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Privacy Policy for Huuuge services’ users

Effective Date: 2025-11-13 
If you are a resident of the U.S., see our U.S. residents supplement.

1. The definitions we use
2. Who is the controller of your personal data?
3. For what purpose, on what legal basis and which of your personal data we process?
4. Retention periods of personal data
5. Cookies, mobile identifiers and similar technologies
6. Huuuge's partner list
7. What rights you have in connection with personal data processing and how you can exercise them?
8. When and with whom do we share your personal data?
9. Transfer of data
10. Do we process the personal data of minors?
11. Privacy policies of linked third-party services
12. Data security
13. How can you get in touch with us?
14. U.S. residents supplement
15. Amendments to the privacy policy
 

 

THE DEFINITIONS WE USE

1.1. Where we use a capitalised term in this Privacy ​P​olicy, it shall have the meaning set out below: 

1.1.1.Controller – the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal data. 

1.1.2. Joint – Controllers – two or more Controllers jointly determine the purposes and means of processing the same Personal data. 

1.1.3. Personal data (also known as personal information or personally identifiable information / PII) – all information about you that makes it possible to identify you​ directly (e.g. your e-mail address) and indirectly (e.g. your activity on the respective website). You can find more information about which of your Personal data we process in Section 3 below. 

1.1.4. Games –​ ​any game that the Huuuge provides to You through Mobile App or other platforms or Websites. 

1.1.5. GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC. The GDPR imposes specific obligations on entities that perform operations on Personal data (whether on their own behalf or on behalf of another entity). It guarantees the exercise of your data protection rights – you will read more about this in Section 6. 

1.1.6. We, Huuuge – companies in the Huuuge Group (group of undertakings) providing Service or access to the Games, indicated in​ section 2.1.​ below, acting together as the​ Joint-Controllers.​ 

1.1.7. ​​​Mobile App​​ – any mobile application through which Huuuge grants access to some Games and/ or provides any Service.​​ 

1.1.8. Website – any Huuuge website through which Huuuge may grant access to Games and/or provide any Service. 

1.1.9. Service – ​any service Huuuge provides to You through any Mobile App or any Website or any third-party platform. 

1.1.10. You, Your – the individual accessing or using the Games, any Website, any Mobile App or any Service. 

1.1.11. ​​​Game Currency – in-game virtual currency.​​ 

1.1.12. ​​Virtual Goods – in-game virtual items such as game virtual currency, level boosts, skins, etc​. 

WHO IS THE CONTROLLER OF YOUR PERSONAL DATA?

2.1. The Joint – Controllers of your Personal data under this Privacy Policy, in each case, are:

2.1.1. Huuuge Global Limited, with its registered seat in Limassol, Cyprus; address: 28th October Street, No. 331, Kanika Enaerios, Lido House, Block 1, Office 762, 3106 Limassol, Cyprus, e-mail address support@huuugegames.com and  

2.1.2. Huuuge Games sp. z o.o., with its registered seat in Szczecin, Poland; address: Storrady Świętosławy 1A/501, 71-602 Szczecin, Poland, e-mail address support@huuugegames.com.  

2.2. We, the Joint-Controllers, may use our affiliates from Huuuge Group: Huuuge Publishing Limited or Billionaire Games Limited as service providers to provide the Services to You. 

2.3. Some third parties who provide services to us may be Controllers with respect to the Personal data they process. For example, Facebook Ireland Limited is a Joint – Controller with the Huuuge companies indicated in section 2.1. above when it comes to using a Facebook tool which enables You to connect Your Facebook accounts to the Website or Mobile App (Facebook Login). The Joint - Controller addendum can be found ​​here. 

FOR WHAT PURPOSE, ON WHAT LEGAL BASIS AND WHICH OF YOUR PERSONAL DATA WE PROCESS?

PROVISION OF SERVICES AND GAMES ACCESS  

3.1. When You use Our Mobile Apps, visit Our Websites, play Our Games, or use any of Our other Services, We process the Personal data in accordance with this Privacy Policy. In some situations described in the Terms of Use, creating an account may be required, or an account may be automatically set up for You by Us. We collect Personal data directly from You and from third party sources.  Please do not provide us with more information than we request.

3.2. In some of Our Games, You can publicly view Personal Data about other players. Please be responsible about what Personal data you choose to make public.

3.3. If you access our Games or Services through a third-party app or connect our Games or Services to a third-party app, you should also review that app’s terms of use and privacy policy. We aren’t responsible for what you see on other websites or apps, or for their privacy policies. If you have questions or requests about your Personal Information, you can find our contact details in Section 13.

3.4. The following charts set out the purposes for which we process Personal data, the legal basis for processing (where required by data protection law), and the types of Personal data we process for those purposes.

 

PROCESSING PURPOSES 

LEGAL BASIS FOR PROCESSING 

TYPES OF DATA  

Creation and maintenance of an in-game account 

Necessity for the performance of a contract to which You are party or in order to take steps at Your request prior to entering into a contract (Article 6 (1)(b) of GDPR); ​with regard to additional data provided, ​the legal basis for processing is Your consent (Article 6(1)(a) of GDPR) 

Required data:  

  • nickname 
  • player ID 
  • country  
     

Additional data:  

  • profile photo 
  • first and last name 
  • gender 
  • age 
  • city  
  • e-mail address 
  • data indicated in the user description 
  • physical location data that You provide 

Provision of electronic services (in terms of providing access to the content of the Games and Services) 

Necessity for the performance of a contract to which You are party or in order to take steps at Your request prior to entering into a contract (Article 6(1)(b) of GDPR) 
  • data about the ways in which You use and interact with our Games or Services 
  • such as when and for how long You play, game features and other players You interact with, etc.  
  • crash data such as crash logs   
  • if You choose to use communication features that allow You to communicate or share information with other players, then We would collect information on what is communicated or shared 

Logging in with a Facebook account​ or with an Apple ID

Your consent (Article 6(1)(a) of GDPR) 

In case of Facebook login: 

  • Facebook Friends’ List 
  • Facebook profile photo 
  • data used to log in 
     

In case of Apple ID login:  

  • data used to log in 

Analysis of Your activity in our Games or Services in order to:  
a) optimize the Games and Services/ adjust the gameplay and offers to Your needs,  

b) enable some marketing activities (ads in the game as a consequence of our game being offered for free),

c) to deliver targeted ads through the Games or Services and on third party platforms (For more information about advertising, see sections 3.5–3.9 below.),

d) detect fraud.

Necessity for the performance of a contract (Article 6(1)(b) of GDPR).

Legitimate interest of Huuuge (Article 6(1) (f) of GDPR which is some form of analysis of Huuuge’s players behaviours in order to learn and optimize the services and provide the services that are free (free to play games).  

In cases required by law (e.g. in the EEA), we will process your data if we obtain your explicit consent (Article 6(1)(a) of the GDPR).

  • IP address or other location data (e.g. GPS-level data), time zone 
  • type of computer or mobile device You are using, device push tokens,  
  • platform type (like Apple iOS or Android) 
  • operating system version, network information 
  • mobile device’s identifiers, like Your MAC Address, Apple Identifier For Advertising (IDFA), Android Advertising ID (AAID), App Set ID and/or Google Advertising ID (GAID) 
  • browser type and language 
  • clicks on an app feature or web page 
  • time spent on an app feature or web page 
  • Game state and the date and time of activity on Our Game 
  • data about the ways in which You use and interact with our Games or Services 
  • such as when and for how long You play, game features and other players You interact with, etc.  
  • crash data such as crash logs   
  • product preferences, privacy preferences or other users choices 
  • purchasing histories
  • inferences drawn from Personal data, including your preferences, interests, and other information used to personalize your experience

 

3.5. We work with advertising partners such as ad networks, social media platforms, publishers, and analytics providers to promote our products and measure campaign performance. These partners use cookies, pixels, SDKs, or similar technologies to deliver ads, measure effectiveness, detect fraud, and limit how often an ad is shown.

3.6. You may see our ads on third-party websites or platforms. If you visit our Service after interacting with one of those ads, our tracking technologies help us understand which campaigns led to your visit and how effective they were.

3.7. Ads may also appear on our Games and Service, delivered by us or by third-party networks. Those partners may collect information about your activity on our Service and across other websites or apps to show ads, measure performance, and provide analytics. Their data practices are governed by their own privacy policies.

3.8. Some of our advertising, both on and off our Games and Service, may be considered “targeted advertising.” This means showing you ads that are more relevant based on your activity over time and across non-affiliated services. We may share hashed identifiers such as email addresses or device IDs with partners that combine our data with their own to deliver or measure these ads. For example, we use the Meta Pixel to reach or analyze audiences on Meta platforms.

3.9. We may also use audience modelling or look-alike services, where we and a partner each share hashed identifiers with a technology provider that matches shared attributes to understand audience overlap and improve campaign reach.

VIRTUAL GOODS PURCHASES 

 

PROCESSING PURPOSES 

LEGAL BASIS FOR PROCESSING 

TYPES OF PERSONAL DATA 

Fulfilling a submitted purchase order and providing the Virtual Goods 

Necessity for the performance of a contract (Article 6(1)(b) of GDPR) 
  • user ID,  
  • information on transaction 
     

In cases where not via intermediary such as Google, Apple, also additionally: 

  • last and first name 
  • e-mail address 
  • billing address 
  • device ID 
  • IP address / location 
  • order ID 
  • tax ID / status 

Performing the statutory obligations imposed on Huuuge, in particular those following from tax and accounting laws  

Legal duty (Article 6(1)(c) of GDPR) 
  • user ID,  
  • information on transaction 
     

In cases where not via intermediary such as Google, Apple, also additionally: 

  • last and first name 
  • e-mail address 
  • billing address 
  • device ID 
  • IP address / location 
  • order ID 
  • tax ID / status 

COMMUNICATION, OUR RELATIONS WITH YOU AND MARKETING  

3.10. We may send You direct marketing communications via email, from Mobile App or via push notifications.  

3.11. We may also contact You from time to time to conduct a satisfaction survey to determine Your satisfaction with the quality of Our Games and Services. 

PROCESSING PURPOSES 

LEGAL BASIS FOR PROCESSING 

    TYPES OF PERSONAL DATA 

Direct marketing communication or satisfaction surveys, maintaining relationship with You 

Users consent (Article 6 (1) (a) of GDPR)  

Legitimate interest pursued by Huuuge (Article 6(1)(f) of GDPR) consisting of conducting marketing activities and satisfaction surveys  

  • email address 
  • information about device (e.g. for push notifications)  

 

REWARDS PROGRAM 

3.12. If you participate in the Rewards Program, at times, We might need some more Personal data to actually provide You with a benefit, e.g. to send You a gift in real life, organize events for our best players, and communicate with You easier.

PROCESSING PURPOSES     

LEGAL BASIS FOR PROCESSING 

TYPES OF PERSONAL DATA 

Providing benefits connecting to participation in the Rewards Program 

With regard to obligatory personal data legal basis for processing is a necessity for the performance of a contract (Article 6(1)(b) of GDPR).  
​ 

​​With regard to additional personal data legal basis for processing is a legitimate interest pursued by Huuuge (Article 6(1)(f) of GDPR), consisting of providing rewards and communication relating to the Rewards Program.​ 

Obligatory personal data: 

  • player ID  
  • e-mail address 
     

Additional personal data: 

  • first name  
  • last name  
  • home address 
  • phone number 
  • Your social media details 
  • additionally, We may also collect the content of Our chats together 
     

 

SOCIAL MEDIA PROFILES 

3.13. If You visit our profiles on social media (Facebook, Instagram, X, Medium, LinkedIn, YouTube), We use Your Personal data for those purposes:

 

PROCESSING PURPOSES 

LEGAL BASIS FOR PROCESSING 

TYPES OF PERSONAL DATA 

Running of the respective profile, including to keep You informed about our activities, our Games and Services and to promote various events, services and products 

Legitimate interest pursued by Huuuge (Article 6(1)(f) of GDPR), consisting of promoting one’s own brand 
  • personal data that You make public on the relevant social media platform 

 

OTHER PURPOSES OF PROCESSING 

 

PROCESSING PURPOSES 

    LEGAL BASIS FOR PROCESSING 

TYPES OF PERSONAL DATA 

Handling complaints 

Necessity for the performance of a contract (Article 6(1)(b) of GDPR) 
  • the contact information You give Us (generally, Your name, e-mail address, player ID) 
  • subject of the complaint 
  • content of the complaint 
     

Handling of data subject requests 

Legal duty (Article 6(1)(c) of GDPR)
  • the contact information You give Us (generally, Your name, e-mail address, player ID) 
  • subject of the request 
  • content of the request 

Handling of other requests and applications 

Legitimate interest pursued by Huuuge (Article​ 6(1)(f)​ of GDPR), consisting of responding to enquiries addressed to it regarding its business activities; with regard to the data provided on an optional basis, the legal basis for processing is consent (Article 6(1)(a) of GDPR) 
  • the contact information You give Us (generally, Your name, e-mail address, player ID) 
  • subject of the request 
  • content of the request 

​​​Improving electronic services quality​​

​​​The legitimate interest of the Huuuge (Art. 6(1)(f) of GDPR) consisting of conducting analyses of Your activities on the Mobile App and Websites in order to improve the functionalities used​​ 
  • data about Your Game play or Your activity in a Game 
  • data about Your activities on the Mobile App and Websites 
  • the communications You have with Our support and any additional information in those communications in order to provide support and improve the Games or Services 

 

RETENTION PERIODS OF PERSONAL DATA

4.1. The duration of Personal data processing depends on the type of service provided and the purpose of processing. As a rule, the data is processed for the duration of the service provision or order processing, until the withdrawal of the expressed consent or filing an effective objection to data processing in cases where the legal basis of data processing is Our legitimate interest. 

4.2. The duration of data processing may be extended if the processing is necessary to establish and assert possible claims or to defend against claims, and thereafter only in the case and to the extent required by law. After the end of the processing timespan, the data is irreversibly deleted or anonymized. 

4.3. In particular, Your Personal data is processed by Us: 

4.3.1. for the purpose of providing You with access to Our Games or providing the Services to You – until You stop playing in particular Game or until the relevant Service is terminated; 

4.3.2. for analytical and statistical purposes – until the termination of storage of Your Personal data in connection with another active purpose of processing or until the moment of expressing an effective objection to the processing of Your Personal data (however, no longer than until the last day of the calendar year following the lapse of 6 years since You stopped playing our Games or after the termination of Services); 

4.3.3. for the purpose of establishing and asserting claims or defending against claims – until the last day of the calendar year following the expiry of 6 years since You stopped playing our Games or after the termination of Services;  

4.3.4. for the purpose of responding to complaints relating to the provision of electronic services and providing a response – until the last day of the calendar year following the expiry of 6 years after the complaint was recognised; 

4.3.5. for Our marketing purposes – until Your marketing consent is withdrawn or an effective objection is made to the processing of Personal data; 

4.3.6. if the duration of the storage of Your Personal data results from mandatory legal provisions, We will store Your Personal data for the period specified in such provisions. 

COOKIES, MOBILE IDENTIFIERS AND SIMILAR TECHNOLOGIES

5.1. W​​​​e collect information about Your device and how You use our Games or Services, including using cookies or similar technologies and / or mobile identifiers. 

5.2. We use cookies or similar technologies and / or mobile identifiers to provide You with our Games, and other Services to understand use and improve their quality, for fraud prevention and security. We also use these technologies to provide you with advertising (including targeted advertising), if you give us consent to do so. You can find detailed information about the cookies or similar technologies and / or mobile identifiers We use in Our Cookies Policy.​​ 

5.3. Remember that you can manage certain aspects of data collection and use from your mobile device or third party application by visiting the "settings" of such application or mobile device or web browser and checking access permissions.

5.4. If You do not want to receive tailored in-application advertisements from third parties that relate to Your interests on your mobile device, You may adjust the ad tracking settings on Your device (such as turning on “Limit Ad Tracking”). You can also reset the “Advertising Identifier” (such as an IDFA) from Your mobile device’s settings, which will prevent continued use of existing behavioural data tied to Your previous “Advertising Identifier.” Further, depending on the platform provider (such as Apple or Google), you may be able to download apps that offer to provide You with control regarding the collection and use of cross-app data for tailored advertising. All of the opt-in or opt-out tools described in this subsection are provided by third parties, not by us. Huuuge does not control or operate these tools or the choices that advertisers and others provide through these tools. Please note that you may still receive third-party advertisements in our Games after using these tools, but the advertising you see would not be customized to your interests or needs.

5.5 We may use Google Analytics and Ad Services. To learn more about the data Google collects and how your data is used by it and to optout of certain Google browser Interest-Based Advertising, please visit here.

5.6. In some regions, you may opt-out of sales, shares, or processing of your Personal data for targeted advertising purposes. For details, see our U.S. Residents Supplement.

HUUUGE'S PARTNER LIST

6.1. Huuuge’s Partner List includes a list of trusted advertising network companies with which Huuuge works directly or indirectly, and which may receive your personal data and further process according to their own rules. We encourage you to review the privacy policies of our partners to ensure that you understand their treatment of personal data that they may process. Please note that Huuuge may not directly work or share personal data with all of the companies listed below. From time to time, we may add partners to this list when we make new agreements with partners who are committed to protecting your personal data.

The Huuuge’s Partner List can be found here. 

WHAT RIGHTS YOU HAVE IN CONNECTION WITH PERSONAL DATA PROCESSING AND HOW YOU CAN EXERCISE THEM?

7.1 This Section addresses the rights of EU residents. If you are a resident of the U.S., see our U.S. Residents Supplement.

7.2. You have the right to access the content of Your Personal data and to request rectification, erasure, restriction of processing, the right to data portability and the right to object to the processing of the data, as well as the right to lodge a complaint with the supervisory authority dealing with the protection of Personal data. The leading protection authority is Polish President of the Office of Data Protection. You may also contact your local data protection authority. For more information, please contact such authority. 

7.3. To the extent that Your Personal data are processed on the basis of consent, this consent may be withdrawn at any time.  

7.4. You have the right to object to the processing of Your Personal data for marketing purposes if the processing is carried out in connection with Our legitimate interest, as well as – for reasons connected with Your special situation – in other cases where the legal basis of the data processing is Our legitimate interest (e.g., in connection with the analytical and statistical activities). 

7.5. Please note that the exercising of the above rights is not unconditional and not feasible in all the cases (e.g. we will not erase Your data if You still play Our Games and those data are necessary to provide You the game services or we will not give You copy of Your data when it infringes other individual’s rights or our trade secrets/ IP). In our response to Your request, we will justify our possible denial of enforcement of Your rights.  

7.6. Authorized Agents may act on Your behalf by submitting requests, to protect Your information, we may request that You verify Your own identity before fulfilling a request submitted by Your agent. Note that since we do not require our users to provide us with names or e-mail addresses, the most certain method to verify your identity is to submit your request from the Service you are using.  

7.7. Additionally, have in mind that in order to execute Your privacy request, Huuuge needs to be sure that it was submitted by the right person. We will have the right to verify the identity/ request due authentication in order to avoid situation where e.g. we may delete the data of someone else’s account.  

7.8. You may ​file a request about exercising​ Your rights in the following manner: 

7.8.1. ​​​via Mobile App/ Services or other platforms settings; 

​alternatively, however, this is subject to the possibilities on verification of our identity (as we normally do not collect e-mails or names of our players)  

​7.8.2. by letter to the address: Huuuge Games sp. z o.o., Storrady Świętosławy Street 1/501, 71-602 Szczecin, Poland; obligatory attn: Data Protection Officer​​ 

7.8.3. ​​​by e-mail to the address: dpo@huuugegames.com.  ​​ 

WHEN AND TO WHOM DO WE SHARE YOUR PERSONAL DATA?

8.1. We share Your Personal data for the purposes described in this Privacy Policy. The categories of persons with whom we share your Personal Data are described below.

SERVICE PROVIDERS

8.2. In connection with provision of Games and Services, Your Personal data may be disclosed to external entities that process Personal data on our behalf, including in particular our payment operator (Stripe Payments Europe, Ltd.), and other service providers a responsible for maintenance of IT systems, data analytics, website hosting, advertising, accounting services, and technical support.

AFFILIATES 

8.3 Your Personal data maybe disclosed to entities related to Huuuge, including companies from its group. (including parent company and subsidiaries) (“Affiliated Entities”) if it is necessary to provide Games and Services.

THIRD PARTIES

8.4. Upon Your consent We might use and share Your Personal data with our partners to tailor the ads to your interests. The list of such partners as well as their privacy policies can be found here . We might update it from time to time.

8.5. We may share Your Personal data with other third parties or allow them to collect your information from our Games or Services if we have Your consent or you direct us to do so. For example:

8.5.1. If You request a refund from the provider of the shop from which you downloaded the app (e.g. Google, Samsung), or from another external payment provider (like PayPal, Stripe, Appcharge), You agree to allow us to share Your data related to the in-game transaction associated with Your request with that provider. This provider will use Your data to determine whether Your refund request should be approved or denied. The data shared for this purpose will not be used for tracking. For information on how a specific provider processes Your personal data, please refer to their privacy policy.

8.5.2. If You are using an Apple-branded product and request a refund from the App Store or other Apple services, You agree to allow us to share Your data related to the in-game transaction associated with Your request with Apple. Apple will use Your data to determine whether Your refund request should be approved or denied. The data we share with Apple for this purpose is not used for tracking. Apple uses and protects Your data in accordance with Apple’s Privacy Policy.

FRIENDS AND OTHER PLAYERS

8.6. Our Games encourage you to interact with other players. In most Games, if you play through a social network or connect to a social network (like Facebook), your friends who also play our Game will see your name, photo, player profile and descriptions of Your in-game activity.

8.7. Further, in our Games other players (not being your friends) will be able to see your player profile; view descriptions of your in-game activity; communicate with you within our Games and send you game requests or friend requests through our Games.

MERGER OR ACQUISITION

8.8. We may disclose Your Personal data in connection with, or during negotiations of, any proposed or actual merger, purchase, sale, or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.

SECURITY MEASURES 

8.9. We share Your Personal data if necessary for safety, security, or compliance with law. Your Personal data and the contents of all of Your online communications in our Games and between you and Huuuge may be accessed and monitored as needed to provide Our Games and Services and may be disclosed: 

8.9.1. to satisfy any laws or regulations that apply;

8.9.2. when we have to disclose the information in response to lawful requests by public authorities;

8.9.3. if Our Games or Services are being used in committing a crime or to share data with other companies and organizations for the purposes of fraud protection and other security precautions;

8.9.4. to protect the rights or property of Huuuge or applicable third parties.

TRANSFER OF DATA

9.1. Note that when you use our Games or Services, your Personal data may be processed outside of the country in which you provide it. When We transfer, store, and use Personal data collected in the European Countries outside of the European Countries, We will ensure that Your Personal data is subject to suitable safeguards (such as encrypting communication or use of Standard Contractual Clauses) or transferred to “approved” territories (having adequate protection/ equalling to the protection of EU).

9.2. As a global company, we may transfer Your personal data to our “Affiliated Entities”, located in many countries. When we transfer your personal data internationally, we will take reasonable steps to ensure that your data is treated securely and lawfully.

9.3. If you are located in a European Country, You may direct any questions, concerns or complaints regarding Huuuge's handling of Personal data or compliance with safeguards related to transfers outside European countries to our Data Protection Officer (see the contact details in point 13.1. below). If your complaint still is not resolved through these channels, an additional binding arbitration option may be available to You.

DO WE PROCESS THE PERSONAL DATA OF MINORS?

10.1. Our Games and Services are not intended for underage persons (under the age of majority at the territory of where You are) (“Child” and “Children”) See more in our Terms of Use relevant to the Game or Service You are using. Children are not permitted to use our Games and Services, and We do not knowingly collect any Personal data from Children. We do our best to ensure that We do not collect information from or about Children. If We learn that We have inadvertently gathered Personal data from a Child, We will take measures to respectively enforce our terms and do not allow such person to play anymore and take reasonable measures to promptly remove the Personal data from our records. 

PRIVACY POLICIES OF LINKED THIRD-PARTY SERVICES

11.1 We are not responsible for the ways in which third parties use Your Personal data (other than companies that process Personal Data on our behalf acting under our instructions). Our Websites and Games may contain advertisements from third-party services that may link to their own websites or services. If You have any questions about how these entities use Your data, You should review their policies and contact them directly.

DATA SECURITY

12.1. We take measures to comply with international security standards and store Personal data on secure servers. We require our personnel to treat all Personal data as confidential information. In addition, We take measures to restrict access to Personal data to only those persons who should have such access. As appropriate, we conduct audits and review internal controls to help ensure that the measures in place are adequate and that there is compliance with international security standards and internal procedures.

12.2. Where We use security features such as a password (or where You use such an option) to access the any Game or any Service, You shall keep such password confidential and shall not disclose it to any third party.

12.3. Unfortunately, the transmission of information via Internet links is not completely secure. Thus, although We take care to protect Your Personal data, We cannot guarantee the security of Personal data transmitted via our Websites or Mobile Apps - any such transmission is at Your risk. When receiving information from You, We make reasonable efforts to ensure compliance with procedures and the application of safeguards against unauthorised access.

CONTACT US

13.1. We have a Data Protection Officer (the “DPO”), who is the person at Huuuge group responsible for all matters related to data protection and privacy matters. The DPO is the designated contact for data protection issues for all Huuuge’s companies, including if you have issues understanding this policy. You can reach Huuuge’s DPO at the following address:

13.1.1. For all users outside the U.S.: Data Protection Officer, Huuuge Games sp. z o.o., Storrady Świętosławy 1/501, 71-602 Szczecin, Poland,

13.1.2. For U.S. Users: Huuuge, 2300 W. Sahara Ave. Suite 800 Las Vegas, NV 89102.

13.1.3.  dpo@huuugegames.com.

13.2. If you have a customer service-related issue, please contact our Support Team instead of contacting the Data Protection Officer.

13.3. Please be sure to include Your name or Your player ID or address and email address in any correspondence to us so that We can respond to Your inquiry in a timely manner.

U.S. RESIDENTS SUPPLEMENT

14.1. This section provides specific disclosures for residents of California or any Consensus State. Consensus States are U.S. states with privacy laws that vary slightly but generally give consumers similar rights, such as the ability to access, correct or delete their personal information. In this policy, “Consensus States” include Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia.

14.2. Terms in this section mean the same as they are defined elsewhere in this policy. Personal data and “personal information” mean the same thing, where applicable.

NOTICE AT COLLECTION

14.3. In the past 12 months, we have collected the categories of personal information and sensitive personal information listed below.

Collection

  • Identifiers, including real name, alias, postal address, unique personal identifier, online or advertising identifier (ex. device numbers, ADFA, GAAID etc.), IP address.
  • Customer records, including mailing address, telephone number.
  • Characteristics, including age, gender.
  • Commercial or Transaction information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies,
  • Internet or other electronic network activity information, including browsing history, search history, and information regarding a consumer’s interaction with an Internet Website, application, or advertisement,
  • Non-precise geolocation data, including location derived from an IP address.
  • Inferences drawn from any of the above.

Sources

14.4. Our Service obtains the categories of personal information listed above from the following categories of sources:

  • directly from You, for example, from forms You complete or products and services You purchase,
  • indirectly from You, for example, from logging Your actions in the game or You’re Your device,
  • third parties, for example:
    • third party vendors and related parties we work with in connection with receiving analytics, advertising, security, and fraud prevention services.
    • social media platforms with which you interact. For example, when you engage with our social media channels, we may collect information associated with your profile. We may also receive additional information from the social media platform that you have authorized the platform to disclose to us. If you publicly reference us, we may feature your post in our Service or marketing materials.
    • business partners that offer co-branded services, sell or distribute our products, or engage in joint marketing or promotional activities.
    • third party integrations that you connect to the Service. For example, if you choose to log-in to the Service through your Meta or Apple account, we receive information that you have authorized to be disclosed to us.
    • data providers, such as licensors of private and public databases.
    • public sources, such as data in the public domain.

Purposes

14.5. Our specific purposes (including business and commercial purposes) for collecting and using personal information are set out in the FOR WHAT PURPOSE, ON WHAT LEGAL BASIS AND WHICH OF YOUR PERSONAL DATA WE PROCESS section above.

Disclosure

14.6. The categories of persons to whom personal information is disclosed, including service providers for business purposes, are set out in the WHEN AND TO WHOM DO WE SHARE YOUR PERSONAL DATA section above. We disclose the categories of personal information listed in the Collection section above to service providers for business purposes.

Sales, Shares, and Targeted Advertising

14.7. Some of our disclosures of personal information to third parties may be considered a sale or share for contextual advertising purposes under applicable law. We may also process your personal information for purposes of targeted advertising as defined by applicable law. The categories of personal information that we sell, share, or process for targeted advertising purposes include: identifiers, customer records, characteristics, commercial or transaction information, internet activity, non-precise geolocation data, and inferences drawn from any of the above. The categories of third parties to whom we sell, share, or disclose your information for targeted advertising purposes include, where applicable, vendors and other parties involved in cross-context behavioral advertising. We do not sell, share, or process for targeted advertising purposes the personal information of consumers we know are minors.

14.8. To the extent we collect sensitive personal information, we collect, use, and disclose such sensitive personal information only for the permissible business purposes for sensitive personal information under applicable law. We do not sell, share or process sensitive personal information for targeted advertising purposes.

Retention

14.9. The criteria used to determine the period of time we retain your personal information is set out in the RETENTION PERIODS OF PERSONAL DATA section above.

Profiling

14.10. We do not process personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning consumers.

RIGHTS

Verifiable Requests

For residents of California:

  • Right to Know. You have a have a right to submit a verifiable request, up to two times a year, for the following information: (1) the categories of personal information we have collected from or about you; (2) the categories of sources from which we have collected that personal information, and the business or commercial purpose for the collection; (3) the categories of third parties with whom we have shared your personal information or sold your information, and the business or commercial purpose for said sharing or selling (if any); and (4) the specific pieces of your personal information.
  • Right to Correct. You have the right to correct inaccurate personal information we maintain about you.
  • Right to Delete. You have a right to request that we delete your personal information.

For residents of Consensus States:

  • Confirm. You have the right to confirm whether or not we are processing your personal information, and in some regions, confirm the categories of personal information we have processed.
  • Access. You have the right to access your personal information.
  • Correct. You have the right to correct inaccuracies in your personal information.
  • Delete. You have the right to delete your personal information.
  • Obtain. You have a right to obtain a copy of your personal information that you previously provided in a portable and readily usable forma.
  • Specific Third Parties. (Minnesota and Oregon residents only) You have a right to obtain a list of the specific third parties to which we have disclosed personal information.
  • Categories of Third Parties. (Delaware and Maryland residents only) You have the right to obtain a list of the categories of third parties to which we have disclosed personal information.

See Exercising Your Rights below for details on how to exercise verifiable requests.

Opt-Out of Sales, Shares, and Targeted Advertising

Residents of California and Consensus States have the right to opt-out of the selling or sharing for cross-contextual advertising purposes of their personal information to third parties, or the processing of their personal information for targeted advertising purposes.

See Exercising Your Rights below for details on how to exercise an opt-out request.

Revocation of Consent

You have the right to revoke consent previously given to us that we rely on to process your personal information or sensitive personal information. If you withdraw consent, you may not be able to receive certain services dependent on that consent.

See Exercising Your Rights below for details on how to withdraw consent.

Nondiscrimination

You have the right not to be discriminated against for exercising any of your rights.

EXERCISING YOUR RIGHTS

Verifiable Requests. Verifiable requests require us to verify your identity before fulfilling them. To exercise any of these rights, submit a request through our form here (specifying the rights you wish to exercise). If you have an account with us, we may require you to submit the request through your account. We will confirm receipt of and respond to your request consistent with applicable law. To verify your identity, we may require you to confirm receipt of an email sent to an email address that matches our records, provide us with details relating to your history with us, or provide additional information. If we cannot verify your identity, we may deny your request in accordance with applicable law.

Sales, Shares, and Targeted Advertising. To opt-out of sales, shares, or targeted advertising for our Games, visit the settings in the menu of our Games and turn off sales, shares, and targeted advertising. You also opt-out for tracking technologies on our website by clicking on “Your Privacy Choices” in the footer and turning off sales, shares, and targeted advertising through your cookie preferences by enabling a recognized opt-out preference signal, such as Global Privacy Control, through your browser. Because we typically do not associate information collected through tracking technologies with information in our systems, the opt-out will apply only to the browser from which you opt-out. If you delete or reset your cookies, or switch browsers, you will need to reconfigure your settings. To extend your opt-out to other information we hold about you, such as your email address, please submit a request through our form here.

Consent: To revoke consent given to us, write us at the email or postal address set out in the Contact Us section above (specifying the consent you wish to withdraw). If you withdraw consent, you may not be able to receive certain services related to that consent.

Authorized Agents. You may exercise your rights through an authorized agent. Authorized agents must submit requests through the same methods designated herein. Except where prohibited by law, we will require written and signed proof of the agent’s permission.

Appeals. You may have the right to appeal our decision in response to your request. To appeal, please write us at the email or postal address set out in Contact Us and specify what you wish to appeal. We will review and respond to your appeal in accordance with applicable law. If we deny your appeal, you may submit a complaint to your Attorney General as follows: Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, Virginia.

Limitations. Your rights are subject to exceptions and our data retention practices. To the extent permitted by law, rights requests must be exercised through the applicable designated method specified herein

ADDITIONAL CALIFORNIA DISCLOSURES

14.11.California Minors. If you are under 18 years old and a California resident, you can request to view, correct, or delete information you provided or publicly posted by sending an email to dpo@huuugegames.com. (You can find more contact options in section 13.). We will review and handle your request accordingly. Keep in mind that copies of the data you delete may remain in backup copies for legal or security purposes, but will be blocked from further use.

14.12. Do Not Track. Your browser settings may allow You to automatically transmit a “Do Not Track” signal to online services You visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals.  For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

14.13. Shine the Light. If you are a customer, you may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To make a request, please write us at the email or postal address set out in the Contact Us section above and specify that you are making a “California Shine the Light Request.”

DISCLOSURES FOR NEVADA RESIDENTS

14.14. Nevada law mandates that each business designate a specific request address where Nevada consumers can submit requests to prevent the sale of certain types of personal information that the business has collected or may collect about them. Under Nevada law, a sale is defined as the exchange of personal information for monetary compensation by the business to a third party, allowing that third party to license or resell the information to others. We do not consider our sharing of your Personal Data to constitute a sale under Nevada law. However, if you are a Nevada resident and wish to make a request regarding our compliance with Nevada’s requirements, please contact us at dpo@huuugegames.com.

AMENDMENTS TO THE PRIVACY POLICY

15.1. We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Games or Services indicates your acknowledgement of the Privacy Policy then posted. If the changes are material, we may provide additional notice to you, such as through email or prominent notice on our Games or Services.