Effective Date: August 5, 2025
Contact:

**Quick Summary**

• We might collect limited data to improve gameplay and show relevant ads.
• You can opt in or out of data collection depending on your region.
• We don’t collect personal identifiers like your name, phone number or email unless you contact us.
• Children’s privacy is protected with strict safeguards.
• You have rights over your data and can contact us anytime at .

We respect your privacy and are committed to protecting your personal data. This Privacy Policy outlines how we collect, use, and share information when you play our games (“Games”), and your rights regarding that data. This Privacy Policy is a part of, and incorporated into the End User License Agreement ("EULA").

This Privacy Policy should be read in conjunction with our End User License Agreement (EULA), which governs your use of our Games. The EULA is available at https://www.actalogic.com/eula.

About ActaLogic Games

This Privacy Policy applies to all ActaLogic-branded Games available on mobile devices and other platforms. By playing, you acknowledge that your interaction with our Games falls under this policy.

ActaLogic d.o.o., located in Ljubljana, Slovenia, is the data controller responsible for processing your personal data in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR).

What We Collect

We gather limited data to improve game functionality and services, serve ads, and offer support. Data may come from:

• Your interaction with our games
• Your device (automatically)
• Contacting us directly

Directly Provided Information

• If you contact us via email or within our Games, we use your data only to respond.
• For certain Games, you might set a nickname. We recommend avoiding real names.

Automatically Collected Information
From your device, we may collect:

• A randomly generated user or device ID
• Unique device and player identifiers (IDFA, AAID, etc.)
• IP address and approximate (coarse) geolocation
• Language, locale, and time zone
• Device specs (model, OS version, screen size, storage, etc.)
• Game progress, game stats, play events, and crash reports
• In-app purchase activity (excluding payment info)
• Interaction with ads and performance metrics
• App store data (downloads, installs, sessions)

Some Games may request access to push notifications and game center services – both are optional and managed by your device settings.

We do not collect personal identifiers like your name, phone number, or email address, with which you could be contacted or personally identified directly.

How We Use Information

Your data helps us:

• Ensure smooth gameplay and fix bugs
• Understand usage patterns
• Improve user experience and gameplay (Cloud saves, Leaderboards, etc.)
• Deliver updates and customer support
• Evaluate game performance and user engagement
• Diagnose bugs or crashes
• Run analytics and improve security
• Offer relevant ads and cross-promotions

All data is processed under principles of necessity, transparency, and security and is used only for specific purposes.

We process your data under the following legal bases:

• Consent (e.g., for personalized ads)
• Performance of a contract (e.g., enabling gameplay features)
• Legitimate interest (e.g., improving game performance and security)

Consent and Opt-Out Mechanisms

Before collecting certain types of data – particularly for advertising and analytics – we request your explicit consent, as required by applicable law.

• In regions governed by the General Data Protection Regulation (GDPR), as well as other regions, players are presented with the option to opt in or opt out of data collection related to personalized advertising and usage analytics.
• On iOS devices, we comply with Apple’s AppTrackingTransparency (ATT) framework, prompting users for permission before using identifiers for tracking purposes.

These mechanisms ensure that your preferences are respected and that any data collected is handled transparently and lawfully.

Sharing Your Data

To provide and improve our services, we work with third-party companies. Data shared is limited to what’s necessary.

• Unity Software helps us develop and run games – see their policy: Unity Privacy Policy
• Unity Analytics helps us understand game performance using aggregated data: Unity Analytics Policy
• Advertising Partners may receive non-identifying data to serve contextual or interest-based ads (varies by region):
  
  • Ironsource
  • Unity Ads
  • Google AdMob
  • InMobi
  • Chartboost
• App Store Game Centers (e.g. Apple Game Center, Google Play Games) may sync your progress. Use of these centers is governed by their policies.

We don’t collect or store payment data – in-app purchases are handled by the app stores.

Advertising & Promotions

Our free Games may include ads to support development. We work with ad partners to deliver content that’s appropriate, and data is shared strictly for this purpose.

Children’s Privacy

We take special care to protect the privacy of children under applicable laws such as COPPA (U.S.) and GDPR-K (EU).

• Age Confirmation Flow: Before gameplay begins, users are asked to confirm their age. If a user indicates they are under the minimum age required by law, access is restricted or limited to a compliant experience.
• No Personal Data Collection: We do not knowingly collect personal data from children.
• Anonymous Gameplay: Children may play anonymously without providing identifiable information.
• No Personalized Ads: Children are only shown contextual ads.
• Limited Data Collection: Only device-based identifiers and essential gameplay data are collected.
• Parental Consent: We do not collect personal data from children, and therefore do not require or seek verifiable parental consent. If a user indicates they are under the minimum age required by law, we restrict gameplay features and prevent any personal data collection.
• Data Deletion: If we learn that personal data from a child was collected improperly, we will delete it promptly.
• Advertisers: Advertisers are required to follow child data standards. We use Google Play Families Self-Certified providers.

Parents or guardians may contact us at to review, delete, or manage their child’s data.

Analytics and Performance

We use aggregated data to:

• Understand how players interact with our Games
• Improve features and user experience
• Measure success of marketing campaigns
• Detect fraud and prevent abuse

We work with partners, like Unity Analytics, who follow strict privacy standards.

Global Data Transfers

Because ActaLogic operates internationally, your data may be transferred outside your home country. We ensure appropriate safeguards are in place under applicable data protection laws.

Data Retention & Security

We apply technical and organizational safeguards to protect your data. No system is perfectly secure, but we commit to doing our best.

We retain your data only as long as needed, typically no longer than five years after your last interaction with our Games (such as launching a game, making an in-app purchase, or contacting support). Some data may be anonymized and stored longer for analysis.

Your Privacy Rights

Depending on your region, you may have the right to:

• Access or receive a copy of your data
• Request deletion or correction
• Object to certain processing
• Limit how your data is used
• Transfer your data to another service
• File a complaint with local authorities

To exercise any of these rights, contact us at . We may verify your identity before responding.

Changes to This Policy

We may revise this Privacy Policy periodically to reflect updates in legal requirements or game features. Any changes will be posted prominently. Material changes will be clearly communicated.

Governing Law

This Privacy Policy is governed by the laws of Slovenia and applicable EU regulations.

Contact Us

For questions or concerns about this Privacy Policy, reach us at:

• Email:

© 2009– ActaLogic. All rights reserved.