Data Privacy Policy of DOG Productions Ltd.


Dorado Games respects your right to control your privacy. We have put in place security measures for your personal data and manage your personal data in accordance with applicable data protection and data privacy regulations. This Privacy Policy explains how we handle and treat your data when you (i) register or visit our site, [] or associated sites or pages (the ”Website”), (ii) use our services, or (iii) engage or communicate with us. It also provides information about your rights relating to your Personal Data.

Throughout this Privacy Policy the following terms have the following meanings:


”Data Privacy Laws” means applicable data protection and data privacy laws and regulations, including but not limited to the EU General Data Protection Regulation (2016/679) (the ”GDPR”).

Processing” and “Process” means all activities involving your Personal Data, including collecting, handling, storing, sharing, accessing, using, transferring and disposing of information.

"Services" means our applications and other products, the Website, email communications, social media accounts and any related services or properties we control.

"Personal Data" means Personal Data that relates to you as an identified or identifiable individual.


All capitalised terms not specifically defined herein shall have the meaning ascribed to such terms in the GDPR.

While operating the Services, Personal Data will be shared with partners we work with. Some of these partners are Controllers independently of us and, therefore, independently determine how and why they process your data. For more information on these partners and the ways in which they may process your data, please refer to section 4 of this Privacy Policy. Under certain circumstances we will transfer your Personal Data to countries outside the European Economic Area. Such transfers will be done in accordance with section 5 of this Privacy Policy.

Our Services are not directed to children and we do not knowingly collect Personal Data from children under 16 years of age.


1. Who are we



The Controller responsible for your Personal Data for the purposes of the GDPR is:


DOG Productions Ltd

The Hedge Business Centre, Triq ir-Rampa, St Julians, STJ1217

E-Mail: [email protected]



hereinafter referred to as the "Company", "we", "us", or "our".


The principles set out in this Privacy Policy apply to all instances in which the Company Processes your personal data as a Controller for the purposes described in this Privacy Policy. The Company is part of the Stillfront Group, a global group of gaming studios with its parent company, Stillfront Group AB (publ), incorporated in Sweden and listed on Nasdaq Stockholm.


Data Protection Officer

The data protection officer of the Controller for the purposes of the GDPR is:

Peter Birgersson, Deloitte AB

Contact details: [email protected]


2. What information do we collect from you?


Information you provide voluntarily when using our services:

Your name, email address, or other contact information communicated to us.

Any Personal Data provided in any communication channel available in our Services.

If you have subscribed to our communications, your content preferences or other information you submit to us when subscribing to our communications.

If you participate in our surveys or other research, any comments, feedback, resoonses, or other information you provide to us when doing so.

Any other information you choose to submit to us through our Services or otherwise.


Directly from you and/or your device by automatic means:

Your device and browser: Certain information is collected by most browsers or automatically through your device, such as your device type, model, manufacturer, operating system, language, display, processor, the Internet browser type you are using, and your IP address (including your coarse location).

Your use of our Services: We track and collect usage data, such as the date and time you access our Services, access status, duration of use of our Services, the site you visited, the information and files that have been downloaded.

Crash logs or other information related to bugs, errors, or other issues in our Services.

Inferences we make based on your activity in our Services.

The Company collects Personal Data directly from you and/or your device (such as your phone or computer) by automatic means when you use our Services or interact with your ads outside of our Services on third-party websites or applications, including through cookies or similar technologies or software development kits (SDKs). For more information regarding the Company's ue of cookies, please view our Cookie Policy.


We do not expect or intend to collect or otherwise process any special categories of data relating to you. By special categories of data, we mean genetic, biometric or health information, information revealing racial or ethnic origin, sex life or sexual orientation, political opinions, religious or philosophical beliefs, trade union membership, or information about your criminal offences or convictions. Please do not provide this kind of information to us or use the Services to make it available to others.


3. How do we use your Personal Data


We use your Personal Data for different purposes. We will for example use the Personal Data to provide you with the Services you have requested, to improve and develop our Services, to predict user trends, to make recommendations and marketing activities based on your usage and to customise our Services to you, these include the following processing activities:


Processing is necessary to perform our contract with you in respect of our Services:

Information provided voluntarily by you is used to enable you to use our Services and administer the Services.

Information provided voluntarily by you and automatically collected data is used to provide, maintain, enhance and personalise the Service(s) (including selecting an appropriate language version for you based on your location).

Automatically collected data is used to know your preferences and to try to ensure that the content on our Website is presented in the most effective manner for you and your computer or mobile device, based on your browsing history on our services.

Information provided voluntarily by you is used to send you newsletters or other similar communications if you have subscribed to them (for example, through a subscription form on our Websites).


Based on our legitimate interest to make our Services the best they can be and provide you with the best possible user experience in our Services

Information provided voluntarily by you and automatically collected data is used to operate and maintain our Services (improve our current Services or develop new Services) including troubleshoot or debug any bugs, errors, or other issues in our Services.

Information provided voluntarily by you and automatically collected data is used to, where available, provide social features (such as chat and forum functions) or events in our Services or other Services.

Contact information provided by you is used for the purpose of contacting you and/or handling your support requests or otherwise managing our relationship with you.

Automatically collected data is used to measure and analyse the use of our Services or data we collect through our Services (for example, to discover trends or other insights or to inform our operations).

Data provided by you as well as automatically collected data is used to create data that is not identifiable to you (for example, aggregate data), which we then use and share freely.

Automatically collected data is used to analyse how visitors use our Services.


Based on our legitimate interest to make our services more intuitive and evaluate user behaviours and preferences.

Automatically generated data, that is not identifiable to you, specifically aggregated data regarding recency and frequency of player events such as “game closed” or “in-app purchases” is analysed to understand retention patterns and player behaviour.


Based on our legitimate interest to market our services.

Account information such as email address is used to market our and our affiliate services that we believe might interest you.

Account information is used to conduct marketing campaigns for our and affiliated services.

Information collected and submitted to us is used to operate, optimise and measure the effectiveness of our marketing campaigns.


Based on our legitimate interest to facilitate performance marketing.

Automatically generated data, that is not identifiable to you, specifically aggregated data regarding recency and frequency of player events such as “watched in-game advertising” or “in-app purchases” is used to understand and measure player lifetime value. Through this data, we can analyse expected future revenue from our players.


Based on our legitimate interest to provide you with interest-based services and advertisement.

We use ad identifiers, third-party tracking ID's (such as AppsFlyer ID) and similar technologies to collect data from your device. Information from third party providers is combined with features including device type, system language and IP address to create a unique player ID. This is done for the purpose of recognising you and your device and providing you with customised player experiences and interest-based advertising.


Based on our legitimate interest to safguard our operations.

Information provided voluntarily by you and automatically collected data is used to audit our operations or processes (for example, to verify that they function as intended).


Processing is necessary for compliance with a legal obligation to which the controller is subject.

For example in the unlikely event of a dispute or a criminal investigation. Where required by law, your Personal Data will be disclosed to an applicable governmental, regulatory, sporting or enforcement authority. Your Personal Data will also be disclosed to any regulatory body in connection with prevention and detection of crime and where the Company considers that there are reasonable grounds to suspect that you may be involved in a breach of the law. Those bodies will then use your Personal Data to investigate and act on any such breaches in accordance with their procedures.


In addition, we may process your data for additional purposes which are compatiable with any of the purposes listed above.


4. Who we share your information with


Your Personal Data will (for the purposes described in this Privacy Policy) be transferred or disclosed to third parties, for the processing of that Personal Data on our behalf, such as to:


5. Appropriate Safeguards to countries outside the EU/EEA-area

In connection with some processing activities described in this Privacy Policy we share information outside of the European Union (“EU”) and the European Economic Area (“EEA”). For example, a number of servers we use for hosting data are located in the United States, and some of our group companies or the service providers we use to provide the Services may be located outside of the EU and the EEA. Where the Company transfers Personal Data outside the EU/EEA, The Company will ensure that Standard Contractual Clauses have been entered into between the transferring entity and the receiving external party. Additional safeguards will also be put in place prior to such transfers.

Data shared will consist of information you provide voluntarily when using our Services and data collected from your device by automatic means. You are under Data Privacy Laws upon request entitled to receive a copy of any documentation demonstrating that appropriate safeguards have been taken in order to protect your Personal Data during a transfer outside the EU/EEA. You can do so by reaching out to our Data Processing Officer [email protected]


6. How long do we keep hold of your information?

We will retain your information only for as long as is necessary for the purposes set out in this Privacy Policy. We are using the following criteria to establish our retention period: (i) as long as we have an ongoing relationship with you; (ii) as required by legal obligations to which the Company is subject (such as tax and accounting obligations); and (iii) as advisable in light of our legal position (such as applicable statutes of limitations). For more specific information about data retention terms, please contact our Data Processing Officer [email protected] and we will provide the specific data retention terms for your jurisdiction.


7. Security

Your data is secured by appropriate safeguards, taking into account the circumstances, the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk. In support of this commitment, we have implemented appropriate technical, physical and organisational measures to protect your Personal Data against unauthorised or accidental destruction, alteration or disclosure; misuse; damage; theft or accidental loss; or unauthorised access.

We process the data collected from you in accordance with Maltese and European data protection law.

All employees are required to protect data privacy and comply with data protection regulation, and are trained accordingly.

For payment purposes, your data is transmitted using the SSL process and encrypted.


8. Your Rights


Providing data to us is not mandatory. However, we are unable to provide the Services, or some parts or features of the Services, without processing your data. If you use our Services, we will collect data relating to you for some or all the purposes described in this Privacy Policy, depending on the Services you decide to use and your choices when using them. You have a number of options to limit or control the extent to which your data is processed. For example, you can choose to not connect your third-party accounts with our Services, use your device settings to reset or limit the use of your Advertising ID, or disable some or all cookies from your browser settings.

In relation to our processing of your Personal Data you have, under certain circumstances, the right to exercise the following rights:


9. Changes to the terms of this Privacy Policy

We may update this Privacy Policy from time to time, for example due to changes in our operations or the legal obligations that apply to us. Updates will be made available here. We will also inform you of any changes by other means that are appropriate to the significance of the changes.