Privacy policy

In short

Kolo has no accounts. We don't ask for your name, email or phone number, show no ads, and use no analytics or tracking. When you buy a pack, your card details and email are handled by WayForPay, not by us.

Who is responsible

The data controller is the sole proprietor (ФОП) listed under Contacts. Write there with any question about your data.

What we handle

• Playing: the name you type in a room (any name will do) and your answers. They are kept on the server while the room is alive and deleted automatically at most 24 hours after the last action in it.
• Packs you make: the questions you write in the pack editor, and a random device ID so you can edit them later. Reports about questions: the text of the report.
• Purchases: the order reference, what was bought, the amount, payment status and dates; the unlock code, encrypted, and its hash (we don't store the code in plain text); for each device the code is entered on, a hash of a random device token and when it was first and last seen. We need these to issue the code, restore it, and keep to the 5-device limit.
• Technical data: the server needs your IP address to limit the number of requests and guard against abuse; for that it is kept only in memory, briefly. It may also appear in the hosting provider's logs [FILL: hosting provider and how long logs are kept].

What is kept on your device

In the browser's storage (localStorage): your language, a random device ID for rooms and packs, a device token for purchases, your unlock codes and any unfinished orders. These are not advertising or analytics cookies. Clearing the site's data in your browser removes them all (you'll then need to enter your code again).

Who receives data

• WayForPay: takes the payment, sees your card details and the email you enter on the payment page, and sends the fiscal receipt. It handles that data as a separate controller under its own privacy policy. From WayForPay we receive only the order reference, amount and payment status.
• The hosting provider whose servers run Kolo [FILL: name].
• Google Fonts: the site and the game load fonts from Google servers, so your browser sends Google its IP address.

We don't sell data or pass it to advertisers.

Why, and on what basis

Purchase data is processed to perform the agreement (the offer) and to keep the records the law requires. Technical data, to keep the game running and protected from abuse. The legal bases are in article 11 of the Law of Ukraine "On Personal Data Protection".

How long we keep it

• Rooms: up to 24 hours after the last action.
• Orders: as long as accounting law requires [FILL: period, check with the accountant]; codes and device records for as long as the code is valid.
• Packs you make: until you delete them or ask us to.

Your rights

You have the right to know what data about you we process, to have it corrected or deleted, to object to processing, and to complain to the Ukrainian Parliament Commissioner for Human Rights (article 8 of the Law "On Personal Data Protection").

As there are no accounts, we can only find your data by an order reference or an unlock code. Include one in your message.

Changes

A new version is published on this page with a new date. This English page is a translation; if it differs from the Ukrainian version, the Ukrainian version prevails.