Privacy Policy

This Privacy Policy describes the ways that Crooto Software Ltd. ("Crooto Software", "us", "our" or "we") may collect, store, use and manage information, including personal information, and data that User ("User" or "you") provides in connection with the website (the”Website”) or Crooto Software Ltd. game provided on a mobile platform (for example, iOS and Android) (the "Service").


1.1 The following terms are used in this Privacy Policy:

1.1.1. “ Administration” (the “Website Administration”) means authorized employees of Crooto Software Ltd. acting on behalf of the company who organize and/or carry out personal data processing as well as determining the purposes of personal data processing, the content of personal data subject to processing, actions (operations) with personal data.

1.1.2. “Personal Data” means any information pertaining, directly or indirectly, to a particular or identifiable individual (the personal data subject).

1.1.3. “Personal Data Processing” means any action (operation) or a combination of actions performed automatically or manually with personal data including personal data collection, recording, systematizing, accumulation, storage, specification (updating, changing), extraction, use, transmission (distribution, granting, making available), depersonalization, blocking, removal, destruction.

1.1.4. “Personal Data Confidentiality” means a mandatory requirement to be observed by the operator or another person, who has access to personal data, of excluding its distribution without the personal data subject’s consent or another lawful ground.

1.1.5. User” (the “User”) means an individual having access to the Website via the Internet and using the website

1.1.6. “Cookies” means a small data fragment sent by the web server and stored on User’s computer that the web client or the web browser sends each time to the web server within the HTTP request during an attempt to open the page of the applicable website.

1.1.7. “IP Address” means a unique network address of the node that uses the Internet Protocol.


2.1. By using the Website, the User accepts this Privacy Policy and the conditions of the User personal data processing.

2.2. If the User does not accept the Privacy Policy conditions, the User should stop using the Website.

2.3. This Privacy Policy applies to the Website only. The Website Administration does not control or is not liable for any third party websites that the User can access via the links located on the Website.

2.4. The Website Administration does not verify the accuracy of the personal data provided by the Website User.


3.1. This Privacy Policy determines the Website Administration obligations related to non-disclosure and maintaining confidentiality of the personal data that the User provides at the Website Administration request when filling in the application forms on the Website.

3.2. The personal data subject to processing according to this Privacy Policy may include, but not limited to:

- contact information (User's name, phone number and email address)

- profile information (gender, age or date of birth, links to profiles on other social networks and the information contained therein)

- technical data on the User’s device (IP address that sent a request to display the website, operating system type, device identifiers, browser type and language)

- mobile device identifiers (such as User’s unique device ID (persistent/non-persistent, hardware type, medial access control ("MAC") address, international mobile equipment identity ("IMEI"), and User's device name

- general location information for the purpose of providing User with the correct version of the application

- precise-geo-location information from User’s mobile device (but only with User’s express consent)

- game data (such as User’s interactions with the game and with the other players inside the game via server log files, User’s player ID)

3.3. If the User accesses the Website content via a third party social network (the “Social Game”), the Website Administration may collect the data on the User’s social network profile, including the information the User makes available themselves, the User’s social network identifier, name, surname, profile photo. If the User invites another user in the User’s Social Game or sends messages via the Social Game, the Website Administration may collect information in relation with these messages, for example, the User friends’ social network identifiers, e-mails and content thereof.

3.4. If the User downloads or accesses the Website content from a mobile device, the Website Administration and its service providers may collect information on the User’s location (through the User’s IP address) and mobile device, including different unique identifiers related to the User’s device, hardware type, operating system type, and game activities. The Website Administration and its service providers may use this information to serve individual advertisement and other content, including location-based advertisement and content.


4.1. The Website Administration may use the User personal data to contact the User, including sending notices, requests related to the use of the Website, providing services, processing the User requests and application forms.

4.2. The Website Administration may use the collected information to compile aggregate anonymous data on the Website’s community for security purposes and to improve the services provided.

4.3. The Website Administration may use information collected for purposes described in this Policy or disclosed by User in connection with the Website. For example, The Website Administration may use User's information to:

- identify and suggest connections with other users;

- operate and improve The Website;

- understand User's preferences to enhance User's experience and enjoyment using The Website;

- respond to User's comments and questions and provide customer service;

- provide and deliver products and services that User requests;

- deliver advertising and marketing and promotional information to User;

- send User related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;

- communicate with User about promotions, rewards, upcoming events, and other news about products and services offered by Crooto Software Ltd.


5.1. The User personal data processing is performed for an unlimited period of time, in any lawful method, including personal data systems, automatically or manually.

5.2. The User personal data may be provided to authorized government bodies of the Republic of Cyprus only as set forth in the laws of the Republic of Cyprus.

5.3. The Website Administration shall inform the User on the loss or disclosure of the User personal data if such loss or disclosure occur.

5.4. The Website Administration takes all the necessary organizational and technical measures to protect the User personal data from unauthorized or accidental access, destruction, changing, blocking, copying, distribution and other unlawful third party actions.

5.5. The Website Administration, together with the User, takes all the necessary measures to prevent damages or other negative consequences caused by the loss or disclosure the User personal data.


6.1. When you use any of Crooto Software Ltd. games or applications on a mobile platform, we may record certain information and data, such as User's application usage, access, session times and in-app purchases, User's unique device ID (persistent / non-persistent), hardware type, media access control ("MAC") address, international mobile equipment identity ("IMEI"), the version of User's operating system ("OS"), User's device name, User's email address (if User has connected to Facebook), and User's location (based on User's Internet Protocol ("IP") address). This information may be utilized for certain purposes, such as troubleshooting, interest based advertising as described elsewhere in this Privacy Policy, or other purposes.

6.2. Crooto Software creates a unique user ID to track your use of our Service. This user ID is stored in connection with User's profile information to track Crooto Software games User is playing.

6.3. Crooto Software may occasionally send User push notifications through mobile applications to send User game updates, high scores and other service related notifications that may be of importance to User. User may opt-out from receiving these types of communications at any time by turning them off at the device through the settings.

6.4. With User's express consent, Crooto Software or its partners may collect User's precise location based information (GPS) for the purpose of matching User with opponent players in User's local area, to tailor content specific to User's area, to show User's location to other players, and to match User's device location to certain points of interest for purposes of interest based advertising as described elsewhere in this Privacy Policy. Other players may then be able to see that User is available to play a game when User participates in specific areas of Crooto Software games.


7.1. Crooto Software may feature advertisements both by itself and with the help of its partners, collect and use data and information about User and User's device (including the presence of applications on the device or in use at a particular time on the device) in connection with such advertising, including User's viewing of and interaction with any such advertising.

7.2. Crooto Software and its partners may use cookies or similar tracking technologies to track the content User accesses or User's device location for purposes of interest based advertising. The privacy policies of Crooto Software partners may include additional terms and disclosures regarding their data collection and use practices and tracking technologies.

7.3. Advertisers on mobile devices and third party advertising and analytics partners may collect and use data and information about User, such as User's Service session activity, viewing of and interaction with an advertisement, device identifier, MAC address, IMEI, geo-location information and IP address for the purposes of analyzing, tracking and measuring advertisement performance and to provide interest based advertising.

7.4. User may see Crooto Software games advertised in other services. After clicking on one of these advertisements and installing Crooto Software game, you will become a user of our Service. In order to verify the installs, a device identifier may be shared with the advertiser or third party advertiser or analytics partner.


8.1. The User shall:

8.1.1. Provide personal data needed for additional services using the Website.

8.1.2. Update, change the personal data when this data changes.

8.2. The Website Administration shall:

8.2.1. Use the information it receives only for the purposes indicated in paragraph 4 of this Privacy Policy.

8.2.2. Provide keeping Confidential Information in secret, and shall not disclose it without prior written notice of the User, and also shall not: sell, exchange, publish or otherwise disclose any received Confidential Information of the Users, except the cases described in paragraphs 5.2. and 5.3. of this Privacy Policy.

8.2.3. Take safety measures for protecting Confidential Information of the Users in the way that is usually applied for protecting such information in the existing business practice.

8.2.4. Block personal data related to the corresponding User since the moment of User’s, his/her legal representative’s or authorized personal right-protective body’s appeal or request for the period of examination, in case of determining false personal data or illegal activities.


9.1. If Website Administration does not fulfil its obligations, it bears responsibility for the loss of the Users due to unauthorized use of the Confidential Information according to the law of the Republic of Cyprus except cases provided in paragraphs 5.2., 5.3. and 7.2. of this Privacy Policy.

9.2. In case of loss or disclosure of the Confidential Information, Website Administration does not bear any responsibility if such Confidential Information:

9.2.1. Became publicly available before such loss or disclosure.

9.2.2. Was known from a third party before it was received by the Website Administration from the User without obligation to keep it confidential.

9.2.3. Was disclosed with the consent of the User.


10.1. The Service may contain third party tracking and data collection and analytics tools from our service providers, examples of which include Google Analytics, AppsFlyer and Firebase. Such third parties may use cookies, APIs, and SDKs in the Service to enable it to collect and analyze User and device related data and information on Crooto Software Ltd. behalf.

10.2. The third parties may have access to and collect data and information about User, such as your device identifier, MAC address, IMEI, locale (specific location where a given language is spoken), geo-location information, IP address, application usage, access and session times, applications present on the device or in use at a particular time on the device, and User's viewing of and interactions with advertising, for the purpose of providing their services, including, for example, enabling, providing and delivering advertising as described in further detail below.

10.3. The privacy policies of providers may include additional terms and disclosures regarding their data collection and use practices and tracking technologies.


Crooto Software Ltd. does not share User's personal information except as approved by User or as described below:

11.1. Crooto Software Ltd. may engage other companies and individuals to perform services on Crooto Software Ltd. behalf. Example of these services include analyzing data and providing customer support. These agents and service providers may have access to User's personal information in connection with the performance of services for Crooto Software Ltd..

11.2. Crooto Software Ltd. may release User's information as permitted by law, investigate fraud, respond to a government request, enforce or apply Crooto Software Ltd. rights; or protect the rights, property, or safety of Crooto Software Ltd. or it's users, or others. This includes exchanging information with other companies and organizations for fraud protection. In certain situations, Crooto Software Ltd. may be required to disclose personal information in response to lawful requests by public authorities or for local law enforcement requirements.

11.3. Crooto Software Ltd. may share aggregate or anonymous information about User with advertisers, publishers, business partners, sponsors, and other third parties.


12.1. Before legal recourse of the claims or disputes that arise due to relations between the Users of and Website Administration, it is required to provide a claim (a written offer to settle the dispute voluntarily).

12.2 .The recipient of the claim sends back a written notification to the claimer about the results of reviewing the claim within 30 calendar days.

12.3. In case of non-settlement of the dispute, it will be passed over to the court according to the effective law of the Republic of Cyprus at the location of the Defendant.

12.4. This Privacy Policy and relations between the User and the Website Administration are subject to the effective law of the Republic of Cyprus.


13.1. Website Administration has the right to make changes to this Privacy Policy without the consent of the Users.

13.2. New Privacy Policy comes into force right after it’s published at, unless otherwise provided in the new edition of the Privacy Policy.

13.3. Effective Privacy Policy is published at

© 2017 "Crooto Software Ltd.". All rights reserved.