Privacy Policy

1. Introduction and Commitment to Privacy

Crazy Games Australia ("we", "us", or "our") is committed to protecting the privacy of all individuals who visit and use our website located at civiccommons.org/en-au/ (the "Platform"). We recognise the importance of privacy and are dedicated to handling personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

This Privacy Policy explains how we collect, use, disclose, store, and protect information when you access or use our Platform. It also describes your rights regarding your information and how you can exercise those rights.

Our Platform is designed with a privacy-first approach. We have intentionally built the Platform so that no personal information is required to access or play any game. You do not need to create an account, provide an email address, enter your name, or submit any identifying information to use our services.

2. Information We Collect

While no personal information is required to use our Platform, we may automatically collect certain non-personal technical information when you visit. This information falls into the following categories:

2.1 Analytics Data

We use analytics tools to understand how visitors interact with our Platform. This data helps us improve our services and content. Analytics data may include:

• Pages visited, time spent on each page, and navigation paths through the site.
• Referring website or search engine that directed you to our Platform.
• General geographic location (country and city level, derived from IP address - not precise location).
• Date and time of your visits.
• Interaction events such as game plays, category browsing, and search queries.

2.2 Cookies and Similar Technologies

We use cookies and similar tracking technologies to enhance your browsing experience. For comprehensive details about the cookies we use, please refer to our Cookie Policy. In summary, cookies may collect:

• Session identifiers to maintain your browsing session.
• Preference settings such as language or display options.
• Analytics identifiers for understanding usage patterns.
• Advertising identifiers used by third-party ad networks.

2.3 Device and Technical Information

When you access our Platform, our servers automatically record certain technical information, including:

• Your device type (desktop, mobile, tablet).
• Operating system and version (e.g., Windows 11, iOS 19, Android 16).
• Browser type and version (e.g., Chrome, Safari, Firefox, Edge).
• Screen resolution and viewport dimensions.
• Internet Protocol (IP) address (which may be truncated or anonymised for analytics purposes).
• Internet service provider and connection type.

2.4 Information We Do Not Collect

For clarity, we do not collect any of the following:

• Names, email addresses, phone numbers, or postal addresses.
• Financial information, credit card details, or payment data.
• Government-issued identification numbers.
• Social media account credentials or profile data.
• Precise geolocation data (GPS coordinates).
• Biometric data.
• Health or medical information.

3. How We Use Information

The non-personal information we collect is used for the following purposes:

• Platform Improvement: To understand how visitors use our Platform, identify popular content, and make improvements to the user experience, game selection, and site performance.
• Technical Optimisation: To ensure the Platform functions correctly across different devices, browsers, and screen sizes, and to optimise loading speeds for Australian internet connections.
• Content Personalisation: To display relevant game recommendations and content based on general usage patterns and preferences (not based on personal identity).
• Analytics and Reporting: To generate aggregated, anonymised statistical reports about Platform usage, such as total visitor numbers, most popular games, and peak usage times.
• Advertising: To serve advertisements that may be relevant to you based on general interest categories. We do not use personal information for ad targeting.
• Security: To detect and prevent fraud, abuse, security incidents, and other harmful activity on the Platform.
• Legal Compliance: To comply with applicable laws, regulations, legal processes, or enforceable governmental requests.

4. Cookies and Tracking Technologies

We use various cookies and tracking technologies on our Platform. For a detailed explanation of the types of cookies we use, their purposes, and how to manage them, please refer to our dedicated Cookie Policy.

In brief, we use the following categories of cookies:

Cookie Type	Purpose
Essential	Required for the Platform to function correctly, including session management and security features.
Analytics	Help us understand how visitors interact with the Platform, which pages are most popular, and how users navigate the site.
Functionality	Remember your preferences such as language settings and display options to provide a more personalised experience.
Advertising	Used by third-party advertising networks to deliver relevant advertisements and measure ad campaign effectiveness.

5. Third-Party Services

We use a limited number of third-party services to operate and improve our Platform. These services may collect and process non-personal information in accordance with their own privacy policies. The third-party services we use include:

5.1 Analytics Services

• Google Analytics: We use Google Analytics to collect anonymised usage data about how visitors interact with our Platform. Google Analytics uses cookies to collect information such as how often users visit the site, what pages they visit, and what other sites they used prior to coming to our Platform. Google's ability to use and share information collected by Google Analytics is governed by the Google Privacy Policy.

5.2 Advertising Networks

• We may display advertisements served by third-party advertising networks. These networks may use cookies and similar technologies to serve ads based on general interest categories and to measure ad performance. We do not share any personal information with advertising partners.

5.3 Content Delivery Networks (CDNs)

• We use CDN services with nodes in Sydney and Melbourne to deliver game content and website assets quickly to Australian users. CDN services may log technical request information such as IP addresses and request headers for security and performance purposes.

6. Data Retention

We retain the non-personal information we collect only for as long as is necessary to fulfil the purposes described in this Privacy Policy. Specific retention periods are as follows:

• Analytics data: Retained for a maximum of 26 months from the date of collection, after which it is automatically deleted or anonymised.
• Server logs: Technical server logs containing IP addresses and request data are retained for a maximum of 90 days, after which they are automatically purged.
• Cookie data: Cookie retention periods vary by type. Please see our Cookie Policy for specific cookie lifespans.

We may retain aggregated, anonymised data (which cannot be used to identify any individual) for longer periods for statistical and analytical purposes.

7. Your Rights Under Australian Privacy Principles (APPs)

Under the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), you have certain rights regarding your personal information. Although our Platform is designed to collect minimal data and does not require personal information, we respect and uphold the following rights:

• APP 1 - Open and Transparent Management: We manage any information we hold in an open and transparent way. This Privacy Policy is our primary means of meeting this obligation.
• APP 5 - Notification of Collection: We notify you at or before the time of collection (or as soon as practicable after) about the information we collect and how it will be used, as detailed in this policy.
• APP 6 - Use and Disclosure: We only use or disclose information for the purposes described in this policy. We do not sell, rent, or lease any information to third parties.
• APP 8 - Cross-Border Disclosure: Where information may be transferred overseas (for example, through the use of international analytics or CDN services), we take reasonable steps to ensure the overseas recipient handles the information in a manner consistent with the APPs (see Section 9 below).
• APP 11 - Security of Information: We take reasonable steps to protect information from misuse, interference, loss, unauthorised access, modification, or disclosure (see Section 10 below).
• APP 12 - Access to Information: You have the right to request access to any personal information we hold about you. Given that we do not collect personal information, such requests are unlikely to yield results, but we will process any request in good faith.
• APP 13 - Correction of Information: You have the right to request correction of any personal information we hold about you that is inaccurate, out-of-date, incomplete, irrelevant, or misleading.

To exercise any of these rights, please contact us using the details provided in Section 12 of this policy.

8. Children's Privacy

Protecting the privacy of children is especially important to us. Our Platform is designed to be accessible to users of all ages, and we have taken specific measures to safeguard children's privacy:

• No Knowing Collection: We do not knowingly collect personal information from children under the age of 13. Since our Platform does not require any account registration, email addresses, or personal data to use, children can play games without providing any identifying information.
• Parental Oversight: We encourage parents and guardians to supervise their children's online activities and to review this Privacy Policy. If you are a parent or guardian and you believe that your child under 13 has provided personal information to us, please contact us immediately using the details in Section 12, and we will take steps to delete such information.
• No Targeted Advertising to Children: We do not knowingly serve behaviourally targeted advertisements to users we reasonably believe to be under 13 years of age.
• Compliance with Australian Guidelines: We follow the guidance of the Australian eSafety Commissioner regarding the online safety and privacy of children and young people.

9. International Data Transfers

Some of the third-party services we use (such as analytics and CDN providers) may process or store data in countries outside of Australia, including the United States and countries within the European Economic Area.

Where data is transferred internationally, we take reasonable steps to ensure that:

• The overseas recipient is subject to a law or binding scheme that is substantially similar to the Australian Privacy Principles.
• We have contractual arrangements in place that require the overseas recipient to handle data in a manner consistent with the APPs.
• You have been informed about the transfer and its implications, as we are doing through this policy.

Countries where data may be processed include, but are not limited to, the United States (Google Analytics, CDN services) and Ireland (certain advertising and analytics services). These transfers are necessary for the operation of our Platform and are conducted in compliance with APP 8.

10. Data Security Measures

We take the security of your information seriously and implement a range of technical and organisational measures to protect against unauthorised access, alteration, disclosure, or destruction. These measures include:

• Encryption: All data transmitted between your browser and our Platform is encrypted using HTTPS/TLS encryption protocols.
• Access Controls: Access to any stored data is restricted to authorised personnel on a need-to-know basis.
• Server Security: Our servers and infrastructure are protected by firewalls, intrusion detection systems, and regular security audits.
• Data Minimisation: We collect only the minimum amount of non-personal data necessary to operate and improve the Platform. This is our strongest security measure - data that is never collected cannot be breached.
• Regular Reviews: We conduct periodic reviews of our data collection, storage, and processing practices to ensure ongoing compliance with our security standards and applicable laws.
• Incident Response: We have procedures in place to respond to data security incidents promptly and effectively, including notification procedures in accordance with the Notifiable Data Breaches scheme under the Privacy Act 1988.

While we strive to use commercially acceptable means to protect your information, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security, but we are committed to maintaining the highest practical level of protection.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, we will:

• Update the "Last Updated" date at the top of this page.
• Post the updated policy on the Platform.
• For significant changes, display a prominent notice on the Platform to alert users.

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. Your continued use of the Platform after any changes to this policy constitutes your acceptance of the updated terms.

12. How to Contact Us About Privacy

If you have any questions, concerns, or requests regarding this Privacy Policy, the handling of your information, or your privacy rights, you may contact us through the following channels:

• Contact Page: civiccommons.org/en-au/contact/
• Email: [email protected]
• Post: Privacy Officer, Crazy Games Australia, Sydney, New South Wales, Australia

We aim to respond to all privacy-related enquiries within 30 days of receipt, in accordance with the requirements of the Privacy Act 1988. If your request is complex or requires further investigation, we will inform you of the expected timeframe for a full response.

13. Office of the Australian Information Commissioner (OAIC)

If you are not satisfied with our response to a privacy enquiry or complaint, you have the right to lodge a complaint with the Office of the Australian Information Commissioner (OAIC). The OAIC is the independent national regulator for privacy and freedom of information in Australia.

You can contact the OAIC through the following channels:

• Website: www.oaic.gov.au
• Phone: 1300 363 992
• Email: [email protected]
• Post: Office of the Australian Information Commissioner, GPO Box 5218, Sydney NSW 2001
• Online Complaint Form: www.oaic.gov.au/privacy/privacy-complaints

Before lodging a complaint with the OAIC, we encourage you to contact us directly first so that we have the opportunity to address your concerns. In most cases, we can resolve privacy issues quickly and to your satisfaction.