PRIVACY POLICY

Last Updated: October 29, 2024

Procedural Games ("we", "us", "our") respects the privacy of our users ("user", or "you"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile games and related services (together Games, Services).

For the purpose of this Policy, "Information" means any information relating to an identified or identifiable individual. When you use the Mobile Games, you accept our rules and policies which set out how we handle your Information, and you understand that we collect, process, use and store your Information as described in this Policy. If you do not agree with this Policy, you must not play any of the Games. If you change your mind in the future, you must stop playing the Games and you may exercise your rights in relation to your Information as set out in this Policy.

The data controller is Procedural Games S.L., a company legally registered in Spain.

1. INFORMATION WE COLLECT

1.1 Information you provide to us

• Customer support information when you contact us
• Survey responses if you choose to participate

1.2 Information automatically collected

• Device identifiers: IP address, device ID, advertising ID
• Game data: gameplay statistics, progress, achievements
• Technical data: device model, operating system, language settings
• Location data at the country level for compliance and localization
• Information regarding your use of the Games, such as date and time stamps of game events, interactions with our teams and ad engagement, and transaction records, or evidence of you using cheating software or using modified versions of the Games.

1.3 Information from third parties

• Advertising partners (AppLovin, ironSource, Unity Ads): ad interactions, device identifiers
• Payment processors: transaction data

2. HOW WE USE YOUR INFORMATION

We share your Information with selected third parties, including:

• Vendors and service providers we rely on for the provision of the Games, for example:
  • Cloud service providers who rely on for data storage, including Amazon Web Services who are based in the U.S.;
  • Customer support solution providers, who help us manage and respond to our customer questions and complaints;
  • Analytics providers. We work with a number of analytics, segmentation and mobile measurement service providers who help us understand our userbase. This includes, but not limited to, Unity Technologies who are based in the US;
  • User acquisition: We work with a variety of user acquisition partners to help us report on the success of our marketing campaigns. We may use some of your personal information to participate in Custom Audience and Lookalike Audience programs, which enable us to display ads to both existing and prospective supporters when they visit one of our partners’ websites. We may provide an identifier (i.e. your Advertising ID or Facebook ID) to them so they can determine whether you are a registered account holder with them. Our ads may then appear when you access their websites.
• Advertising partners. We are an ad-supported service. Subject to your settings, we provide certain Information to advertisers who will use them to serve you with ads in our Games, and we measure who sees and clicks on their ads. We also share advertising identifiers, along with the interests or other characteristics of a device or the person using it, to help partners decide whether to serve an ad to that device or to enable them to conduct marketing, brand analysis, personalize advertising, or similar activities.
• Payment processors: For Mobile Games, we may use payment processors such as Google (if you run Android on your mobile device), Apple App Store payments (if you run IOS on your mobile device).
• Law enforcement agencies, public authorities or other judicial bodies and organizations. We disclose Information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to comply with a legal obligation, process or request; enforce our terms of service and other agreements, policies, and standards, including investigation of any potential violation thereof; detect, prevent or otherwise address security, fraud or technical issues; or protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organizations for the purposes of fraud protection).
• Change of corporate ownership. If we are involved in a merger, acquisition, bankruptcy, reorganization, partnership, asset sale or other transaction, we may disclose your Information as part of that transaction.

Legal bases for processing (EU/EEA users):

• Performance of contract
• Legal obligations
• Legitimate interests
• Consent (for certain data uses, especially regarding children)

3. ADVERTISING

We work with the following advertising partners:

• AppLovin (Privacy Policy)
• ironSource/LevelPlay (Privacy Policy)
• Unity Ads (Privacy Policy)

To opt out of personalized advertising:

• iOS: Settings > Privacy > Tracking > Disable «Allow Apps to Request to Track»
• Android: Settings > Google > Ads > Opt out of Ads Personalization

4. YOUR RIGHTS AND CHOICES

Under GDPR and other applicable laws, you have the right to:

• Access your personal data
• Correct inaccurate data
• Request deletion of your data
• Object to data processing
• Data portability
• Withdraw consent
• Lodge complaints with supervisory authorities

Contact games@proceduralgames.com to exercise these rights.

5. DATA RETENTION AND SECURITY

We retain your data only as long as necessary for the purposes described in this policy or as required by law. Although we have in place security measures to maintain the privacy and integrity of your Information, unfortunately, the transmission of Information via the internet is not completely secure. We may also take extra steps to protect your Information and minimize the Information we process.

6. INTERNATIONAL DATA TRANSFERS

We may transfer your data to countries outside the EEA. When we do, we ensure appropriate safeguards are in place through:

• EU Standard Contractual Clauses
• Adequacy decisions
• Other legal mechanisms as required

7. CHANGES TO THIS POLICY

We may update this Privacy Policy. We will notify you of any material changes through:

• App Store or Google Play policy links
• Notice on our website

8. CONTACT US

For any questions about this Privacy Policy or our data practices: Email: games@proceduralgames.com

9. SPECIFIC REGIONAL RIGHTS

California Residents (CCPA/CPRA)

You have specific rights under California law, including:

• Right to know what personal information is collected
• Right to delete personal information
• Right to opt-out of the sale of personal information
• Right to non-discrimination

European Economic Area (GDPR)

Additional rights include:

• Right to restrict processing
• Right to object to automated decision-making
• Right to lodge complaints with supervisory authorities

For any data protection inquiries, contact us at games@proceduralgames.com