Last revised on May 21, 2026
1.1. “Privacy Policy” is a document that informs Users about the processing of their personal information and personal data while using the mobile application (mobile game).
1.2. “User” means any person who has accepted the terms of this Policy and who has installed the mobile application from an app store.
1.3. “Personal Data Subject” means a User who has downloaded the Mobile Application and performed any actions therein.
1.4. “Administrator” means an individual entrepreneur Nykonenko Oleksandra Mykolaivna, individual tax number (RNOKPP) No. 3515812584, address: 52500, Sirka Ivana St., 6, Synelnykove, Synelnykivskyi district, Dnipropetrovsk region, Ukraine, who is the owner of the Mobile Application.
1.5. “Data Controller” – a person who determines the purpose and means of processing personal data.
1.6. “Mobile Application” means software created and intended for installation (download) on the User's device through electronic application stores such as App Store and/or Google Play or others.
1.7. “Mobile Application Functionality” means the capabilities of the Mobile Application provided to the User to perform actions in the application aimed at fulfilling the gaming needs of Users.
1.8. “Contact details” means the email address provided in the Mobile Application's Privacy Policy for contacting the game Administrator.
1.9. “Personal data” means any information relating to the User as an identifiable individual based on the Personal data obtained.
1.10. “Personal Data Processing” - an action and/or set of actions that may be performed by the Data Controller/Administrator for the purposes specified in this Privacy Policy.
1.11. “Processor” - a natural or legal person (public authority or their authorized representatives) who processes (handles) personal data on behalf of the controller.
1.12. “Cookies” - small text files that are placed and stored on Users' electronic devices.
1.13. “Third parties” - other companies and/or persons who may process the personal information of the data subject.
2.1. This Privacy Policy for the mobile game contains information about how/what/in what way/for what purpose/for how long the Administrator may collect/process/store/use/transfer Users' personal information in accordance with the General Data Protection Regulation (EU) 2016/679 of 27.04.2016 (EU General Data Protection Regulation – GDPR), as well as the methods and means of communication with the Administrator.
2.2. This Privacy Policy applies to the Mobile Application.
2.3. The Administrator may collect only non-personalized analytical information about the User when and/or if the User downloads the Mobile Application and accepts this Privacy Policy, views material posted in the Mobile Application, views advertisements, or otherwise interacts with the Mobile Application.
2.4. The controller of personal data within the meaning of the Legislation is the Administrator of the Mobile Application.
2.5. The personal data processor within the meaning of the Legislation is the Google AdMob service (hereinafter also referred to as “AdMob”/“AdMob service”/“Google AdMob”), which is owned by Google LLC, registered under the laws of the State of Delaware (USA) and operating in accordance with US law, registered at 1600 Amphitheatre Parkway Mountain View, California, 94043. For more detailed information about the location of servers, follow this–link, and other details regarding the collection/processing/storage of User information by Google LLC, please visit the following link.
2.6. Upon first interaction with the Mobile Application, the User confirms that they have read and agrees the Privacy Policy and Cookie Policy by clicking on the button “I agree” and fully and unconditionally agrees to them and accordingly gives their personal consent to the collection and processing of personal data by the AdMob service by clicking the “Consent” button (or through the “Privacy Settings” section, if available) in accordance with applicable law.
2.7. If the User does not agree with this Privacy Policy and Cookie Policy, they must stop using the Mobile Application.
2.8. Data Controller agrees to take all necessary measures to ensure the safe use of the Mobile Application, protect Users' Personal Data, and prevent unauthorized access, theft, editing, and other illegal actions by third parties with regard to Users' Personal Data.
2.9. The Mobile Application is intended exclusively for Users who have reached the age of 18 years. By downloading and/or using the Mobile Application, the User confirms that they are at least 18 years of age.
3.1. The User's personal data is processed in the following cases and on the following grounds (in accordance with Article 6(1) of the GDPR):
3.1.1. The User's direct consent to such data processing in accordance with this Privacy Policy and the law.
3.1.2. To fulfill the obligations of the Data Controller and to protect the interests of the User.
3.1.3. The necessity to protect the interests of the Data Controller and/or a third party, except where the fundamental rights and freedoms of the data subject override such interests, requiring the protection of personal data, in particular where the data subject is a child.
3.2. The purpose of processing User data (in accordance with Article 6(1) of the GDPR) is:
3.2.1. The fulfillment of the Administrator's obligations under the Law.
3.2.2. Displaying personalized and non-personalized advertising in the Mobile Application. To do this, the Data Processor may store and access information on the User's technical device, such as cookies, online identifiers, and others; creating and using a User profile based on previously collected information, for example, to select personalized advertising.
3.2.3. Obtaining analytical information, including Mobile Application conversion, number of downloads, deletions, number of players, device model, and other technical data.
3.2.4. Collecting information about Users' activity in the Mobile Application, their preferences, and clicks on viewed advertisements. The collection of such information is necessary to improve the measurement of advertising effectiveness.
3.2.5. Compliance with legal requirements, namely the prevention and/or termination of illegal actions by Users and/or third parties.
3.2.6. Interaction of Users with the Mobile Application Administrator (by sending emails to the Administrator's email address).
3.2.7. Improving the information/technical structure of the Mobile Application to facilitate and improve the interaction between the User and the Mobile Application, as well as to increase the level of security of the collection/processing/storage of User Personal data.
4.1. The processing of Users' personal data may be carried out exclusively in accordance with the Privacy Policy and in accordance with the principles of the GDPR and the lawfulness of their processing (Articles 5 and 6 of the GDPR). Users' personal data may be collected in accordance with the legal grounds set out in section 3.1 of this Privacy Policy and stored for the time necessary to enable the User to use the Mobile Application, as well as to display personalized advertising, while the Mobile Application is installed to the User's electronic device or until the User takes action to delete personal information, but no longer than permitted by law or until such data is anonymized automatically by AdMob. AdMob anonymizes personal information as follows:
For information on the automatic anonymization of personal data by service AdMob, please visit link.
4.2. The Mobile Application Administrator does not independently collect, process, or store Users' personal data, but when collecting and processing Users' personal data through the AdMob service, - only has access to non-personalized and analytical information received from AdMob. Personal information is collected by the Processor, namely Google LLC, for the purpose of displaying personalized advertising, as described in more detail in section 2.5 of this Policy.
4.3. The Administrator may collect Users' personal data only if the User provides them on their own initiative when sending an email to the Administrator, namely:
| № | User action | Type of information that may be collected | Storage period |
| 1 | When sending a request to the Administrator by email. | 1.User's last name and first name 2.User's photo, if available 3.Email address 4.Other information that the user may provide voluntarily when submitting the request |
Until the request to the Administrator is reviewed, but no longer than the moment the User refuses the Administrator's services, which means the termination of the Agreement, taking into account the deadline for submitting objections to the processing of personal data and the statute of limitations. |
4.4. The Administrator uses the Google AdMob service, which is owned by Google LLC and which collects data about Users for the purpose of selecting personalized and non-personalized advertisements for subsequent display in the Administrator's Mobile Application (for more details on how this works, please visit link).
4.5. AdMob, may automatically collect the following information:
Follow this link to learn how Google uses data through the AdMob service and see a list of data that AdMob transfer to partners advertising networks.
You can also find out how Google LLC processes information received from the Mobile Application by following this link.
4.6. The Mobile Application Administrator reserves the right to determine the list of information, including personal information, that it may request from the User. If the list of personal information collected by the Administrator is changed, this will be reflected in the Privacy Policy and will take effect upon publication of the revised Privacy Policy and, if necessary, the Cookie Policy.
4.7. The Administrator does not intentionally collect data from Users who have not reached the age of majority, namely 18 years of age. If a minor nevertheless sends their personal data to the Administrator's email address, the Administrator will delete it within a reasonable time after discovering the collection of such information. Control over the actions of minors is the responsibility of their parents, guardians, and/or custodians (representatives). If a minor independently and/or their parents/guardians and/or custodians discover that such a
person has provided personal information to the Mobile Application Administrator, they may write an email to the Administrator at the address specified in the last section of the Privacy Policy requesting that such information be deleted. The Administrator, in turn, agrees to take the necessary measures to delete such information as soon as possible after receiving such a letter.
5.1. The following persons have access to the personal data of Mobile Application Users: the Controller in the name of the Administrator, (within the limits specified in sections 4.2. and 4.3. of this Policy), Google LLC represented by the Processor (using the Google AdMob service) and its advertising partners. Google LLC's privacy policy is available via the link.
5.2. Also, in the event that state authorities request personal information about Users on the basis of a court decision/request/order/decree, the Administrator may provide such information to state authorities or persons authorized by them.
6.1. Cookie files are small text files that are stored on the User's device when using the Mobile Application. This can be a phone, tablet, or other technical device.
6.2. Cookie files are used to collect User data, which helps to improve the usability of the Mobile Application, its efficiency, and the display of advertisements.
6.3. When Users use the Mobile Application, the following categories of cookie files may be collected:
6.3.1. Necessary cookies are files that are necessary for the operation of the Application and are stored on the User's technical device for a certain period of time after the end of the Mobile Application session.
6.3.2. Functional cookies are files that help store and remember the User's choices for future visits.
6.3.3. Third-party cookies are files from third parties that are used to collect information about Users' visits to the Mobile Application. For more detailed information about which cookies are used, please follow and familiarize yourself with the link and the Cookie Policy.
7.1. The processing of Users' personal data is carried out in accordance with the Privacy Policy and in compliance with the GDPR.
7.2. The Administrator agrees not to store Users' personal information longer than necessary and to destroy and/or anonymize it after the expiration of such period.
7.3. The personal data protection system consists of organizational, technical, and/or software measures designed to taking into the current and potential threats to the security, integrity, and confidentiality of personal data and technologies and also Google LLC protection systems. If necessary, the Administrator and Google LLC regularly updates its security measures and installs additional measures.
7.4. However, despite all the measures and efforts taken to protect personal data, no electronic data transmission can be 100% protected from hacking, fraud, and other actions, so the transfer of personal data is carried out by the User at their own risk.
8.1. In accordance with the GDPR, the User has the right to:
8.1.1. Receive information about the collection of such User's personal data.
To exercise this right, the User may refer to section 4 of this policy, as well as via the following link.
8.1.2. Access their personal data.
To exercise this right, the User may use the following link to take the necessary steps and export their data collected by Google LLC.
If the User wishes to access the data sent to the Administrator by email, they may write a request to the Administrator's email address.
8.1.3. Make corrections to their personal data.
To exercise this right, the User may use the following link to follow the necessary steps and make changes to their data collected by Google LLC.
If the User wishes to correct data sent to the Administrator by email, they can send a request to the Administrator's email address.
8.1.4. Restrict the Processor in processing their personal data.
If the User wishes to completely restrict the Processor in processing their Personal Data, they must delete the Mobile Application from their device.
8.1.5. Contact the Administrator to delete personal data that the User has sent by email.
To exercise this right, the User may send a letter to the Administrator's email address with a request to destroy personal data.
If the User wants to delete the data collected by Google LLC, then to exercise this right, the User can use the following link to take the necessary steps and delete the data collected by Google LLC.
8.1.6. Data mobility.
To exercise this right, the User may use the following link.
8.1.7. Object to the processing of personal data, including profiling.
If the User wishes to object to the processing of personal data, including profiling, they must delete the Mobile Application from their device.
8.1.8. Not to be subject to automated decisions, including profiling.
If the User does not wish to be subject to automated decisions, including profiling, they must delete the Mobile Application from their device.
8.1.9. To protect against the provision of information that is inaccurate or violates honor, dignity, and business reputation.
To exercise this right, the User may apply legal remedies in case of violation of personal data protection legislation. To exercise this right, the User may apply to the Google LLC, court and/or other authorities regulating personal data protection rights.
8.2. When collecting Users' personal information, the Administrator undertakes to inform such subjects of personal information about the list of personal data that may be collected by providing a list of such data in the Privacy Policy and/or to provide an explanation of where Users can obtain such information if Users' personal data may be collected by third-party services (third parties), namely a link to the privacy policy of such third-party services.
8.3. The User, in exercising their rights and/or in case of questions regarding their rights, may contact the Administrator at the email address specified in the last section of the Privacy Policy.
8.3.1. The request shall specify:
8.3.1.1. Data of the applicant, the purpose, essence, and legal grounds for the request.
8.4. The Administrator is obliged to consider the User's request within a period not exceeding 45 calendar days from the date of receipt of the request. Depending on the complexity and number of requests, this period may be extended for three consecutive months, with the User being notified thereof.
8.5. If necessary, the Administrator may send an email to the User to obtain additional information to resolve their issue.
9.1. The Administrator may unilaterally change this Privacy Policy without prior notice to Users, except where required by law. The latest version of the policy is available at any time via the link.
The User is responsible for reviewing changes to the Privacy Policy and agreeing/disagreeing with them (by deleting the Mobile Application).
9.2. The User is responsible for updating the Mobile Application to the latest version.
To contact the Administrator, the User may send an email.
E-mail: appgameprograms@gmail.com