Legal · this website
Privacy policy for this website
Draft
This text is a draft under legal review. It describes how things are meant to work, but it is not legal advice and not yet final.
This policy covers the website kozmaworks.com. Each of our games has its own privacy policy, linked at the end of this page.
Who is responsible
The controller of the personal data described here is Árpád Kozma, sole proprietor (egyéni vállalkozó), trading as Kozma Works; registered address: Szabadság tér 6., 2337 Délegyháza, Hungary; registering authority: Ministry of the Interior of Hungary (register of sole proprietors); registration number: 62570660; EU VAT ID: HU92217287; e-mail: [email protected].
What happens when you visit
This website is a set of static pages. It sets no cookies, stores nothing on your device, and loads no scripts, fonts, images or videos from other companies’ servers.
Like every website, it is delivered by a server that has to know where to send the page. Our hosting provider, Cloudflare, therefore processes your IP address, the page you asked for, the time, and the browser identifier your browser sends (the “User-Agent”), to deliver the page and to protect the site against attacks. We do not use this information to identify you.
Legal basis: our legitimate interest in delivering the website and keeping it secure (Article 6(1)(f) GDPR).
Website statistics
We may count visits with our own statistics, which use no cookies. When it is switched on, it works like this. When you open a page, your browser sends us the page address (without query parameters), the domain of the website that linked to it, your browser language, a size class of the window (small, medium, large or extra large), any campaign tags in the link (utm_source, utm_medium, utm_campaign) and, for a few buttons, the name of the action (for example “store_click”).
Our server also sees your IP address and browser identifier, as it does for any request. It uses them only to compute a one-day pseudonymous counter (a 16-digit hash made with a random key that is replaced every day) and does not store the IP address or the browser identifier themselves. The counter stays in our statistics store during the day and is deleted, together with the key, at the first visit of the next day. From then on only daily counts remain. Where our hosting provider supplies it, we also count your country. If your browser sends “Do Not Track” or “Global Privacy Control”, nothing is sent at all.
Legal basis: our legitimate interest in knowing how our website is used (Article 6(1)(f) GDPR).
Videos
Some game pages may show a trailer. The page displays a still image from our own server until you press play. Only then does your browser connect to the video service (YouTube in its privacy-enhanced mode, or Vimeo with “do not track”), which processes your data under its own privacy policy.
When you write to us
If you email us, we receive your address and whatever you write, and we use them to answer you (legal basis: our legitimate interest in replying, or steps towards a contract you ask for). We delete the correspondence when it is no longer needed, at the latest two years after the last message, unless the law requires us to keep it longer.
Who else processes your data
- Cloudflare, Inc. hosts the website and, if statistics are switched on, runs and stores them for us, as our processor. Cloudflare may process data outside the European Union; it is certified under the EU–US Data Privacy Framework and offers the European Commission’s standard contractual clauses.
- Our email provider stores the emails you send us. Mail to [email protected] is forwarded through Cloudflare Email Routing by Cloudflare, Inc.
We do not sell your data and do not share it for advertising.
How long we keep it
Server logs are kept by Cloudflare for a short period for security purposes. The one-day counter is deleted as described above. The daily counts contain no personal data, and we keep them for [X] [TODO: owner decides]. Emails: see above.
Your rights
Under the GDPR you can ask us for a copy of your personal data, ask us to correct or delete it, ask us to restrict its use, ask for it in a portable format where the law provides for that (Article 20 GDPR), and object to processing based on our legitimate interest. Write to [email protected]. We answer within one month.
You can also complain to the Hungarian data protection authority: Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH), Falk Miksa utca 9–11, 1055 Budapest, naih.hu, or to the authority of the country where you live. You can also go to court: in Hungary, the regional court (törvényszék) has jurisdiction, and you can choose the one of your home address.
Our games
The games have their own policies, because they work differently from this website:
Changes
If this policy changes, the new version will appear on this page with a new date.