Who are we?

Karmafy is a software service owned and operated by Karma Holdings Ltd., (company no. C65879), Seaview apt. 4, Ix-Xatt Ta' Qui-Si-Sana, Sliema SLM3130, Malta.

Please direct questions and comments on this Privacy Policy to dataprotection@karmafy.com.

What is Karmafy?

Karmafy Points are a global currency for doing good.  You earn Karmafy Points by using a Karmafy-enabled app, website, or other service ("Services"). Karmafy keeps track of your Karma Points and how you choose to spend them. The Karmafy experience as embedded in apps, games, websites, or other services, is governed by an agreement between Karmafy and the owner or operator of such services (“Service Provider”). In order to deliver the Karmafy experience and to determine the Service Provider’s charitable contribution and service fee, we keep a record of some of your activities in the Service as described below.

Your Service Provider’s privacy policy may have additional information about their integration with Karmafy.

Using a Karmafy-enabled Service

As an Anonymous User

When you start using a Karmafy-enabled Service, we create an anonymous Karmafy account to hold the Karmafy Points you earn. The account is identified by a random number and does not reveal your real identity to Karmafy. While you are using the app, we will record the following data:

  • In-app activities that can earn you Karmafy points, e.g., completing a level in a game, making an in-app purchase, beating a high score, watching advertising material.
  • A history of Karmafy Points earned and how you earned them.
  • Your choice of one or more causes as beneficiary/ies of the Karmafy Points you earn. This includes previous choices, even if you change your mind later.
  • Possibly your user name and/or user ID in the Service itself, if the Service developer has chosen to support this.
  • Device settings that improve the user experience, such as your language preferences and the device type.
  • The IP number currently assigned to your device. This is usually enough information to determine the country and city you’re in.

While you are using a Karmafy-enabled app anonymously, we will not:

  • Ask for your personal identity or attempt to figure it out.
  • Access personal information on your device, such as contacts, messages, photos, etc.
  • Attempt to determine your exact physical location.

Occasionally, you will be presented with the option of sharing your Karmafy activities through a third-party channel such as Facebook, Twitter, email, etc. In this case, the privacy policy of operators of such services applies. Karmafy will not associate your identity in the third-party service with your anonymous Karmafy account.

As a Registered User

You will be given the option of registering with Karmafy and becoming a Karmafy user. This requires you to identify yourself with either a valid email address and/or log in through a third-party service such as Facebook. You will be asked to choose a user name. Your email address, Facebook identity and Karmafy user name will be recorded and stored by Karmafy.

As a registered Karmafy user, you use a single account to hold the Karmafy Points you earn in all Karmafy-enabled apps. You will be able to access the Karmafy website to view and modify all information associated with your account.

Since we intend to build a social network for doing good, the following information about you may be made available to other participants in the network:

  • Your user name and (if uploaded) profile picture.
  • Your total earned Karma Points, achievements, high scores, etc.
  • Your selections, contributions and interactions with causes.

Nobody but Karmafy will have access to your personal identity such as email address and Facebook user ID. We will not share this information with anybody without your consent, except in certain cases with the Service Provider for resolution of disputes.

Your Rights

  • You can access, change, and remove personal information through the Karmafy Menu inside the Service.
  • You are entitled to view the entire set of your personal data held by Karmafy.
  • If you believe Karmafy is holding erroneous, outdated, or irrelevant personal data, you are entitled to request the rectification or erasure of such data.
  • You are entitled to withdraw your consent to Karmafy processing any of your data.

From within mobile apps, use the button “Data Access Rights” in the Settings menu. If you have registered with email and password, you can also simply send an email to dataprotection@karmafy.com.

Note that in order to correctly invoice the Service Provider, Karmafy is allowed to retain records necessary to prove that the Karmafy experience has been delivered to you prior to your withdrawal of consent.

Third-party Data Processors

In operating Karmafy, we make use of several third-party services:

  • Google Analytics. We use GA for statistical and monitoring purposes only. We may send records of your Karmafy activities to GA, but in anonymised form.
  • Branch.io. Used for attributing new installs to selection of HTTP links, Facebook shares, etc. We are not sending personal user data to Branch.io.

We may choose to contract with additional third-party services in the future, but we will always anonymise your data.


We endeavour to keep your information secure through industry-standard physical, electronic, and procedural safeguards. If we detect a breach of security that may have caused your information to be revealed or compromised, we shall notify you.

Hosting Service

The Karmafy servers are hosted by Hetzner GmbH in data centres located in Germany.

Changes to this Policy

Changes to this policy will be announced on the Karmafy web site and, if such changes have direct relevance to yourself, in a message displayed inside Karmafy-enabled Services.


As a company operating in Malta, Karmafy is required to comply with the General Data Protection Regulation (2016/679). The Supervisory Authority is: Office of the Data Protection Commissioner, 2, Airways House, High Street, Sliema SLM 1549, tel. +356 2328 7100, http://www.dataprotection.gov.mt/.