Poki

Poki is in principle responsible for the processing of your data in the context of this website. We for instance use technical information about your device to make sure a game fits to your screen.

Other parties may also be involved with using data of our website visitors. They are responsible themselves, as specified below.

Please click here for a full overview of the cookies placed directly by Poki or on behalf of Poki.

The overview includes information on the types and the names of the cookies, their purpose, what they are used for, whether it concerns a first or third-party cookie and the related validity period.

Game developers

We do not make the games you can play on our Website. These games are created by game developers. Game developers sometimes use cookies or similar technologies. For example, to track how many points you earned during a game. When they use cookies or your data for this, they must of course comply with the privacy laws. To ensure they do this, we have taken various steps. Firstly, we have agreements in place with the developers and inform them of their responsibilities. The developers of the games on the Website are in principle required to remove all outgoing links and branding/advertisements from their game(s). Such as splash-screens, social links and app-store links. They are only allowed to include cookies and similar technologies in their game if they abide by the local privacy laws. We’ve prepared this list of the cookies used by our game developers, categorized per game, to inform you on behalf of the developers.*

If developers do gather personal data for their own purposes, they are responsible for this, not Poki. Only the developer decides what (personal) data is processed and for what purpose. However, because Poki knows it is important that your data is also safe when you play a game, we take further steps to help us check that developers are complying with privacy laws. For example, we actively search for certain cookies and similar technologies that developers shouldn’t be using on our Website. If we find any, we quickly contact the developer and may decide to stop offering their game on (part of) our Website. Also, we proactively block contact between a game and third-parties such as Google. This way, we prevent that developers can track you. They can only use cookies for the functioning of their game.

While we are proud of our measures to check on our developers’ use of cookies, we do not control their games. Thus, we cannot prevent every inappropriate cookie or similar technology. Therefore, if you notice something that makes you wonder, please let us know!

Advertisers

Poki uses the services of several advertising parties. These parties provide us with advertisements for our website. They are responsible for their part of using your data in this context. To protect your privacy in this respect, Poki ensures, amongst other things, that suitable contracts are in place with these advertisers. Further information regarding the use of cookies, also by advertisers, can be found in the How we use cookies section.

If you do not provide consent, we only show non-personalized ads. These ads are non-personalized ads “house ads” or non-personalized ads from third-parties. House ads are advertisements about other games available on the Poki website, displayed by Poki. Other non-personalized ads can be contextual ads. These ads are selected based on the context – such as the game being played – instead of any information about you. The advertisers engaged are thoroughly vetted.

Games on other websites

The information in this Privacy Center does not apply to the usage of your data by parties other than Poki that are responsible themselves (”data controllers”). This for instance includes providers of third-party games available via our website. Poki is not responsible for cookies that are placed by and for other parties when you visit another website (i.e. a non-Poki webpage). Such games are not hosted on our website, but e.g. on the website of the developer we work with. To play such a game, you need to access the website of that developer. This means that the owner of that website is responsible for the data it processes.

To help you decide when you go to websites outside of Poki, we show a banner if you play a game via our website that's actually hosted on another website (but still looks like the website of Poki). This banner tells you that you're going to a different website. It states: “Please note that this game is hosted on a third-party website.” You’ll see an exclamation mark on the upper left top, and text informing you that the game is hosted on a third-party website. The message, styled with bold text for emphasis, advises you to review the third-party site's cookies and privacy policies if they proceed to the game. Below this, a rounded blue button labeled "Got it, play now!" allowing you to acknowledge the message and continue. The design ensures clarity and compliance by highlighting the shift in responsibility for data practices to the third party. The company that offers the game on that other website is responsible for making sure they follow the privacy and data protection laws when they use your data for the game. Normally, Poki doesn't let other companies collect your personal data if you visit our Website. If a company does need to collect your personal data to offer the game, we'll require them to follow the law when they do so.

All features on the website are available without the need for registration. To offer our website, Poki does collect certain electronic data. We may process this data in various ways.

Please find directly below some information about our use of your data in general (”general processing purposes”). Below that, you will find information on two legal grounds we sometimes rely on to use your data: the “legitimate interest” and “legal obligation.” Please click on these topics for more information on this.

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

• For maintenance (including debugging), administration and network and security purposes;
• For internal control and business operations;
• For developing, analysing and improving the website and our products;
• For handling any requests, complaints and disputes;
• For determining, exercising and defending our rights;
• For mergers or acquisitions of Poki or another company; and
• For complying with legal obligations (incl. fraud prevention) and requests of authorized governmental institutions.

We process your data for providing, maintaining, analyzing and improving the website. We have specified this below.

Sensitive information

In the context of our website, we do not purposefully process sensitive information, such as information about your race or health.

Why we use your data

Poki may also process your personal data when you contact us.

Sensitive information

If you contact us, we do not purposefully process sensitive information, such as information about your race or health. We therefore ask you not to share such information with us.

Why we use your data

Sometimes, we use your data to handle requests or communications from you, or for legal reasons. The data we use if you contact us, is included in the overview below. We don’t share this information with anyone else, unless necessary for legal reasons.

• Automatically obtained. Most data we obtain automatically via the website, for example by using cookies and similar technologies. When your computer or mobile device contacts our web servers when you visit the website, our web servers automatically collect usage information. Such usage information includes information about how you use and navigate our website. It can include how often a web page was visited and for how long. For more information on the use of cookies please see the section How we use cookies.
• Provided by you. Some data about you, we receive straight from you. Examples include information you share if you use our contact form or if you e-mail us. In that case we receive the information you share with us directly from you.
• Derived. Certain data we do not receive directly from you, but can be derived from the information we already have. For example, information about the applicable law. We determine your location on country-level. We use this to show you the right version of our website and legal documents.
• Obtained internally. It is possible that we obtain your data via other Poki systems. An example is if website visitors agree to participate in a user play test. This happens when we test if website visitors of our website are happy with the way it works. We always look for how we can make it better. If you sign-up for a user play test, we can connect the data from the application form to the game play data.
• Obtained from third parties. Below we added some examples of third parties that may share data with us.
  • Local authorities. Sometimes we receive a request from local authorities to share data about players. For instance, if they are looking for a criminal. If we are legally required to share player data, we may share this. But only if this is allowed under the privacy laws as well.
  • Developers. In very rare cases, you may access a game that is running on the website of the developer. If so, this developer may share player data with us. We analyze the player data for the developer. For example, to show how many players finish a level.
  • Advertisers. We may receive technical data from advertisers, e.g. to see whether an ad was clicked on and was shown correctly. We need this information to check how much they need to pay for showing the ad.
  • Service providers. We cannot make all the technical magic happen ourselves. We pay service providers to help us. For instance, to make our website really fast. These service providers may share data with us.
• Non-personal data. Other (aggregated) information we receive is no longer considered personal data. This data is completely anonymized before we receive it. This means that we do not know to whom the data relates.

You are not required to give us any information about yourself. But if you do not share some data, this may impact how our website works or if we can answer your question. For instance, if you use a VPN connection which makes it appear that you are in another country, we may show you our website for the wrong country.
If the provision of certain personal data is a legal or contractual obligation or an essential requirement for concluding an agreement with us, we will separately provide additional information about this for as far as this is not clear in advance. In such case we will also inform you about the possible consequences if this information is not provided.

We only share your data with third parties - people outside Poki - if:

• This is necessary. If sharing the data is necessary for the service this party provides or its involvement. Sub-contractors, for example, will only get access to data which they need for their part of the service provision.
• Confidentiality is ensured. The persons within the third-party that have access to the data must treat your data confidentially. Where necessary, this is also agreed upon in a contract.
• The privacy rules are complied with. The third-party is obliged to comply with the applicable privacy rules. To make sure that they do so, we may also include this in our contract with this party. This for instance means that the party is obligated to ensure appropriate technical and organizational security measures.

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

• Poki personnel. Authorized persons, employed by Poki, who are involved with the processing activity concerned. Such as, the members of the support team you are in contact with.
• Personnel of our service providers. Authorized persons, employed by service providers/sub-contractors engaged by Poki, who are involved with the processing activity concerned. Such as, the service provider for Poki's internal processes.
• Advertisers. Advertisers on the Poki website may receive information gathered by cookies for advertising purposes. For more information on the use of cookies please see the section How we use cookies.
• Authorized local authorities and more. Such as, courts, police, and law enforcement agencies. We may release information about our website visitors when we are legally required to do so. For instance at the request of local authorities or other governmental institutions conducting an investigation. Or to verify or enforce compliance with the policies governing the website and applicable laws. We may also disclose such information about website visitors if we believe this is necessary to protect the rights, property or safety of Poki, or any of our business partners, customers or others.
• Non-personal data. We may also disclose non-identifying, aggregated statistics regarding website visitors to third parties for a variety of purposes. For instance, to describe our services to prospective game developers. Examples of such non-personal information include the number of website visitors who visited this website during a specific time period or played a specific game.

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

Poki has internal documents in which it is described how we safeguard an appropriate level of technical and organizational security. In addition, we have a data breach procedure in which it is explained how (potential) data breaches need to be handled. We will, for example, inform the competent supervisory authority and involved individuals when this is required by the applicable law.

Poki stores your data in the Netherlands. For storing data, Poki uses BigQuery, a Google Cloud solution. The data is stored in the Netherlands. However, Google is headquartered in the US. How this relates to the transfer rules, is explained on this webpage.

Poki uses the data of CloudFlare to make the Website fast. How CloudFlare makes sure that the transfer rules are complied with, is explained on this webpage.

More generally, we can inform you as follows about the involvement of parties in other countries. In case your data is transferred from your country to another country, the transfer is legitimized in the manner described below.

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

EU transfers and UK transfers are legitimized in the manner described below. You may contact us for information on the legitimization of data transfers for other countries/regions or for more specific info. Our contact details are included in the bottom of the Privacy Center.

If you exercise certain privacy rights, it is possible that Poki will remove your data earlier than the general applicable retention period or – oppositely – retain it for a longer period of time. For more information about this, please refer to the section Your privacy rights.

In some situations, we process your data longer than is necessary for the purpose of the processing. This is for instance the case:

• Retention obligation. To comply with a minimum retention period or other legal obligation to which we are subject based on the applicable law.
• Procedure. We need to store your data in relation to a legal procedure.
• Freedom of expression. If further usage of your data is necessary to exercise the right to freedom of expression and information.