Privacy Policy

Effective date:Draft — set on public launch

This Privacy Policy explains how G7 Game Studios collects, uses, and shares information when you play our mobile games or contact us about them. It covers every mobile game we publish, including titles in testing and titles offered to the public.

Contents

• Who we are
• Information collected
• How it is used
• Third parties and SDKs
• Advertising and in-app purchases
• Children's privacy
• Data retention
• User rights
• International transfers
• Security
• Changes to the policy
• Contact

Who we are

G7 Game Studios is the brand and publisher name for our mobile games. The publisher is G7 Game Studios LLC, a Texas limited liability company. In this policy, "G7 Game Studios," "we," "us," and "our" mean G7 Game Studios LLC.

We publish casual mobile games for iOS, through the Apple App Store, and for Android, through Google Play. You do not need to create an account with us to play.

G7 Game Studios LLC is the controller of personal information for which we decide the purposes and means, including gameplay analytics that we configure. Apple and Google are separate controllers for information they collect through their stores, device accounts, and payment services.

This policy applies to our games and to email you send us about them. It does not apply to the Apple App Store, Google Play, or other services that we do not operate. Those companies describe their practices in their own privacy policies.

The web page that displays this policy does not set cookies and does not load advertising or analytics scripts.

In this policy, "personal information" means information that identifies, relates to, or could reasonably be linked with a person or with a device associated with a person. The term includes "personal data" under the EU General Data Protection Regulation (GDPR) and the UK GDPR.

We have not appointed a data protection officer. We have not appointed a European Union or United Kingdom representative. Send privacy requests to the email address in Contact.

Information collected

What we collect depends on the game, the features you use, and your device settings.

Information you provide

If you email us, we receive your email address, the content of your message, and any details you choose to include, such as a game name, a device model, or a store order reference.

We do not ask you to create a player account, username, or password. We do not ask you to enter your legal name, postal address, or payment card number in the game.

Information collected automatically

When you play a game, we and our service providers may automatically collect:

• Device and application data, including device model, operating-system name and version, language, time zone, app version, and whether the device is on a mobile network or Wi-Fi.
• Identifiers for the installation or the device, including an identifier created by the game or by an analytics software development kit (SDK). If your device settings allow it, this may include an advertising identifier (Apple's Identifier for Advertisers, or the Android advertising ID).
• Gameplay analytics, including session timing, game events, feature use, and progress.
• Crash and diagnostic data, including crash logs, error reports, and basic device state at the time of a failure.
• Coarse location, such as country or region, inferred from an IP address, and the IP address itself where an SDK records it.

We do not collect player account credentials, payment card numbers, precise GPS location, contact lists, photos, microphone audio, or camera images through our games. The games are not written to request those permissions.

Purchase records

If you make an optional in-app purchase, Apple or Google processes the payment. We may receive a product identifier, a transaction or order identifier, the time of the transaction, and the status of the purchase or restore. We do not receive your full payment card number, card security code, or full payment-account details.

How it is used

We use personal information for the purposes below. If we need to use it for a purpose that is incompatible with those purposes, we will give any further notice the law requires and, where the law requires it, we will identify a further legal basis.

Purposes

• To operate the game, including unlocking and restoring items you purchase through Apple or Google.
• To understand how the game is played, to measure reliability, and to improve content, features, and performance.
• To diagnose and fix crashes and other technical errors.
• To answer support and privacy requests, including requests to delete information.
• To protect players and the games against fraud, abuse, and security incidents.
• To meet legal duties, respond to lawful requests, and keep records we are required to keep.
• If a game shows advertising, to deliver ads, measure their performance, and honor the choices you make about personalized ads.

We do not use personal information for automated decisions that produce legal effects, or similarly significant effects, about you.

If you stop playing

You may stop further collection from a device by uninstalling the game. You may also use the device settings described in Advertising and in-app purchases. Uninstalling the game does not erase information already stored by us or by our service providers. You may request deletion as described in User rights.

Legal bases

Where the GDPR, the UK GDPR, or a similar law applies, we rely on the following bases:

• Contract. We process information that is needed to provide the game you choose to play and to complete a purchase you request through a store.
• Legitimate interests. We process information to keep the games secure and working, to understand gameplay, and to fix crashes, where those interests are not overridden by your interests or rights. You may object as described in User rights.
• Consent. Where the law requires consent, including for personalized advertising and for certain analytics or device tracking, we ask for it before that processing begins. You may withdraw consent at any time. Withdrawal does not affect processing that took place before the withdrawal.
• Legal obligation. We process information where the law requires us to retain or disclose it.

Third parties and SDKs

We use third-party services to distribute the games, to understand gameplay, to diagnose crashes, and, where a title includes them, to show ads or complete purchases. A provider may process information on our instructions, or it may act as an independent controller for its own purposes, as described in its privacy notice.

Analytics

We may include analytics SDKs in our games. These may include Unity Analytics and other Unity Gaming Services offered by Unity Technologies and its affiliates. An analytics SDK may collect the device, identifier, and gameplay information described in Information collected. Unity describes its practices in its Game Player and App User Privacy Policy.

Crash reporting

We may include a crash-reporting SDK. That SDK may be provided through Unity Gaming Services or by a comparable provider. It may collect crash logs and diagnostic data.

Stores and payments

Apple Inc. and Google LLC, and their affiliates, distribute our games and process in-app payments. Information they collect when you use an Apple ID, a Google account, the App Store, or Google Play is governed by their policies:

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

Advertising SDKs

We may add advertising SDKs to free titles. An advertising SDK may receive advertising identifiers, device data, coarse location, and information about ads shown and ads selected, according to your device settings and any consent we request. Before an advertising SDK begins collecting information in a game, we will name that provider in this policy or in that game's store listing. This policy does not name a current advertising partner. It covers our games as a group, including games that do not show ads.

Other disclosures

People acting for G7 Game Studios LLC may read mail sent to info@g7gamestudios.com so they can respond to it and handle the requests described in this policy.

We may disclose information to professional advisers who are bound to confidentiality, and to authorities or other parties when we believe in good faith that disclosure is required by law or legal process, or is necessary to protect the rights, safety, or security of players, the public, or us.

In connection with a merger, acquisition, or transfer of our business or assets, personal information may be transferred to a successor. We will require the successor to honor the privacy commitments that applied when the information was collected, including our commitment not to sell personal information. We will provide any notice and obtain any consent required by applicable law.

G7 Game Studios LLC does not and will not sell personal information.

Advertising and in-app purchases

Advertising

A game does not have to show ads in order to be played. We may offer free games that include third-party advertising. When a game includes advertising, we do the following:

• Where the law or the platform requires consent, we request consent before advertising or tracking SDKs collect information for personalized advertising. This includes consent required by the GDPR and the UK GDPR, and permission under Apple's App Tracking Transparency framework.
• You may decline or withdraw that consent and still play the game. Ads, if the game shows them, may then be less relevant or limited.
• On iOS, you can control app tracking in the system privacy settings. On Android, you can delete or reset the advertising ID and adjust ad personalization in the system settings.
• We apply the limits in Children's privacy to advertising in our games.

In-app purchases

Some games offer optional digital goods or features for purchase. Apple or Google processes the payment under that store's terms. We do not receive or store your payment card data. We use the store's confirmation of the purchase to provide or restore the item. Refund requests are handled by Apple or Google under the store's rules.

Children's privacy

Our games are general-audience games. They are not directed to children under 13.

We do not knowingly collect personal information from children under 13. Our children's-privacy practices are aligned with the Children's Online Privacy Protection Act (COPPA) and with the expectations of the Google Play Families policy. We do not knowingly use personal information from a child under 13 for advertising, profiling, or analytics. If we offer a title in a way that makes the Google Play Families policy apply to that title, we will meet that policy's limits on advertising, SDKs, and data collection for that title.

Request from a parent or guardian

If you are a parent or guardian and you believe that a child under 13 has provided personal information to us, email info@g7gamestudios.com with the subject line "Child privacy request." Include the name of the game, whether it was installed from the Apple App Store or Google Play, and any detail that will help us find the information, such as an approximate date and a device model. We may take reasonable steps to confirm that you are the child's parent or guardian.

After we locate the information, we will delete it from our records and direct our service providers to delete it. We may keep a limited record of the request where the law allows that record. We will respond within the time required by applicable law.

Data retention

We keep personal information only for as long as we need it for the purposes in this policy, unless the law requires a longer period.

• We retain analytics and crash information for up to 24 months after collection, and we then delete it or de-identify it. Service providers processing personal information on our behalf must follow our retention and deletion instructions, subject to applicable legal requirements. Third parties that act as independent controllers, such as Apple and Google for information collected through their stores, retain that information under their own privacy policies, described in Third parties and SDKs.
• We retain support messages and privacy requests for up to 24 months after the matter is closed, unless we need them longer to establish, exercise, or defend a legal claim.
• We retain store transaction identifiers that we hold, such as product and transaction identifiers, for as long as needed to restore purchases and to meet accounting and tax duties. That period is not expected to exceed 7 years. These records do not include payment card numbers.

When you request deletion, we delete or de-identify the personal information we control and can associate with the request. We may retain information that we must keep for a legal duty, to complete a store transaction you requested, or to establish, exercise, or defend legal claims. Copies may remain in routine backups until the backup cycle overwrites them.

User rights

Your rights depend on where you live and on whether a particular statute applies to us. A right described below applies to the extent the relevant law applies to G7 Game Studios LLC and to the information at issue. These descriptions are general.

We do not discriminate against you for exercising a privacy right. We do not offer money or a different price in exchange for personal information.

How to submit a request

Email info@g7gamestudios.com. Because we do not create player accounts, there is no in-game account to delete. You may still request access, correction, or deletion of personal information we hold about you.

Include the game name, the store you used (Apple App Store or Google Play), your device type, and the email address you are writing from, so we can search for matching records. We will not ask you for a payment card number. We may ask for additional information that is reasonably necessary to verify the request. If we cannot reasonably link stored analytics records to you, we will tell you what we were able to do and what we could not locate.

An authorized agent may submit a request where the law allows it. We may ask for proof of the agent's authority and for verification of the person who is the subject of the request.

If we deny a request and the applicable law provides an appeal, you may appeal by replying to our decision email. If we deny the appeal and the statute requires it, we will tell you how to contact the relevant authority.

EEA and the United Kingdom

If the GDPR or the UK GDPR applies, you have the right to request access, correction, deletion, and restriction, and to receive a portable copy of personal data you provided to us. You may object to processing based on legitimate interests, including analytics and crash reporting that we base on that ground. You may withdraw consent where we rely on consent.

You may lodge a complaint with a supervisory authority in your country of residence, place of work, or the place of an alleged infringement. In the United Kingdom, the supervisory authority is the Information Commissioner's Office: https://ico.org.uk. We welcome the opportunity to address your concerns directly. You may also contact the relevant supervisory authority without first contacting us.

California (CCPA/CPRA)

If the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA), applies, a California resident may request that we:

• Disclose the categories and specific pieces of personal information we collected, the categories of sources, the business or commercial purposes, and the categories of third parties to whom we disclosed it.
• Delete personal information, subject to the exceptions in the statute.
• Correct inaccurate personal information.
• Opt out of the sale or sharing of personal information.

G7 Game Studios LLC does not and will not sell personal information. We do not knowingly share the personal information of consumers under 16. Sharing personal information for cross-context behavioral advertising may be a "share" under the CPRA. Before we share personal information for that purpose, we will provide a "Do Not Sell or Share My Personal Information" choice, and we will honor a valid opt-out preference signal to the extent California law requires it.

We do not use or disclose sensitive personal information for purposes that create a separate right to limit use under the CPRA, beyond the purposes the statute allows without that right.

Other U.S. state privacy laws

Other U.S. states, including Texas, have enacted comprehensive consumer privacy laws with rights similar to those above. Where such a law applies, a resident may have the right to access, correct, delete, and obtain a copy of personal information, and to opt out of targeted advertising, the sale of personal information, and profiling used in furtherance of decisions that produce legal or similarly significant effects. The request and appeal method in How to submit a request is how we receive those requests.

International transfers

G7 Game Studios LLC is established in Texas, in the United States. Service providers that process information for us, including analytics and crash-reporting providers, may process that information in the United States and in other countries where they or their subprocessors operate.

Laws in those countries may differ from the laws where you live. Where applicable data-protection law requires safeguards for an international transfer, we ensure those safeguards are in place before the transfer occurs. For transfers subject to the GDPR or the UK GDPR, we use a recognized mechanism, such as the European Commission's Standard Contractual Clauses and the United Kingdom International Data Transfer Agreement or Addendum, together with supplementary measures the provider applies. You may email us for information about the safeguards that apply to an international transfer and, where applicable, to obtain a copy of those safeguards or information about where they are available. We may redact confidential or unrelated information where permitted by law.

Security

We use administrative, technical, and organizational measures designed to protect personal information against accidental or unlawful destruction, loss, alteration, and unauthorized disclosure or access. Access is limited to people and service providers who need the information for the purposes in this policy. Apple or Google handles payment card data. We do not store payment card data on our systems.

No method of transmission or storage is completely secure. We cannot guarantee absolute security. If a breach of security involving personal information occurs, and the law requires notice, we will notify the people and authorities the law requires us to notify.

Changes to the policy

We may update this policy when our games, our service providers, or our legal duties change. When we update it, we will change the effective date at the top of this page. If a change materially affects how we use personal information we already hold, we will give any additional notice the law requires, which may include a notice in the affected game or on this page.

Where applicable law requires consent to a material change affecting previously collected personal information, we will obtain that consent before applying the change. Updates to this policy will not reverse our commitment not to sell personal information.

The version in effect is the version that shows the current effective date above.

Contact