1. Who we are

We are Soobimo. We offer a browser game platform where you can discover and experience many different web games in an easy and accessible way (“Platform”). You can access our Platform via an account (“Account”) or without. The Platform is made available via one of Soobimo' websites as visible in the address bar depending on your region (“Website”).

Legal information about Soobimo ("Soobimo", "we", "us"):

address

We recognize the trust you place in us and take our responsibility to protect your privacy seriously. This Privacy Policy (this “Policy”) provides important details about how we collect, process, disclose, retain, and protect your personal data. Please review it carefully to understand your rights and our obligations regarding your information.

The Platform is intended for visitors and users who are thirteen (13) years of age (or the applicable minimum age in your country) or older. If you are under thirteen (13) years of age (or the applicable minimum age in your country), this Platform is not intended for you. We do not knowingly collect or solicit personal information from children under the age of thirteen (13) (or the applicable minimum age in your country) through our Platform. However, we have launched a website specifically for younger children below the applicable minimum age, Organisation (“Kids Site”) and have a separate privacy policy for the Kids Site, available on policy. Soobimo does not allow personalised advertising on its Kids Site.

For information about the terms upon which we do business, you should also read our Terms of Service.

2. What is Personal Data?

Personal Data is any information about you that allows us to identify you. This could be, for example, your name or email address. But equally data about the games you played if we can link it to your account on our Platform (“Account”).

Soobimo strongly recommends not to use your real name or share any other personal data in any of the games provided on our Platform including, without limitation, when engaging in multiplayer.

3. From whom do we collect personal data?

In order to operate our Platform, we may collect data from users and visitors of the Platform and Website, developers of web games, persons who otherwise provide us with their contact details, and persons who contact us by email or other means. As described above under article 1.3, we do collect personal data from children older than the age of thirteen (13) or the applicable minimum age in your country.

4. What personal data does Soobimo process and why?

• To evaluate your job application
  Which personal data: Email address, name, age, gender, CV
  On what basis: Necessary for the performance of a contract or to take steps at your request, before entering a contract
• To register and authenticate your Account of the Platform
  Which personal data: email address, name, age, gender, external account, username and password
  On what basis: The prior, express, free, specific and informed consent of you
• Personalisation of your game experience (Account)
  Which personal data: username, device and connection data, selected interests, gaming behaviour and feedback
  On what basis: The prior, express, free, specific and informed consent of you
• To respond to your question or complaint, or to help you with technical problems
  Which personal data: name, e-mail address and other information that you provide to us
  On what basis: Necessary for the exercise of our legitimate interests, in particular to enhance the quality of our Platform
• To inform you of new functionalities of our Platform
  Which personal data: username and email address
  On what basis: Necessary for the exercise of our legitimate interests, in particular to communicate relevant information about our Platform
• To analyse statistics about visitors to our Platform and games in order to improve the Platform, the games and user experience
  Which personal data: data on visitors' behaviour (usage & device data) and in-game statistics
  On what basis: Necessary for the exercise of our legitimate interests, in particular collecting statistics about the usage and performance of our Platform and the games
• To comply with legal obligations
  Which personal data: data required by applicable law
  On what basis: Necessary to comply with a legal obligation
• To prevent, detect and combat fraud and other illegal or unauthorised activities
  Which personal data: data required for detection of fraud and illegal activities
  On what basis: Necessary for the exercise of our legitimate interests, in particular the prevention of fraud and other illegal activities
• For marketing of Soobimo (for example newsletters)
  Which personal data: username and email address
  On what basis: The prior, express, free, specific and informed consent of you
• To enable advertising on our Platform
  Which personal data: data gathered by the use of cookies, web beacons or similar technologies such as IP address, user IDs, browser type and operating system
  On what basis: The prior, express, free, specific and informed consent of you when you accept our Privacy and Cookie Policy, and confirm your ad preferences. This authorisation can be withdrawn by you at any time. For more information, please consult ‘Manage Your Ad Preferences’ and our Cookie Policy.
• To fulfil our obligations to game developers
  Which personal data: e-mail, tax identification number, bank account identification, Paypal Account, preferred payment method
  On what basis: Necessary for the performance of a contract
• To enable in-game purchases
  Which personal data: data related to the in-game purchase
  Soobimo does not collect any specific payment data when you make an in-game purchase. The payment is executed by a third-party payment provider. We store and link your in-game purchases to your Account. Necessary for the performance of a contract.

Registration of Account

If you register an Account with us, you give your explicit consent to collect a password, email address, user agent, and IP address. We also facilitate login via third-party providers. If you log in to our Platform using social media (such as Facebook) or Google login, you are granting permission to the third-party service to share your user details with us. This may include your name, email address, date of birth, and location, which will then be used to create your Account. These third-party services may use information about your visit to our Platform on their pages. If you browse these pages while still logged in to your Account with us, information they collect may be connected to your Account on their website. For more information on how these third-party services use information, please review their privacy policies.

Advertising

Soobimo displays ads from various advertising companies on the Platform. These ads may be personalised or non-personalised content-related ads. To show you personalised ads and only if you have given consent via our Consent Management Platform (“CMP”), we share certain data (such as your IP address, ad identifiers and the information that you have given consent for personalised ads) with third-party advertisers and ad networks. We also use this information to measure how effective these ads are. In our CMP shown to you when you first visit our Website, you can customise your ad tracking preferences or choose not to accept personalised ads at all. You can change your ad preferences at any time via “Preferences” in the menu of the Website. If you choose not to receive personalised ads at all, we will still show you ads, but they may not reflect your interests, as these ads will be content-specific and not user-specific.

Profiling

Soobimo may analyse your game data from the web games you play. Based on your game statistics, Soobimo may then recommend games you might be interested in. However, you will not be subject to decisions that will have a significant impact on you based solely on automated decision making, unless we have a lawful basis for doing so, e.g., if we have compelling legitimate grounds for us to continue or to establish a legal defence, and we have notified you. Please note that if you are located in the Us, you may have the right to object at any time to your personal data being processed for direct marketing purposes (including profiling to the extent that it is related to such direct marketing).

5. Do we share your personal data with others?

Yes. We may share your personal data with other companies. These companies help Soobimo to perform tasks for the Platform. For example, we may disclose your personal data to suppliers of IT and payment services, external consultants, and other subcontractors of Soobimo who provide services for the Website and Platform.

Users

We provide the option for our users to view profiles of other users, send friend requests, and game invites. By default, your profile is open to other users, which means that other users can send you friend requests. Only friends that you have accepted can view your profile (profile name, picture and background, games played, liked, and activity). You can customize these settings in the ‘Privacy Preferences’.

Advertising

Additionally, we may share information collected from you, such as your email (in hashed form), IP address, or information about your browser or operating system, with our identity partners/service providers. These partners return an online identification code that we may store in our first-party cookie for advertising use, which may be shared with advertising companies to enable interest-based and personalized advertising.

Game Developers

Soobimo may share specific personal data with external game developers when required to fulfill contractual obligations. Soobimo will always anonymize data when sharing usage data with a developer about their game.

Payment Providers

If you make in-game purchases, the transaction is processed by an external payment provider and subject to their privacy policy.

International Data Transfers

Soobimo may share your personal data outside the European Economic Area and will take the necessary steps to protect your data. For more details, contact us via email at email.

6. How long do we keep your personal data?

Soobimo retains data as necessary to fulfill listed purposes or until account deletion. You may delete your account via Account Settings, but please note that this is permanent and linked purchases will be inaccessible afterward.

7. Is your data safe at Soobimo?

Soobimo takes security seriously. Access to personal data within Soobimo is limited to those who need it for their work. Processors are under contract to ensure data is handled safely and deleted once their task is completed.

8. In charge of your data

You have rights over your data, including:

• View: See what data Soobimo holds about you.
• Edit: Correct personal data on your Account.
• Delete: Request deletion of your personal data.
• Freeze: Restrict processing of your data temporarily.
• Opt-out of marketing communications: Unsubscribe from newsletters at any time.
• Object to personalized advertising: Manage your ad preferences in the CMP.
• Transfer: Request a copy of your data for transfer to another company.
• Submit a complaint: Contact Soobimo or a data protection authority.
• Withdraw consents: Retract consent when data processing is based on your consent.

9. Manage your ad preferences

Upon first visit, you can accept or reject advertising services through our CMP. You can adjust these preferences at any time via the "Preferences" button on our Platform.

10. Privacy of children

The Platform is intended for users 13 years or older. Children under 13 (or the minimum age in their country) should use the Kids Site, which does not enable personalized advertising or user login features.

11. Links to Other Websites

Our Platform or web games of developers may contain links to other websites that do not belong to us. If you click on such a link, you will be directed to that other company's website, such as social media. You should check the privacy policy of each website you visit by clicking on such a link.

We have no control over and take no responsibility for the content, privacy policies, or practices of any third-party websites or services.

12. Externally Hosted Games

This Privacy Policy does not apply to the processing of personal data by data controllers other than Soobimo, such as providers of third-party games available on the Platform. Such game providers may, for example, post their own advertisements, offer their own game accounts, or a chat system to talk to other players. We will provide you with an explicit notice when you click to play such a game. The relevant provider of such a third-party game is itself responsible for ensuring that any processing of personal data by it in the context of a game complies with applicable data protection legislation.

In principle, Soobimo does not allow third-party providers to collect personal data on Platform users. If personal data is nevertheless collected by third-party providers, Soobimo will require that any processing of personal data by them, for example in the context of a game, complies with applicable legislation.

Please note that if you choose to play a third-party game, you are playing that game in the environment of that game's third-party developer, over which we have no control. We, therefore, recommend that you read the privacy statement of that game distributor before playing the game.

13. United States Privacy Rights

Residents of certain US states are granted specific legal rights regarding their personal information. These rights are not absolute and may be subject to exceptions and exemptions. For the purposes of this section, "Personal Information" is defined according to the California Consumer Privacy Act of 2018 ("CCPA") as 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.

In these states, individuals have enhanced rights concerning their Personal Information, including the ability to access, confirm, correct, obtain a copy of, delete, and opt-out of the sale or sharing of their Personal Information. They also have the right to opt-out of profiling for targeted advertising. Depending on the circumstances, we may need to obtain consent before collecting sensitive personal information and limit its use and disclosure. Detailed notices about these rights and how to exercise them will be provided upon request.

We may collect or process (and may have collected or received during the 12 months prior to the last updated date of this Policy) the same categories of personal information as mentioned in Section 7 of this Policy. We collect and use these categories of personal data for the business purposes described in the "Why" column of Section 7, of this Policy, for the business purposes described therein. Furthermore, Soobimo does not collect or process sensitive personal information for the purpose of inferring characteristics about a user.

While we do not generally sell personal information in the traditional sense, certain state laws, such as the CCPA, may interpret certain activities involving the sharing or disclosure of personal information as a "sale" or to the extent that any activities described in Sections 4 and 5 of this Privacy Policy are considered a "sale" or "share" of personal information under applicable state laws, Soobimo will comply with all legal requirements regarding such activities.

14. Changes to Our Privacy Policy

From time to time, it may be necessary to amend this Privacy Policy. When we announce changes to our Privacy Policy, we will change the "last updated" date at the top of the document. In case you have an Account, we will also notify you by email. You will always be able to access the most recent version of this Privacy Policy on our Websites.

15. More Questions About Your Data

If you have any questions or concerns about this Privacy Policy or our handling of your data, please send a message to email or through our address.

We hope that you will first contact us. But if your question or request is not resolved by us, you can also always lodge a complaint with the appropriate data protection authority. You can reach this authority by asking us at our email address or by researching the appropriate authority on the web. You may also write to us by post at our address.

Soobimo Cookie Policy

1. Who We Are

We are Soobimo. We offer a browser game platform where you can discover and experience many different web games in an easy way (“Platform”). You can access our Platform via an account (“Account”) or without. The Platform is made available via one of Soobimo' websites as visible in the address bar (“Websites”).

Legal information about Soobimo ("Soobimo", "we", "us"):

address

2. What Are Cookies?

Cookies are small files that are saved on your computer when you visit web pages. They contain information linked to a web browser and the specific website. They are saved in a specific folder on your hard drive. If you return to a specific website, this page can recognize the visitor by means of the cookie and further elaborate the history. A web beacon is an (often transparent) graphic image, usually no larger than 1 pixel, that is placed on a website and is used to monitor the behavior of the user visiting the website.

Cookies are used to increase visitor-friendliness: by identifying visitors with a cookie, they do not always have to enter the same data such as login information or screen settings every time they visit the website.

In this Cookie Policy, we explain what cookies are, their purposes, and which cookies we use on our Websites. More information on your privacy and data protection rights can be found in our Privacy Policy.

3. What kind of cookies exist?

Often a distinction is made between two large groups of cookies:

• First party cookies: These cookies are created by a website to make the web page function better. They regulate the technical part of a site, such as language choice or remembering the products in the shopping basket in an online store. The visited website creates and places first-party cookies.
• Third party cookies: These cookies are created and placed on your computer by another (third) party than the website you visit. They remember the behaviour of a user. Examples are social media platforms or Google Analytics.

Cookies essential for the correct functioning of our Websites do not require permission. All other cookies do.

4. Why do we use Cookies?

Cookies are generally used to increase visitor-friendliness: by identifying visitors with a cookie, they do not always have to enter the same data such as login information or screen settings every time they visit the Websites. Soobimo and our authorised, third-party service providers use cookies and other similar information-gathering technologies throughout our Platform to collect certain information automatically and store it in log files for a variety of legitimate business interests and purposes.

We use these technologies for statistical purposes, to analyse and improve the use of our Platform, and to prepare aggregated usage reports. Cookies are essential for us to optimise each visit to the Platform, offer you a better game experience, or provide relevant ads that you might be interested in.

5. What is our legal basis?

On our free, ad-supported Platform, we use these technologies for our legitimate business purposes of providing standard advertising controls, determining user response to advertisements and promotions, and delivering targeted advertisements that we or our authorised, third-party service providers believe will be of most interest to you.

6. Which Cookies do we use?

First party: We will only use first-party cookies to help improve your user and game experience on the Platform. This includes recording specific information about the user, such as the language chosen, pages visited, and the duration of visits.

Game distributors: We may offer games from third-party game distributors on our Platform. By playing a third-party game, your personal data may be processed by the third-party game distributor. We recommend that you read the privacy statement of that game distributor before playing.

Third party: Third parties might use information gathered by cookies and/or web beacons for online behavioural advertising. Soobimo declines all liability for any third-party cookies or web beacons deployed by third parties for whatever purpose.

The Websites may use third-party cookies such as cookies from:

• Appnexus
• Google Ad Exchange
• Google Adsense
• Magnite

Google Analytics: We use third-party cookies like Google Analytics to collect website statistics and analyze visitor flow and behavior. This data helps us adapt parts of the website to visitor interests.

8. Changes to our Cookie Policy

We may occasionally amend this Cookie Policy. When changes are made, the "last updated" date will change. Account holders will also be notified by email. The latest version will always be accessible on our Platform.

9. More questions about Cookies

If you have any questions or concerns about this Cookie Policy or our use of cookies, please send a message to email or use our contact form.