Last Updated: January 1, 2020
Ninja Kiwi is committed to making our games both fun and safe to use, and we are committed to international best practices regarding the collection and minimal use of both anonymous and personally identifiable information (PII), in ways that are fully compliant with international standards such as GDPR, COPPA, and the California Consumer Privacy Act. In general, our approach is to only collect anonymous data wherever possible and use as little PII as is necessary to provide the best games and services, and then only to use PII to make those games and services better, mainly through having an email address for communications with our support team. We do not gather or use anonymous data or any personal information to broker to third parties for commercial purposes; we only want to make our games better, and we only work with best in class advertising companies with similar policies. We ask players whether they are under 16 if in the European Union and under 13 in all other territories, and if players are under those respective ages, we do not collect or store on our servers any PII, including IP address. Still wanting to make sure we provide best-in-class customer service, those players are given a non-personal unique code if they need to contact customer support.
Types of and Use of Information
Ninja Kiwi is committed to only using information when there is legitimate interest and where that interest supports player-focused services, such as registration, communication, customer support, and relevant advertising.
Ninja Kiwi Mobile Registration: When you register for a Ninja Kiwi mobile account, this account can be used across most Ninja Kiwi mobile games but does not provide registration to ninjakiwi.com or forums. You may provide us with an email that we use as a unique identifier for your account or choose a 3rd party login like Facebook, Google, or Gamecenter. We do not collect any age, gender, country, or other information. The primary use of this email is to allow customers to contact email@example.com from that email, so that customer support can immediately validate ownership and offer assistance more quickly. We do not do email marketing to mobile players. We do need to reserve the right to email all registered players in the case of legal notices or major company news, but we have never needed to do this to date. Players under the age of 16 in the European Union or under the age of 13 in all other territories are allowed to register for Ninja Kiwi accounts, but they cannot supply any personally identifiable information and are instead generated a non-personal unique code that they can reference for customer support. For games with social teams such as Clans or Guilds, players under 16 in the EU or under 13 elsewhere must identify themselves as such before they join a Clan or Guild in these games, and these younger players are then excluded from sending, receiving, or reading any chat messages - chat is completely disabled. Instead of simply excluding under age players from the game or from participating in Clans and Guilds, we choose this approach as it allows under age players to participate in the fun of Clan and Guild play and be part of a team, but without risking PII sharing. Players 16 and over in the EU and 13 and over elsewhere consent that any information they enter into chat, along with any and all other data, may be stored on servers in the United States or other countries.
Ninja Kiwi Website Registration: Registration for ninjakiwi.com is exclusively for the website and does not apply to mobile games or forums, which are separate registrations. While you do not need to register to play many of the games on ninjakiwi.com, several games or game features will not work without a successfully registered account, and we cannot provide effective customer support for any game progress without a successfully registered account. Registration does ask for username, email, and password or for 3rd party login via Facebook or Google. Players under the age of 16 in the EU or under the age of 13 in all other territories are directed specifically to use parent or guardian emails. Emails are used for customer support purposes; a checkbox exists for opt-in email marketing, and this is only used in the event of a major game release or update. We do need to reserve the right to email all registered players in the case of legal notices or major company news, but we have never needed to do this to date.
Ninja Kiwi Website Forum Registration: If you register for the ninjakiwi.com forums, we require an email address for registration validation. Children under the age of 13 in all territories are not allowed to register for the Ninja Kiwi forums because forums have open communication and we cannot reasonably monitor the forums for exchanges of personal information. We use reasonable efforts to monitor and remove any personally identifiable information; any forum member may also contact firstname.lastname@example.org to have their posts or accounts removed from view or deleted.
Facebook, Google+, Game Center, and Game Circle Logins: We use these services to simplify logins to our mobile and website logins and to connect players to their friends for co-operative and competitive play, and to compare scores and progress. We use the respective platform standard versions of these services and only reference the username/email associated to associate with your saved data, scores, and game progress.
Facebook and Google+ Information: When you register for Ninja Kiwi using Facebook or Google+, use Facebook likes or Google “+”, or share links through these services, Ninja Kiwi accesses data already provided to Facebook and Google in accordance with their Privacy Policies, and is only granted access to that information via the player-approved permissions necessary to use those games or services. Ninja Kiwi from time to time may review Facebook and Google+ data such as aggregate (not individual) age, country, and gender along with various data about how the overall player community are playing a game or using the web site in order to make our games and services more awesome. This information may be stored in cookies or on our secured servers but is not accessed by Ninja Kiwi in this way; if reviewed, such information is only viewed in aggregate via developer dashboards made available by these 3rd parties and covered by their privacy and security standards. Ninja Kiwi does not share or sell this information with any party.
Mobile Game Data: Ninja Kiwi tracks gameplay information about the way players play our mobile games, which includes game and player progress information that is essential for saving and protecting that progress. Analytics track elements of the game the players interact with most and least frequently, where players stop playing or play less, and other aspects of aggregate player progression through the game. Ninja Kiwi does not use analytics to try to squeeze more money out of players; we like to think we are in the old fashioned business of making fun games, so we use these analytics to help us understand what elements players are enjoying and when the fun stops so we can try to improve all players’ enjoyment. For players age 16 or older in the EU and age 13 or older in all other territories, IP address, device type, OS type, time stamp, and other general device level information are accessed and stored on distributed, scalable servers, which may be located in the United States. For players under age 16 in the EU and under age 13 in all other territories, no PII is stored.
Advertising: Ninja Kiwi uses third-party advertising companies to serve ads when visiting our web pages and mobile games. We offer our web games and many of our mobile games for free, so these ads allow us to continue making and updating top quality free games. The third-party advertising companies may collect and use information (but not your name, address, email address, telephone number, or other PII) about your visits to ninjakiwi.com and our mobile games in order to provide advertisements about goods and services of interest to you. For Bloons Adventure Time TD, Turner Broadcasting may collect non-personally identifiable information to manage and measure the delivery of advertising within that game, including the number of times the same advertisement is served and viewed. For players registered as under age 16 in the EU or under age 13 elsewhere, we use designated non-PII ad calls that either do not send PII (usually IP address) or encrypt that PII so that we have no access to it. These companies may use non-personally identifiable information (e.g., click stream information, browser type, time and date, heat maps, player behavior) during your visits to ninjakiwi.com and Ninja Kiwi mobile games in order to provide advertisements about goods and services likely to be of greater interest to you. These companies typically use a cookie or third party beacon to collect this information. We do not have access to this information or influence over third party ad network policies, barring our ability to discontinue their services. If you would like more information about advertising practices and to know your choices about not having this information used by these companies, you can visit Google's Advertising and Privacy page or the Network Advertising Initiative. Please understand that if you disable or block certain ad features, then other aspects of ninjakiwi.com, its games, or mobile games may not work correctly.
Billing and Financial: Ninja Kiwi does track the act of purchasing (that a purchase happened and what was purchased) when using Facebook Credits, Super Rewards, Xsolla, Trial Pay, iTunes, Google Wallet, Amazon, and/or other 3rd party wallet services, but
Ninja Kiwi does not have access to any personal billing information. The act of purchasing is tracked for purposes of making sure that Ninja Kiwi games deliver great value for money and so that we can provide awesome customer support should something go wrong, and in such cases assist in the processing of refunds where possible.
Other Use of Information
Ninja Kiwi does not sell, rent, or publicly share your PII or aggregate data to anyone. We may use the information you provide to provide customer support or respond to forum posts. In the event of a change in corporate ownership or control, we would transfer all personally-identifiable and non-personally identifiable information to the new owner or controlling party. Ninja Kiwi would also share the minimum PII necessary to comply with court order, fraud protection, or other legal proceedings, to enforce our Terms of Service, or to protect the safety, rights, or property of Ninja Kiwi or its employees.
Children Under 16 in the EU and Under 13 In All Other Territories
We respect the privacy of parents, guardians, and their children, and we are committed to complying with the Children's Online Privacy Protection Act (COPPA), the California Consumer Privacy Act (CCPA) and EU standards, including the Global Data Protection Regulation (GDPR). On ninjakiwi.com, players under age 16 in the EU or under age 13 in all other territories may not enter PII during the registration process (they must use a parent’s or guardian’s email address) and they may not sign up for forum accounts at all. Mobile players under age 16 in the EU or under age 13 in all other territories, do not share any personal information in the registration process and no PII such as IP address is stored for those players. Bloons TD Battles and Tower Keepers allow children under 16 in the EU and under 13 elsewhere to participate in guilds but not to send, receive, or view any chat messages. The ninjakiwi.com and Kongregate versions of Bloons TD Battles, Bloons TD 5, and SAS Zombie Assault 4 allow text chat to coordinate and enhance the multiplayer experiences; children under 16 may not use these chat systems. If anyone ever asks for personal information in chat, please screenshot the interaction and send the image to email@example.com for investigation. Helpful “mute” buttons also exist in each of those games that will hide chat entirely, and we encourage parents and guardians to use this setting for those under 13.
If at any time a parent or guardian believes that his or her child has submitted personal information to Ninja Kiwi, he or she can contact us at firstname.lastname@example.org. Ninja Kiwi will make reasonable efforts to delete the information upon learning that it relates to a child under the age of 16. Ninja Kiwi believes that parents should supervise their children's online activities and actively advise them on appropriate behavior and online safety, including avoiding chat systems and other open communication tools and never sharing personal information.
Many of our games provide additional content for a direct fee - usually buying an item or an amount of in-game currency to make gameplay faster or more fun. Parents and guardians should be aware that they can set up their mobile devices to disallow one touch purchases and enforce password entry before any real-money purchase. Parents and guardians are responsible for maintaining password security for these systems and in general should not share passwords with their children. The following links describe how to make sure purchase verification is in place:
Ninja Kiwi’s games and websites may contain advertisements or other links to other websites or apps as a service to you. These third party sites and apps are outside of our control and your activities with them are subject to their terms and privacy practices. We encourage you to review their terms and privacy practices before sharing any personal information with them, but we are not responsible for their privacy practices or for your disclosure of information to them. Nevertheless, we only want to be working with partners who exercise best practices, so if you ever have concerns about third parties, the services the provide, or the ads they serve, you may contact us at email@example.com so that we can review our relationship with them.
Ninja Kiwi takes appropriate and reasonable precautions to protect the information you provide, both during delivery and in its stored location. These precautions include but are not limited to the encryption of network and player cloud data, separate project save storage, distributed storage with no sensitive data stored at Ninja Kiwi’s offices, and breach detection and countermeasures. On the player’s side of the equation, we urge you to keep your login and password information private, to log out from any computer or mobile device that could be accessed by someone else, and to refrain from leaving written passwords near your computer or device. If you believe your account has been compromised, please reset your account password immediately, or contact us at firstname.lastname@example.org so that we may assist you.
California and European Union Additional Privacy Rights (CCPA and GDPR)
Residents of California have rights granted by the California Consumer Privacy Act to request access to the information we have collected about them and/or to delete that information. Residents of the European Union have rights granted by the General Data Protection Regulation to request access to the information we have collected about them and/or to delete that information. If you are a California or EU resident, you (or your parent or guardian) may request access to information collected about you and/or to delete that information by contacting us at email@example.com.
Additional Options and Questions
Feel free to contact us about any questions regarding Ninja Kiwi or our policies at firstname.lastname@example.org.
PO Box 26