XAMVER GAMES PRIVACY POLICY

Last update: 12.05.2025

Welcome to the privacy policy of Xamver Games!

First of all, thank you for playing our games!

This document describes how and why Xamver Games collects and processes your personal data (the “Data”) when you interact with our mobile games (the “Games”) or our xamver.games website (the “Website”). Hereinafter, we refer to both the Games and the Website as the “Services”.

We act as a data controller for the processing of personal data under applicable privacy laws, including the General Data Protection Regulation („GDPR”).

Please note that this policy only applies to information collected and/or processed received by Xamver Games through your use of the Services.

If you have any questions, feel free to contact us at hello@xamver.games

1. Who we are

Xamver Games and its affiliated companies („Xamver Games „, „we”, „our”, „us”) develop and publish mobile games and operate related websites and services (collectively, the „Services”).

Xamver Games is a Polish company incorporated under national judicial register (KRS) 0001075834 with the Trade and Commerce registries of Gdańsk and having its main place of business located at Nowomiejska 3, 80-864 Gdańsk.

2. Our Games

2.1 Why do we collect or use your Data

When you install and play Xamver Games games, we can collect and process some of your Data based on your express consent or for different purposes.

In cases in which Xamver Games is a data “controller” (meaning, when Xamver Games is the main decision-maker, exercising overall control over the purposes and means of the processing of your Data), Xamver Games only uses your Data with a legal basis for doing so, such as:

– for the performance of our contract with you;

– where you have given your consent for a specific purpose;

– to comply with our own legal and regulatory obligations;

– for our legitimate interests or those of a third party.

A legitimate interest happens when we have a business or commercial reason to use your personal information and includes our own interests or the interests of third parties, and can cover commercial interests (e.g. sustain our free-to-play model), so long as this is not overridden by your own rights and interests.

In cases we are required under law or regulation to obtain your consent for the processing of your personal information, we will ask for your consent.

Here’s why Xamver Games may collect your personal information and the legal basis we rely on in each case :

• To provide and operate our Games: Contractual Necessity
• To show personalized ads, based on your preferences and interests : Consent
• To gather and provide third-party analytics, i.e. data collected through our applications may be shared with third-party partners that provide Xamver Games with analytics services : Consent
• To gather first party analytics, i.e. Data collected through our applications may be used for the purposes of Xamver Games internal analytics tool ›› to understand how users interact with our applications to continuously improve them. This Data is not shared with third party partners : Legitimate interest
• Attribution, i.e. match an advertisement of one of our Games you may have seen in another application with the install of such Game : Legitimate interest
• To ensure the functionalities of our applications (for instance, debug, maintain the apps) : Legitimate interest

For all data processing activities that rely on users’ consent, you can always change your preferences and withdraw your consent in the privacy settings of any of our applications.

Note that, if you opt-out, you will still be able to see ads in our applications and some of our partners may still serve ads to you.

2.2. Data we collect

When you use any of Xamver Games applications on a mobile platform and, for the above specific purposes, we may collect and process (store, share with our partners, process for analytics purposes) the following Data strictly for the purposes identified above:

1. Data that you provide to Xamver Games directly

• Your profile information, which can include your player name or tag;
• Any content you submit while using our Games, including Data collected during your discussions with our customer support channels (for instance, Data included in your support requests);
• Data you provide in connection with promotional operations, surveys, competitions, sweepstakes or other events.

2. Data collected automatically by Xamver Games

• Data about your player account, game progress, which includes a unique internal ID;
• Data pertaining to your activities in game and the way you interact with our apps (for instance, gameplay data, total play time, how and when you use our applications, your level in game…);
• Data about your purchases in our Games, excluding any payment/credit card information;
• Identifiers, such as your mobile device identifiers, advertising ID, Adjust ID…;
• Your location at a city/region level (based on your Internet Protocol – “IP” – address);
• Technical information about the device you use and your connection (for instance, the operating system, device model, type of connection, language, timezone);
• Technical data pertaining to the app you’re using (for instance, the app version you’ve installed);
• Data pertaining to the advertising served in our applications (for instance, number of ads you’ve clicked on, purchase time, quantity of IAP you’ve purchased).

2.3. How is your Data collected

Most of the personal information we process via our Games comes directly from you.

In addition, we may also collect personal information:

• from our business partners SDK’s, as outlined below;
• from any other third party to whom you have given your consent.

2.4. With whom may we share your Data

When you consent to the collection of Data for advertising and third party analytics purposes, we may share the data listed above with the following categories of recipients.

1. a) Advertising networks and Attribution

To provide users with free-to-play Games, we are working with third parties to (i) advertise our Games on different networks and other applications and (ii) monetize our Games via advertising revenue (we insert ads in our apps) and in-app purchases. 

These third parties generally collect user and device-related Data via their own SDKs (Software Development Kit), notably for attribution purposes. For example, you may see our Games advertised in other apps. After clicking on one of these advertisements and installing our Game, you will become a user of our Services. In order to verify the installs, a device identifier may be shared with our attribution partner to ‘match’ the advertisement with your install: this is what we call the “mobile attribution”. 

The privacy policies of our partners may include additional terms and disclosures regarding their data collection and tracking technologies. We encourage you to check those privacy policies to learn more about practices and exercise your rights directly towards them: 

AdColony https://www.adcolony.com/consumer-privacy/

Adjust https://www.adjust.com/fr/terms/privacy-policy/

Adnet.qq https://www.qq.com/yszc-en.htm

Appier https://www.appier.com/privacy-policy/

Apple Search Ads https://searchads.apple.com/fr/privacy/

AppLovin https://searchads.apple.com/fr/privacy/

Bidmachine https://bidmachine.io/privacy-policy/

Chartboost https://answers.chartboost.com/en-us/articles/200780269

Digital Turbine https://www.hubsupport.center/privacypolicy/

Facebook https://www.facebook.com/policy.php

Fyber https://www.fyber.com/privacy-policy/

Google AdMob https://policies.google.com/privacy

Google Ads https://privacy.google.com/businesses/adsservices/

Helpshift https://www.helpshift.com/legal/privacy/

InMobi https://www.inmobi.com/privacy-policy/ https://www.inmobi.com/privacy-policy-for-eea/

IronSource https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/

Jetfuel https://www.jetfuel.it/privacy

Liftoff https://liftoff.io/privacy-policy/

Mintegral https://www.mintegral.com/en/privacy/

MoPub https://www.mopub.com/en/legal/privacy

MyTarget https://legal.my.com/us/mytarget/privacy/

Nativex https://legal.my.com/us/mytarget/privacy/

Ogury https://ogury.com/privacy-policy/

Pangle https://www.pangleglobal.com/privacy/enduser-en

CSJ https://www.csjplatform.com/en/policy-center 

ShareIt https://cdn.ushareit.com/shareit/w/privacy/pr_en/index.html

Snap https://www.snap.com/en-US/privacy/privacy-policy

TapJoy https://www.tapjoy.com/legal/general/privacy-policy/ 

TikTok https://ads.tiktok.com/i18n/official/policy/privacy 

Unity Ads https://unity3d.com/legal/privacy-policy

Verizon Media https://legal.yahoo.com/ie/en/yahoo/privacy/index.html 

Vungle https://vungle.com/privacy/

1. b) Analytics partners

These partners provide us with tools and technologies that allow us to better understand how users interact with our Games and will help us improve it:

Adjust https://www.adjust.com/fr/terms/privacy-policy/
GameAnalytics https://gameanalytics.com/privacy/

1. c) Storage / Servers

Xamver Games is relying on either AWS or GCP to store the Data we collect via our apps :
Amazon Web Services https://aws.amazon.com/fr/privacy/ 
Google Cloud Platform https://cloud.google.com/terms/cloud-privacy-notice

In addition to the other disclosures described in this Privacy Policy, we will also share your information:

– as is necessary to comply with any legal obligation;
– if there is a sale of the assets of Xamver Games or corporate restructuring, or as a result of a change of control of Xamver Games, or in preparation of any of these events. Any third party to which Xamver Games transfers or sells Xamver Games assets will have the right to continue to use the Data that you provide to us in the manner set out in this Privacy Policy.

1. d) Payment processors

We rely on different payment processors for our Games, depending on your device type (Google if it runs with Android, Apple AppStore Payments if it runs with iOS).

Please refer to their respective privacy policies and terms:

• Google https://policies.google.com/privacy
• Apple: https://www.apple.com/legal/privacy/

2.5. How long do we keep your Data

We keep the Data collected and processed for the purposes described in this policy only as long as necessary.

We will also retain and use your information for as long as is required in order to comply with our legal obligations.

2.6. Our policy regarding children

You must be over a certain age to play our Games and use our Services, depending on where you live. For the list of age restrictions by country, you can refer to this page published by the European Union Agency for Fundamental Rights.

We do not knowingly or willingly collect or solicit personal information from anyone under the applicable age, or knowingly allow such persons to use our Services.

If you are under the legal age in your country, please do not play our Games or use our Services.

In the event that we learn that we have collected personal information from children under the legal age, we will delete that information as quickly as possible. If you believe that we might have any information from or about children under the legal age please contact us at hello@xamver.games

2.7. Data storage and International transfers

We store our Data on servers located in Europe via Amazon Web Services or Google Cloud Platform.

To deliver Services to you, it is sometimes necessary for us to share your Data outside of your country or region, e.g.:

– with our offices and group companies;
– with our service providers.

We may therefore transfer information that we collect about you to our third-party partners across borders, including outside of the European Economic Area (the “EEA”).

Please note that these countries outside of the EEA may not have the same data protection laws as your own jurisdiction. We take steps to ensure that there are adequate safeguards and mechanisms in place (including the use of EU Standard Contractual Clauses) to allow the transfer of your information outside of the EEA.

We also make sure any third parties we share information with have an adequate transfer mechanism in place, as well.

2.8. Security

We take appropriate security and technical measures to protect your information from unauthorised access, loss and misuse.

In addition, we request that our suppliers who process personal information on our behalf take a range of security measures designed to help protect your personal information and maintain an appropriate level of security.

3. Our Website

When you visit our xamver.games Website, here are the information that we may collect and process :

– browsing events and interactions with the Website’s contents and services (for instance, operating system, IP address access times, browser type and language);
– information that you provide us with when you fill in forms on our Website;
– if you contact us or respond to messages and communications that we send to you, we may keep a record of that correspondence;
– your interactions with us on our social media channels;
– information we collect via cookies and other similar technologies. For more information, see the “Cookies” section below.

We, or our partners may use these information:

– to operate and optimize the Website;
– to contact you, for example to send you updates about our Games or the Website;
– for the purposes of research, surveying, and engaging with you, for example by sending you communications (including by email) for these purposes.

If you no longer wish to receive these emails, you may opt-out from receiving them at any time by emailing us at hello@xamver.games

Cookies

The website uses cookies.

We would like to inform you that we use cookies on our websites, i.e. computer files to record information about which pages you have visited and what you have done on them.

Cookies are simply pieces of information stored by your browser. Thanks to cookies, websites remember your preferences and settings, such as the city setting in the weather forecast. Cookies do not allow personal data to be identified. A cookie does not even have the slightest effect on your software and hardware. These cookies are used for the following purposes:

Authentication – primarily to identify the logged-in user in order, for example, to display the right information to him/her, corresponding to his/her interests;

Security – necessary to support security mechanisms on the website, e.g. to protect against data leakage;

Research and analysis – We may use cookies to research and analyse the performance of the website and mobile applications. This is also used to improve their performance.

We may use the popular Google Analytics software, in which case the website places a special code on your computer to collect data. However, you can disable data collection by Google Analytics software at any time by changing your browser settings accordingly.

Please be advised that web browsers usually allow users to control cookies in the settings. Restricting cookies in these settings may result in a decrease in the quality of the website’s performance.

4. Your choices and rights

Under data protection law, you have certain rights in connection with your personal information and how we handle it. You can exercise these rights at any time by contacting us at hello@xamver.games :

– Right of access. You have the right to know what information we hold about you and in some cases to have the information communicated to you. If you wish to exercise this right please contact us letting us know that you wish to exercise your right of access and what information in particular you would like to receive. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information.
– Right to rectification. You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
– Right to erasure. You have the right to ask us to erase your personal information in certain circumstances. 
You can contact us, as indicated in the “Contact” section below, in order to have the data previously collected by Xamver Games on you and/or your device permanently erased.
In addition, in order for your data not to be collected anymore (for the future), you can, in the following order: 

• Activate “Limit Ad Tracking” (LAT) in your device settings to opt-out of having an ID for Advertisers and don’t see specific ads targeted at you; and
• Desinstall our Games; and
• Reinstall our Games.

Where we delete personal information about you, we may still retain some or all of that information for other purposes such as maintaining financial records, protecting or enforcing legal rights. We may also retain your information in an anonymised form.
– Right to restrict processing. In some cases, you may have the right to request a restriction of the processing of your personal data, such as when you are disputing the accuracy of your data held by us.
– Right to data portability. When the processing of your personal data is based on consent or contract, you may have the right to request that personal data that you have provided to us is provided to another data controller of your choice in a portable format.
– Right to object to processing. You have the right to object to the processing of personal data about you which is processed on the grounds of legitimate interests.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. 
Please contact us at hello@xamver.games 

If you’re a user under CCPA or other US state laws

In order to comply with CCPA or other US state laws, this paragraph aims at disclosing the mandatory information.

Sharing and Selling of Personal Data

We may share your data with third-party service providers such as:

• Advertising networks
• Analytics providers
• Attribution platforms

Under the CCPA, „selling” includes disclosing personal data for monetary or other valuable consideration. While we do not sell your personal data in the traditional sense, some of our ad partners may process data in a way that qualifies as a „sale” under the CCPA.

We share data with our partners for advertising and analytics, subject to appropriate safeguards. You have the right to opt-out of such selling and sharing.

5. Contact Information

You may exercise your rights in the Games or by contacting us at:

Email: hello@xamver.games

Postal Address:

Xamver Games 

Nowomiejska 3

80-864 Gdańsk

We will respond within the timelines prescribed by applicable law. Identity verification may be required.

If you have any questions about this Privacy Policy, please contact us at hello@xamver.games

6. Information about data collection

When you install and use Xamver Games mobile applications, we can collect and process some of your data for different legitimate purposes. You will find below explanations regarding the reasons why we may collect data. Why is data collected? Xamver Games and its third-party partners collect data:

• To provide you with the services you asked for

• To run analytics and understand how users interact with our product and services to improve them continuously The third-party partners that Xamver Games will share the data with are:

• GameAnalytics
• Facebook Analytics
• Adjust
• Voodoo

Data deletion requests

To delete user data collected by Xamver Games, please reach out to hello@xamver.games

If you also want to request the deletion of the data that may have been collected about you or your device by our third-party partners that are acting as independent data controllers, you will find below the contact for each partner and the link to the relevant section of their privacy policies:

• GameAnalytics:

• email: privacy@gameanalytics.com
• privacy policy: https://gameanalytics.com/privacy/#6-changing-or-deleting-your-information

• Facebook Analytics:

• email: none, please refer to the privacy policy
• privacy policy: https://www.facebook.com/policy.php

• Adjust:

• email: privacy@adjust.com
• privacy policy: https://www.adjust.com/terms/privacy-policy/

• Voodoo:

• Voodoo does not collect any of your personal data and only provides an SDK package to retrieve the data collected by the above-mentioned partners. You can still contact them to request the deletion of their access to the partners’ interfaces.
• email: dpo@voodoo.io