Legal
Privacy policy
This privacy policy explains how Pawtown handles personal data on the website pawtown.nl and in games released under the Pawtown name. We keep it simple: we only process data that is genuinely needed, and we only describe what we actually do today. Features that do not exist yet are listed separately. This is a translation; if the two versions differ, the Dutch version prevails.
1. Who is responsible
Pawtown is a brand of Kejovideos (KVK 88897176), registered with the Dutch Chamber of Commerce. This business is the data controller under the General Data Protection Regulation (GDPR).
- Company
- Kejovideos
- Legal form
- Eenmanszaak
- Brand
- Pawtown
- KVK number
- 88897176
- D-U-N-S number
- 494555401
- Address
- Dr.Schaepmanstraat 8
8471 ME Wolvega
The Netherlands - Website
- pawtown.nl
For privacy questions, email kejointeractive@gmail.com.
2. Overview: what is active now
| Item | Status | What data |
|---|---|---|
| Visiting pawtown.nl (hosted by Cloudflare) | Active | Technical data such as IP address and browser type (see §3) |
| Contact by email | Active | Email address, name (if you give it) and your message (see §4) |
| Cookies, analytics and tracking on the website | Not active | None. Only possible strictly necessary security cookies from Cloudflare (see §5) |
| Contact form, newsletter | Not active | None |
| Games | In development | Listed per game once it is released (see §7) |
| Advertising (for example Google AdMob) | Not active | None (see §8) |
| Accounts and progress saved online | Not active | None (see §8) |
| In-game purchases | Not active | None (see §8) |
3. Visiting the website
pawtown.nl is hosted by Cloudflare (Cloudflare Pages). When you visit the website, Cloudflare automatically processes technical data needed to deliver and secure the pages, such as:
- your IP address;
- date and time of the visit;
- the requested page or file;
- browser and device information (user agent) and the referring page.
Purpose: making the website available, fast, and protected against abuse and attacks (such as DDoS attacks).
Legal basis: legitimate interest (Article 6(1)(f) GDPR): a secure, working website.
What we see: we do not store visitor logs ourselves and do not use an analytics tool. The Cloudflare dashboard only shows us aggregated statistics, such as the number of requests and the countries they came from.
4. Contact by email
When you email us, we process your email address, your name (if you include it), the content of your message and any attachments.
Purpose: answering your question and helping you, for example with support for a game or a privacy request.
Legal basis: legitimate interest in answering your question (Article 6(1)(f) GDPR). If your question concerns a game you use, also performance of a contract (Article 6(1)(b) GDPR). Handling a privacy request is a legal obligation (Article 6(1)(c) GDPR).
Retention: up to 2 years after your question has been handled, unless we must keep the message longer for a legal obligation or an ongoing dispute.
Email service: we receive email through Gmail, a Google service. Google also processes messages under its own privacy policy.
Please do not send sensitive data (such as medical information or identity documents) by email unless necessary.
5. Cookies and tracking
The website uses no analytics cookies, no tracking cookies and no advertising cookies, and loads no tracking pixels, social media plugins or advertising scripts. That is why we do not ask for cookie consent.
In some cases Cloudflare may set strictly necessary security cookies, for example to detect automated traffic (bots) or to remember that you passed a security check. These cookies are needed to secure the website, are not used to track you, and do not require consent under Dutch law.
6. External services and links
The website does not load fonts, videos, maps or other content from third parties. All files are served from pawtown.nl.
The website may link to other websites, such as an app store. If you follow such a link, the other party's privacy policy applies.
7. Games
At the time of this version, Pawtown games are still in development. No Pawtown game has been published in an app store yet.
When a game is released, this policy will state for each game what data it processes, for what purpose, and through which services or SDKs. Principles:
- If a game stores progress and settings only locally on your device, we do not receive that data. You remove it by uninstalling the app, clearing the app data, or (for a web game) clearing the site data in your browser.
- If you download a game through an app store such as Google Play, that store processes data about your download and any payments under its own privacy policy.
8. Possible future features
The features below are not active now. We mention them so you know what may change. Before introducing any of them, we will update this policy with the specific services, SDKs, data, legal bases and retention periods, and ask for consent first where required.
Advertising
Some games may in future show ads through an ad network such as Google AdMob. Such a network typically processes device and advertising IDs, IP address and data about the ads you see and tap. For personalised ads in the EEA we will first ask for your consent through a consent message in the game.
Accounts and online saves
Games may in future offer an account or cloud saves so you can use your progress on multiple devices. This may involve storing an email address or account ID, a username and your game progress. How to have such an account and its data deleted will then be described at pawtown.nl/delete-account.
Purchases, crash reports and statistics
Games may in future include purchases (handled by the app store), crash reporting to fix bugs, or usage statistics. Again, we will list the data and services involved here in advance.
9. Children
Some Pawtown games may be suitable for, or aimed at, children. In the Netherlands, children under 16 need consent from a parent or guardian where processing is based on consent. We do not knowingly collect data from children on the website. If a child has emailed us and you, as a parent or guardian, want that data deleted, please contact us.
For games aimed (in part) at children, we follow the additional requirements of the GDPR and Google Play's Families policy. For example, we do not show personalised ads to children.
10. Recipients
We do not sell your data. We only share data with service providers we need:
- Cloudflare, Inc.: hosting, delivery and security of the website;
- Google (Gmail): receiving and managing email.
We may also disclose data where required by law, for example under a court order.
11. Transfers outside the EEA
Cloudflare and Google are US companies, so data may be processed outside the European Economic Area (EEA), including in the United States. Such transfers rely on the EU-US Data Privacy Framework, under which these companies are certified, and/or the European Commission's standard contractual clauses.
12. Retention periods
| Data | Retention |
|---|---|
| Technical data from website visits | Not stored by us. Cloudflare keeps it under its own policy, only as long as needed for delivery and security. |
| Email correspondence | up to 2 years after your question has been handled |
| Data we must keep by law (such as records of payments) | As long as the law requires, for example 7 years under Dutch tax law |
13. Security
We take appropriate technical and organisational measures to protect data. The website is served only over an encrypted connection (HTTPS), sends security headers and loads no third-party scripts. We collect as little data as possible and limit access to what is necessary. To report a security issue, email kejointeractive@gmail.com.
14. Your rights
Under the GDPR you have the right to:
- access the data we hold about you;
- rectification of incorrect data;
- erasure (‘right to be forgotten’);
- restriction of processing;
- object to processing based on legitimate interest;
- data portability for data you provided to us;
- withdraw consent where processing is based on consent. This does not apply retroactively.
Send your request to kejointeractive@gmail.com. We respond within one month. For complex requests this may be extended by up to two further months; if so, we will tell you within the first month. We may ask you to confirm your identity in a proportionate way. Never send a copy of your ID unless we explicitly ask for it.
We do not use automated decision-making or profiling with legal effects for you.
15. Complaints
If you are not happy with how we handle your data, please contact us first. You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) or with the supervisory authority in your own EU country.
16. Account and data deletion
Pawtown games currently have no accounts. The page Account and data deletion (in Dutch) explains how to clear locally stored game data and how to ask us to delete data you sent us by email. Once games offer accounts, it will also explain how to have your account and related data deleted. Email a deletion request
17. Changes
We update this policy when our services or the law change, and in any case before introducing new processing such as ads, accounts or online storage. The date at the top shows when it was last updated. We will also announce important changes in the game concerned.