We collect certain information about our users and visitors to our Site and users of our Game(s).
This personal data falls into these categories:
- Contact Data includes email address.
- Profile Data includes your login user id’s, as well as any profile data which we have added (for example, first name, screen name and profile picture from an External Web Site (as defined below)).
- Technical Data includes internet protocol (IP) address and other technology on the devices you use to access the Site or Game(s).
- Usage Data includes information about how you use our Site and the Game(s).
- Tracking Data includes information we or others collect about you from cookies and similar tracking technologies, such as web beacons, pixels, and mobile identifiers.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Site feature or Game(s). Aggregated Data may be linked to a login ID.
How is your Personal Data Collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Contact Data by filling in forms or by corresponding with us by email.
This includes personal data you provide when you:
- fill in a form;
- make inquiries or request information be sent to you;
- contact us via email.
Automated technologies or interactions. As you interact with us, including via the Game(s), we may automatically collect Technical Data. We may also collect Tracking Data or Usage Data when you use our Site or Game(s).
If you use the Game(s) on or through an External Web Site (as defined below), we receive your Profile Data (i.e. your login ID) from the External Web Site. We may be able to identify your first name, screen name and profile picture on an External Web Site with your login ID.
Note that as your purchases of virtual in-Game fictional currencies ("VC") or virtual items are administered on External Web Sites by third parties, we do not collect your credit card or billing information.
How we use your Personal Data
- Where we need to perform the contract we are about to enter into or have entered into with you. For example, when you agree to our Game(s) License Agreement, that’s a contract.
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests. For example, when we ensure that you are authorized to login to the Game(s) or to provide you with support you have requested.
- Where we need to comply with a legal or regulatory obligation. For example, keeping records of our sales for tax compliance.
See Explaining the legal bases we rely on to process personal data to find out more about the types of lawful basis that we will rely on to process your personal data.
Explaining the legal bases we rely on to process personal data
The table below shows you a description of all the ways we plan to use personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Type of data
Lawful basis for processing
To enable you as a user to use our Game(s)
Performance of a contract with you
To process your transaction for our Game(s) including:
- Manage payments, fees and charges from External Web Sites
- Collect and recover money owed to us from External Web Sites
Necessary for our legitimate interests (including to recover debts due to us)
To provide our Game(s) and to manage our relationship with you which will include:
- Providing you with the Game(s), including tracking your Game(s) play progress, and providing you with support
- Ensuring you are authorized to login to the Game(s)
Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests
To administer and protect our business and this Site and the Game(s) (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Necessary for our legitimate interests (for running our business, provision of administration and services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)
Necessary to comply with a legal obligation
To use data analytics to improve our Site, Game(s), marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Site and Game(s) updated and relevant, to develop our business and to inform our marketing strategy)
To prevent and detect unlawful acts
Necessary for our legitimate interests (to protect our business and our customers by way of undertaking fraud monitoring and suspicious transaction monitoring)
Necessary to comply with a legal or contractual obligation to share personal data for the purposes of law enforcement
In order to resolve legal claims or disputes involving you or us
All relevant data categories, depending on the nature of the allegation or claim
Necessary to bring or defend a claim
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
We do not carry out any automated decision making.
Jolly Bear recognizes the privacy interests of children and we encourage parents and guardians to take an active role in their children’s online activities and interests. Neither our Site nor our services are intended for children under the age of 16. Jolly Bear does not target its Game(s) or this Site to children under 16. Jolly Bear does not knowingly collect personal data from children under the age of 16. If you use the Game(s) through an External Web Site, such as Facebook or Pogo.com, they may confirm your age but they do not provide us with your age or date of birth.
Cookies and tracking
We do not follow browser “do not track signals”.
When you use our Site, your device or browser may be sent cookies from third parties. It's important for you to know that we have no access to or control over cookies used by these companies or third-party websites. We suggest you check the third-party websites for more information about their cookies and how to manage them.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.
Third Party Analytics Tools
Beyond the personal data you voluntarily provide to us, Jolly Bear utilizes analytics tools including third party technologies, such as Google Analytics and Facebook Analytics, to collect non-personal data through the Game(s) and/or an API. Certain types of information, including geolocation, device type, onsite Site usage and behavior, demographic data, purchase history and game play statistics (e.g. game play time), is collected and aggregated for our analysis.
Users may learn more about Google Analytics by visiting the Google Privacy and Terms page at www.google.com/policies/. You may opt out of being tracked by Google Analytics by i) Turning off cookies in the preferences settings in your browser ii) Downloading the Google Analytics opt-out browser add on available at: https://tools.google.com/dlpage/gaoptout/ iii) Opting out of user interest and demographic categories in the Settings for Google Ads feature to manage or opt out of Google interest based ads at: or iv) Managing cookies used for online advertising across multiple companies at the US-based Network Advertising Initiative at www.networkadvertising.org/choices/.
Disclosure of Personal data
Service Providers. We may provide your personal data and the data generated by cookies and the aggregate information to the vendors and service agencies that we may engage to assist us in providing our services to you. For example, we use a third party to host our Site. Such third party entities are obligated to use your personal data solely to provide the services to us.
Legal Requirements and Merger. We will disclose your personal data if we reasonably believe we are required to do so by law, regulation or other government authority or to assist in any investigation, to protect our or our users’ rights or to enforce our Game(s) License Agreement. We may transfer your personal data to a successor entity upon a merger, consolidation or other corporate reorganization in which Jolly Bear participates or to a purchaser of all or substantially all of Jolly Bear’s assets to which this Site relates.
Links to Third Party Sites and Use of Game(s) through Third Party Sites
The Site may provide links to other Web sites or resources over which Jolly Bear does not have control (“External Web Sites”) and you may find and use the Game(s) on or through an External Web Site. Such links, or the distribution of the Game(s) on an External Web Site, do not constitute an endorsement by Jolly Bear of those External Web Sites. You acknowledge that Jolly Bear is providing these links to you only as a convenience.
We employ industry standard procedural and technological measures that are reasonably designed to help protect your personal data from loss, unauthorized access, disclosure, alteration or destruction. Jolly Bear uses, without limitation, firewalls, password protection, virus checking software, encryption and other security measures to help prevent unauthorized access to your personal data. Each External Web Site has their own security and we are not responsible for their security or data collection or use practices.
We will only keep your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 unauthorized 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.
In some circumstances you can ask us to delete your data; see Your rights below for further information.
Notice to European Users
If the General Data Protection Regulation applies to you because you are in the European Union and if we are the controller of such personal data, you have rights under data protection laws in relation to your personal data as follows.
- The right of access – that’s a right to make what’s known as a ‘data subject access request’ for copy of the personal data we hold about you;
- The right to rectification – that’s a right to make us correct personal data about you that may be incomplete or inaccurate;
- The right to erasure – that’s also known as the ‘right to be forgotten’ where in certain circumstances you can ask us to delete the personal data we have about you (unless there’s an overriding legal reason we need to keep it);
- The right to restrict processing – that’s a right for you in certain circumstances to ask us to suspend processing personal data;
- The right to data portability – that’s a right for you to ask us for a copy of your personal data in a common format (for example, a .csv file);
- The right to object – that’s a right for you to object to us processing your personal data (for example, if you object to us processing your email for support); and
- Rights in relation to automated decision making and profiling – that’s a right you have for us to be transparent about any profiling we do, or any automated decision making.
These rights are subject to certain rules around when you can exercise them. Note that if Jolly Bear is not the controller of the personal data, you must contact the controller to request your rights. For example, you may be able to request that Facebook delete your personal data and if you play Game(s) through Facebook, your personal data associated with the Game(s) (including any Game(s) play or progress data) will be deleted.
If you wish to exercise any of the rights set out above, please contact us (see How to contact Jolly Bear about privacy).
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You have the right to make a complaint at any time to the supervisory authority for data protection issues in your country of residence. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us in the first instance.