Privacy Policy

Last updated: 14 March 2022

This policy explains what Gummywolf Ltd ("Gummywolf", "we", "us") collects when you play our mobile games (the "Games") or use this website, why we collect it, who we share it with and the choices you have. Gummywolf Ltd, Spyrou Kyprianou 73, 2nd Floor, Office 203, Potamos Germasogeias, 4042 Limassol, Cyprus, is the data controller. Where a Game is distributed by a publishing partner, that partner may be a separate controller for the data it collects, and its own policy applies alongside this one.

1. Summary

• Our Games are free to play and funded by in-game advertising and optional in-app purchases.
• We collect device identifiers, technical data and gameplay data automatically, and support or account data when you give it to us.
• Advertising, analytics and attribution partners receive some of this data through software development kits (SDKs) built into the Games.
• You can limit personalised advertising in the Game settings and in your device settings at any time.
• We do not knowingly collect data from children, and we do not collect precise location.

2. Information we collect

2.1 Information you give us

• Account data. If you sign in with Apple, Google Play Games or a publisher account, we receive the identifier and display name that service provides. Signing in is optional and is used to save progress across devices.
• Support data. Messages you send us, your email address if you email us, and the Support ID and device details attached by the in-game support option.
• Purchase data. Records of in-app purchases as reported by the app store you bought through: product, price, currency, date and an order identifier. We never receive your payment card details.

2.2 Information collected automatically

• Device identifiers. The mobile advertising identifier (IDFA on iOS, where you have allowed tracking; Google Advertising ID on Android), a vendor identifier and a random installation identifier we generate.
• Technical data. Device model and manufacturer, operating system and version, language, time zone, screen size, memory, network type, mobile carrier, IP address, app version and crash logs.
• Gameplay data. Sessions and their length, levels played and completed, in-game events, progression, virtual currency balances and spending, settings, and whether you watched or skipped rewarded advertising.
• Advertising data. Which advertisements were shown, viewed and clicked, and the identifiers above.
• Attribution data. The campaign, network or store listing that led you to install the Game, and post-install events used to measure that campaign.

We derive an approximate location (country and region) from your IP address to show the right content, currency and legal notices. We do not collect precise location data.

3. How we use information

• To run the Games, save and restore progress, deliver purchases and provide support (performance of a contract).
• To fix bugs, balance difficulty, measure performance and understand how the Games are used (legitimate interests).
• To show advertising that funds the Games, including personalised advertising where you have consented (consent) and non-personalised advertising otherwise (legitimate interests).
• To measure marketing campaigns and attribute installs (legitimate interests).
• To detect cheating, fraud and abuse and to keep the Games secure (legitimate interests).
• To comply with tax, accounting and other legal obligations (legal obligation).
• To send push notifications about the Games, where you have enabled them on your device (consent, withdrawable in your device settings).

4. Advertising, analytics and attribution partners

The Games include SDKs from third-party companies that show and measure advertising, collect analytics and attribute installs. These partners receive device identifiers, technical data and event data directly from your device. Some of them act as independent controllers and use the data in accordance with their own privacy policies. The partners used by a specific Game are listed in that Game's settings under Privacy. The partners we work with across our Games are:

Your advertising choices

• In the Game. Settings, Privacy, "Personalised ads" lets you withdraw consent at any time. You will still see advertising, but it will not be personalised.
• iOS. When a Game first asks, choose "Ask App Not to Track" to withhold the IDFA. You can change this later under Settings, Privacy & Security, Tracking.
• Android. Under Settings, Google, Ads you can opt out of ads personalisation or delete your advertising ID.
• Industry tools. Many advertising partners also honour the opt-outs at optout.networkadvertising.org and youradchoices.com.

5. Who we share information with

• The advertising, analytics and attribution partners listed above.
• Service providers that host our servers, store backups, send email and provide support tooling, in each case only as needed to provide the service to us and under contract.
• Publishing partners that distribute a Game in a given region, for the purposes described in that Game's store listing and the partner's policy.
• Authorities, courts or professional advisers where the law requires it or to establish, exercise or defend legal claims.
• A buyer or successor if Gummywolf or a Game is sold or merged, under this policy.

We do not sell personal information for money. Sharing device identifiers with advertising partners may count as a "sale" or "sharing" under some state laws; see section 9 for how to opt out.

6. International transfers

We are based in Cyprus, in the European Economic Area. Some partners and service providers process data in the United States and other countries. Where data leaves the EEA we rely on the European Commission's standard contractual clauses or an adequacy decision, and we require our providers to protect the data to the same standard.

7. How long we keep information

• Gameplay and account data: while you play the Game and for up to 24 months after your last session, then deleted or anonymised.
• Advertising identifiers and advertising event data: no longer than 12 months.
• Analytics data: up to 26 months, then aggregated.
• Support correspondence: 24 months after the ticket is closed.
• Purchase records: as long as tax and accounting law requires, usually 7 years.

8. Children

The Games are not directed at children under 13, and we do not knowingly collect personal data from them. In the EEA and the United Kingdom, players under 16 are not shown personalised advertising and cannot sign in. Where a Game asks for your age, that answer is stored on the device only. If you believe a child has provided us with personal data, contact us and we will delete it.

9. Your rights

European Economic Area and United Kingdom. You may request access to, rectification or erasure of your personal data, restriction of or objection to processing, and portability, and you may withdraw consent at any time without affecting earlier processing. You may lodge a complaint with the Office of the Commissioner for Personal Data Protection in Cyprus or with your local supervisory authority.

California. Under the California Consumer Privacy Act you may request the categories and specific pieces of personal information we have collected, ask us to delete it, and opt out of the "sale" or "sharing" of personal information. We do not sell personal information for money and we do not use or disclose sensitive personal information. To opt out of sharing for advertising, use the choices in section 4 or email us. We will not discriminate against you for exercising your rights. We do not respond to browser "Do Not Track" signals.

Brazil. Under the Lei Geral de Proteção de Dados you have equivalent rights of access, correction, deletion, portability and information about sharing.

To exercise any right, use Delete account or Privacy in the Game settings, or email privacy@gummywolf.com with your Support ID so that we can find your data. We answer within 30 days and may ask you to verify the request.

10. Security

Data is transmitted over encrypted connections and stored with access limited to staff and providers who need it. No system is completely secure; if a breach affects you, we will notify you and the relevant authority as the law requires.

11. This website

gummywolf.com does not use cookies, analytics or tracking of any kind and collects no personal data. Email you send to us is handled as support data under this policy.

12. Changes

We will post changes on this page and update the date above. For material changes we will also notify you in the Games.

13. Contact

Gummywolf Ltd
Spyrou Kyprianou 73, 2nd Floor, Office 203
Potamos Germasogeias
4042 Limassol, Cyprus
privacy@gummywolf.com