Kuato Studios Privacy Policy

Kuato Games (UK) Limited respects your privacy and is committed to protecting your personal data. This
privacy policy will inform you as to how we look after your personal data when you visit our website
(regardless of where you visit it from) or use all software applications created by Kuato Games (UK)
Limited and tell you about your privacy rights and how the law protects you. Kuato Games (UK) Limited is
a data controller and is responsible for your personal data in this context (collectively referred to as "we",
"us" or "our" in this privacy policy).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this
privacy policy. If you have any questions about this privacy policy, including any requests to exercise your
legal rights, please contact the data privacy manager using the details set out below.
Full name of legal entity: Kuato Games (UK) Limited
Name or title of data privacy manager: Amy Walkers
Email address: privacy@kuatostudios.com
Postal address: Metropolitan Wharf, 70 Wapping Wall, London, E1W 3SS

The data we collect about you
Personal data, or personal information, means any information about an individual from which that person
can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of data as follows.

User Provided Information
Applications created by Kuato obtain the information you provide when you download the Application, or
create an online account through our website, and/or use the Application.
When you register with us or visit us through our website we generally collect and use anonymized data
using Google Analytics. However, we also collect and use your personal data in the form of IP addresses
as well as email addresses which are used for marketing purposes.
When you download and use our newer Apple/Google Applications, we do not collect your personal data.
However, the older versions of our Application do collect your personal data in the form of email
addresses.
We may use the information you provided us to contact you from time to time to provide you with
important information, required notices and marketing promotions.

Automatically Collected Information
Our website may collect certain information automatically, including, but not limited to, the type of browser
you use, the IP address of your machine, your operating system, and information about the way you use
our website.

Does the Application collect precise real time location information of the
device?
This Application does not collect precise information about the location of your mobile device.

Do third parties see and/or have access to information obtained by the
Application?
Only aggregated, anonymized data is periodically transmitted to external services to help us improve the
Application and our service. We will share your information with third parties only in the ways that are
described in this privacy statement.

We may disclose User Provided and Automatically Collected Information:
● as required by law, such as to comply with a subpoena, or similar legal process;
● when we believe in good faith that disclosure is necessary to protect our rights, protect your
safety or the safety of others, investigate fraud, or respond to a government request;
● with our trusted services providers who work on our behalf, do not have an independent use of
the information we disclose to them, and have agreed to adhere to the rules set forth in this
privacy statement; and
● if Kuato Games (UK) Limited is involved in a merger, acquisition, or sale of all or a portion of its
assets, you will be notified via email and/or a prominent notice on our Website of any change in
ownership or uses of this information, as well as any choices you may have regarding this
information.
We require all third parties to respect the security of your personal data and to treat it in accordance with
the law. We do not allow our third-party service providers to use your personal data for their own
purposes and only permit them to process your personal data for specified purposes and in accordance
with our instructions.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and
you fail to provide that data when requested, we may not be able to perform the contract we have or are
trying to enter into with you (for example, to provide you with goods or services). In this case, we may
have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How we use your personal data
We will use your personal data for sales and marketing purposes.

Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably
consider that we need to use it for another reason and that reason is compatible with the original purpose.
If you wish to get an explanation as to how the processing for the new purpose is compatible with the
original purpose, please contact us at privacy@kuatostudios.com.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the
legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance
with the above rules, where this is required or permitted by law.

International transfers
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is
afforded to it by ensuring that appropriate safeguards have been implemented.
Where we use certain service providers, we may use specific contracts approved by the European
Commission which give personal data the same protection it has in Europe. For further details, see
European Commission: Model contracts for the transfer of personal data to third countries.

What are my legal rights?
Users who reside in the UK or in the EEA have certain rights relating to the personal information we hold
in accordance with and subject to the General Data Protection Regulation (GDPR) and other UK and
European data privacy laws to: (i) check whether we hold personal information about you and to access
such data (in accordance with our policy); (ii) request the correction of personal information about you that
is inaccurate; (iii) have a copy of the personal information we hold about you provided to you or another
controller where technically feasible; (iv) request the erasure of your personal information; (v) object to the
processing of your personal data; and (vi) request the restriction of processing concerning you. To do so,
please send your request to privacy@kuatostudios.com and write “EU Privacy Rights” as the subject.
Information is only collected by the Application when you log in online and use the Application. You can
stop all collection of information by the Application easily by not using the service. You can also request to
opt-out via email, at privacy@kuatostudios.com.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the
UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the
chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Data Retention Policy, Managing Your Information
To determine the appropriate retention period for personal data, we consider the amount, nature, and
sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your
personal data, the purposes for which we process your personal data and whether we can achieve those
purposes through other means, and the applicable legal requirements.

We will retain User Provided data for as long as you use the Application in accordance with our data
retention policy and as long as reasonably necessary for the purposes for which it is collected. We will
retain Automatically Collected information for up to one year and thereafter may store it in aggregate. If
you’d like us to delete User Provided Data that you have provided via the Application, please contact us
at privacy@kuatostudios and we will respond in a reasonable time. Please note that some or all of the
User Provided Data may be required in order for the Application to function properly.

Children
We do not use the Application to knowingly solicit data from or market to children under the age of 13. If a
parent or guardian becomes aware that his or her child has provided us with information without their
consent, he or she should contact us at privacy@kuatostudios.com. We will delete such information from
our files within a reasonable time.

Security
We are concerned about safeguarding the confidentiality of your information. We provide physical,
electronic, and procedural safeguards to protect information we process and maintain. For example, we
limit access to this information to authorized employees and contractors who need to know that
information in order to operate, develop or improve our Application. They will only process your personal
data on our instructions and they are subject to a duty of confidentiality. Please be aware that, although
we endeavor to provide reasonable security for information we process and maintain, no security system
can prevent all potential security breaches and you should take customary precautions to guard against
“malware” (viruses, Trojan horses, bots, etc.), for example by installing and updating suitable anti-virus
software.
We have put in place procedures to deal with any suspected personal data breach and will notify you and
any applicable regulator of a breach where we are legally required to do so.

Changes
This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to
our Privacy Policy by posting the new Privacy Policy here http://kuatostudios.com/privacy/. You are
advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of
all changes. You can check the history of this policy by http://www.kuatostudios.com/privacy/.

Your Consent
By using the Application, you are consenting to our processing of your information as set forth in this
Privacy Policy now and as amended by us. "Processing” means using cookies on a computer / handheld
device or using or touching information in any way, including, but not limited to, collecting, storing,
deleting, using, combining and disclosing information, all of which activities will take place in the United
Kingdom. If you reside outside the United Kingdom your information will be transferred, processed and
stored there under United Kingdom privacy standards.

Contact us
If you have any questions regarding privacy while using the Application, or have questions about our
practices, please contact us via email at privacy@kuatostudios.com