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Privacy Policy for SapienPlay Mobile Games

Original Effective Date: 10 February 2020

Last Updated: 06 July 2025

1. Introduction & Scope

Welcome to SapienPlay! This Privacy Policy describes how SAPIENPLAY LTD ("SapienPlay," "we," "us," or "our") collects, uses, stores, shares, and protects your personal information when you download, access, or play any of our mobile games (our "Services").

This policy is a legally binding agreement between you and SapienPlay. By using our Services, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy. If you do not agree with this policy, please do not install or use our Services.

2. About Us & Data Controller Information

For the purpose of the General Data Protection Regulation (GDPR) and the UK Data Protection Act 2018, the data controller is:

  • Company Name: SAPIEN PLAY LIMITED

  • Registered in: England and Wales

  • Company Number: 12450802

  • Registered Address: Flat 39, 2 Pilot Walk, Greenwich Peninsula, London SE10 0UD. UK

  • Contact Email for Data Protection: [email protected]

  • Website: https://www.sapienplay.com

3. The Data We Collect and How

We collect information in several different ways to provide and improve our Services.

3.1. Data You Provide to Us Directly

  • Contact Information: When you contact our player support via email or other channels, we collect your name, email address, and the content of your communications.

3.2. Data We Collect Automatically When You Use Our Services

  • Device and Technical Information:

    • Device model, operating system, and version.

    • Device identifiers (e.g., Device ID, Advertising ID such as IDFA for iOS and GAID for Android).

    • IP address and general location data derived from it (e.g., country, region).

    • Device language and mobile network information.

  • Gameplay and Usage Data:

    • Information about your game progress, levels, achievements, and in-game purchases.

    • Logs of your interactions with our Services, including session start/end times and features used.

    • Crash logs and performance data to identify and fix bugs.

  • Advertising Data:

    • Information on which advertisements are shown to you within our games.

    • Your interactions with those advertisements (e.g., clicks, views).

3.3. Data We Collect from Third-Party Partners

  • Advertising and Analytics Partners: We may receive information about you from our partners, such as data to help us serve more relevant ads or analytics data to understand how you interact with our Services.

  • Payment Processors: When you make an in-app purchase (e.g., through the Apple App Store or Google Play Store), we do not collect your financial information like credit card numbers. We receive a transaction receipt or confirmation from the store, which may include a transaction ID but not your payment details.

4. How and Why We Use Your Data (Our Lawful Bases)

We use your data for specific purposes and only where we have a legal basis to do so under data protection laws.

Purpose of Processing Data Used Lawful Basis (under GDPR/UK Law)

To operate and provide our Services

Device Info, Gameplay Data, Contact Info

Performance of a Contract: To deliver the game experience you have requested.

To improve and optimize our Services

Device Info, Gameplay Data, Crash Logs

Legitimate Interest: To fix bugs, analyze performance, and improve our games for our players.

To provide player support

Contact Info, Gameplay Data

Legitimate Interest: To respond to your queries and resolve issues.

To serve personalized advertising

Advertising ID, Device Info, Gameplay Data

Consent: We will request your consent (e.g., via an in-app pop-up) before processing data for personalized ads.

To serve non-personalized (contextual) ads

General Location, Game Context

Legitimate Interest: To fund our free-to-play games with advertising that is not based on your personal profile.

For security and fraud prevention

Device Info, IP Address, Gameplay Data

Legitimate Interest: To protect our Services, players, and intellectual property.

To comply with legal obligations

All relevant data as required

Legal Obligation: To comply with applicable laws and requests from regulatory bodies.

5. Data Sharing and Disclosures

We do not sell your personal data. We only share it with trusted partners who help us operate our Services, as described below.

  • Advertising Partners: We share technical and advertising identifiers with partners like Google AdMob, Unity Ads, and Meta to show advertisements in our games.

  • Analytics Providers: We use services like Google Analytics for Firebase and Unity Analytics to understand player behavior and improve our games.

  • Cloud Hosting Providers: We may use cloud services to store game data and support our backend infrastructure.

  • Legal Authorities: We may disclose your information if required by law, a court order, or a binding request from a governmental authority.

  • Business Transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred to the new entity.

6. Your Data Protection Rights

You have specific rights over your personal data. The rights available to you depend on your location.

6.1. Rights for Users in the UK and European Economic Area (EEA)

  • Right of Access: You can request a copy of the personal data we hold about you.

  • Right to Rectification: You can ask us to correct any inaccurate information.

  • Right to Erasure (Right to be Forgotten): You can request that we delete your personal data.

  • Right to Restrict Processing: You can ask us to temporarily halt the processing of your data in certain situations.

  • Right to Data Portability: You can request a copy of your data in a machine-readable format.

  • Right to Object: You can object to us processing your data for our legitimate interests.

  • Right to Withdraw Consent: Where we process data based on your consent (e.g., for personalized ads), you can withdraw that consent at any time.

To exercise these rights, please contact us at [email protected]. You also have the right to lodge a complaint with your local data protection authority (e.g., the Information Commissioner's Office (ICO) in the UK).

6.2. Rights for Users in California (CCPA/CPRA)

  • Right to Know: You can request to know the categories and specific pieces of personal information we have collected about you.

  • Right to Delete: You can request the deletion of your personal information.

  • Right to Opt-Out of Sale/Sharing: We do not "sell" personal data in the traditional sense. However, our use of advertising partners may be considered "sharing" under the CPRA. You can opt-out of this by using the "Limit Ad Tracking" or "Opt out of Ads Personalization" settings on your device.

  • Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

7. Children's Privacy

Our Services are not directed to or intended for use by children under the age of 13 (or the age of digital consent in your country). We do not knowingly collect personal information from children. If you are a parent or guardian and believe that we have inadvertently collected data from your child, please contact us immediately at [email protected] so we can take steps to delete it.

8. Data Security and Retention

We implement appropriate technical and organizational measures to protect your data from unauthorized access, loss, or misuse. We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including for legal, accounting, or reporting requirements.

9. International Data Transfers

Our Services are global, and your data may be processed on servers located outside of your home country. When we transfer data from the UK/EEA to other countries, we use legally-approved mechanisms like Standard Contractual Clauses to ensure your data is afforded a similar level of protection.

10. Changes to This Privacy Policy

We may update this policy from time to time to reflect changes in our practices or for legal reasons. We will post the updated policy on our website at https://www.sapienplay.com/mobile-game-privacy and update the "Last Updated" date at the top. We encourage you to review it periodically.

11. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your data, please contact us:

Email: [email protected]

Website: https://www.sapienplay.com