PRIVACY POLICY

I. INFORMATION WE PROCESS AND HOW WE DO THE PROCESSING

Depending on the circumstances mentioned below, the following general categories of personal information may be collected and otherwise processed. The examples describe possible categories and do not mean that we collect every example from every User:

PLEASE, NOTE THAT:

We do not request special categories of personal data, such as information about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health, genetic or biometric data, or criminal convictions and offences. Please do not submit such information through support or user-content features. If you voluntarily include it in a message, it may be received as part of that communication and will be handled only where there is an applicable lawful basis.

Moreover, we cannot access or use your credit card or debit card information.

When the App includes store-billed in-app purchases, the relevant store provider, such as Google Play or Apple, handles billing and payment information under its own terms and privacy policy. We may receive purchase records needed to provide the purchased entitlement, as described below. We do not guarantee the absolute security of a third party's systems. The applicable purchase and refund rules are available from the store used for your purchase.

We obtain the categories of personal information listed above from the following categories of sources:

1.1. Directly from you (Information that you submit):

Some Apps can be used without registering an account; other Apps offer account, third-party sign-in, profile or community features. If you use those features, we may process the information you provide or authorise the sign-in provider to share, such as a player identifier, nickname, email address, provider identifier, name, profile image or messages, as relevant to that feature. When you contact us by email or a support form, we process your contact information and the contents of your messages or attachments to respond to your inquiry, fulfil your request and provide requested services. We apply data minimisation and the relevant legal basis described in Section II.

1.2. Indirectly from you (Information that is processed automatically):

We use integrated advertising, analytics and diagnostic technologies to process information sent by your device, including an advertising ID or other technical identifier where available and permitted. Optional consent-based tracking and personalised advertising are subject to your choices and any permission required by law. Some advertising or analytics tools listed in Section III may use profiling to infer interests or advertising preferences from App events, device information or interactions. Technical processing needed for security, diagnostics or service delivery may rely on another lawful basis, as described in Section II; the absence of an advertising ID does not itself make processing anonymous or exempt it from consent requirements. You can withdraw optional consent as described in Section IX.

Where legally permitted, we may process certain technical and usage information on the basis of our legitimate interests described in Section II. Device and usage information can remain personal data even when it does not reveal your name or is pseudonymised. Aggregated information is treated as anonymous only where it can no longer reasonably be linked to an identifiable person. The level of detail available to us depends on the service and its configuration.

REGIONAL PATTERN (European Economic Area and the UK):

For Users in the EEA and UK, the legal basis depends on the purpose and technology, as explained in Section II. The App presents a consent-management platform (CMP) where required for the User's region. Where advertising or analytics requires consent, the relevant processing is subject to the choice provided through that platform. Elsewhere, an acknowledgement of this Privacy Policy or acceptance of the Terms of Use is not a substitute for any separate consent or opt-out required by local law. Legitimate interests do not replace legally required consent.

Apps using Google's CMP (CMP ID 300) may present choices through the IAB Europe Transparency & Consent Framework (TCF). A CMP or TCF signal communicates choices; its use does not by itself establish compliance with every data protection requirement.

Where Google's EU User Consent Policy applies, its advertising-consent requirements also cover Users in Switzerland. Any consent choices remain separate from acceptance of the Terms of Use.

The consent choices apply to the purposes and recipients presented to you. Separate technical processing on another valid legal basis is described in Section II.

You can revisit your privacy choices at any time from the privacy settings available to you in the App.

The following are the types of information we collect indirectly from you:

• Device Details. When you use a mobile device to access the App, some details about your device are reported, including “device identifiers”. Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device (but not your personality). Device identifier enables generalized reporting or personalized content and ads by our partners, service providers, and/or other third parties.

  The following data can be processed:

  • Information about the device itself: type of your mobile device, type of operating system and its version, model and manufacturer, screen size, screen density, orientation, battery, and device memory usage.
  • Information about the internet connection: mobile carrier, network provider, network type, Internet Protocol (“IP”) address, timestamp and duration of sessions, speed, browser.
  • Location-related information: approximate country, region or city inferred from your IP address or device settings, language and time zone. If a particular feature accesses device location, that access is subject to the relevant permission and legal requirements; this description is not a statement that every App collects precise location.
  • Other device identifiers: e.g. user identifiers (if they are set up by the App's developer).
• Information about the App. Its name, API key (identifier for the App), version and properties can be reported for processing and analysis. If an integrated service accesses information about installed applications or running processes, that access remains subject to applicable platform restrictions and any required in-App disclosure, permission and consent. Mentioning that category in this policy does not itself authorise access to it.
• Cookies and similar technologies. When you use the App, cookies and similar technologies may be used (pixels, web beacons, scripts). A cookie is a text file containing small amounts of information that is downloaded to your device when you access the App. The text file is then sent back to the server each time you use the App. This enables us to operate the App more effectively. For example, we will know how many users access specific areas or features within our App and which links or ads they clicked on. We use this aggregated information to understand and optimize how our App is used, improve our marketing efforts, and provide content and features that are of interest to you. We may ask advertisers or other partners to serve ads or services to the App, which may use cookies or similar technologies.
• Log file information. Log file information is automatically reported each time you request to access the App. It can also be provided when the App is installed on your device. When you use our App, analytics tools automatically record certain log file information, including the time and date when you start and stop using the App, and how you interact with the App.
• Ad-related information. The following data might be reported about the ads you can view: the date and time a particular ad is served; a record if that ad was “clicked”, or if it was shown as a “conversation” event; what ad offer is about; what type of ad it is (e.g., text, image, or video); which ad placement is involved (where the ad offer is displayed within the App); whether you respond to the ad.
• In-app events. When you use our App, analytics tools automatically record in-App information (tutorial steps, leveling up, payments, in-app purchases, custom events, progression events, and methods of limiting the processing of user data).
• Purchase information. Product identifier, price, currency, order identifier and the purchase receipt issued by the app store. We use this information to deliver, validate and restore purchases and share it with our analytics and attribution partners, including Tenjin and AppMetrica where integrated, to measure revenue, subject to applicable law and your privacy choices. We do not receive your payment card details: payments are processed by Google Play or, for Apps distributed through the Apple App Store, Apple.
• Crash reports and diagnostics. Stack traces, device model, operating system and App version, and information about the state of the App at the moment of a crash. We use these reports to identify errors and improve the stability and security of the App.
• Technical identifiers. Advertising ID, App Set ID and identifiers assigned by analytics and crash-reporting tools, such as Firebase installation ID and AppMetrica device ID, where these tools are integrated. Availability and use of these identifiers depend on the platform, device settings and any consent required by law. Even where an identifier does not directly reveal your name, it may still be personal data.
• Advertising revenue information. The value and currency of ad revenue associated with an ad impression, together with the advertising network, placement and related App events. Where supported by the App, this information is shared with analytics and attribution partners to measure advertising performance and revenue, subject to applicable law and your privacy choices.

Our access to information processed by a third party depends on its role and the service used. We remain responsible for processing for which applicable law makes us accountable, including processing carried out by providers on our behalf. Independently acting third parties may also process information under their own policies, including profiling or information they obtain outside our Apps. We do not guarantee their independent practices. Contact us about data for which we are responsible, and consult the recipients in Section III for their independent processing and privacy options.

II. THE PURPOSES OF PROCESSING YOUR PERSONAL DATA

Our mission is to constantly improve our App and provide you with new experiences. As part of this mission, we use your information for the following purposes:

1. To provide the App, maintain, improve, test, and monitor the effectiveness of our App. We use information you provide to us directly and information that is processed automatically to provide and deliver the App to you as well as to better understand User behavior and trends, detect potential outages and technical issues, support the existing functions of the App, and to add new features and services to the App.
2. To provide you with interest-based (behavioral) advertising or other targeted content. We may use information that is processed automatically for marketing purposes (to show ads that may be of interest to you based on your preferences). We provide personalized content and information to you, which can include online ads or other forms of marketing.
3. To communicate with you. We may use information that is processed automatically to send you push notifications with technical notices, updates, security alerts, and support and administrative messages. Similarly, we use your contact information to respond to you when you contact us.
4. To prevent fraud and spam, and to enforce the law. We aimed our App to be free of spam and fraudulent content so that you feel safe and free. We may use your information to prevent, detect, and investigate fraud, security breaches, and potentially prohibited or illegal activities, protect our trademarks, and enforce our Terms of Use.

If a new purpose for processing your personal data arises, we will update this Privacy Policy and provide any notice required before that processing begins. Further processing requires an applicable lawful basis and any legally required consent; publication of an updated policy alone does not authorise an incompatible new use.

Legal bases for processing (EEA and UK)

Where the EU-GDPR or UK-GDPR applies, we process personal data for the purposes described above on the following legal bases:

• Your consent: for personalised advertising, product analytics and attribution using your advertising ID, wherever consent is required by law. You may withdraw your consent as described in Sections VIII and IX.
• Our legitimate interests: to diagnose crashes, configure the App remotely, prevent fraud and cheating, maintain security and reliability, and, where permitted without consent, show non-personalised advertising and measure installs without your advertising ID. We rely on this basis only where the processing is necessary and our interests are not overridden by your rights and interests.
• Performance of a contract: to provide the App features and support you request and to deliver, validate and restore your in-app purchases.
• Compliance with legal obligations: to keep records required by tax and accounting law and respond to legally binding requests.

These legal bases do not replace any separate consent required for storing information on, or accessing information from, your device. Non-personalised advertising and measurement without an advertising ID may still involve personal data or device access; where consent is required, that processing is subject to your consent. Declining optional advertising or analytics consent does not prevent processing that has another valid legal basis.

III. INFORMATION SHARING AND DISCLOSURE

We will share your information with third parties only in the ways that are described in this Privacy policy.

We do not rent personal information or sell it for monetary payment. We may disclose information such as log files, device identifiers and location-related data to providers and advertising partners for the purposes described here. Some advertising disclosures may have a broader legal classification as a “sale” or “sharing” under California law even without a monetary payment; the applicable rights are explained in Section VIII.

We may also share certain information such as cookie data with third-party advertising partners. This information allows third-party ad networks, inter alia, to deliver targeted advertisements that they believe will be of most interest to you.

When engaging providers, we take account of appropriate technical and organisational safeguards and the contractual requirements applicable to their role. We cannot guarantee the absolute security of a third party's systems. Independent recipients are responsible for their own practices; this does not exclude responsibility that law assigns to us for selecting, instructing or using a provider.

The following categories of recipients (third-party providers and advertising partners) may be engaged by us in the processing of your information for a variety of business purposes (namely to provide us with the necessary infrastructure for the delivery and improvement of our App, and to perform App-related services):

This table includes partners used across different Apps and versions. In Apps that use AppLovin MAX, advertising partners may participate through its mediation service. Liftoff is listed in addition to the existing Vungle entry to cover the current branding. Google services may include Firebase Analytics, Crashlytics and Remote Config; Yandex services may include AppMetrica and Yandex Mobile Ads.

Some entries retain legacy names for earlier App versions. The current notice linked from the Chartboost entry identifies Chartboost LLC within the LoopMe group. The applicable recipient and its processing role depend on the service and agreement in effect; a legacy name does not mean that every current service is operated by that historical entity.

The above-said legal entities provide us with automatic data processing technologies for the App and deliver data processing, payment processing, and other services to us concerning the App, and may be involved in the other types of services and activities otherwise discussed in this Privacy Policy. That is why the App may contain tracking and data collection and analytics tools and other automatic data processing technologies for the App provided to us by such legal entities, and that is why third-party companies may have access to and collect data and information about you (within the categories of personal information mentioned above), such as your device identifier, Advertising ID or Android ID, Designated Market Area (DMA), geo-location information, IP address, application usage, access and session times, and your viewing of and interactions with advertising, provided and delivered as described in further detail below.

A recipient may act as our processor or service provider, or as an independent controller, depending on the service, purpose and applicable terms. Advertising partners are not automatically service providers for every purpose. A recipient's permitted processing and any required contractual restrictions depend on that role.

In case you want to learn more about these services and their privacy options (including an opt-out) please consult the correspondent websites and privacy policies. We are not responsible for any usage of your personal data by the abovementioned third parties in violation of our instructions.

Please, note that the App may include links to third-party websites/services, plug-ins, and applications (for example, allowing Users to share certain content and information on social media platforms), or you may access the App from a third-party site. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites/services, plug-ins, and applications, and are not responsible for the privacy practices or the content of these third-party websites/services, plug-ins, and applications linked to or from our App, including the information or content contained within them. We encourage you to read the privacy notice of every website you visit/service, plug-in, and application you use.

In addition to the above, we may disclose your personal information if needed for objective reasons, due to public interest, or in other unforeseen circumstances:

• as required by law;
• when we believe in good faith that disclosure is necessary to protect our rights, protect the safety of yours, or the safety of others, investigate fraud, or respond to a government request;
• if we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice in our App of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

It means that your personal information may also be disclosed to the following categories of recipients:

• Government and law enforcement officials, courts.
• Authorized Agents (for example, when you decide to designate an authorized agent to submit requests on your behalf).
• Affiliates. (for example, when corporate audit, analysis, consolidated reporting, or compliance with applicable laws is needed).

IV. INTERNATIONAL DATA TRANSFERS

We work in the cross-border area and provide our App to our Users around the world.

We and the legal entity that provides automatic data processing technologies for the App or our third-party advertising partners may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world.

Please note that we may transfer information, including personal data, to a country and jurisdiction that does not have the same data protection laws as in your jurisdiction.

This means that your personal information can be transferred to a third country, a territory, or one or more specified sectors within that third country, or to an international organization where data protection and confidentiality regulations may not provide the same level of protection of a personal data as your country does.

Cross-border processing is subject to the transfer requirements applicable to the data and the entities involved. Using the App is not blanket consent to an unrestricted transfer or a waiver of legally required protection.

Storage of information covered by this Privacy Policy is provided through third-party services, rather than dedicated storage infrastructure operated by Black Box Digital LLP. For analytics, attribution and diagnostics, these services include AppMetrica, Tenjin and other providers listed in Section III, depending on the App. Information may be transmitted directly from the App to those services through their SDKs. Our access may include reports or information available through the relevant service's account tools, depending on its features and settings. A provider's processing role and the safeguards required depend on the data, service and applicable law; its headquarters do not necessarily identify every storage location.

Depending on the App and the services used, recipients listed in Section III may process personal data in the United States, Russia, Singapore and China, as well as other countries described in their privacy policies. The location column identifies the listed entity's location and is not an exhaustive list of processing or storage locations.

Transfers subject to EEA or UK data protection law require an applicable adequacy decision or another lawful transfer mechanism. Where an adequacy decision does not apply, appropriate safeguards may include the European Commission's Standard Contractual Clauses and, for UK transfers, the UK Addendum or International Data Transfer Agreement, together with any supplementary measures required for the particular transfer. The EU–U.S. Data Privacy Framework and its UK Extension apply only to transfers covered by a relevant adequacy decision to recipients with an active certification covering the data concerned. Use of the App alone does not replace safeguards required by law. You may contact us at [email protected] to request information about the mechanism applicable to your data and a copy of relevant safeguards, subject to necessary redactions.

V. HOW LONG DO WE USE YOUR PERSONAL DATA

Personal information is stored within the third-party services described in Section III, rather than in a separate storage system operated by us. Where a provider processes information on our behalf, retention must be limited to the App service, stated purpose and applicable legal obligations, with the relevant contractual, retention and deletion arrangements in place. A provider's technical limitations do not waive a User's statutory rights. Outsourcing storage does not remove responsibilities that applicable law assigns to us. You may request deletion of data for which we are responsible, including information held by providers acting on our behalf, subject to lawful exceptions.

The applicable retention period depends on the category of data, its purpose, the App, the provider's terms and the settings available for the service. Independent controllers' retention practices are also described in their own privacy policies. Where a single fixed period cannot be specified for all Apps, the following criteria apply to processing for which we are responsible:

• Analytics and attribution events: the period needed to compare App versions, understand engagement and measure campaign and revenue performance, taking account of the retention settings applicable to the analytics or attribution service and whether identifiable event data is still needed for that purpose.
• Crash reports and diagnostics: the period needed to investigate, reproduce and resolve faults and verify the stability of affected App versions, taking account of the diagnostic service's retention settings.
• Purchase records: the period needed to validate, deliver and restore purchases, handle refunds or disputes and meet applicable tax and accounting retention requirements.
• Support correspondence: the period needed to resolve your request and any related follow-up, complaint or dispute, taking account of applicable legal requirements.

For processing for which we are responsible, retention in identifiable form is limited to the relevant purpose and applicable legal requirements. You can ask us about the period applicable to a particular App, category of data or service at [email protected]. Where a provider processes data on our behalf, we handle applicable deletion requests through the relevant service tools or contractual procedures. An independently acting controller may need to address requests about its own processing. Deletion remains subject to lawful exceptions, and uninstalling the App does not itself delete records already held within third-party services.

However, some data may still be stored for a certain period (but no longer than the storage purpose requires) if the information is necessary to comply with a legal obligation (taxation, accounting, audit) or to maintain safety and data backup settings, prevent fraud or other malicious acts.

VI. SECURITY

The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.

We take reasonable and appropriate measures to protect personal information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the personal information.

We apply technical and organisational safeguards appropriate to the processing and the risk, guided by data minimisation and applicable security requirements. Depending on the service, safeguards may include access restrictions, encryption, pseudonymisation or other protective measures. Hashing and pseudonymisation do not necessarily make information anonymous.

No method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security. If a personal data breach occurs, we assess the incident and provide any notification to affected Users or authorities required by applicable law within the applicable legal time limits.

If you have any questions about the security of our App, you can contact us through the email displayed below.

VII. CHILDREN'S PRIVACY

Our Apps are intended for Users aged 13 and over, subject to any higher age expressly stated for a particular App or required by law. They are not directed to children under 13, and we do not knowingly collect or solicit their personal information. If you are under 13 or the applicable higher minimum age, DO NOT DOWNLOAD OR USE the App.

We do not impose a blanket parental-consent requirement on all Users aged 13–17. However, where a User cannot lawfully consent to a particular processing activity independently, the legally required authorisation must be obtained before that activity. For EEA services offered directly to children, the age for independently consenting to processing based on consent varies by country between 13 and 16; the UK threshold for that purpose is 13. The general minimum age does not override these rules or other safeguards for minors.

If we learn that we have collected personal information from a child below the applicable minimum age, we will take steps to delete it without undue delay, subject to any necessary lawful retention. If you believe we hold such information, or a parent or guardian wishes to raise a privacy concern, please contact us.

VIII. YOUR RIGHTS AND CHOICES

If you are a resident of the European Economic Area, your rights to access, edit, and delete your information can be found in clause 8.1. of this section.

If you are a California resident, your rights to access, edit, and delete can be found in clause 8.2. of this section.

Depending on your location, you may have rights to access, correct, delete or restrict use of your personal information or to appeal a privacy decision. Contact [email protected] to exercise applicable rights. Where the law permits verification, we may request proportionate information needed to establish identity, authority or the applicable jurisdiction. We will handle requests under applicable law, including any exceptions for legal obligations, security, fraud prevention or the rights of others. Deleting data needed for a particular feature may affect that feature; withdrawing optional consent does not remove unrelated rights.

8.1. Information for Individuals in the European Economic Area (EEA) and the UK

If you reside in the European Economic Area ("EEA") or the UK, applicable privacy laws (in particular EU-GDPR and UK-GDPR respectively) give you certain rights regarding your personal data.

According to both EU-GDPR and UK-GDPR, you have the following options concerning your personal data that was collected:

• Data Access and Portability. You can request copies of your personal information.
• Change or Correct Data. You have the right to ask us to correct, change, update or rectify your data.
• Data Retention and Deletion. The User data is generally retained for as long as it is needed to provide you with the App. However, specific retention times can vary based on the context of the processing performed. You have the right to ask to delete all or some of the personal data that is held about you.
• Restriction of Processing. Under certain circumstances, you may have the right to limit how your personal information is used.

To exercise these rights, contact [email protected]. Our responsibility covers data for which we are the controller, including data processed on our behalf; independent controllers may need to address requests concerning their own processing.

When your personal information is processed automatically you may object to such processing in some circumstances. Where your personal information is processed for direct marketing purposes, you may ask to cease processing your data for these direct marketing purposes. To exercise your right please contact the recipients listed in Section III of this Privacy Policy to learn how you can object to processing your data. Most of them have clear instructions on their privacy pages, functional API, or other options.

If you don't want us to share device identifiers and geolocation data with service providers, please check your device settings to opt-out as described below.

If you are located in the European Union, you may contact Black Box Digital LLP directly when you have questions on privacy issues by sending an email to [email protected].

If you are located in the UK, you may contact Black Box Digital LLP directly when you have questions on privacy issues by sending an email to [email protected]. This email is the controller's direct contact address and is not presented as the contact of a separately appointed EEA or UK representative.

Withdrawal of consent and complaints. You may withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal. Where the App offers a “Privacy Settings” option or a consent-management screen, you can change your choices there at any time. You may also contact us for assistance. You have the right to lodge a complaint with the data protection supervisory authority in the country of your habitual residence, place of work or the alleged infringement.

You may object to processing based on legitimate interests on grounds relating to your particular situation, and you may object to direct marketing at any time. For personal data processed by service providers on our behalf, you may also contact us so that we can assist with your request. These rights apply subject to the conditions and exceptions in applicable law.

Where the EU-GDPR or UK-GDPR applies, requests are handled without undue delay and within the applicable legal deadline, normally one month after receipt. Any extension or necessary identity check is subject to the applicable law and required notice; this policy does not create a general right to restart the response period after sending a confirmation email.

8.2. Information for Residents of California: Your California Privacy Rights

The California Consumer Privacy Act of 2018, as amended (CCPA), provides California residents with specific rights regarding their personal information. Where the CCPA applies to our processing, this section describes those rights and how to exercise them.

The CCPA provides consumers (California residents) with the following rights regarding their personal information:

• Right to Access. You may request the following information up to twice in twelve months. The ordinary reporting period covers the preceding twelve months. You may also request retained information collected on or after January 1, 2022 beyond that period, subject to legally permitted exceptions and any required explanation:
  • The categories of personal information we have collected about you.
  • The categories of sources for the personal information we have collected about you.
  • The business or commercial purpose for collecting, selling or sharing your personal information.
  • The categories of third parties to whom we disclose your personal information.
  • The specific pieces of personal information we have collected about you.
  • Whether we have sold, shared or disclosed your personal information for a business purpose, identifying the categories involved and their recipients separately for sale/sharing and for disclosures to service providers or contractors for a business purpose.
• Deletion rights. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions outlined in the CCPA.
• Right to Opt-Out (“Do Not Sell or Share”). You may opt out of sale of your personal information for monetary or other valuable consideration and sharing for cross-context behavioural advertising, as explained below.
• Non-discrimination. You are entitled to exercise the rights described in this section free from discrimination. This means that we will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights.

We do not sell personal information for monetary payment. California law defines sale and sharing more broadly, and advertising disclosures may fall within those definitions as explained below. Material changes to these practices are subject to applicable notice and choice requirements.

If you wish to stop or restrict processing, contact [email protected]. Where particular data is necessary to provide a requested feature, that feature may not be available without it. An opt-out of optional advertising or analytics is not itself a request to delete your account or stop unrelated processing on another valid legal basis.

Now, when you are aware of your California privacy rights, please note, the following:

• The categories in Section I describe information that may be collected across our Apps. The categories actually collected about a User during the preceding twelve (12) months depend on the App, its features and the User's choices.
• Disclosures during that period depend on those same factors and involve the recipient categories and purposes in Sections II and III; we do not represent that every category is disclosed for every purpose.
• Advertising-related disclosures must be considered separately from a sale for monetary payment when assessing California sale and sharing rights.

How to Exercise Your California Privacy Rights

To request access to your personal information or request deletion, please submit a verifiable consumer request to us by e-mail: [email protected].

You may submit a request yourself or through an authorised agent as permitted by the CCPA. Where legally permitted, we may request reasonable proof of identity or the agent's authority; this is not a requirement to register the agent with the California Secretary of State.

To help us route your request, you may identify it as a California privacy request, but no particular wording is required.

For requests to know, correct or delete, we acknowledge receipt within ten (10) business days and normally respond within forty-five (45) calendar days after receipt, subject to lawful exceptions and extensions with required notice. The twice-per-twelve-month limit applies to requests to know, rather than all privacy requests.

Additional rights under the CCPA as amended by the CPRA

Where the CCPA applies, disclosures of device identifiers, advertising interactions and App-usage information to the advertising partners in Section III for personalised advertising may constitute a “sale” or “sharing” for cross-context behavioural advertising, depending on the recipient and arrangement, even without a monetary payment. The categories involved generally fall within identifiers and internet or similar activity information in Section I. The statements about not selling information for money do not exclude these broader statutory categories.

Do Not Sell or Share My Personal Information. You have the right to opt out of sale or sharing of personal information, including sharing for cross-context behavioural advertising. Use the privacy or consent settings available in the App, or send us an opt-out request by email. Device-level options such as “Delete advertising ID” or “Opt out of Ads Personalization” may also limit identifier-based advertising, but do not replace your right to make an opt-out request to us. An opt-out request does not require a verified consumer request. Where the CCPA applies, we implement it as soon as feasibly possible and within fifteen (15) business days at the latest.

Correction and authorised agents. You may request correction of inaccurate personal information we hold about you, subject to the nature and purpose of the processing. You may use an authorised agent as permitted by California law; any verification of identity or authority will be limited to what that law allows.

Minors and additional choices. Where the CCPA applies and we have actual knowledge that a User is under 16, sale or sharing requires the affirmative authorisation specified by that law; Users aged 13–15 may provide the applicable opt-in themselves. The App's 13+ minimum does not remove that requirement. Where legally applicable, you may also have a right to limit use of sensitive personal information. Where the law requires, a valid opt-out preference signal, such as Global Privacy Control, received by our services is processed as an opt-out for the relevant browser, device and associated profile in accordance with that law. A browser signal does not necessarily communicate a choice to a separately installed App; contact us for assistance with an App-specific choice.

The twice-per-year limit described above relates to requests to know or access and does not limit requests to opt out, correct or delete. You do not need to use a particular subject line or the suggested wording above to exercise your rights. We will handle requests within the deadlines applicable to the type of request; the 45-day response period described above is not the deadline for implementing an opt-out. You will not be discriminated against for exercising these rights.

IX. HOW TO OPT-OUT

Where available, open “Privacy Settings” or the consent-management screen in the App to review your choices and withdraw optional consent. The available controls depend on the App and platform. You may also contact [email protected] for assistance. California residents can use the Do Not Sell or Share My Personal Information options in Section VIII.

Opt-out of marketing tracking

To limit identifier-based advertising on Android, review the available options under Settings / Google / Ads, such as “Delete advertising ID” or “Opt out of Ads Personalization”. On Apple devices, review Settings / Privacy & Security / Tracking. Menu names and available options vary by device and operating-system version. Device controls supplement the in-App consent and statutory request options; they do not necessarily stop every type of processing.

You can also visit youradchoices.com for the same purpose.

Please mind when you opt out of certain interest-based advertising, you may continue to receive contextual ads based on other non-personal information, such as ads related to the content of other digital products you are using.

Opt-out of Location Data Processing

If you don't want third-party service providers to use your precise location data, or street-level location information about you, you should turn Location off for the App via the menu “Settings > Apps > [our App] > Permissions > Location”. Then turn off the “Location” button.

Where the App offers push notifications, you can manage or disable them in the App or device settings. Disabling notifications may prevent delivery through that channel; legally required notices may still be provided through another appropriate method.

Uninstalling the App stops collection through that installation while it is no longer running, but does not itself delete previously collected data, cancel a subscription or prevent processing of an existing support request or legally retained record. Retention is described in Section V, and you may exercise the applicable rights in Section VIII.

X. CHANGES TO THE PRIVACY POLICY

We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Policy as we undertake new personal data practices or adopt new privacy policies.

We publish changes on this page with an updated revision date and provide additional notice or obtain consent where required by law. A policy update does not retrospectively authorise processing that required prior notice, another lawful basis or consent.

XI. HOW TO CONTACT US

If you have any questions about this Privacy Policy, please feel free to send your message at [email protected].

Data controller: Black Box Digital LLP, business identification number (BIN) 221040033549. Registered address: Kazakhstan, Almaty, Bostandyk District, Al-Farabi Avenue, Building 21, N.P. 1247.

For a privacy request, please identify the App and describe the request so that we can locate the relevant records. Where necessary, we may ask for proportionate information to verify your identity or your authority to act for someone else, as permitted by law. Please do not send passwords, payment card details or unrelated sensitive information. General privacy requests may be sent to [email protected]; California opt-out requests can also be initiated using the link in Section VIII.