e.g., account data) and visiting our websites (e.g., IP addresses).
We and our Subsidiary jointly process analytical data that one of us might collect within a game or on a website of ours to improve how our games and website work.
We and our Subsidiary jointly process personal data required for purchases made in our online shop, e.g., to be able to send you the merch you bought.
We and our Subsidiary jointly process personal data in relation to raffles and giveaways.
You can find further details on how we and our Subsidiary jointly process your data in the respective section below (see Section VII. that gives specifics on how we use your data).
Who is responsible for what?
If not expressly stated otherwise in this Section, our Subsidiary, Ninja Kiwi Europe Ltd, is responsible for safeguarding your rights set out in this Privacy Policy, when processing your personal data. In such case, our Subsidiary is your primary contact point for all requests you may have relating to data protection. You can at any time of course also contact us to exercise your data subject rights. We and our Subsidiary can assist each other to comply with our obligations of the UK GDPR that apply regarding you and will inform each other about matters of significance to a joint controllership. Irrespective of this, the UK GDPR grants you the possibility to exercise your rights in respect of and against each of the joint controllers.
How is your data secured?
We have implemented technical and organisational measures to ensure a level of security appropriate to the risk presented by the processing in accordance with Art. 24 and 32 UK GDPR.
What happens in a case of a personal data breach?
In case of a personal data breach and if this breach is likely to result in a risk to your rights and freedoms, we will, with the assistance of our Subsidiary and without undue delay and, if possible, not later than 72 hours after having become aware of it, notify the data breach to the Information Commissioner’s Office (ICO) and/or if data of EU citizens is affected the competent supervisory authority of the EU. Should such a breach likely result in a high risk for your rights and freedoms, we or – where required by article 34 UK GDPR – our Subsidiary will inform you about the personal data breach without undue delay.
Contact: If you want to exercise your rights afforded by UK GDPR regulations or if you have any questions for us regarding the processing, you can contact us via email: privacy@ninjakiwi.com
Depending on your request, it is possible that our Subsidiary or we will forward your request to one another; should this be necessary to help each other out to answer your request or to get directly in touch with you for this purpose. In case of a forward of your request, we and our Subsidiary inform each other about the matter to the extent necessary for answering your request.
III. Meaning of Terms
Some terms we use in this Privacy Policy are defined by the UK General Data Protection Regulation ("UK GDPR"), a data protection law of the UK. When we refer to the UK GDPR we are referring to the General Data Protection Regulation of the European Union as well since both laws are very similar, unless we otherwise specify that we are referring to only one of them.
Art. 4 UK GDPR gives detailed definitions of terms which we also apply in this Privacy Policy. We’d like to explicitly mention the meanings of the following terms in simple words since they are used quite often throughout this Privacy Policy. Check out Art. 4 UK GDPR for the detailed definitions:
‘personal data’ means any information relating to a person that can be identified or could be identified through an identifier (‘data subject’);
‘processing’ means using your personal data (e.g., collecting, storing, sharing or deleting it);
‘controller’ means the person, company or other body that decides if and how your personal data is being processed;
‘processor’ means a person, company or other body that processes personal data on behalf of the controller according to the controller’s instructions.
IV. Legal Basis
As a controller we need a legal basis to be allowed to process your personal data. If:
you have given us your consent to process your personal data, this forms a legal basis according to Art. 6 para. 1 let. a) UK GDPR;
you have given us your consent to process special categories of personal data (e.g. data concerning health) for one or more specified purposes, and such consent is possible according to applicable law, this forms a legal basis according to Art. 9 para. 2 let. a) UK GDPR;
processing your personal data is necessary for the performance of a contract between you and us or in order to take steps at your request prior to entering into a contract, the legal basis for this is Art. 6 para. 1 let. b) UK GDPR;
processing your personal data is necessary for compliance with a legal obligation to which we are subject, the legal basis for this is Art. 6 para. 1 let. c) UK GDPR;
processing your personal data is necessary because we or a third party have a legitimate interest to do so and such legitimate interests are not outweighed by your interests or fundamental rights and freedoms, the legal basis for this is Art. 6 para. 1 let. f) UK GDPR.
V. Your Rights
Under the UK GDPR you have the following rights when we process your personal data:
Right of information: You can ask us to let you know what we are doing with your data, e.g., why we collect it, or for how long we keep it (Art. 13 and 14 UK GDPR).
Right of access: You can at any time ask us to confirm as to whether or not we are processing your personal data and, if this should be the case, access to the personal data (Art. 15 UK GDPR).
Right to rectification: If you find that personal data that we process about you is inaccurate, you can ask us to correct it (Art. 16 UK GDPR).
Right to erasure ("right to be forgotten"): Under certain circumstances, e.g., if you have objected to us using your data or if you have withdrawn your consent, you can ask us to delete your personal data. There are certain exceptions to this, e.g., if this would contradict other people’s free speech or if we have a legal obligation for which we need the data (Art. 17 UK GDPR).
Right to restriction: Under certain circumstances, e.g., if your personal data we store isn’t accurate or you have objected to us using your personal data, you have the right to request that we restrict the processing of your personal data until a solution has been found (Art. 18 UK GDPR).
Right to data portability: Under certain circumstances you can receive your personal data you have provided us in a structured, commonly used and machine-readable format and you can transfer this data to another controller (Art. 20 UK GDPR).
Right to object: Under certain circumstances, e.g., if we base the use of your personal data on a legitimate interest, you have the right to object to us using your data. If we don’t have an overriding interest to keep using your data, we will stop using it (Art. 21 UK GDPR).
Right to lodge a complaint: You can always send a complaint regarding our processing of your personal data to a data protection supervisory authority (Art. 77 UK GDPR).
Right to withdraw consent: If you have granted us your consent for us to process your personal data, you have the right to withdraw your consent at any time with effect for the future (Art. 7 para. 3 UK GDPR).
Right to not be subject to a decision based solely on automated processing: You have the right not to be subject to a decision based solely on automated processing which produces legal effects for you or similarly significantly affects you (Art. 22 para 1 UK GDPR). We do not make automated decisions by processing your personal data (e.g., profiling you).
VI. Recipients / Categories of Recipients
The personal data we process can also be either processed by other parties on our behalf and according to our instructions by processors or shared with and processed by other controllers. When data is processed according to this Privacy Policy, it is principally done so by employees and freelancers of ours that are responsible for the specific matter the data is required for.
The following list gives you an overview of the main providers of tools and services we use and who might be recipients of your data:
Office tools, advertising and analytics tools:
Google Ireland Limited
register number 368047
Gordon House
Barrow Street
Dublin 4
Ireland ("Google Ireland")
and
Google LLC, 1600,
Amphitheatre Parkway
Mountain View
CA 94043
USA (both together: "Google")
and
Twilio Ireland Limited
25 – 28 North Wall Quay
Dublin 1
Ireland ("Twilio SendGrid")
and
OneTrust LLC
1200 Abernathy Road, Suite 700
Atlanta
GA 30328
USA ("OneTrust")
Social media platforms and direct messaging:
Facebook Ireland Limited,
4 Grand Canal Square,
Dublin 2
Ireland ("Facebook")
and
Twitter International Company
One Cumberland Place
Fenian Street
Dublin D02 AX07
Ireland ("Twitter")
and
Discord,
444 De Haro Street Suite 200
San Francisco
CA 94107
USA ("Discord")
Customer support tools:
Zendesk, Inc.
1019 Market Street
San Francisco
CA 94103
USA ("Zendesk")
Host providers:
Amazon Web Services
Level 20, Pricewaterhousecoopers Tower
188 Quay Street
Auckland 1010
New Zealand ("AWS")
and
OVHCloud
Becket House 1 Lambeth Palace Road
London SE1 7EU
UK ("OVH")
and
Cloudflare, Inc
101 Townsend Street
San Francisco
CA 94107
USA ("Cloudflare")
Messaging software:
Slack Technologies, Inc.
500 Howard Street
San Francisco
CA 94105
USA ("Slack")
Shop tools:
Shopify Inc.
150 Elgin Street, Suite 800
Ottawa
ON K2P 1L4
Canada
and
Shopify International Ltd.
Victoria Buildings, 2. Etage
1-2 Haddington Road
Dublin D04 XN32
Ireland (both together: "Shopify")
Video and photo platforms:
Google Ireland (YouTube)
and
Twitch Interactive, Inc.
350 Bush Street, 2nd Floor
San Francisco
CA 94104
USA ("Twitch")
Login Providers
Facebook
and
Apple Inc.
1 Infinite Loop
Cupertino
CA 95014
USA ("Apple")
and
Twitch
and
Valve Corporation
10900 NE 4th St, Unit 500
Bellevue
WA 98004
USA ("Steam")
and
Google (Ireland)
And
Amazon Media EU S.a.r.l.
38 Avenue John F. Kennedy
L-1855 Luxembourg ("Game Circle")
Some of these recipients are established outside of the European Union. Principally, there are two possible safeguards we rely on when we share your personal data with these recipients:
If a recipient is located in a country for which the European Commission ("EU Commission") has found it ok to send personal data to, since that country provides an adequate level of data protection, we rely on this so-called adequacy decision by the EU Commission.
If a recipient is not located in a country with an adequate level of data protection according to the EU Commission, we have concluded a special contract with this recipient in which we agree on rules to make sure the recipient takes adequate care of your personal data. This contract is called the EU Standard Contractual Clauses and was developed by the EU Commission.
Since we are located in New Zealand, any data that is transferred to us from our Subsidiaries is transferred to a country that is recognised by the EU Commission as a country that provides an adequate level of data protection. Any data that is transferred by us to our Subsidiary in the UK is transferred to a country that provides an adequate level of data protection according to the EU Commission.
Apart from this, the following categories of recipients process data either on our behalf or with us as joint controllers or as individual controllers: financial and IT services; media; social media platforms; website analytics providers; messaging systems; gameplay analytics.
You can find further information on which recipients and categories of recipients are involved in the processing of personal data under Section VII.
VII. General Data Processing
In the following we’d like to inform you about how we process your personal data. These are the general processing activities that can apply when you interact with us. Every processing activity is broken down into 5 parts:
(a.) What: What data is processed? (b.) Who: Who receives the data? (c.) Why: For what purpose is the data processed? (d.) Legal Basis: What law allows us to process the data? (e.) How Long: How long do we keep the data?
1. Communicating With You
a. What
If we communicate with you via email, mail, or telephone, we process all personal data you disclose to us during our conversation (e.g., you name, email address, the reason why you are contacting us etc.). With your consent we will process your email address to send newsletters and/or marketing information.
Apart from this, it is also possible that we use other online messaging systems to communicate with you, if you wish to contact us over these channels. Please note that if you wish to contact us via such messaging systems, it is possible that the respective companies that offer these communication services may also process your personal data and that regarding this their privacy policies apply. We have no influence over such data processing by third parties. For further information on how these services process your personal data, please view their privacy policies.
b. Who
Recipients of the processed personal data are the respective internal employees and freelancers of ours that are responsible for pursuing our purposes for the processing (e.g., someone from a department that you are contacting with a request). Possible further recipients: the providers of the respective messaging systems; Facebook, Twitter, Discord, Zendesk
Depending on the specific topic of the conversation as well as the circumstances (e.g., a certain game you’re playing) it is possible that our Subsidiaries jointly process personal data with us according to Sect.II.
c. Why
Depending on the specific conversation with you, the personal data can either be processed in order to take steps at your request prior to entering into a contract with us or to perform a contract you have concluded with us. Also, the processing can be necessary for us to comply with legal documentation obligations. Also, the processing can be necessary for the purposes of our legitimate interest to respond to mails and calls of yours when you contact us and are not our contractual partner as well as to have proof regarding substantial content of our conversation, including but not limited to cases of potential legal claims on our or your side.
d. Legal Basis
The legal basis for processing the personal data in order to take steps at your request prior to entering into a contract with us or to perform a contract you have concluded with us is Art. 6 para. 1 let. b) UK GDPR. The legal basis for processing the data for compliance with our legal obligations is Art. 6 para. 1 let. c) UK GDPR. The legal basis for processing the data due to our legitimate interest is Art. 6 para. 1 let. f) UK GDPR. The legal basis for processing the data at your request is Art.6 para. 1 let. a) UK GDPR.
e. How long
The data is stored at least for the time until our contract with you is fully performed. If the data has been stored in order to take steps at your request prior to entering into a contract with us, we will store the data for as long as reasons objectively exist to believe that the respective conversation will be continued within the foreseeable future. Any other data will be retained for a period of five years starting with the end of the year in which we received the communications.
If the data is also processed for another purpose set out in this Privacy Policy, the storage period regarding that purpose applies as well.
2. Visiting our Websites
a. What
When you visit our website, we process personal data of yours, such as your IP-address, the time of your visit, what browser type you use, country of origin, if applicable, also the website from which you were referred to our website.
b. Who
Recipients of the processed personal data are the respective internal employees and freelancers of ours that are responsible for pursuing our purposes for the processing. Possible further recipients: IT service providers and host providers, especially Amazon Web Services and CloudFlare.
Depending on the specific case, it is possible that our Subsidiaries jointly process personal data with us according to Sect. II.
c. Why
We process this data to display the website correctly in your browser, so you are able to make use of the full functionality of the services and the website content. We also process the data for troubleshooting, should the website not work correctly as well as for security purposes (e.g. to prevent malicious attacks on our website). These are legitimate interests of ours.
d. Legal Basis
The legal basis for processing the data is Art. 6 para. 1 let. f) UK GDPR.
e. How long
The data is stored for as long as our legitimate interest is given. For this, the data is stored for the time that we reasonably need to ensure our systems have not been subject to malicious use and to be able to effectively respond to any potential bugs or other malfunctions of the website.
If the data is also processed for another purpose set out in this Privacy Policy, the storage period regarding that purpose applies as well.
3. Ninja Kiwi Website Registration
a. What
Registration for ninjakiwi.com is exclusively for the website and does not apply to mobile games or forums, which are separate registrations. Registration asks for username, email, and password or for 3rd party login via Facebook or Google. Players under the age of 16 are directed specifically to use parent or guardian emails.
Your Ninja Kiwi Website profile will have multiple stats stored on our servers which are based on your web game performance and actions. For example, profile level, coins earned, clan chosen, etc.
b. Who
Recipients of the processed personal data are the respective employees and freelancers of ours that are responsible for processing the data. Possible further recipients: IT service providers and host providers.
Depending on the specific case, it is possible that our Subsidiaries jointly process personal data with us according to Sect. II.
c. Why
While you do not need to register to play many of the games on ninjakiwi.com, several games or game features will not work without a successfully registered account, since they are online multiplayer or online co-op games with the key feature of playing with or against other players. Also, we cannot provide effective customer support for game progress in such games without a successfully registered account.
We might email all registered players in the case of legal notices or major company news.
d. Legal Basis
The legal basis for processing the data is to enter into or perform a contract we concluded with you is Art. 6 para. 1 let. b) UK GDPR.
e. How long
Your account data is stored for as long as you maintain your account which can be closed anytime at your request, or it will be deleted automatically after 5 years of inactivity. If possible, we will notify you one week before we delete your inactive account to give you the possibility to keep your account if you wish.
If the data is also processed for another purpose set out in this Privacy Policy, the storage period regarding that purpose applies as well.
4. Ninja Kiwi Account Registration
a. What
When you register for a Ninja Kiwi account, this account can be used across most Ninja Kiwi games but does not provide registration to ninjakiwi.com or forums. You may provide us with an email that we use as a unique identifier for your account or choose a 3rd party login like Facebook, Apple, Google, Steam, Twitch, or Gamecenter.
If you are under the age of 16 you are allowed to register for Ninja Kiwi accounts, but you cannot supply any personally identifiable information (e.g., no email address or name) and are instead generated:
a random non-editable player name,
a randomly assigned unique long and short code, and
a randomly assigned unique recovery code.
For games with social guilds such as Clans, Parties, or Teams, you must identify your age before you join a Clan, Party, or Team in these games, and you are then excluded from sending, receiving, or reading any user generated chat messages. Depending on the game, chat is either completely disabled or limited to canned messages for users under 16. Instead of simply excluding minor players from the game or from participating in social guilds, we chose this approach as it allows underage players to participate in the fun of social guild play and be part of a team, but without risking personal data sharing.
If you are 16 and over you can use the chat functionality. For this functionality we process the information you enter into the chat.
Please note that for some games, your leaderboard scores and player name may be publicly available to other players.
b. Who
Recipients of the processed personal data are the respective employees and freelancers of ours that are responsible for processing the data. Possible further recipients: IT service providers and host providers.
Depending on the specific case, it is possible that our Subsidiaries jointly process personal data with us according to Sect. II.
c. Why
The registration data is required so you can play the game as intended to allow you to contact support@ninjakiwi.com from that email, so that customer support can immediately validate the account ownership and offer assistance more quickly.
If you are considered a minor, the randomly assigned nickname is required to identify you as a player for other players in the game, the short and long randomly assigned unique codes are required so we can make the game work and the randomly assigned recovery code can be used by you to get support from us.
We might email all registered players in the case of legal notices or major company news, provided we have their email address.
d. Legal Basis
The legal basis for processing the data to enter into or perform a contract we concluded with you is Art. 6 para. 1 let. b) UK GDPR as well as Art. 6 para. 1 let. f) UK GDPR since it’s a legitimate interest of ours to provide you a game that works properly.
e. How long
Your account data is stored for as long as you maintain your account which can be closed anytime at your request, or it will be deleted automatically after 5 years of inactivity. If possible, we will notify you one week before we delete your inactive account to give you the possibility to keep your account if you wish.
Chat data is deleted automatically four weeks after being sent.
If the data is also processed for another purpose set out in this Privacy Policy, the storage period regarding that purpose applies as well.
5. Game Data
a. What
We track gameplay information about the way you play our mobile games, which includes game and player progress information that is essential for saving and protecting that progress. Analytics track elements of the game you interact with most and least frequently, where you stop playing or play less, and other aspects of aggregating player progression through the game.
For players aged 16, IP address, device type, OS type, time stamp, and other general device level information are accessed and stored on distributed, scalable servers. For players under age 16 no personal data is stored.
b. Who
Recipients of the processed personal data are the respective employees and freelancers of ours that are responsible for processing the data. Possible further recipients: IT service providers and host providers.
Depending on the specific case, it is possible that our Subsidiaries jointly process personal data with us according to Sect. II.
c. Why
The data is used to fix bugs and help you out if you contact us to report technical issues as well as for anti-cheat purposes. We also use gameplay information to identify the most engaging components of our game designs, so we can better concentrate our development work where players are having the most fun. These are legitimate interests of ours and our players.
d. Legal Basis
The legal basis for processing data based on our legitimate interest is Art. 6 para. let. f) UK GDPR.
e. How long
Your account data is stored for as long as you maintain your account which can be closed anytime at your request, or it will be closed automatically after 5 years of inactivity. If possible, we will notify you one week before we delete your inactive account to give you the possibility to keep your account if you wish. If you delete your account, analytics data will be kept under a random anonymous ID that cannot be linked to you after you have deleted your account.
If the data is also processed for another purpose set out in this Privacy Policy, the storage period regarding that purpose applies as well.
6. Advertising
a. What
Since some of our games are free to download and play, we display ads in many of these free games. The advertising companies pay us for displaying the ads and this makes it possible for us to offer you the game free of charge. Apart from this, we might also give you the possibility to watch an ad instead of paying for a feature that you otherwise would have to pay for in a game of ours. When displaying ads, we use third-party advertising companies to serve the ads in our games. The third-party advertising companies may collect and use information (but not your name, address, email address, telephone number, or other personal data) about how you play our games.
Non-personally identifiable information to manage and measure the delivery of advertising within that game can be collected, including the number of times the same advertisement is served and viewed.
For players registered as under age 16 we use designated non-personal data ad calls that either do not send personal data (usually IP address) or encrypt that personal data so that we have no access to it. Ad companies may use non-personally identifiable information (e.g., click stream information, browser type, time and date, heat maps, player behaviour) when you play our games in order to provide ads about goods and services likely to be of greater interest to you. These companies typically use a cookie or third-party beacon to collect this information. We do not have access to this information or influence over third party ad network policies, barring our ability to discontinue their services.
You can choose to agree or disagree with us sharing your personal data for displaying targeted ads depending on which platform you play our games:
iOS: Choose from the consent pop-up at the start of the game (if you haven’t already generally disabled tracking in your system settings).
Android: Opt out of ad tracking by going to Settings > Ads > Opt out of Ads Personalisation
Fire OS: Opt out of ad tracking by going to Settings > Security & Privacy > Advertising ID > Interest-Based Ads
If you would like more information about advertising practices and to know your choices about not having this information used by these companies, you can visit Google's Advertising and Privacy page or the Network Advertising Initiative. Please understand that if you disable or block certain ad features, then other aspects of our mobile games may not work correctly.
b. Who
Recipients of the processed personal data are the respective employees and freelancers of ours that are responsible for pursuing our purposes for the processing. Possible further recipients: Ad Networks.
Depending on the specific case, it is possible that our Subsidiaries jointly process personal data with us according to Sect. II.
c. Why
The data is processed by us to provide advertisements about goods and services of interest to you. We offer our mobile games for free, so these ads allow us to continue making and updating top quality free games which is a legitimate interest of ours but also of yours if you want to play games for free. Without displaying personalised ads, we would not make sufficient money to keep offering the games for free to you.
d. Legal Basis The legal basis for processing your personal data for personalised ads on iOS is your consent (Art. 6 para. 1 let. a) UK GDPR). If you are an Android player, the legal basis is our legitimate interest (Art. 6 para. 1 let. f) UK GDPR).
e. How long
The data is stored for as long as you maintain your account which can be closed anytime at your request, or it will be closed automatically after 5 years of inactivity. If possible, we will notify you one week before we delete your inactive account to give you the possibility to keep your account if you wish. If you delete your account, analytics data will be kept under a random anonymous ID that cannot be linked to you after you have deleted your account.
If the data is also processed for another purpose set out in this Privacy Policy, the storage period regarding that purpose applies as well.
7. Facebook, Apple, Google, Game Center, Twitch, Steam and Game Circle Logins
a. What
When you register for Ninja Kiwi using Facebook, Apple, Google, Twitch, Steam, Game Center or Game Circle or share links through these services, Ninja Kiwi accesses data already provided to those login services. Please check their privacy policies for details on how they share information when you make use of their login services. We are only granted access to that information via the player-approved permissions necessary to use those games or services.
b. Who
Recipients of the processed personal data are the respective employees and freelancers of ours that are responsible for processing the data. Possible further recipients: the provider of the third-party login platform (Facebook, Twitter, Google (YouTube), etc.).
c. Why
We use these services to simplify logins to our mobile and website logins and to connect players to their friends for co-operative and competitive play, and to compare scores and progress. We use the respective platform standard versions of these services and only reference the username/email associated with your saved data, scores, and game progress.
d. Legal Basis
The legal basis for processing data based on our legitimate interest is Art. 6 para. 1 let. f) UK GDPR.
e. How Long
Any data provided for login services will be retained for as long as the player account is active. Once the player account has been deleted or the retention period of 5 years of inactivity has been reached the data will be deleted along with the player account data.
If the data is also processed for another purpose set out in this Privacy Policy, the storage period regarding that purpose applies as well.
8. Social Media Presences
a. What
We have presences on social media platforms such as Facebook, Instagram, Twitter, Discord, and Reddit that help us connect with our players and the most awesomer Ninja Kiwi community.
When you interact with a social media presence of ours (e.g. you comment on a post of ours or write on our timeline), we process your name/nickname, profile picture and other personal data that your account may publicly display as well as personal data that you provide e.g. in a comment or post of yours. This Privacy Policy applies only to Ninja Kiwi. Please be aware that when you use social media platforms the providers of such platforms process your personal data as well and their privacy policy or terms of service of third parties apply. We refer you to the respective terms and privacy policies for details on how they handle your data.
If you apply as a moderator for our Discord and Reddit channels, we require your username and time zone.
b. Who
Recipients of the processed personal data are the respective employees and freelancers of ours that are responsible for processing the data. Possible further recipients: the provider of the social media platform.
c. Why
Your personal data is processed by us to effectively communicate with you within the social media platform (e.g. respond to posts and comments). If you apply as moderator, we require the data to be able to appropriately identify and assign you as such. These are legitimate interests of ours.
d. Legal Basis
The legal basis for processing data based on our legitimate interest is Art. 6 para. 1 let. f) UK GDPR.
e. How long
The data is stored for as long as we maintain the respective social media presence and you do not decide to delete your account or the respective post, comment or other interaction with us on the social media presence. If you are a moderator, the data is stored for as long as you have this role.
If the data is also processed for another purpose set out in this Privacy Policy, the storage period regarding that purpose applies as well.
9. Applications (only Ninja Kiwi Europe Ltd.)
a. What
Our Subsidiary processes the personal data you provide when applying for a job or to work together with it as a freelancer (e.g., your name, date of birth, address, etc.).
b. Who
Recipients of the processed personal data are the respective employees of our Subsidiary that are responsible for pursuing its purposes for the processing (e.g. HR employees, your potential line manager and management). Possible further recipients: Google (Workspace).
Depending on the specific case, it is possible that we jointly process personal data with our Subsidiary according to Sect. II.
c. Why The data is processed to decide if a contract with you will be concluded or, if you already have a contract with our Subsidiary, to perform our obligations or terminate the contract.
d. Legal Basis
The legal basis for processing the personal data is Art. 6 para. 1 let. b) UK GDPR.
e. How long
If we work together with you, your data is stored for the applicable statutory storage periods, at least for six years and one month starting at the end of the year in which your contract has ended.
All job application data from applications that have been declined or reserved will be stored for up to six months after your application has been received.
If the data is also processed for another purpose set out in this Privacy Policy, the storage period regarding that purpose applies as well.
10. Data Subject Requests
a. What
When you contact us to make use of your data subject rights (see above), we process your name, email address and any additional information you provide us in your request.
To make sure we can correctly identify you we may ask you to provide a copy of your passport or other identification document ("ID"). When you upload this information, we will process the personal data of yours stated on the ID, namely: your name, birth date, address and validity of the document. Please make any other data on the copy of your ID-document unreadable (e.g. serial number of the document) before the upload and mark the document as copy (e.g. add the imprint "copy" on it).
We kindly ask you to only use the portal in which your ticket was created for you after addressing us over privacy@ninjakiwi.com to upload the ID. Documents provided through any other channel are not accepted and will be deleted by us.
b. Who
Recipients of the processed personal data are the respective employees and freelancers of ours that are responsible for answering your request. Possible further recipients: Zendesk; OneTrust.
Depending on the specific case, it is possible that our Subsidiaries jointly process personal data with us according to Sect. II.
Only the designated employees of ours entrusted with privacy matters, and possibly employees that maintain our IT infrastructure, will view your ID. Processors processing your data on our behalf are Zendesk; OneTrust.
c. Why
The personal data of your request is processed for the purpose of answering your request – if necessary also with the help of other Ninja Kiwi companies or to answer such request for other Ninja Kiwi companies should it be directed at it – as well as the purpose of proving our compliance with the UK GDPR by helping you as data subject exercise your rights set out in the UK GDPR. This is also a legitimate interest of ours.
We process the ID data to verify your identity. This is required to prevent cases of fraud committed by using false identities. We have a legitimate interest in this purpose that outweighs a potential contrary interest of yours to not disclose this information, since we have a responsibility in protecting our players’ and partners’ personal data and since we will delete your ID promptly after we have verified your identity. The ID will not be used for any other purposes.
d. Legal Basis
The legal basis for processing the data of your request and – if necessary – sharing this information with our Subsidiaries is Art. 6 para. 1 let. c) in connection with Art. 12 UK GDPR as well as Art. 6 para let. f) UK GDPR.
The legal basis for ID verifications is Art. 6 para. 1 let. f) UK GDPR.
e. How long
The data of your request is stored for 5 years and one month starting with the end of the year in which you made your request.
The uploaded ID will be deleted promptly after we have verified your identity.
If the data is also processed for another purpose set out in this Privacy Policy, the storage period regarding that purpose applies as well.
11. B2B Partnerships
a. What
When we communicate and conclude contracts with you as a business partner (B2B only), we store certain personal data of yours in our B2B database, such as your business email address and other business information related to our (potential) partnership.
b. Who
Recipients of the processed personal data are the respective employees and freelancers of ours that are responsible for pursuing our purposes for the processing. Possible further recipients: Google (Workspace);.
Depending on the specific case, it is possible that our Subsidiaries jointly process personal data with us according to Sect. II.
c. Why
The data is processed to decide if a contract with you will be concluded or, if you already have a contract with us, to perform our obligations or terminate the contract.
We also have a legitimate interest in processing this data of yours to be able to remain in contact with you for business purposes. We have a legitimate interest in processing the information of B2B contacts with whom we have a contractual relationship or objectively likely will have a contractual relationship with in the future. Since this is not only necessary to properly perform the contract between us and them, but also to facilitate communication with them concerning their cooperation with us. We also have a legitimate interest in processing the personal data of the B2B contacts who are currently not commissioned by us and have not been commissioned in the past, since it facilitates getting in touch with them for future projects.
d. Legal Basis
The legal basis for processing the personal data to enter into or perform a contract with you is Art. 6 para. 1 let. b) UK GDPR. The legal basis for processing the personal data based on our legitimate interest is Art. 6 para. 1 let. f) UK GDPR.
e. How long
Documentation regarding B2B contacts that we have concluded a contract with will be stored for as long as the contract remains active or for up to 5 years and one month after that contract has ended in case we want to contact you in the future.
Personal data of B2B contacts with whom we have no contract and have no objective reasons to believe we will be concluding a contract with in the near future, will be deleted from our database after 3 years of inactivity.
If the data is also processed for another purpose set out in this Privacy Policy, the storage period regarding that purpose applies as well.
12. Legal Work
a. What
We work together with our Subsidiaries and external consultants to assess and manage legal matters. If a matter or dispute between you and us or between you and our Subsidiaries requires relevant legal review, we and, if necessary, the relevant subsidiary process the data relevant to the matter or dispute. In particular, this may include your name, e-mail address and contact details.
b. Who The recipients of the personal data processed are our respective employees and freelancers responsible for processing the matter. Possible further recipients: Google (Workspace); External Legal Consultant.
Depending on the specific case, it is possible that our Subsidiaries jointly process personal data with us according to Sect. II.
c. Why
The purpose of the processing of the data by us and – if applicable – our Subsidiaries is the effective and uniform handling of legal matters. This is a legitimate interest of ours and our Subsidiary. In addition, the data processing may serve to conclude and perform contracts with you.
d. Legal Basis
As far as the data processing concerns the conclusion or performance of a contract with you, the legal basis of the data processing is Art. 6 para. 1 let. b) UK GDPR.
If the data processing is based on a legitimate interest, the legal basis is Art. 6 para. 1 let. f) UK GDPR.
e. How Long
The storage period for data processed for the purpose of handling legal matters or disputes is governed by the relevant limitation period, so that we can sufficiently defend ourselves against claims, or by the relevant legal obligations to retain documents.
If the data is also processed for another purpose set out in this Privacy Policy, the storage period regarding that purpose applies as well.
13. Shop
a. What
You can buy products on our online shop. In this case, we process the personal data you enter during the ordering process, such as your name, e-mail address, contact details and information about your purchase.
b. Who
The recipients of the personal data processed are our respective employees and freelancers responsible for processing the matter. Possible further recipients: Shopify.
Depending on the specific case, it is possible that our Subsidiaries jointly process personal data with us according to Sect. II.
c. Why
We process the data in order to initiate a contract with you and to conclude and perform it when you make a purchase, as well as to fulfil our accounting and tax obligations.
d. Legal Basis
The legal basis for the processing of data for the concluding or performing a contract we have concluded with you is Art. 6 para. 1 let. b) UK GDPR.
The legal basis for the processing of data on the basis of one of our legal obligations is Art. 6 para. 1 let. c) UK GDPR.
e. How Long
The purchase data will be stored for 7 years to comply with retention obligations for financial records.
If the data is also processed for another purpose set out in this Privacy Policy, the storage period regarding that purpose applies as well.
14. Raffles and Giveaways
a. What
Visitors to our social media profiles have the opportunity to win prizes by interacting with certain posts. In this case winners are contacted through their social media account and asked to send us directly their details, such as name, e-mail address and address so that we can award their prize.
b. Who
The recipients of the personal data are our respective employees. Possible further recipients: Shopify.
Depending on the specific case, it is possible that our Subsidiaries jointly process personal data with us according to Sect II.
c. Why
The personal data is processed so that the raffle or give away can be concluded and a prize sent to the winner.
d. Legal Basis
The legal basis for the processing of data for this is Art. 6 para 1 let b) UK GDPR.
e. How Long
The data will be stored until we receive confirmation that the prize has been received or up to six months following shipping.
If the data is also processed for another purpose set out in this Privacy Policy, the storage period regarding that purpose applies as well.
VIII. Group Cooperation
We are part of a group of gaming studios that are owned by our parent company Modern Times Group MTG AB ("MTG"), a Swedish gaming company. We cooperate with MTG and the other gaming studios of the group (each a "Group Company") to learn from one another, help each other and improve how we all make games. We like to see ourselves as a small gaming village in which we strive together to make great games.
Joint controllerships
In some cases when we cooperate with MTG and/or a Group Company, we jointly determine if and how certain personal data of yours is processed. In such a case the involved companies each are controllers of your data when doing so. We have concluded an agreement with MTG and all Group Companies in which the rules for our joint controllership are set out and which also includes so called standard contractual clauses which ensure that personal data of European players is adequately safeguarded when transferred between us and a Group Company which is not established in the European Union or a country considered to have the same level of data protection as the European Union.
Joint controllerships between us and MTG or us and a Group Company:
1. Mergers and Acquisitions
a. What
MTG, the Group Companies and us can support each other when buying or selling a company. In such cases a strictly limited number of personnel involved in such a transaction can receive access to personal data (e.g., names, email addresses, unique identifiers) included in relevant documentation shared by a potential seller or determine which personal data is shared with a potential buyer and how this shall be done. Principally, personal data is anonymised before it is disclosed and, should it be necessary to disclose personal data, such disclosure of personal data will be kept to a minimum.
b. Who
Recipients of the processed personal data can be our providers of office tools, providers of data rooms as well as external financial and legal advisors, MTG, involved Group Companies, and the potential buyer. We can receive your personal data from a Group Company, or a potential seller in which case the same recipients can apply.
c. Why
The purpose of such a cooperation is to review relevant material shared with us by a potential seller, so we and/or MTG, and/or the involved Group Companies can make good business decisions, or to enable a potential buyer to do so when sharing such data with it. This is a legitimate interest of ours, MTG, the involved Group Companies, and the potential sellers or buyers.
d. Legal Basis
The legal basis for processing your personal data is our legitimate interest, Art. 6 para. 1 let. f) UK GDPR
e. How Long
The storage period for data processed for the purpose of handling legal matters or disputes is governed by the relevant limitation period, so that we can sufficiently defend ourselves against claims, and by relevant legal obligations to retain documents. If a transaction has been successful, we might be obliged to store the respective personal data according to the applicable statutory provisions, in which case we will store the documents according to the retention periods stated in such provisions. Personal data that is no longer relevant if a transaction has not been successfully made, will be deleted if it is not relevant for another purpose under this privacy policy.
Joint controllerships between us and MTG:
1. Business Intelligence
a. What We share a limited amount of data with MTG to get a better understanding of how you play our games and what you like about them so we can improve them. This includes a group-internal unique identifier, game title, time of install, platform, country code per install, marketing channel/category and marketing campaign, browser information, engagement with the game (log-in sessions), amount of money spent in the game, and how effective a marketing campaign was.
b. Who
The Recipient of the processed personal data is our parent company, MTG. The information is not shared with Group Companies.
c. Why
A better understanding of how you play our games and what you like about them helps us to make them better and improve how we market them. As a gaming studio, it is essential for us that we can understand how games are played and how effective our marketing efforts are to ensure that enough players enjoy our games so we can keep making them. This interest is shared by MTG and the Group Companies.
d. Legal Basis
The legal basis for processing your personal data is our legitimate interest, Art. 6 para. 1 let. f) UK GDPR
e. How Long
The data is stored for as long as you are an active player of the game. Your data will be deleted or anonymised after six years of inactivity, which depends on the date of the last time you played a game of ours.
2. Data Protection Compliance Work
a. What
MTG supports us with our data protection compliance work. We can jointly process personal data of yours required to ensure compliance with data protection laws, e.g., names, email addresses, usernames, unique identifiers (e.g., game-ID players). E.g., this can be the case when you reach out to us with a data protection request, and we seek MTG’s support to respond adequately and in time.
b. Who
Recipients of the processed personal data can be our providers of office tools, OneTrust and MTG.
c. Why
We want to be able to offer you a high level of data protection when you play our games. To ensure that we comply with the relevant data protection laws we receive support from MTG. This is a legitimate interest of ours, MTG, the other Group Companies and you.
d. Legal Basis
The legal basis for processing your personal data is Art. 6 para. 1 let. c) and f) UK GDPR
e. How Long
The data will be stored for the duration that we need to be able to prove that we are complying with data protection laws. Due to this, data protection requests of yours will be stored for five years and one month.
Who can you contact?
When we process your personal data, you have certain rights under the GDPR, which you can find in section V of this privacy policy. If you have questions regarding the joint controllerships or want to make use of your data protection rights, you can contact us anytime. You can find a detailed list of your rights and our contact address in section V and section I of this privacy policy.
How is your data secured?
We have implemented technical and organisational measures to ensure a level of security appropriate to the risk presented by the processing in accordance with Art. 24 and 43 GDPR.
What happens in a case of a personal data breach?
In case of a personal data breach under the GDPR and if this breach is likely to result in a risk to your rights and freedoms, MTG will, without undue delay, and where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the competent supervisory authority.
Should such a breach likely result in a high risk for your rights and freedoms, we, or – where required by article 34 GDPR -, MTG, or the respective Group Company will inform you about the personal data breach without undue delay.
IX. Other Cooperations
Apart from cases in which we jointly process personal data, we cooperate within the group in the following cases:
1. Developing or Distributing Games
a. What
MTG can support us when we are developing or distributing our games (e.g., consulting regarding game features or functionalities). In the process of this it is possible that certain personal data of players of our games might be disclosed to MTG, such as names, email addresses, usernames, or unique identifiers. Such personal data will not be actively stored or used by MTG for such support.
b. Who Recipients of the processed personal data can be our providers of office tools and MTG.
c. Why
Since we are part of the same group and MTG is our parent company, we both share the same legitimate interest of developing and distributing great games. To be able to do this we work closely together.
d. Legal Basis
The legal basis for processing your personal data is our legitimate interest, Art. 6 para. 1 let. f) UK GDPR
e. How Long
The personal data is stored by us according to the applicable retention periods of this privacy policy (e.g., the retention period of your account data).
2. Legal Support
a. What
MTG supports us with legal guidance regarding legal complaints, claims, court proceedings or other legal matters we might be facing. In such cases MTG might receive personal data (e.g., names and contact details of plaintiffs or complainants) of persons involved in such legal matters from us.
b. Who
Recipients of the processed personal data can be our providers of office tools and MTG.
c. Why
Since we are part of the same group and MTG is our parent company, we both share the same legitimate interest in effectively handling legal complaints, claims, court proceedings or other legal matters we might be facing. To be able to do this we work closely together.
d. Legal Basis
The legal basis for processing your personal data is our legitimate interest, Art. 6 para. 1 let. f) UK GDPR
e. How Long
Data will be retained according to legal obligations (e.g., employment laws) or our legitimate interest of defending ourselves against legal claims.
3. Freelancer & Outsourcing
a. What
If you are a freelancer providing services to us, we can share certain personal data of yours with MTG, e.g., names and contact details.
b. Who
Recipients of the processed personal data can be our providers of office tools and MTG.
c. Why
Since we are part of the same group and MTG is our parent company, we both share the legitimate interest of effectively handling budgets and ensuring an effective project management which can make it necessary for us to share with MTG information on the freelancers with whom we work with.
d. Legal Basis
The legal basis for processing your personal data is our legitimate interest, Art. 6 para. 1 let. f) UK GDPR
e. How Long
The personal data will be stored at least for the term of the contract you have with us and, if required by bookkeeping laws, as long as it is necessary to retain documentation on financial transactions connected to your work.
X. Privacy Information for California Residents
If you are a consumer residing in California, the California Consumer Privacy Act ("CCPA") applies when you use our Services. The CCPA defines personal information and sensitive information as follows:
"Personal information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
"Sensitive personal information" is personal information that reveals:
A consumer’s social security, driver’s licence, state identification card, or passport number.
A consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.
A consumer’s precise geolocation.
A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership.
The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication.
A consumer’s genetic data.
Sensitive personal information can also mean:
The processing of biometric information for the purpose of uniquely identifying a consumer.
Personal information collected and analysed concerning a consumer’s health.
Personal information collected and analysed concerning a consumer’s sex life or sexual orientation.
The information we provide in Sections VII, VIII and IX of this Privacy Policy regarding which personal data we process, and for which purposes we process it, apply correspondingly to cases in which we process personal information of yours as resident of California.
Please view the following chart for information on what personal information of yours we share to which recipients and for how long we intend to store it.
Under the CCPA "sharing" principally means making a consumer’s personal information available to a third party for cross-context behavioural advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioural advertising for the benefit of a business in which no money is exchanged.
Category of Personal Information | Third Parties With Whom We Have Shared This Information | Retention Period --- | --- | — Identifiers such as an alias, unique personal identifier, online identifier, Internet Protocol address, or other similar identifiers. | Advertising companies that provide ads in our games (e.g. ad networks, mediation platforms). | We will retain the data for as long as is reasonably necessary to provide our services to you but not more than 5 years after your account is inactive. Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Advertising companies that provide ads in our games (e.g. ad networks, mediation platforms). | We will retain the data for as long as is reasonably necessary to provide our services to you but not more than 5 years after your account is inactive. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement.| Advertising companies that provide ads in our games (e.g. ad networks, mediation platforms). | We will retain the data for as long as is reasonably necessary to provide our services to you but not more than 5 years after your account is inactive. Geolocation data. | Advertising companies that provide ads in our games (e.g. ad networks, mediation platforms). | We will retain the data for as long as is reasonably necessary to provide our services to you but not more than 5 years after your account is inactive.
Please view the following chart for information on what personal information of yours we disclose for a business purpose to which recipients and for how long we intend to store it.
According to the CCPA, "business purposes" are:
Auditing: Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
Security and Integrity: Helping to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for these purposes.
Debugging: Debugging to identify and repair errors that impair existing intended functionality.
Short-term, transient use: This includes, but is not limited to, non-personalised advertising shown as part of your current interaction with us, provided that your personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction with us.
Performing services on behalf of the business: this includes maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of us.
Advertising and marketing services: Providing advertising and marketing services, except for cross-context behavioural advertising, to you provided that, for the purpose of advertising and marketing, a service provider or contractor shall not combine your personal information if you have opted-out that the service provider or contractor receives from, or on behalf of, us with personal information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with you.
Internal Research: Undertaking internal research for technological development and demonstration.
Quality or safety of a service or device: Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.
Category of Personal Information | Third Parties With Whom We Have Shared This Information | Retention Period --- | --- | — Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. | Service providers of office tools, social media platforms, customer support tools, host providers, shop tools and login providers. | We will retain the data for as long as is reasonably necessary to provide our services to you but not more than 5 years after your account is inactive. Any personal information described in subdivision (e) of Section 1798.80 | Service providers of office tools, social media platforms, customer support tools, host providers, shop tools and login providers. | We will retain the data for as long as is reasonably necessary to provide our services to you but not more than 5 years after your account is inactive Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Service providers of office tools, social media platforms, customer support tools, host providers, shop tools and login providers. | We will retain the data for as long as is reasonably necessary to provide our services to you but not more than 5 years after your account is inactive Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement. | Service providers of office tools, social media platforms, customer support tools, host providers, shop tools and login providers. | We will retain the data for as long as is reasonably necessary to provide our services to you but not more than 5 years after your account is inactive. Geolocation data. | Service providers of office tools, social media platforms, customer support tools, host providers, shop tools and login providers. | We will retain the data for as long as is reasonably necessary to provide our services to you but not more than 5 years after your account is inactive.
Please view the following chart for information on what sensitive personal information of yours we collect and use, for which purpose we do this, and for how long we intend to store it. We do not share or sell your sensitive personal information.
Category of Sensitive Personal Information | Third Parties With Whom We Have Shared This Information | Retention Period --- | --- | — A consumer’s account log-in, in combination with any required security or access code, password, or credentials allowing access to an account. | We use a consumer’s account login details to enable them to log in, play our games and save progress. | We will retain the data for as long as is reasonably necessary to provide our services to you but not more than 5 years after your account is inactive.
Your Rights
If you are a resident of California, you have the following rights:
Right to Delete Personal Information: You have the right to request that we delete your Personal Information. Depending on the specific case, exceptions can apply to this right, e.g/, if we have to keep you information to comply with legal obligations or to ensure the freedom of expression (Section 1798.105 CCPA).
Right to Correct Inaccurate Personal Information: You have the right to request the correction of Personal Information we maintain about you (Section 1798.106 CCPA).
Right to Know What Personal Information is Being Collected:
You have the right to request the following information from us (Section 1798.110 and 1798.115 CCPA):
The categories of personal information we have collected about you.
The categories of sources from which the personal information is collected. -The business or commercial purpose for collecting, selling, or sharing personal information. -The categories of third parties to whom we disclose personal information. -The specific pieces of personal information we have collected about you.
The categories of personal information that we sold or shared about you and the categories of third parties to whom the personal information was sold or shared, by category or categories of personal information for each category of third parties to whom the personal information was sold or shared.
The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
Right to Opt-Out of Sale and Sharing: We do not sell your Personal Information. We share your Personal Information with advertising partners to show you ads that might be more interesting to you. You have the right to opt out of any sale or sharing of your Personal Information (Section 1798.120 CCPA). Please see Section VII (6) of this Privacy Policy on how to do this.
Right to Limit the Use and Disclosure of Sensitive Personal Information: Even though we do not process Sensitive Personal Information of yours, we’d like to also inform you that you principally have the right to limit the use or disclosure of your Sensitive Personal Information should we be using such data of yours beyond what is reasonable and proportionate to provide the requested services or other purposes permitted by the CCPA (Section 1798.121 CCPA).
Right of No Retaliation Following Opt Out or Exercise of Other Rights: If you exercise your CCPA rights, you have the right that we do not unlawfully treat you in a detrimental way (Section 1798.152 CCPA). Please note though, that depending on your request, features within our game might not work the same way as they would have without your request (e.g., if you want to see ads that might interest you more).
Terms of Service
Last Updated: March 4, 2025Latest Updates
For ease of access and understanding, recent revisions are highlighted here, but please take the time to read this full Terms of Service agreement as this is a binding legal agreement between you and Ninja Kiwi Limited.
In compliance with California’s Consumer Privacy Act, we have added clarity in our Privacy Policy about how California residents (or their parents or guardians) can request access to information stored and/or to delete that information via request to privacy@ninjakiwi.com.
In compliance with Europe’s General Data Protection Regulation (GDPR), we have updated our Ninja Kiwi Login to explicitly ask whether players are under 16; in the case that players are under that age limit, no personally identifiable information (PII) will be requested during login and other PII such as IP address will not be stored. Further GDPR information is also located in our Privacy Policy.
This Terms of Service and the Ninja Kiwi Privacy Policy are addressed to players at least 16 years of age. If a player is below the age of 16, they must have a parent or guardian read and accept these Terms of Service and the Ninja Kiwi Privacy Policy on their behalf.
Ninja Kiwi has updated its Fan Content terms to make it clearer and easier for streamers and content creators to work with Ninja Kiwi games.
Ninja Kiwi has updated terms specific to the player creator revenue sharing available within Bloons TD 6.
Introduction/Binding Agreement
These Terms of Service govern your access to and use of the Application and/or Ninja Kiwi Login, including any content, information, products, related communications, or related Services. This is a binding legal agreement between you and Ninja Kiwi Limited. (“Ninja Kiwi”) and applies to you in relation to any interaction with the Application, Ninja Kiwi Login, Services, or any related communications. Your access and use of the Application, Ninja Kiwi Login, or Services or participation in related communications signifies your acceptance of these Terms of Service and agreement to the collection, storage, review, and use of your information; this information will be stored on servers, some of which may be located in the United States. If you do not accept these Terms of Service and the Ninja Kiwi Privacy Policy in their entirety, you may not access, engage, or in any way use the Application, Ninja Kiwi Login, or any related Services. Ninja Kiwi reserves the right at any time to modify, discontinue, or terminate the Application, Ninja Kiwi Login, or Services, or modify these Terms of Service or the Privacy Policy at its sole discretion; when these Terms of Service or the Privacy Policy are updated they will be posted here and updated to the Ninja Kiwi blog and social channels (https://www.facebook.com/ninjakiwigames/ and https://twitter.com/ninjakiwigames). For players under the age of 18, we appreciate you reading these terms to understand your responsibilities as a player and member of the Ninja Kiwi community, but you must review these Terms of Service with your parent or guardian and your parent or guardian must agree to these Terms of Service on your behalf.
Eligibility and Use
By your (or your child’s in the case of a parent or guardian) access and use of the Application, Ninja Kiwi Login, Services, or Application-related communications you signify your agreement to the following:
a. You affirm that you are at least 16 years of age and that you are fully able and competent to comply with and adhere to these Terms of Service. Alternatively or in conjunction, you affirm that you are the parent or guardian of a player under the age of 16 for whom you take full responsibility for their compliance with these Terms of Service;
b. For Ninja Kiwi Login, players under the age of 16, in order to comply with the Children’s Online Privacy Protection Act (COPPA) and Europe’s General Data Protection Regulation (GDPR) standards, must signify their true age by selecting the “No, I am under 16”; c. For Ninja Kiwi Facebook Applications, you verify that you have a legitimate account in accordance with Facebook’s Terms of Service, and you will prevent anyone under the age of consent in your country from using your Account;
d. You shall use the Application, Ninja Kiwi Login, or Services only for non-commercial purposes, and you shall not solicit services, advertise, or send repetitive or spam messages;
e. If you access the Application, Ninja Kiwi Login, or Services from a social networking site or any other website you will comply with the terms of service of that site along with these Terms of Service;
f. You may not enter, submit, or upload player-generated content (including but not limited to Ninja Kiwi Login player names, forum posts, blog posts, chat, character or other in-game names, game editor content, Content Browser content, Map Editor content, or any video or streamed content where a core visual or topical content is Ninja Kiwi or its games) that is defamatory, harassing, threatening, bullying, bigoted, hateful, violent, obscene, pornographic, or that harms or can reasonably be expected to harm any person or property, and you understand that any such activity will lead to suspension of your Ninja Kiwi Account; g. You shall not use the Application, Ninja Kiwi Login, or Services to engage in any illegal activity;
h. You are responsible for safeguarding and maintaining the confidentiality of your Account information, you will not disclose that information, and you will not disclose personally identifiable information unless as part of the setup of your Ninja Kiwi Login account or via Facebook, Google, Apple, or Twitch permissions. You shall not share personally identifiable information or account information with other players or community members. You agree that you are entirely and solely responsible for all access and use of your Account, whether or not you authorised it and whether or not you were aware of it. Please review our Privacy Policy for more information about our collection and limited use of personally and non-personally identifiable information. For players of the Red Reign game on Apple Arcade, please review the Red Reign Privacy Policy. For players of the Bloons TD 6+ game on Apple Arcade, please review the Bloons TD 6+ Privacy Policy;
i. You shall not share, copy, clone, gift, trade, barter, sell, or in any other way exchange your Ninja Kiwi Login or game data with any other person or entity, and you understand that any such activity will lead to segregation and/or suspension of your Ninja Kiwi account;
j. You shall not use alternative Ninja Kiwi Login accounts in any way that enables or supports tampering with other players’ multiplayer experiences, specifically multiplayer leaderboard competitions, for instance joining other Clans, Parties, or Teams for the purpose of blocking other players from joining and/or to weaken that Clan’s, Party’s, or Team’s scoring; and
k. You will only connect to the Application, Ninja Kiwi Login, and Services through legitimate, unmodified clients for the purposes of any multiplayer or competitive play and rewards, including public co-op game sessions, all leaderboards, and all player vs player game sessions, and you understand that any such modified activity will lead to the automated or manual segregation and/or suspension of your Ninja Kiwi account. For clarity use of modified clients is tolerated for private single player use and private co-op games but you understand that such use may also lead to automated segregation and/or suspension of your Ninja Kiwi account, which you may appeal by contacting the community management team at https://support.ninjakiwi.com/hc/en-us/requests/new.
Limited License; Content; Ownership
Subject to your agreement to and compliance with these Terms of Service, Ninja Kiwi grants you a non-exclusive, non-transferable, non-sublicensable, revocable limited license to access, play, and otherwise use the Ninja Kiwi Applications and Services provided such access, play, customise characters, create in-game content using in-game editors and tools, and use is for your own entertainment and not for commercial purposes. Ninja Kiwi makes special provisions for commercial performance play on popular platforms such as YouTube and Twitch as covered under Fan Content below.
Except where otherwise noted, the Application, Ninja Kiwi Login, Services, related communications, and all content including but not limited to graphics, audio, text, user interface, characters, animations, buttons, icons, thumbnails, reward systems, quest systems, downloads, game data, game design, events, content editors and their components, and player created content using content editors such as but not limited to the Bloons TD 6 Content Browser Challenge Creator, Odyssey Creator, and Map Editor, are the property of Ninja Kiwi and are protected by United States, New Zealand, and international copyright, trademark, and intellectual property laws. You may access, engage, and use the Application, Ninja Kiwi Login, or Services as they are presented to you and in accordance with these Terms of Service. Without express written consent from Ninja Kiwi, any attempts to modify, hack, cheat, autoplay, bot, datasniff, data capture, interfere with, disrupt, reproduce, frame, copy, post, sell, scrape, transmit, clone accounts, clone characters, or create related or derivative works is expressly prohibited and immediately terminates the limited license granted and will lead to the automated or manual segregation and/or suspension of your account; any attempts to promote such proscribed usage through video, stream, social network, public display, digital communications, or any other mass audience channel is expressly prohibited and immediately terminates the limited license granted and will lead to the segregation and/or suspension of your account.
Any and all content including but not limited to bloons, monkeys, buildings, towers, characters, environments, maps, worlds, creatures, items, pets, homes, robots, tools, weapons, powers, powerups, upgrades, equipment, display areas, user interface, virtual currency, or any other virtual items or organised display or use of any such items remains the sole and exclusive property of Ninja Kiwi. No amount of customization, stat changes, item changes, configuration, levelling up, decorating, or in any other way modifying game elements through use of the Application, Ninja Kiwi Login, Ninja Kiwi Services, or any other means conveys any ownership or alteration of the limited license to use; all elements remain the sole and exclusive property of Ninja Kiwi.
Where Ninja Kiwi games provide in-game tools such as but not limited to the Bloons TD 6 Content Browser Challenge Creator, Odyssey Creator, and Map Editor that allow players to modify, customise, and otherwise manipulate game content to create player-generated content for display and play within or outside Ninja Kiwi games whether private or public, all such content remains the exclusive property of Ninja Kiwi Limited, and any use of such tools to create and display content is done on a voluntary basis without any right, claim, or interest to compensation of any kind, except as defined specifically for content creator and player creator revenue sharing as detailed in the Fan Content and Player Creator Content and Revenue Sharing sections below.
Ninja Kiwi reserves the right at its sole discretion and without notice to make changes, modifications, additions, deletions, copies, or any other alterations and edits to any and all content elements, including but not limited to their appearance, animation, statistics, behaviour, performance, cost, component parts, display, visibility, or in-game value. Ninja Kiwi reserves the right at its sole discretion and without notice to delete, suspend, or modify any item, feature, account or the entire Application, Ninja Kiwi Login, or Services. In the event that access to the Application, Ninja Kiwi Login, or Services is terminated, all virtual items, virtual currency, and player’s game progress is forfeited and you will not receive any compensation, monetary or otherwise, for any of these elements forfeited. Any suspension or termination of your access to the Application, Ninja Kiwi Login, or Services will not waive or diminish your obligations under these Terms of Service (including but not limited to ownership, indemnification, and limitation of liability).
Fan Content
Ninja Kiwi supports the maintenance and growth of healthy, non-sponsored communities, fan-art channels, and content creator/streamer ecosystems and seeks to encourage and support fan creations that use or perform our IP, as long as they adhere to these Terms.
Fan Content includes but is not limited to art, animation, memes, crafts, game designs, game mechanics, stories, ‘ships, music, videos, merchandise, printed material, and any other creation that uses Ninja Kiwi IP, as well as any performance of Ninja Kiwi IP, including but not limited to video content creation and streaming as appears on platforms like Twitch and YouTube. Fan Content must comply with each of the following requirements; any fan content that violates the following requirements is prohibited : a. Streamers and content creators may monetize their performances of Ninja Kiwi IP through platform (e.g. Twitch or YouTube) ads, platform currencies, and other standard platform methods provided the performance of the Ninja Kiwi IP must adhere to all other conditions of these Terms; b. Fan Content other than streamer and content creator performances on major platforms as described at (a) above must have no commercial and/or monetary objective or implementation; c. Fan Content must not be posted as stand alone products whether free or for purchase to commercial platforms such as app stores (e.g. Apple App Store, Google Play Store, Steam) or content stores (e.g. Spotify, Bandcamp, Printful, Redbubble, Zazzle, Etsy). For clarity, this does not restrict streamers and content creators from posting their Fan Content to content creator platforms available on app stores (e.g. Twitch, Youtube, and Facebook); d. Fan Content must not use the Ninja Kiwi company or game logos or trademarks and must not be presented in any way that could cause people or search algorithms to react as if it was an official Ninja Kiwi production or post; e. Fan Content must not derogate Ninja Kiwi, Ninja Kiwi games or services, or Ninja Kiwi staff or otherwise cause damage to the reputation, public perception, or goodwill of Ninja Kiwi or its games or brands, as determined solely by Ninja Kiwi; f. Fan Content must not be used to communicate, link, distribute, or promote cheats or hacks to any Ninja Kiwi games; g. Fan Content must not be obscene, sexually explicit, defamatory, hateful, or harmful to others, as determined solely by Ninja Kiwi; h. You acknowledge that Ninja Kiwi games appeal to broad audiences that may include children and as such Fan Content should be appropriate for broad audiences or gated behind sufficient warning for mature content as provided by performance platforms, and you further acknowledge your understanding that Ninja Kiwi will not promote any Fan Content that is not appropriate for broad audiences.
If you have a channel on YouTube, Twitch, Facebook, or another platform and have any questions about media kits, game information, or just want to say hello, please get in touch with us at streamers@ninjakiwi.com; there is no obligation or requirement to contact Ninja Kiwi, but we do like to hear from people finding fun and value creating content with Ninja Kiwi IP in accordance with these Terms.
Content creators and streamers can also participate in a revenue share exchange managed by Nexus.gg and subject to their terms: https://www.nexus.gg/legal/terms-of-use.
As a standard practice, Ninja Kiwi does not accept Fan Content submitted directly to Ninja Kiwi for the Application, Ninja Kiwi Login, and/or Services of any other Ninja Kiwi game or property. From time to time, Ninja Kiwi may run promotions based on Fan Content for the purpose of community engagement. Whether part of a promotion or unsolicited, if you make any Fan Content submissions to Ninja Kiwi via any delivery mechanism including but not limited to blogs, forums, emails, letters, videos, community sites, or social networking posts and comments, you acknowledge your understanding that Ninja Kiwi is in the business of making games and is constantly creating game ideas, features, concepts, technologies, designs, mechanics, and all other elements for Applications or Services and likely has ideas that are similar to or identical to your submissions. In addition, you acknowledge that you will receive no compensation or credit and that your submission is not confidential. By communicating the submission, you warrant that you are the originator of the idea and that it does not infringe on the rights of any other person or entity, and you grant Ninja Kiwi a worldwide, royalty-free, non-exclusive perpetual right and license to use, modify, translate, publish, perform, produce derivative works, and in any other way manifest the submission without any liability, payment, or expense. Ninja Kiwi at its sole discretion and where possible will make efforts to acknowledge promotional Fan Content submissions that are reinterpreted and/or reauthored by Ninja Kiwi and subsequently incorporated into any Applications or Services.
Player Creator Content and Revenue Sharing
Player Creator Content is defined as any content created within any Ninja Kiwi game or service that can then be shared with other players for their use, performance, and enjoyment. The main examples of Player Created Content are the Challenge, Odyssey, and Map creations within Bloons TD 6. All such Player Created Content is bound by these Terms.
While all Player Creator Content creation is voluntary and is done without any right, claim, or interest in compensation of any kind, Ninja Kiwi is facilitating a platform-specific revenue share from In App Purchases made from players who are actively playing a Player Creator’s Challenge, Odyssey, and/or Map creations; this revenue share is conditional on the Player Creator: a) creating a Nexus.gg account; b) linking that Nexus account to their Ninja Kiwi player account, and; c) accepting the Nexus.gg terms: https://www.nexus.gg/legal/terms-of-use. For additional visibility, the Nexus.gg terms restrict revenue share participation to players 18 years of age and older.
Because IAPs and/or IAP validation are not available on all platforms where Bloons TD 6 is distributed, players on Apple Arcade, Netflix, Amazon App Store, and Windows Store cannot give Accolades. Because of platform specific data constraints, player creators on Apple Arcade and Netflix cannot receive revenue sharing.
Revenue share amounts are subject to change at Ninja Kiwi’s sole discretion and without notice, but reasonable efforts will be made to update the current revenue share percentage within the Accolades Store information panel when playing Bloons TD 6 while connected to the internet.
Player creator data related to revenue sharing will be stored for six months from the time of content creation to allow players to take their time to register with Nexus.gg and link their accounts. Potential revenue share older than six months before Nexus.gg registration will not be stored or claimable.
Merchandise
Ninja Kiwi provides IP related merchandise for sale at https://store.ninjakiwi.com, and this merchandise is sold in accordance with Store Policies available at https://store.ninjakiwi.com/pages/store-policies.
Ninja Kiwi supports and encourages fan creativity in the creation of Fan Content merchandise provided it adheres to all of the requirements of Fan Content. Making limited-run (50 or less) hand-authored prints, t-shirts, stickers, and other merchandise for non-commercial distribution to friends and other fans is permitted so long as they adhere to all of the requirements of Fan Content and are not similar to any items listed at https://store.ninjakiwi.com.
Virtual Currency and Premium Items
Through use of the Application, Ninja Kiwi Login, or Services you may accumulate virtual currency and virtual items whose sole use is within the Application, Ninja Kiwi Login, or Services where they were obtained. Ninja Kiwi engages with industry leading platform storefronts, including but not limited to Apple’s App Store, Google Play, Amazon’s App Store, and Steam, and with reputable third party services to allow purchase of virtual currency with real world currency, and Ninja Kiwi reserves the right to enable or disable any in-game acquisition of or real world purchase of virtual currency. Ninja Kiwi reserves the right at its sole discretion and without notice to change the rate of exchange for in-game or purchased virtual currency or the cost of any in-game item. Use of the platform storefront or third party service for purchase of virtual currency is governed by the terms of use of that service and any issues with that transaction are to be resolved with that platform storefront or third party service according to their support procedures. Ninja Kiwi will offer support assistance in contacting and attempting to resolve such platform storefront or third party service issues if you email support@ninjakiwi.com. You understand and acknowledge that Ninja Kiwi is not required to provide a refund for any currency or other item for any reason. Further, you understand and acknowledge that you will receive no money or other compensation for unused virtual currency, premium items, or any other game resources when an account is closed, when an account is suspended, when an Application or Service is under maintenance, offline, closed, or otherwise unavailable, or when your data has been lost, corrupted, deleted, or otherwise made unavailable. Ninja Kiwi reserves the right at its sole discretion and without notice to remove, suspend, or close any Application or Service without any compensation to you.
Parents and guardians acknowledge that your children and wards may purchase virtual currency only with your supervision and authorization. We encourage all players, regardless of age, to understand their device settings and limit or restrict in-app purchasing on their device if they do not wish to engage with in-app purchase features. Additional information on restricting in-app purchases is available here: https://support.google.com/googleplay/answer/1626831 https://support.apple.com/HT204396 https://www.amazon.com/gp/help/customer/display.html
Virtual currency and items are non-transferrable to any other Application, Service, website, or anywhere else. Virtual currency, virtual items, and player progress are not redeemable for any monetary value from Ninja Kiwi, any third party service, or any other entity. You agree not to sell, exchange, or attempt to transfer virtual currency, virtual items, or player progress, and any such actions will not be tolerated by Ninja Kiwi and will lead to suspension of your Ninja Kiwi account.
Whether you obtained virtual currency and virtual items through use of the Application, Ninja Kiwi Login, and Services, by purchase via a third party service, or by interacting with advertisements, you have no right or title to any virtual currency, virtual items, or any other game assets. You agree to pay all fees and related taxes incurred by you or anyone using an account that is registered to you. You agree to pay all internet, carrier, device, power, repair, replacement, data, bandwidth and any other fees and related taxes related to the operation of any equipment or devices required to access any Application or Service.
Bloons TD 5 Deluxe Terms of Sale
The downloadable PC desktop Application, “Bloons TD 5 Deluxe,” is no longer for sale but these Terms still apply for players of the game. There are no physical goods comprising or associated with the Bloons TD 5 Deluxe Application. Customers must have access to the internet to download and to validate their serial key and complete the installation; customers are solely responsible for their internet access and any related fees. The Bloons TD 5 Deluxe Application may only be used according to the Ninja Kiwi End User License Agreement that must be accepted during the installation process.
Third Party Links
The Application and Services may link to or rely on third party websites or resources. Ninja Kiwi is not responsible or liable for the availability or accuracy of such websites or resources. You acknowledge sole responsibility for and assume all risk arising from your use of any such websites or resources.
Electronic Communications
You consent to receive email communications from the Ninja Kiwi community management team if you create a support ticket via an Application or via support@ninjakiwi.com. Ninja Kiwi endeavours to respond to customer support tickets, app store reviews, and community posts in a timely and appropriate manner, but any such or other communications contact with Ninja Kiwi does not guarantee a reply or in any way impact the Disclaimer of Warranties or any other aspect of these Terms of Service.
Ninja Kiwi reserves the right to use, and you consent to receive, emails for critical communications such as legal notices or announcements. Any marketing or game status emails would be opt-in only, and your opt in or out will not affect your access to the Application, Ninja Kiwi Login, Services, or related communications. You can opt out at any time from your in game profile or through the unsubscribe link at the bottom of any marketing email.
Ninja Kiwi Competitions
By submitting a Fan Content entry for any competition run by, or in association with Ninja Kiwi, you fully and unconditionally agree to and accept these additional rules, terms, and conditions: a. You grant Ninja Kiwi a worldwide, royalty-free, non-exclusive perpetual right and license to use, reproduce, modify, publicly display, perform, produce derivative works of, or otherwise use any entry in any and all media, whether now known or hereafter existing, throughout the world for any and all purposes without compensation to you of any kind; b. You represent and warrant that your entry does not infringe on any copyright, trademark, property rights, or any other rights of any third party and that you have the right to transfer the entry to Ninja Kiwi free of any claims. Ninja Kiwi shall have no liability for any alleged or actual infringement of a third-party's rights in connection with any entry; c. You agree that you have not or will not receive any compensation or other consideration for your entry. Ninja Kiwi may in its sole discretion and without notice choose to award fan merchandise, including but not limited to t-shirts, stickers, badges, mouse pads, and virtual currency. All such items have no cash value and are purely for promotional purposes. Ninja Kiwi is under no obligation to award any fan merchandise regardless of the number or types of entries; d. You further agree to release and hold harmless Ninja Kiwi and its licensors, distributors, agents, shareholders, directors, officers, employees and representatives from and against any and all losses, damages, rights, claims, and actions of any kind arising in connection with your participation in the contest, including, not limited to, claims based on publicity rights, defamation, or invasion of privacy. All federal, state, local, provincial and municipal laws and regulations apply. Void where prohibited by law.
Disclaimer of Warranties
The Application, Ninja Kiwi Login, and/or Services are for use “as available” and “as is” and without any warranty, regardless of the amount of time and/or money you have spent on the Application, Ninja Kiwi Login, and/or Services. Use of the Application, Ninja Kiwi Login, and/or Services are at your sole risk and sole discretion, and you are solely responsible for any damage to your computer system or smart device, for any device performance issues, and for any loss of data. Ninja Kiwi disclaims any warranty express or implied regarding title, merchantability, availability, fitness, freedom from errors, error correction, and timeliness of communication or error correction. Ninja Kiwi does not warrant that the Application, Ninja Kiwi Login, and Services are bug free, error free, or virus free. You are solely responsible for how you spend your time and money. No communication whether written or oral shall supersede this Disclaimer of Warranties.
Limitation of Liability; Indemnification; Force Majeure
In no event will Ninja Kiwi, its directors, or its employees be liable for any damages whatsoever and without limitation, whether they be direct, indirect, punitive, commercial, intangible, or of any other type, arising from the use of the Application, Ninja Kiwi Login, or Services, regardless of whether the damages are foreseeable, even if Ninja Kiwi, its directors, and/or its employees have been advised of the possibility of such damages. To the extent that the above limitation applied to its fullest extent in applicable jurisdiction assigns liability, that cumulative liability shall not exceed US$10.
You agree to indemnify and hold harmless Ninja Kiwi, its directors, employees, partners, and service partners from any claim and demand, including any attorney’s fees, made by any party due to your use of the Application, Ninja Kiwi Login, or Services, your violation of these Terms of Service, or your violation of applicable law or the rights of another party.
Ninja Kiwi shall not be liable for any damages, disruptions, or claims related to its Application, Ninja Kiwi Login, or Services that arise from acts of nature, weather, war, social upheaval, economic upheaval, unavailability of utilities or resources, terrorism, the public enemy, any government or public authorities requirements, or any other event outside of Ninja Kiwi’s control.
Supplemental Terms for PlayStation®
For Purchases in PlayStation™ Store in North America
Purchase and use of items are subject to the Network Terms of Service and User Agreement. This online service has been sublicensed to you by Sony Interactive Entertainment America.
For Purchases in PlayStation™ Store in Europe
Any content purchased in an in-game store will be purchased from Sony Interactive Entertainment Network Europe Limited ("SIENE") and be subject to PlayStation™Network Terms of Service and User Agreement which is available on the PlayStation™Store. Please check usage rights for each purchase as these may differ from item to item. Unless otherwise shown, content available in any in-game store has the same age rating as the game.
General
These Terms of Service shall be governed by and interpreted in accordance with the laws of New Zealand. Any legal action or proceeding will be brought exclusively in courts located in Auckland, New Zealand and you consent to this jurisdiction. If any provision in these Terms of Service is held to be invalid, the remaining provisions shall survive in full effect. These Terms of Service are personal to you and imply no partnership, employment, or any other business relationship between you and Ninja Kiwi, and you may not transfer, assign, or delegate these Terms of Service to any other party with the exception of a parent or guardian taking responsibility for these Terms of Service for their child or ward. No delay, failure to communicate, or failure to take action in relation to any of these Terms of Service shall invalidate any provision of these Terms of Service.
Contact
You may address comments or questions to the following email address: support@ninjakiwi.com.
Privacy Policy
Last Update: March 04, 2025Hello and Welcome to Ninja Kiwi’s Privacy Policy!
We are committed to making our games both fun and safe to use. In general, our approach is to only collect anonymous data wherever possible and use as little personal data as is necessary to provide the best games and services. We don’t gather or use anonymous data or any personal information to sell these to third parties for commercial purposes; we only want to make our games more awesomer.
Please take a moment and read this Privacy Policy. It will help you understand how we process your personal data. Depending on the specific case it is possible that other privacy policies of ours may apply additionally, in which case we will inform you about this additional application (e.g., by referring to them). If you have any questions regarding our use of your personal data, please feel free to contact us over the channels provided below.
When you or your children or wards use Ninja Kiwi games and services, our Terms of Service and the terms of this Privacy Policy apply. You or your children or wards should not use any Ninja Kiwi games or services unless you agree to this.
The descriptions of how we process your personal data, your rights, and limitations to processing your personal data that are mentioned in this privacy policy apply to you when you use our services. They are based on the rules of the UK General Data Protection Regulation ("UK GDPR") and the General Data Protection Regulation ("GDPR") which applies when you reside in the United Kingdom or European Union and use our services.
If you do not reside in the UK or EU and use our services, the descriptions of this privacy policy may not fully apply to you and other data protection laws might be applicable. If you are a resident of the State of California, please see Section X below for detailed information according to the California Consumer Privacy Act ("CCPA").
When we refer to "you" in this Privacy Policy, we refer to you as data subject (see Sect. III below for more details on what this means). If you are interacting with us on behalf of others, please make sure all affected people receive the information stated in this Privacy Policy.
I. Who Are We?
If we speak of "we" or "us" in this Privacy Policy, we refer to ourselves as controller as defined below. Our contact details are:
Ninja Kiwi Ltd.
PO Box 26
Kumeu 0841
New Zealand
Our group data protection officer ("DPO") is
Kat Small
c/o Ninja Kiwi Europe Ltd.
Unit 13 The Vision Building
20 Greenmarket
Dundee DD1 4QB
Scotland
Ninja Kiwi Europe Ltd. is our representative in the UK (Art. 27 GDPR).
Supervisory Authority (UK)
Information Commissioner’s Office (ICO)
Wycliffe House
Water Lane
Wilmslow SK9 5AF
England
Our representative in the EU is
Modern Times Group MTG AB
Skeppsbron 18, Box 2094
111 30 Stockholm
Sweden
Supervisory Authority (EU)
Integritetsskyddsmyndigheten (IMY)
Box 8114
104 20 Stockholm
Sweden
You can reach out to us regarding any data protection matters by sending an email to privacy@ninjakiwi.com.
II. Joint Controllerships
What does joint controllership mean?
We and our subsidiaries, Ninja Kiwi Europe Ltd and Ninja Kiwi Americas LLC ("Subsidiaries"), cooperate closely together to provide our games and services. This means that we and our Subsidiary jointly determine if and how personal data of yours is processed. Since we and our Subsidiary each are controllers of your data when doing so, the working relationship is called a joint controllership. Our Subsidiaries are:
Ninja Kiwi Europe Ltd.
Unit 13 The Vision Building
20 Greenmarket
Dundee DD1 4QB
Scotland
and
Ninja Kiwi Americas LLC
140 Divisadero Street
San Francisco CA 94117
USA
Our Subsidiaries’ group data protection officer ("DPO") is
Kat Small
c/o Ninja Kiwi Europe Ltd.
Unit 13 The Vision Building
20 Greenmarket
Dundee DD1 4QB
Scotland
You can reach out to our DPO regarding any data protection matters by sending an email to privacy@ninjakiwi.com and noting that you are addressing our Subsidiary.
Is there a contract between us and our Subsidiaries?
Yes. We and our Subsidiaries have concluded a contract that legitimises any data flows between us and our Subsidiary. It contains rules for joint controllerships between us, especially which company is responsible for what when it comes to your personal data.
In which cases do we process your data together with our Subsidiaries and why?
We cooperate with our Subsidiary and jointly process personal data with them in the following cases:
We and our Subsidiary administer HR matters related to data subjects outside of the EU and process personal data related to this (e.g., regarding job applications and performance reviews).
We and our Subsidiary share IT services that are provided and administered by Ninja Kiwi Ltd. and through this process personal data such as personal data of yours when you play Ninja Kiwi games or use our services as well as personal data of employees of partners who cooperate with us and/or our Subsidiary.
We and our Subsidiary jointly market Ninja Kiwi products and services. For this purpose, we and our Subsidiary may process personal data, such as player data (e.g., your name when responding to a post of yours in our social media channels), as joint controllers. Such data is managed separately. However, we and our Subsidiary may jointly decide whether and how personal data is used for marketing purposes.
We and our Subsidiary may share the services of Ninja Kiwi’s external legal consultants (e.g., lawyers) for any legal questions and for administering and cooperating in intercompany matters. Through this we and our Subsidiary may jointly process personal data such as names and other personal data provided in connection with a legal assessment or proceeding.
We and our Subsidiary jointly handle data protection requests that you as data subject might send us (e.g., if you want to have your data deleted). Through this we and our Subsidiary may jointly process personal data such as names and other personal data provided in connection with your request.
We and our Subsidiary jointly process data required for playing our games (e.g., account data) and visiting our websites (e.g., IP addresses).
We and our Subsidiary jointly process analytical data that one of us might collect within a game or on a website of ours to improve how our games and website work.
We and our Subsidiary jointly process personal data required for purchases made in our online shop, e.g., to be able to send you the merch you bought.
We and our Subsidiary jointly process personal data in relation to raffles and giveaways.
You can find further details on how we and our Subsidiary jointly process your data in the respective section below (see Section VII. that gives specifics on how we use your data).
Who is responsible for what?
If not expressly stated otherwise in this Section, our Subsidiary, Ninja Kiwi Europe Ltd, is responsible for safeguarding your rights set out in this Privacy Policy, when processing your personal data. In such case, our Subsidiary is your primary contact point for all requests you may have relating to data protection. You can at any time of course also contact us to exercise your data subject rights. We and our Subsidiary can assist each other to comply with our obligations of the UK GDPR that apply regarding you and will inform each other about matters of significance to a joint controllership. Irrespective of this, the UK GDPR grants you the possibility to exercise your rights in respect of and against each of the joint controllers.
How is your data secured?
We have implemented technical and organisational measures to ensure a level of security appropriate to the risk presented by the processing in accordance with Art. 24 and 32 UK GDPR.
What happens in a case of a personal data breach?
In case of a personal data breach and if this breach is likely to result in a risk to your rights and freedoms, we will, with the assistance of our Subsidiary and without undue delay and, if possible, not later than 72 hours after having become aware of it, notify the data breach to the Information Commissioner’s Office (ICO) and/or if data of EU citizens is affected the competent supervisory authority of the EU. Should such a breach likely result in a high risk for your rights and freedoms, we or – where required by article 34 UK GDPR – our Subsidiary will inform you about the personal data breach without undue delay.
Contact: If you want to exercise your rights afforded by UK GDPR regulations or if you have any questions for us regarding the processing, you can contact us via email: privacy@ninjakiwi.com
Depending on your request, it is possible that our Subsidiary or we will forward your request to one another; should this be necessary to help each other out to answer your request or to get directly in touch with you for this purpose. In case of a forward of your request, we and our Subsidiary inform each other about the matter to the extent necessary for answering your request.
III. Meaning of Terms
Some terms we use in this Privacy Policy are defined by the UK General Data Protection Regulation ("UK GDPR"), a data protection law of the UK. When we refer to the UK GDPR we are referring to the General Data Protection Regulation of the European Union as well since both laws are very similar, unless we otherwise specify that we are referring to only one of them.
Art. 4 UK GDPR gives detailed definitions of terms which we also apply in this Privacy Policy. We’d like to explicitly mention the meanings of the following terms in simple words since they are used quite often throughout this Privacy Policy. Check out Art. 4 UK GDPR for the detailed definitions:
‘personal data’ means any information relating to a person that can be identified or could be identified through an identifier (‘data subject’);
‘processing’ means using your personal data (e.g., collecting, storing, sharing or deleting it);
‘controller’ means the person, company or other body that decides if and how your personal data is being processed;
‘processor’ means a person, company or other body that processes personal data on behalf of the controller according to the controller’s instructions.
IV. Legal Basis
As a controller we need a legal basis to be allowed to process your personal data. If:
you have given us your consent to process your personal data, this forms a legal basis according to Art. 6 para. 1 let. a) UK GDPR;
you have given us your consent to process special categories of personal data (e.g. data concerning health) for one or more specified purposes, and such consent is possible according to applicable law, this forms a legal basis according to Art. 9 para. 2 let. a) UK GDPR;
processing your personal data is necessary for the performance of a contract between you and us or in order to take steps at your request prior to entering into a contract, the legal basis for this is Art. 6 para. 1 let. b) UK GDPR;
processing your personal data is necessary for compliance with a legal obligation to which we are subject, the legal basis for this is Art. 6 para. 1 let. c) UK GDPR;
processing your personal data is necessary because we or a third party have a legitimate interest to do so and such legitimate interests are not outweighed by your interests or fundamental rights and freedoms, the legal basis for this is Art. 6 para. 1 let. f) UK GDPR.
V. Your Rights
Under the UK GDPR you have the following rights when we process your personal data:
Right of information: You can ask us to let you know what we are doing with your data, e.g., why we collect it, or for how long we keep it (Art. 13 and 14 UK GDPR).
Right of access: You can at any time ask us to confirm as to whether or not we are processing your personal data and, if this should be the case, access to the personal data (Art. 15 UK GDPR).
Right to rectification: If you find that personal data that we process about you is inaccurate, you can ask us to correct it (Art. 16 UK GDPR).
Right to erasure ("right to be forgotten"): Under certain circumstances, e.g., if you have objected to us using your data or if you have withdrawn your consent, you can ask us to delete your personal data. There are certain exceptions to this, e.g., if this would contradict other people’s free speech or if we have a legal obligation for which we need the data (Art. 17 UK GDPR).
Right to restriction: Under certain circumstances, e.g., if your personal data we store isn’t accurate or you have objected to us using your personal data, you have the right to request that we restrict the processing of your personal data until a solution has been found (Art. 18 UK GDPR).
Right to data portability: Under certain circumstances you can receive your personal data you have provided us in a structured, commonly used and machine-readable format and you can transfer this data to another controller (Art. 20 UK GDPR).
Right to object: Under certain circumstances, e.g., if we base the use of your personal data on a legitimate interest, you have the right to object to us using your data. If we don’t have an overriding interest to keep using your data, we will stop using it (Art. 21 UK GDPR).
Right to lodge a complaint: You can always send a complaint regarding our processing of your personal data to a data protection supervisory authority (Art. 77 UK GDPR).
Right to withdraw consent: If you have granted us your consent for us to process your personal data, you have the right to withdraw your consent at any time with effect for the future (Art. 7 para. 3 UK GDPR).
Right to not be subject to a decision based solely on automated processing: You have the right not to be subject to a decision based solely on automated processing which produces legal effects for you or similarly significantly affects you (Art. 22 para 1 UK GDPR). We do not make automated decisions by processing your personal data (e.g., profiling you).
VI. Recipients / Categories of Recipients
The personal data we process can also be either processed by other parties on our behalf and according to our instructions by processors or shared with and processed by other controllers. When data is processed according to this Privacy Policy, it is principally done so by employees and freelancers of ours that are responsible for the specific matter the data is required for.
The following list gives you an overview of the main providers of tools and services we use and who might be recipients of your data:
Office tools, advertising and analytics tools:
Google Ireland Limited
register number 368047
Gordon House
Barrow Street
Dublin 4
Ireland ("Google Ireland")
and
Google LLC, 1600,
Amphitheatre Parkway
Mountain View
CA 94043
USA (both together: "Google")
and
Twilio Ireland Limited
25 – 28 North Wall Quay
Dublin 1
Ireland ("Twilio SendGrid")
and
OneTrust LLC
1200 Abernathy Road, Suite 700
Atlanta
GA 30328
USA ("OneTrust")
Social media platforms and direct messaging:
Facebook Ireland Limited,
4 Grand Canal Square,
Dublin 2
Ireland ("Facebook")
and
Twitter International Company
One Cumberland Place
Fenian Street
Dublin D02 AX07
Ireland ("Twitter")
and
Discord,
444 De Haro Street Suite 200
San Francisco
CA 94107
USA ("Discord")
Customer support tools:
Zendesk, Inc.
1019 Market Street
San Francisco
CA 94103
USA ("Zendesk")
Host providers:
Amazon Web Services
Level 20, Pricewaterhousecoopers Tower
188 Quay Street
Auckland 1010
New Zealand ("AWS")
and
OVHCloud
Becket House 1 Lambeth Palace Road
London SE1 7EU
UK ("OVH")
and
Cloudflare, Inc
101 Townsend Street
San Francisco
CA 94107
USA ("Cloudflare")
Messaging software:
Slack Technologies, Inc.
500 Howard Street
San Francisco
CA 94105
USA ("Slack")
Shop tools:
Shopify Inc.
150 Elgin Street, Suite 800
Ottawa
ON K2P 1L4
Canada
and
Shopify International Ltd.
Victoria Buildings, 2. Etage
1-2 Haddington Road
Dublin D04 XN32
Ireland (both together: "Shopify")
Video and photo platforms:
Google Ireland (YouTube)
and
Twitch Interactive, Inc.
350 Bush Street, 2nd Floor
San Francisco
CA 94104
USA ("Twitch")
Login Providers
and
Apple Inc.
1 Infinite Loop
Cupertino
CA 95014
USA ("Apple")
and
Twitch
and
Valve Corporation
10900 NE 4th St, Unit 500
Bellevue
WA 98004
USA ("Steam")
and
Google (Ireland)
And
Amazon Media EU S.a.r.l.
38 Avenue John F. Kennedy
L-1855 Luxembourg ("Game Circle")
Some of these recipients are established outside of the European Union. Principally, there are two possible safeguards we rely on when we share your personal data with these recipients:
If a recipient is located in a country for which the European Commission ("EU Commission") has found it ok to send personal data to, since that country provides an adequate level of data protection, we rely on this so-called adequacy decision by the EU Commission.
If a recipient is not located in a country with an adequate level of data protection according to the EU Commission, we have concluded a special contract with this recipient in which we agree on rules to make sure the recipient takes adequate care of your personal data. This contract is called the EU Standard Contractual Clauses and was developed by the EU Commission.
Since we are located in New Zealand, any data that is transferred to us from our Subsidiaries is transferred to a country that is recognised by the EU Commission as a country that provides an adequate level of data protection. Any data that is transferred by us to our Subsidiary in the UK is transferred to a country that provides an adequate level of data protection according to the EU Commission.
Apart from this, the following categories of recipients process data either on our behalf or with us as joint controllers or as individual controllers: financial and IT services; media; social media platforms; website analytics providers; messaging systems; gameplay analytics.
You can find further information on which recipients and categories of recipients are involved in the processing of personal data under Section VII.
VII. General Data Processing
In the following we’d like to inform you about how we process your personal data. These are the general processing activities that can apply when you interact with us. Every processing activity is broken down into 5 parts:
(a.) What: What data is processed? (b.) Who: Who receives the data? (c.) Why: For what purpose is the data processed? (d.) Legal Basis: What law allows us to process the data? (e.) How Long: How long do we keep the data?
1. Communicating With You
a. What
If we communicate with you via email, mail, or telephone, we process all personal data you disclose to us during our conversation (e.g., you name, email address, the reason why you are contacting us etc.). With your consent we will process your email address to send newsletters and/or marketing information.
Apart from this, it is also possible that we use other online messaging systems to communicate with you, if you wish to contact us over these channels. Please note that if you wish to contact us via such messaging systems, it is possible that the respective companies that offer these communication services may also process your personal data and that regarding this their privacy policies apply. We have no influence over such data processing by third parties. For further information on how these services process your personal data, please view their privacy policies.
b. Who
Recipients of the processed personal data are the respective internal employees and freelancers of ours that are responsible for pursuing our purposes for the processing (e.g., someone from a department that you are contacting with a request). Possible further recipients: the providers of the respective messaging systems; Facebook, Twitter, Discord, Zendesk
Depending on the specific topic of the conversation as well as the circumstances (e.g., a certain game you’re playing) it is possible that our Subsidiaries jointly process personal data with us according to Sect.II.
c. Why
Depending on the specific conversation with you, the personal data can either be processed in order to take steps at your request prior to entering into a contract with us or to perform a contract you have concluded with us. Also, the processing can be necessary for us to comply with legal documentation obligations. Also, the processing can be necessary for the purposes of our legitimate interest to respond to mails and calls of yours when you contact us and are not our contractual partner as well as to have proof regarding substantial content of our conversation, including but not limited to cases of potential legal claims on our or your side.
d. Legal Basis
The legal basis for processing the personal data in order to take steps at your request prior to entering into a contract with us or to perform a contract you have concluded with us is Art. 6 para. 1 let. b) UK GDPR. The legal basis for processing the data for compliance with our legal obligations is Art. 6 para. 1 let. c) UK GDPR. The legal basis for processing the data due to our legitimate interest is Art. 6 para. 1 let. f) UK GDPR. The legal basis for processing the data at your request is Art.6 para. 1 let. a) UK GDPR.
e. How long
The data is stored at least for the time until our contract with you is fully performed. If the data has been stored in order to take steps at your request prior to entering into a contract with us, we will store the data for as long as reasons objectively exist to believe that the respective conversation will be continued within the foreseeable future. Any other data will be retained for a period of five years starting with the end of the year in which we received the communications.
If the data is also processed for another purpose set out in this Privacy Policy, the storage period regarding that purpose applies as well.
2. Visiting our Websites
a. What
When you visit our website, we process personal data of yours, such as your IP-address, the time of your visit, what browser type you use, country of origin, if applicable, also the website from which you were referred to our website.
b. Who
Recipients of the processed personal data are the respective internal employees and freelancers of ours that are responsible for pursuing our purposes for the processing. Possible further recipients: IT service providers and host providers, especially Amazon Web Services and CloudFlare.
Depending on the specific case, it is possible that our Subsidiaries jointly process personal data with us according to Sect. II.
c. Why
We process this data to display the website correctly in your browser, so you are able to make use of the full functionality of the services and the website content. We also process the data for troubleshooting, should the website not work correctly as well as for security purposes (e.g. to prevent malicious attacks on our website). These are legitimate interests of ours.
d. Legal Basis
The legal basis for processing the data is Art. 6 para. 1 let. f) UK GDPR.
e. How long
The data is stored for as long as our legitimate interest is given. For this, the data is stored for the time that we reasonably need to ensure our systems have not been subject to malicious use and to be able to effectively respond to any potential bugs or other malfunctions of the website.
If the data is also processed for another purpose set out in this Privacy Policy, the storage period regarding that purpose applies as well.
3. Ninja Kiwi Website Registration
a. What
Registration for ninjakiwi.com is exclusively for the website and does not apply to mobile games or forums, which are separate registrations. Registration asks for username, email, and password or for 3rd party login via Facebook or Google. Players under the age of 16 are directed specifically to use parent or guardian emails.
Your Ninja Kiwi Website profile will have multiple stats stored on our servers which are based on your web game performance and actions. For example, profile level, coins earned, clan chosen, etc.
b. Who
Recipients of the processed personal data are the respective employees and freelancers of ours that are responsible for processing the data. Possible further recipients: IT service providers and host providers.
Depending on the specific case, it is possible that our Subsidiaries jointly process personal data with us according to Sect. II.
c. Why
While you do not need to register to play many of the games on ninjakiwi.com, several games or game features will not work without a successfully registered account, since they are online multiplayer or online co-op games with the key feature of playing with or against other players. Also, we cannot provide effective customer support for game progress in such games without a successfully registered account.
We might email all registered players in the case of legal notices or major company news.
d. Legal Basis
The legal basis for processing the data is to enter into or perform a contract we concluded with you is Art. 6 para. 1 let. b) UK GDPR.
e. How long
Your account data is stored for as long as you maintain your account which can be closed anytime at your request, or it will be deleted automatically after 5 years of inactivity. If possible, we will notify you one week before we delete your inactive account to give you the possibility to keep your account if you wish.
If the data is also processed for another purpose set out in this Privacy Policy, the storage period regarding that purpose applies as well.
4. Ninja Kiwi Account Registration
a. What
When you register for a Ninja Kiwi account, this account can be used across most Ninja Kiwi games but does not provide registration to ninjakiwi.com or forums. You may provide us with an email that we use as a unique identifier for your account or choose a 3rd party login like Facebook, Apple, Google, Steam, Twitch, or Gamecenter.
If you are under the age of 16 you are allowed to register for Ninja Kiwi accounts, but you cannot supply any personally identifiable information (e.g., no email address or name) and are instead generated:
a random non-editable player name,
a randomly assigned unique long and short code, and
a randomly assigned unique recovery code.
For games with social guilds such as Clans, Parties, or Teams, you must identify your age before you join a Clan, Party, or Team in these games, and you are then excluded from sending, receiving, or reading any user generated chat messages. Depending on the game, chat is either completely disabled or limited to canned messages for users under 16. Instead of simply excluding minor players from the game or from participating in social guilds, we chose this approach as it allows underage players to participate in the fun of social guild play and be part of a team, but without risking personal data sharing.
If you are 16 and over you can use the chat functionality. For this functionality we process the information you enter into the chat.
Please note that for some games, your leaderboard scores and player name may be publicly available to other players.
b. Who
Recipients of the processed personal data are the respective employees and freelancers of ours that are responsible for processing the data. Possible further recipients: IT service providers and host providers.
Depending on the specific case, it is possible that our Subsidiaries jointly process personal data with us according to Sect. II.
c. Why
The registration data is required so you can play the game as intended to allow you to contact support@ninjakiwi.com from that email, so that customer support can immediately validate the account ownership and offer assistance more quickly.
If you are considered a minor, the randomly assigned nickname is required to identify you as a player for other players in the game, the short and long randomly assigned unique codes are required so we can make the game work and the randomly assigned recovery code can be used by you to get support from us.
We might email all registered players in the case of legal notices or major company news, provided we have their email address.
d. Legal Basis
The legal basis for processing the data to enter into or perform a contract we concluded with you is Art. 6 para. 1 let. b) UK GDPR as well as Art. 6 para. 1 let. f) UK GDPR since it’s a legitimate interest of ours to provide you a game that works properly.
e. How long
Your account data is stored for as long as you maintain your account which can be closed anytime at your request, or it will be deleted automatically after 5 years of inactivity. If possible, we will notify you one week before we delete your inactive account to give you the possibility to keep your account if you wish.
Chat data is deleted automatically four weeks after being sent.
If the data is also processed for another purpose set out in this Privacy Policy, the storage period regarding that purpose applies as well.
5. Game Data
a. What
We track gameplay information about the way you play our mobile games, which includes game and player progress information that is essential for saving and protecting that progress. Analytics track elements of the game you interact with most and least frequently, where you stop playing or play less, and other aspects of aggregating player progression through the game.
For players aged 16, IP address, device type, OS type, time stamp, and other general device level information are accessed and stored on distributed, scalable servers. For players under age 16 no personal data is stored.
b. Who
Recipients of the processed personal data are the respective employees and freelancers of ours that are responsible for processing the data. Possible further recipients: IT service providers and host providers.
Depending on the specific case, it is possible that our Subsidiaries jointly process personal data with us according to Sect. II.
c. Why
The data is used to fix bugs and help you out if you contact us to report technical issues as well as for anti-cheat purposes. We also use gameplay information to identify the most engaging components of our game designs, so we can better concentrate our development work where players are having the most fun. These are legitimate interests of ours and our players.
d. Legal Basis
The legal basis for processing data based on our legitimate interest is Art. 6 para. let. f) UK GDPR.
e. How long
Your account data is stored for as long as you maintain your account which can be closed anytime at your request, or it will be closed automatically after 5 years of inactivity. If possible, we will notify you one week before we delete your inactive account to give you the possibility to keep your account if you wish. If you delete your account, analytics data will be kept under a random anonymous ID that cannot be linked to you after you have deleted your account.
If the data is also processed for another purpose set out in this Privacy Policy, the storage period regarding that purpose applies as well.
6. Advertising
a. What
Since some of our games are free to download and play, we display ads in many of these free games. The advertising companies pay us for displaying the ads and this makes it possible for us to offer you the game free of charge. Apart from this, we might also give you the possibility to watch an ad instead of paying for a feature that you otherwise would have to pay for in a game of ours. When displaying ads, we use third-party advertising companies to serve the ads in our games. The third-party advertising companies may collect and use information (but not your name, address, email address, telephone number, or other personal data) about how you play our games.
Non-personally identifiable information to manage and measure the delivery of advertising within that game can be collected, including the number of times the same advertisement is served and viewed.
For players registered as under age 16 we use designated non-personal data ad calls that either do not send personal data (usually IP address) or encrypt that personal data so that we have no access to it. Ad companies may use non-personally identifiable information (e.g., click stream information, browser type, time and date, heat maps, player behaviour) when you play our games in order to provide ads about goods and services likely to be of greater interest to you. These companies typically use a cookie or third-party beacon to collect this information. We do not have access to this information or influence over third party ad network policies, barring our ability to discontinue their services.
You can choose to agree or disagree with us sharing your personal data for displaying targeted ads depending on which platform you play our games:
iOS: Choose from the consent pop-up at the start of the game (if you haven’t already generally disabled tracking in your system settings).
Android: Opt out of ad tracking by going to Settings > Ads > Opt out of Ads Personalisation
Fire OS: Opt out of ad tracking by going to Settings > Security & Privacy > Advertising ID > Interest-Based Ads
If you would like more information about advertising practices and to know your choices about not having this information used by these companies, you can visit Google's Advertising and Privacy page or the Network Advertising Initiative. Please understand that if you disable or block certain ad features, then other aspects of our mobile games may not work correctly.
b. Who
Recipients of the processed personal data are the respective employees and freelancers of ours that are responsible for pursuing our purposes for the processing. Possible further recipients: Ad Networks.
Depending on the specific case, it is possible that our Subsidiaries jointly process personal data with us according to Sect. II.
c. Why
The data is processed by us to provide advertisements about goods and services of interest to you. We offer our mobile games for free, so these ads allow us to continue making and updating top quality free games which is a legitimate interest of ours but also of yours if you want to play games for free. Without displaying personalised ads, we would not make sufficient money to keep offering the games for free to you.
d. Legal Basis The legal basis for processing your personal data for personalised ads on iOS is your consent (Art. 6 para. 1 let. a) UK GDPR). If you are an Android player, the legal basis is our legitimate interest (Art. 6 para. 1 let. f) UK GDPR).
e. How long
The data is stored for as long as you maintain your account which can be closed anytime at your request, or it will be closed automatically after 5 years of inactivity. If possible, we will notify you one week before we delete your inactive account to give you the possibility to keep your account if you wish. If you delete your account, analytics data will be kept under a random anonymous ID that cannot be linked to you after you have deleted your account.
If the data is also processed for another purpose set out in this Privacy Policy, the storage period regarding that purpose applies as well.
7. Facebook, Apple, Google, Game Center, Twitch, Steam and Game Circle Logins
a. What
When you register for Ninja Kiwi using Facebook, Apple, Google, Twitch, Steam, Game Center or Game Circle or share links through these services, Ninja Kiwi accesses data already provided to those login services. Please check their privacy policies for details on how they share information when you make use of their login services. We are only granted access to that information via the player-approved permissions necessary to use those games or services.
b. Who
Recipients of the processed personal data are the respective employees and freelancers of ours that are responsible for processing the data. Possible further recipients: the provider of the third-party login platform (Facebook, Twitter, Google (YouTube), etc.).
c. Why
We use these services to simplify logins to our mobile and website logins and to connect players to their friends for co-operative and competitive play, and to compare scores and progress. We use the respective platform standard versions of these services and only reference the username/email associated with your saved data, scores, and game progress.
d. Legal Basis
The legal basis for processing data based on our legitimate interest is Art. 6 para. 1 let. f) UK GDPR.
e. How Long
Any data provided for login services will be retained for as long as the player account is active. Once the player account has been deleted or the retention period of 5 years of inactivity has been reached the data will be deleted along with the player account data.
If the data is also processed for another purpose set out in this Privacy Policy, the storage period regarding that purpose applies as well.
8. Social Media Presences
a. What
We have presences on social media platforms such as Facebook, Instagram, Twitter, Discord, and Reddit that help us connect with our players and the most awesomer Ninja Kiwi community.
When you interact with a social media presence of ours (e.g. you comment on a post of ours or write on our timeline), we process your name/nickname, profile picture and other personal data that your account may publicly display as well as personal data that you provide e.g. in a comment or post of yours. This Privacy Policy applies only to Ninja Kiwi. Please be aware that when you use social media platforms the providers of such platforms process your personal data as well and their privacy policy or terms of service of third parties apply. We refer you to the respective terms and privacy policies for details on how they handle your data.
If you apply as a moderator for our Discord and Reddit channels, we require your username and time zone.
b. Who
Recipients of the processed personal data are the respective employees and freelancers of ours that are responsible for processing the data. Possible further recipients: the provider of the social media platform.
c. Why
Your personal data is processed by us to effectively communicate with you within the social media platform (e.g. respond to posts and comments). If you apply as moderator, we require the data to be able to appropriately identify and assign you as such. These are legitimate interests of ours.
d. Legal Basis
The legal basis for processing data based on our legitimate interest is Art. 6 para. 1 let. f) UK GDPR.
e. How long
The data is stored for as long as we maintain the respective social media presence and you do not decide to delete your account or the respective post, comment or other interaction with us on the social media presence. If you are a moderator, the data is stored for as long as you have this role.
If the data is also processed for another purpose set out in this Privacy Policy, the storage period regarding that purpose applies as well.
9. Applications (only Ninja Kiwi Europe Ltd.)
a. What
Our Subsidiary processes the personal data you provide when applying for a job or to work together with it as a freelancer (e.g., your name, date of birth, address, etc.).
b. Who
Recipients of the processed personal data are the respective employees of our Subsidiary that are responsible for pursuing its purposes for the processing (e.g. HR employees, your potential line manager and management). Possible further recipients: Google (Workspace).
Depending on the specific case, it is possible that we jointly process personal data with our Subsidiary according to Sect. II.
c. Why The data is processed to decide if a contract with you will be concluded or, if you already have a contract with our Subsidiary, to perform our obligations or terminate the contract.
d. Legal Basis
The legal basis for processing the personal data is Art. 6 para. 1 let. b) UK GDPR.
e. How long
If we work together with you, your data is stored for the applicable statutory storage periods, at least for six years and one month starting at the end of the year in which your contract has ended.
All job application data from applications that have been declined or reserved will be stored for up to six months after your application has been received.
If the data is also processed for another purpose set out in this Privacy Policy, the storage period regarding that purpose applies as well.
10. Data Subject Requests
a. What
When you contact us to make use of your data subject rights (see above), we process your name, email address and any additional information you provide us in your request.
To make sure we can correctly identify you we may ask you to provide a copy of your passport or other identification document ("ID"). When you upload this information, we will process the personal data of yours stated on the ID, namely: your name, birth date, address and validity of the document. Please make any other data on the copy of your ID-document unreadable (e.g. serial number of the document) before the upload and mark the document as copy (e.g. add the imprint "copy" on it).
We kindly ask you to only use the portal in which your ticket was created for you after addressing us over privacy@ninjakiwi.com to upload the ID. Documents provided through any other channel are not accepted and will be deleted by us.
b. Who
Recipients of the processed personal data are the respective employees and freelancers of ours that are responsible for answering your request. Possible further recipients: Zendesk; OneTrust.
Depending on the specific case, it is possible that our Subsidiaries jointly process personal data with us according to Sect. II.
Only the designated employees of ours entrusted with privacy matters, and possibly employees that maintain our IT infrastructure, will view your ID. Processors processing your data on our behalf are Zendesk; OneTrust.
c. Why
The personal data of your request is processed for the purpose of answering your request – if necessary also with the help of other Ninja Kiwi companies or to answer such request for other Ninja Kiwi companies should it be directed at it – as well as the purpose of proving our compliance with the UK GDPR by helping you as data subject exercise your rights set out in the UK GDPR. This is also a legitimate interest of ours.
We process the ID data to verify your identity. This is required to prevent cases of fraud committed by using false identities. We have a legitimate interest in this purpose that outweighs a potential contrary interest of yours to not disclose this information, since we have a responsibility in protecting our players’ and partners’ personal data and since we will delete your ID promptly after we have verified your identity. The ID will not be used for any other purposes.
d. Legal Basis
The legal basis for processing the data of your request and – if necessary – sharing this information with our Subsidiaries is Art. 6 para. 1 let. c) in connection with Art. 12 UK GDPR as well as Art. 6 para let. f) UK GDPR.
The legal basis for ID verifications is Art. 6 para. 1 let. f) UK GDPR.
e. How long
The data of your request is stored for 5 years and one month starting with the end of the year in which you made your request.
The uploaded ID will be deleted promptly after we have verified your identity.
If the data is also processed for another purpose set out in this Privacy Policy, the storage period regarding that purpose applies as well.
11. B2B Partnerships
a. What
When we communicate and conclude contracts with you as a business partner (B2B only), we store certain personal data of yours in our B2B database, such as your business email address and other business information related to our (potential) partnership.
b. Who
Recipients of the processed personal data are the respective employees and freelancers of ours that are responsible for pursuing our purposes for the processing. Possible further recipients: Google (Workspace);.
Depending on the specific case, it is possible that our Subsidiaries jointly process personal data with us according to Sect. II.
c. Why
The data is processed to decide if a contract with you will be concluded or, if you already have a contract with us, to perform our obligations or terminate the contract.
We also have a legitimate interest in processing this data of yours to be able to remain in contact with you for business purposes. We have a legitimate interest in processing the information of B2B contacts with whom we have a contractual relationship or objectively likely will have a contractual relationship with in the future. Since this is not only necessary to properly perform the contract between us and them, but also to facilitate communication with them concerning their cooperation with us. We also have a legitimate interest in processing the personal data of the B2B contacts who are currently not commissioned by us and have not been commissioned in the past, since it facilitates getting in touch with them for future projects.
d. Legal Basis
The legal basis for processing the personal data to enter into or perform a contract with you is Art. 6 para. 1 let. b) UK GDPR. The legal basis for processing the personal data based on our legitimate interest is Art. 6 para. 1 let. f) UK GDPR.
e. How long
Documentation regarding B2B contacts that we have concluded a contract with will be stored for as long as the contract remains active or for up to 5 years and one month after that contract has ended in case we want to contact you in the future.
Personal data of B2B contacts with whom we have no contract and have no objective reasons to believe we will be concluding a contract with in the near future, will be deleted from our database after 3 years of inactivity.
If the data is also processed for another purpose set out in this Privacy Policy, the storage period regarding that purpose applies as well.
12. Legal Work
a. What
We work together with our Subsidiaries and external consultants to assess and manage legal matters. If a matter or dispute between you and us or between you and our Subsidiaries requires relevant legal review, we and, if necessary, the relevant subsidiary process the data relevant to the matter or dispute. In particular, this may include your name, e-mail address and contact details.
b. Who The recipients of the personal data processed are our respective employees and freelancers responsible for processing the matter. Possible further recipients: Google (Workspace); External Legal Consultant.
Depending on the specific case, it is possible that our Subsidiaries jointly process personal data with us according to Sect. II.
c. Why
The purpose of the processing of the data by us and – if applicable – our Subsidiaries is the effective and uniform handling of legal matters. This is a legitimate interest of ours and our Subsidiary. In addition, the data processing may serve to conclude and perform contracts with you.
d. Legal Basis
As far as the data processing concerns the conclusion or performance of a contract with you, the legal basis of the data processing is Art. 6 para. 1 let. b) UK GDPR.
If the data processing is based on a legitimate interest, the legal basis is Art. 6 para. 1 let. f) UK GDPR.
e. How Long
The storage period for data processed for the purpose of handling legal matters or disputes is governed by the relevant limitation period, so that we can sufficiently defend ourselves against claims, or by the relevant legal obligations to retain documents.
If the data is also processed for another purpose set out in this Privacy Policy, the storage period regarding that purpose applies as well.
13. Shop
a. What
You can buy products on our online shop. In this case, we process the personal data you enter during the ordering process, such as your name, e-mail address, contact details and information about your purchase.
b. Who
The recipients of the personal data processed are our respective employees and freelancers responsible for processing the matter. Possible further recipients: Shopify.
Depending on the specific case, it is possible that our Subsidiaries jointly process personal data with us according to Sect. II.
c. Why
We process the data in order to initiate a contract with you and to conclude and perform it when you make a purchase, as well as to fulfil our accounting and tax obligations.
d. Legal Basis
The legal basis for the processing of data for the concluding or performing a contract we have concluded with you is Art. 6 para. 1 let. b) UK GDPR.
The legal basis for the processing of data on the basis of one of our legal obligations is Art. 6 para. 1 let. c) UK GDPR.
e. How Long
The purchase data will be stored for 7 years to comply with retention obligations for financial records.
If the data is also processed for another purpose set out in this Privacy Policy, the storage period regarding that purpose applies as well.
14. Raffles and Giveaways
a. What
Visitors to our social media profiles have the opportunity to win prizes by interacting with certain posts. In this case winners are contacted through their social media account and asked to send us directly their details, such as name, e-mail address and address so that we can award their prize.
b. Who
The recipients of the personal data are our respective employees. Possible further recipients: Shopify.
Depending on the specific case, it is possible that our Subsidiaries jointly process personal data with us according to Sect II.
c. Why
The personal data is processed so that the raffle or give away can be concluded and a prize sent to the winner.
d. Legal Basis
The legal basis for the processing of data for this is Art. 6 para 1 let b) UK GDPR.
e. How Long
The data will be stored until we receive confirmation that the prize has been received or up to six months following shipping.
If the data is also processed for another purpose set out in this Privacy Policy, the storage period regarding that purpose applies as well.
VIII. Group Cooperation
We are part of a group of gaming studios that are owned by our parent company Modern Times Group MTG AB ("MTG"), a Swedish gaming company. We cooperate with MTG and the other gaming studios of the group (each a "Group Company") to learn from one another, help each other and improve how we all make games. We like to see ourselves as a small gaming village in which we strive together to make great games.
Joint controllerships
In some cases when we cooperate with MTG and/or a Group Company, we jointly determine if and how certain personal data of yours is processed. In such a case the involved companies each are controllers of your data when doing so. We have concluded an agreement with MTG and all Group Companies in which the rules for our joint controllership are set out and which also includes so called standard contractual clauses which ensure that personal data of European players is adequately safeguarded when transferred between us and a Group Company which is not established in the European Union or a country considered to have the same level of data protection as the European Union.
Joint controllerships between us and MTG or us and a Group Company:
1. Mergers and Acquisitions
a. What
MTG, the Group Companies and us can support each other when buying or selling a company. In such cases a strictly limited number of personnel involved in such a transaction can receive access to personal data (e.g., names, email addresses, unique identifiers) included in relevant documentation shared by a potential seller or determine which personal data is shared with a potential buyer and how this shall be done. Principally, personal data is anonymised before it is disclosed and, should it be necessary to disclose personal data, such disclosure of personal data will be kept to a minimum.
b. Who
Recipients of the processed personal data can be our providers of office tools, providers of data rooms as well as external financial and legal advisors, MTG, involved Group Companies, and the potential buyer. We can receive your personal data from a Group Company, or a potential seller in which case the same recipients can apply.
c. Why
The purpose of such a cooperation is to review relevant material shared with us by a potential seller, so we and/or MTG, and/or the involved Group Companies can make good business decisions, or to enable a potential buyer to do so when sharing such data with it. This is a legitimate interest of ours, MTG, the involved Group Companies, and the potential sellers or buyers.
d. Legal Basis
The legal basis for processing your personal data is our legitimate interest, Art. 6 para. 1 let. f) UK GDPR
e. How Long
The storage period for data processed for the purpose of handling legal matters or disputes is governed by the relevant limitation period, so that we can sufficiently defend ourselves against claims, and by relevant legal obligations to retain documents. If a transaction has been successful, we might be obliged to store the respective personal data according to the applicable statutory provisions, in which case we will store the documents according to the retention periods stated in such provisions. Personal data that is no longer relevant if a transaction has not been successfully made, will be deleted if it is not relevant for another purpose under this privacy policy.
Joint controllerships between us and MTG:
1. Business Intelligence
a. What We share a limited amount of data with MTG to get a better understanding of how you play our games and what you like about them so we can improve them. This includes a group-internal unique identifier, game title, time of install, platform, country code per install, marketing channel/category and marketing campaign, browser information, engagement with the game (log-in sessions), amount of money spent in the game, and how effective a marketing campaign was.
b. Who
The Recipient of the processed personal data is our parent company, MTG. The information is not shared with Group Companies.
c. Why
A better understanding of how you play our games and what you like about them helps us to make them better and improve how we market them. As a gaming studio, it is essential for us that we can understand how games are played and how effective our marketing efforts are to ensure that enough players enjoy our games so we can keep making them. This interest is shared by MTG and the Group Companies.
d. Legal Basis
The legal basis for processing your personal data is our legitimate interest, Art. 6 para. 1 let. f) UK GDPR
e. How Long
The data is stored for as long as you are an active player of the game. Your data will be deleted or anonymised after six years of inactivity, which depends on the date of the last time you played a game of ours.
2. Data Protection Compliance Work
a. What
MTG supports us with our data protection compliance work. We can jointly process personal data of yours required to ensure compliance with data protection laws, e.g., names, email addresses, usernames, unique identifiers (e.g., game-ID players). E.g., this can be the case when you reach out to us with a data protection request, and we seek MTG’s support to respond adequately and in time.
b. Who
Recipients of the processed personal data can be our providers of office tools, OneTrust and MTG.
c. Why
We want to be able to offer you a high level of data protection when you play our games. To ensure that we comply with the relevant data protection laws we receive support from MTG. This is a legitimate interest of ours, MTG, the other Group Companies and you.
d. Legal Basis
The legal basis for processing your personal data is Art. 6 para. 1 let. c) and f) UK GDPR
e. How Long
The data will be stored for the duration that we need to be able to prove that we are complying with data protection laws. Due to this, data protection requests of yours will be stored for five years and one month.
Who can you contact?
When we process your personal data, you have certain rights under the GDPR, which you can find in section V of this privacy policy. If you have questions regarding the joint controllerships or want to make use of your data protection rights, you can contact us anytime. You can find a detailed list of your rights and our contact address in section V and section I of this privacy policy.
How is your data secured?
We have implemented technical and organisational measures to ensure a level of security appropriate to the risk presented by the processing in accordance with Art. 24 and 43 GDPR.
What happens in a case of a personal data breach?
In case of a personal data breach under the GDPR and if this breach is likely to result in a risk to your rights and freedoms, MTG will, without undue delay, and where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the competent supervisory authority.
Should such a breach likely result in a high risk for your rights and freedoms, we, or – where required by article 34 GDPR -, MTG, or the respective Group Company will inform you about the personal data breach without undue delay.
IX. Other Cooperations
Apart from cases in which we jointly process personal data, we cooperate within the group in the following cases:
1. Developing or Distributing Games
a. What
MTG can support us when we are developing or distributing our games (e.g., consulting regarding game features or functionalities). In the process of this it is possible that certain personal data of players of our games might be disclosed to MTG, such as names, email addresses, usernames, or unique identifiers. Such personal data will not be actively stored or used by MTG for such support.
b. Who Recipients of the processed personal data can be our providers of office tools and MTG.
c. Why
Since we are part of the same group and MTG is our parent company, we both share the same legitimate interest of developing and distributing great games. To be able to do this we work closely together.
d. Legal Basis
The legal basis for processing your personal data is our legitimate interest, Art. 6 para. 1 let. f) UK GDPR
e. How Long
The personal data is stored by us according to the applicable retention periods of this privacy policy (e.g., the retention period of your account data).
2. Legal Support
a. What
MTG supports us with legal guidance regarding legal complaints, claims, court proceedings or other legal matters we might be facing. In such cases MTG might receive personal data (e.g., names and contact details of plaintiffs or complainants) of persons involved in such legal matters from us.
b. Who
Recipients of the processed personal data can be our providers of office tools and MTG.
c. Why
Since we are part of the same group and MTG is our parent company, we both share the same legitimate interest in effectively handling legal complaints, claims, court proceedings or other legal matters we might be facing. To be able to do this we work closely together.
d. Legal Basis
The legal basis for processing your personal data is our legitimate interest, Art. 6 para. 1 let. f) UK GDPR
e. How Long
Data will be retained according to legal obligations (e.g., employment laws) or our legitimate interest of defending ourselves against legal claims.
3. Freelancer & Outsourcing
a. What
If you are a freelancer providing services to us, we can share certain personal data of yours with MTG, e.g., names and contact details.
b. Who
Recipients of the processed personal data can be our providers of office tools and MTG.
c. Why
Since we are part of the same group and MTG is our parent company, we both share the legitimate interest of effectively handling budgets and ensuring an effective project management which can make it necessary for us to share with MTG information on the freelancers with whom we work with.
d. Legal Basis
The legal basis for processing your personal data is our legitimate interest, Art. 6 para. 1 let. f) UK GDPR
e. How Long
The personal data will be stored at least for the term of the contract you have with us and, if required by bookkeeping laws, as long as it is necessary to retain documentation on financial transactions connected to your work.
X. Privacy Information for California Residents
If you are a consumer residing in California, the California Consumer Privacy Act ("CCPA") applies when you use our Services. The CCPA defines personal information and sensitive information as follows:
"Personal information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
"Sensitive personal information" is personal information that reveals:
A consumer’s social security, driver’s licence, state identification card, or passport number.
A consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.
A consumer’s precise geolocation.
A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership.
The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication.
A consumer’s genetic data.
Sensitive personal information can also mean:
The processing of biometric information for the purpose of uniquely identifying a consumer.
Personal information collected and analysed concerning a consumer’s health.
Personal information collected and analysed concerning a consumer’s sex life or sexual orientation.
The information we provide in Sections VII, VIII and IX of this Privacy Policy regarding which personal data we process, and for which purposes we process it, apply correspondingly to cases in which we process personal information of yours as resident of California.
Please view the following chart for information on what personal information of yours we share to which recipients and for how long we intend to store it.
Under the CCPA "sharing" principally means making a consumer’s personal information available to a third party for cross-context behavioural advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioural advertising for the benefit of a business in which no money is exchanged.
Category of Personal Information | Third Parties With Whom We Have Shared This Information | Retention Period --- | --- | — Identifiers such as an alias, unique personal identifier, online identifier, Internet Protocol address, or other similar identifiers. | Advertising companies that provide ads in our games (e.g. ad networks, mediation platforms). | We will retain the data for as long as is reasonably necessary to provide our services to you but not more than 5 years after your account is inactive. Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Advertising companies that provide ads in our games (e.g. ad networks, mediation platforms). | We will retain the data for as long as is reasonably necessary to provide our services to you but not more than 5 years after your account is inactive. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement.| Advertising companies that provide ads in our games (e.g. ad networks, mediation platforms). | We will retain the data for as long as is reasonably necessary to provide our services to you but not more than 5 years after your account is inactive. Geolocation data. | Advertising companies that provide ads in our games (e.g. ad networks, mediation platforms). | We will retain the data for as long as is reasonably necessary to provide our services to you but not more than 5 years after your account is inactive.
Please view the following chart for information on what personal information of yours we disclose for a business purpose to which recipients and for how long we intend to store it.
According to the CCPA, "business purposes" are:
Auditing: Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
Security and Integrity: Helping to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for these purposes.
Debugging: Debugging to identify and repair errors that impair existing intended functionality.
Short-term, transient use: This includes, but is not limited to, non-personalised advertising shown as part of your current interaction with us, provided that your personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction with us.
Performing services on behalf of the business: this includes maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of us.
Advertising and marketing services: Providing advertising and marketing services, except for cross-context behavioural advertising, to you provided that, for the purpose of advertising and marketing, a service provider or contractor shall not combine your personal information if you have opted-out that the service provider or contractor receives from, or on behalf of, us with personal information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with you.
Internal Research: Undertaking internal research for technological development and demonstration.
Quality or safety of a service or device: Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.
Category of Personal Information | Third Parties With Whom We Have Shared This Information | Retention Period --- | --- | — Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. | Service providers of office tools, social media platforms, customer support tools, host providers, shop tools and login providers. | We will retain the data for as long as is reasonably necessary to provide our services to you but not more than 5 years after your account is inactive. Any personal information described in subdivision (e) of Section 1798.80 | Service providers of office tools, social media platforms, customer support tools, host providers, shop tools and login providers. | We will retain the data for as long as is reasonably necessary to provide our services to you but not more than 5 years after your account is inactive Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Service providers of office tools, social media platforms, customer support tools, host providers, shop tools and login providers. | We will retain the data for as long as is reasonably necessary to provide our services to you but not more than 5 years after your account is inactive Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement. | Service providers of office tools, social media platforms, customer support tools, host providers, shop tools and login providers. | We will retain the data for as long as is reasonably necessary to provide our services to you but not more than 5 years after your account is inactive. Geolocation data. | Service providers of office tools, social media platforms, customer support tools, host providers, shop tools and login providers. | We will retain the data for as long as is reasonably necessary to provide our services to you but not more than 5 years after your account is inactive.
Please view the following chart for information on what sensitive personal information of yours we collect and use, for which purpose we do this, and for how long we intend to store it. We do not share or sell your sensitive personal information.
Category of Sensitive Personal Information | Third Parties With Whom We Have Shared This Information | Retention Period --- | --- | — A consumer’s account log-in, in combination with any required security or access code, password, or credentials allowing access to an account. | We use a consumer’s account login details to enable them to log in, play our games and save progress. | We will retain the data for as long as is reasonably necessary to provide our services to you but not more than 5 years after your account is inactive.
Your Rights
If you are a resident of California, you have the following rights:
Right to Delete Personal Information: You have the right to request that we delete your Personal Information. Depending on the specific case, exceptions can apply to this right, e.g/, if we have to keep you information to comply with legal obligations or to ensure the freedom of expression (Section 1798.105 CCPA).
Right to Correct Inaccurate Personal Information: You have the right to request the correction of Personal Information we maintain about you (Section 1798.106 CCPA).
Right to Know What Personal Information is Being Collected:
You have the right to request the following information from us (Section 1798.110 and 1798.115 CCPA):
The categories of personal information we have collected about you.
The categories of sources from which the personal information is collected. -The business or commercial purpose for collecting, selling, or sharing personal information. -The categories of third parties to whom we disclose personal information. -The specific pieces of personal information we have collected about you.
The categories of personal information that we sold or shared about you and the categories of third parties to whom the personal information was sold or shared, by category or categories of personal information for each category of third parties to whom the personal information was sold or shared.
The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
Right to Opt-Out of Sale and Sharing: We do not sell your Personal Information. We share your Personal Information with advertising partners to show you ads that might be more interesting to you. You have the right to opt out of any sale or sharing of your Personal Information (Section 1798.120 CCPA). Please see Section VII (6) of this Privacy Policy on how to do this.
Right to Limit the Use and Disclosure of Sensitive Personal Information: Even though we do not process Sensitive Personal Information of yours, we’d like to also inform you that you principally have the right to limit the use or disclosure of your Sensitive Personal Information should we be using such data of yours beyond what is reasonable and proportionate to provide the requested services or other purposes permitted by the CCPA (Section 1798.121 CCPA).
Right of No Retaliation Following Opt Out or Exercise of Other Rights: If you exercise your CCPA rights, you have the right that we do not unlawfully treat you in a detrimental way (Section 1798.152 CCPA). Please note though, that depending on your request, features within our game might not work the same way as they would have without your request (e.g., if you want to see ads that might interest you more).