Privacy Policy

Last updated: January 30, 2026

This Privacy Policy explains how an individual developer Dzmitry Kavaliou (the "Developer", "we", "us") collects, uses, stores, and otherwise processes personal data of users of our mobile games ("you", "players").

It also explains your rights and available choices in relation to such processing under applicable data protection laws, including the EU General Data Protection Regulation (GDPR), the UK GDPR, and other applicable privacy laws.

It is important that you read this Privacy Policy carefully before downloading, accessing, or playing our mobile games. If you do not agree with this Privacy Policy, you should not download, access, or use the games.

By downloading, accessing, or using the games, you confirm that you have read and understood this Privacy Policy and acknowledge that personal data relating to you may be processed in accordance with it.

This Privacy Policy should be read together with our Terms of Use, which govern your use of the games.

For the purposes of this Privacy Policy, "personal data" means any information relating to an identified or identifiable natural person, as defined in Article 4 of the EU General Data Protection Regulation (GDPR).

1. Data Controller

For the purposes of the GDPR, the UK GDPR, and other applicable data protection laws, Developer acts as the data controller in respect of the personal data processed as described in this Privacy Policy.

Controller: Individual (independent game developer) Dzmitry Kavaliou

Location: Poland

Contact email: [email protected]

Certain third-party partners integrated into our games may process personal data either as independent data controllers or as data processors acting on our behalf. Further details are provided in Section 5 below.

2. What Personal Data We Process

Depending on how you interact with our mobile games, we may process different categories of personal data.

Most of our games can be played without creating an account. Users may optionally create a profile and choose to provide a name or nickname. Creating a profile is not required to access core gameplay features.

Users may also optionally link a third-party account (such as Facebook or other social platforms). Linking a third-party account is voluntary and is used only to enable specific features, such as saving game progress across devices or accessing social functionality.

We do not receive or store passwords from any third-party services. When you log in using a third-party platform, we receive only the information that you explicitly authorize that platform to share with us.

We do not collect:

• Special categories of personal data (e.g., racial or ethnic origin, political opinions, religious beliefs, health data, biometric data, sexual orientation, trade union membership, or criminal records).
• Payment card details or financial information - all in-app purchases are handled securely by Google Play and Apple App Store. We receive only transaction confirmations (e.g., item purchased), without access to your card or billing data.

The table below describes the main categories of personal data we process:

3. How We Collect Your Personal Data

We collect personal data in the following ways, always limited to what is necessary for the purposes described in this Privacy Policy:

• Directly from you. This occurs when you voluntarily provide information to us, for example:

• by sending an email, reporting issues, or requesting support – in which case we process your contact details and any information you include in your message solely to respond to and handle your request;
• by optionally creating, editing, or filling in your in-game profile (where this feature is available in certain games) This may include entering a nickname or adding other optional profile details. We collect only the information you choose to provide and use it solely to personalize and enhance your in-game experience (e.g., displaying your chosen nickname or avatar to other players where applicable).

• Automatically from your device. When you launch and use the game, certain technical, usage, and identifier data is collected automatically by the game. This may include device information, gameplay events, and advertising interaction data necessary for core functionality, analytics, fraud prevention, and ad delivery, subject to applicable consent requirements. The purposes for which such data is processed, as well as the applicable legal bases, are described in the table Section 4 below.
• Through integrated third-party services. Our games include analytics and advertising services as described in Section 5. These partners may receive relevant data directly from your device while the games are running. These third parties may act as independent data controllers and process the data for their own purposes (for example, aggregated analytics, fraud prevention, or ad personalization). Information about these partners, the categories of data they receive, and links to their privacy policies are made available through the in-app consent management platform (CMP), where required by law.
• From third-party platforms when you choose to link a social or identity account. In certain games, you may optionally sign in or link your account using a third-party service such as Facebook, Google, Apple (Sign in with Apple, Game Center), or other similar third-party identity or social login providers that may be supported from time to time. When you do so, the third-party platform shares certain information with us based on the permissions you grant during the login process. This typically includes your user ID, name/nickname, profile picture/avatar, and sometimes your email address (only what you explicitly authorize). We collect and process this data solely to enable account-based features such as cross-device progress saving, leaderboards, or social interactions. We do not receive or store your password from any third-party service.

4. Purposes of Data Processing and Legal Bases

Special notes for users in the European Economic Area (EEA) and United Kingdom

We use Google’s Consent Management Platform (CMP) (CMP ID 300), which is aligned with the IAB Europe Transparency and Consent Framework (TCF).
Where required by law, our advertising and analytics partners rely on your consent signals collected via the CMP.

If you do not provide consent for personalised advertising, ads shown to you will be limited to non-personalised or contextual advertising, where applicable.

5. Sharing Your Personal Data

We work with third-party service providers, including analytics providers, advertising partners, and other similar partners integrated into the games.

Third-party partners may act as independent data controllers or as data processors acting on our behalf, depending on the nature of the services they provide.

While we carefully select partners and require them to comply with applicable data protection laws, we are not responsible for their independent processing activities where they act as separate data controllers, beyond the scope of our contractual arrangements.

For details on what each partner collects and how they process it, please refer to their individual privacy policies (linked below where available).

For personalized advertising or advanced profiling, sharing with these partners only happens after you give explicit consent through Consent Management Platform (CMP). Without such consent, ads remain non-personalized/contextual.

In rare cases, we may share limited personal data to comply with applicable legal obligations (e.g., responding to valid court orders), protect our rights (e.g., enforcing our Terms of Use in disputes), or as part of a corporate transaction (e.g., merger, acquisition, reorganization, or sale of assets).

You can exercise control over much of this data sharing by managing your consent choices via the in-game privacy settings, adjusting ad preferences via your device settings (e.g., limiting ad tracking on Android or allowing/disallowing tracking on iOS), or opting out directly with certain partners where such options are made available (instructions are typically provided through the consent management platform (CMP)).

6. International Data Transfers

We operate and support our mobile games on a global basis. As a result, your personal data may be transferred to, stored in, or otherwise processed in countries outside the European Union (EU) and the European Economic Area (EEA), including, for example, the United States and other jurisdictions where our service providers operate.

Some of the servers used for hosting our games, analytics, advertising, and related infrastructure may be located outside the EU/EEA, and some of the service providers and partners we rely on to operate and support our games may also be established in jurisdictions outside the EU/EEA. The data protection laws in these countries may differ from, and may not provide the same level of protection as, the laws applicable in your country of residence.

Where required by applicable data protection laws, including the GDPR, we ensure that appropriate safeguards are in place to protect your personal data when it is transferred internationally, such as the use of standard contractual clauses approved by the European Commission or other legally recognized transfer mechanisms.

7. Data Retention

We retain your personal data only for as long as necessary to achieve the purposes for which it was collected and processed. This includes, in particular, providing and supporting our games, operating and improving the games, handling customer support requests, and complying with applicable legal, accounting, and reporting obligations.

Retention periods vary depending on the nature of the data and the purpose for which it is processed.

Once the applicable retention period has expired, we will delete your personal data or, where deletion is not possible or feasible (for example, where the data is stored in system backups), securely de-identify, anonymise, or isolate the data from further processing until deletion or de-identification becomes possible.

8. Data Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration, or disclosure, taking into account the nature of the data and the associated risks.

These measures may include, where appropriate, encryption, access controls, pseudonymisation, and regular review of our security practices, as well as contractual safeguards with third-party service providers.

However, no method of transmission over the internet or electronic storage is completely secure. While we take reasonable steps to protect personal data, we cannot guarantee its absolute security.

9. Your Rights

Under applicable data protection laws, including the EU GDPR and the UK GDPR, you have certain rights in relation to your personal data where we act as the data controller.

Subject to the conditions and limitations set out in applicable law, these rights may include the right to:

• request access to your personal data and obtain information about how it is processed;
• request the correction of inaccurate or incomplete personal data;
• request the deletion of your personal data;
• request the restriction of processing of your personal data;
• object to the processing of your personal data where such processing is based on our legitimate interests;
• where technically feasible, request a copy of the personal data you have provided to us in a structured, commonly used, and machine-readable format (data portability).

Where we process your personal data based on your consent (for example, for personalised advertising or certain types of analytics), you have the right to withdraw that consent at any time. You can withdraw or change your consent easily at any time directly within the game by accessing the privacy/consent settings and adjusting your choices through the integrated CMP.

Withdrawal of consent does not affect the lawfulness of processing carried out before such withdrawal. Please note that even after consent is withdrawn, we may continue to process certain personal data where we have another valid legal basis to do so (for example, to comply with legal obligations or to establish, exercise, or defend legal claims).

If you withdraw consent for personalised advertising, you will continue to see contextual (non-personalised) ads where applicable, and core gameplay functionality will remain unaffected.

9.1. Account deletion

If you have created an in-game account or linked a third-party account (such as a social or platform account), you may delete your account and associated personal data directly through the account deletion option available within the game’s interface (where available).

If you cannot find this option or encounter any issues, you may request account deletion by contacting us at [email protected]

Where technically feasible, account deletion will result in the removal or anonymisation of personal data associated with your account, subject to applicable legal retention requirements (for example, data that must be retained for accounting, tax, security, fraud prevention, or legal compliance purposes).

Please note that account deletion is irreversible and may result in the permanent loss of your game progress, in-game purchases, achievements, virtual currency, and other account-related content.

9.2. How to exercise your rights

You may exercise your rights by contacting us at [email protected]. In order to process your request, we may need to verify your identity and request additional information solely for the purpose of confirming that the request is made by the relevant individual.

We will respond to your request without undue delay and within the time limits required by applicable law.

9.3. Complaints

You have the right to lodge a complaint with a competent data protection authority in your country of residence or place of work, or where an alleged infringement has occurred.

We encourage you to contact us first, so that we can try to resolve your concerns directly.

10. Children

Our Games are intended for a general audience and are not directed to children below the applicable age of digital consent.

We do not knowingly collect or process personal data from such children, nor do we knowingly engage in interest-based advertising directed at them.

If we become aware that personal data of a child has been collected without appropriate consent, we will take reasonable steps to delete such data and comply with applicable legal requirements.

Parents or legal guardians who believe that their child has provided personal data may contact us at [email protected].

11. Region-specific information

11.1. Information for California Residents: Your California Privacy Rights

If you are a resident of California, the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act (CPRA), grants you specific rights regarding your personal information.

Your Rights Include:

• Right to Know / Access: You can request information about the categories of personal information we collect, the sources of that information, the purposes for which it is used, and the categories of third parties with whom it is shared. You may exercise this right up to twice in a 12-month period.
• Right to Delete: You may request that we delete your personal information, subject to certain exceptions required by law.
• Right to Correct: You may request that we correct inaccuracies in your personal information.
• Right to Opt-Out of Sale / Sharing: We do not sell personal information as defined under the CCPA. However, certain disclosures of personal information to advertising partners for the purpose of personalized (targeted or cross-context behavioral) advertising may be considered "sharing" under the CPRA. You may opt out of such sharing by following the instructions in Section 12 ("How to Opt-Out or Manage Your Privacy Choices") of this Privacy Policy.
• Right to Limit Use of Sensitive Information: We do not collect or use sensitive personal information in a way that triggers this right under CPRA.
• Non-Discrimination: Exercising any of these rights will not result in any penalty or reduced access to our services.

How to Submit a Request:

To submit a request, please email [email protected] with the subject line "California Privacy Rights Request" and provide sufficient information to verify your identity (e.g., name, email address). We will verify your identity and respond within 45 days, which may be extended by an additional 45 days if necessary. Authorized agents may submit requests on your behalf with proof of authorization.

Disclosures for the Past 12 Months

In the past 12 months, we have collected categories of personal information such as identifiers, device information, internet or network activity information, and coarse location data derived from IP address. This information may be disclosed to third parties for business purposes, including analytics and advertising. We have not sold personal information

12. How to Opt-Out or Manage Your Privacy Choices

We offer the following ways to control how your data is used, especially for advertising:

Device-level controls

Limit personalized (interest-based) advertising through your device settings:

Android: Settings -> Google  -> Ads  -> Opt out of Ads Personalization

iOS: 1) Settings -> Privacy & Security  -> Apple Advertising  -> Turn off Personalized Ads 2) Settings -> Privacy & Security -> Tracking ->  turn off "Allow Apps to Request to Track"

Please note: On iOS devices, we request permission to track in accordance with Apple’s App Tracking Transparency (ATT) framework.

If you do not grant permission, we do not engage in tracking for advertising purposes.

Uninstall the game

To stop all further collection of usage data, uninstall the game using the standard process on your device. Some data processed before uninstallation may remain stored as described in the Section 7 (Data Retention).

Important notes:

Opting out of personalized advertising does not remove ads - you will continue to see contextual (non-personalized) ads.

Core gameplay functionality remains fully available regardless of your choices.

Changes apply only to future processing and do not affect data already collected or shared.

13. Changes

We may update this Privacy Policy from time to time. Where required by law, we will notify you of material changes through an in-app notice or other appropriate means.

The updated Privacy Policy becomes effective as of the date indicated at the top (“Last updated”). Your continued use of the games after the effective date constitutes acceptance of the updated policy. If you do not agree with the changes, you should stop using and uninstall the games.

The most current version of this Privacy Policy is always available within the app and on the relevant app store listing.

Copyright © 2026 Dzmitry Kavaliou