Privacy Policy
Last updated: 10 February 2022

IE Kuzmenko Dmitriy Grigoryevich (“KDG” “I” or “me”), is committed to respecting your privacy and the integrity and security of your personal data.

This Privacy Policy applies to and, all other sites or online services that are owned or operated by me, all mobile games published by me, my games that can be played through third party platforms (collectively “Services”). This Privacy Policy explains how I collect, store, use and share your personal data and how you can exercise your privacy rights.

I am an individual entrepreneur registered at: Protopopovkiy Alley, 17-2-4, Moscow, Russia

I may update our Privacy Policy from time to time. When I do, I will revise the date at the top of the policy. If I make changes that are material, I will use reasonable efforts to notify you (such as by placing an in-game notice or a push-notification). I encourage you to check this Privacy Policy regularly for updates, so that you know our current practices.

By downloading, accessing and/or using our Services, you acknowledge the collection and use of your information in accordance with this Privacy Policy, including me and my partners’ use of your data for the purposes as described below.

You are not obliged to actively provide any of your personal data. However, some functionalities of my Services may not be accessible if you do not provide me with the respective personal data (such as contact information for customer support).

Please, read the following carefully and make sure you fully understand this Privacy Policy. If you have any concerns about providing information to me or it being used as described in this Privacy Policy, please, discontinue and avoid using my Services.

The personal data I collect will depend on the circumstances and the Services you are using. I collect data in three ways: (a) data you provide to me; (b) data I collect automatically; and (c) data I collect from my partners. I do not knowingly collect (d) special categories of information.

  • Contact information (such as name and email address)
  • Other data you choose to provide me when you contact me (through the Services, social media, e-mail or any other channels).
  • Data and analytics about your use of my Services (e.g. your game progress, the date and time you used a Service, session length, features you have used, your in-app purchase history, your interaction with advertisements)
  • Your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI)
  • Non-identifying data about your device, such as device name and operating system, browser type, language and other technical data like screen size or processor, or combination of this data available for a developer for checking the device compatibility with a particular Service
  • General location data (e.g. country or city-level location) inferred from your IP address
  • Precise geo-location data (GPS, with your consent)
  • Data about your use of the Services, such as gameplay data and your interactions with other players inside the Services

Note that I do not use such data to learn a person’s true identity or contact details, but mostly to understand how my users typically use and interact with my Services, so that I could maintain and improve them.


  • Third-party tools. Data I may receive if you choose to link a third-party tool with the Services (such as Facebook, Google or Apple). Exactly what information I receive from such third-party tool will depend on your privacy settings, but it would typically include your basic profile information such as your user id, username, gender, picture, e-mail, your friends playing the same game. I do not get access to or store your logins or passwords for any of these third-party tools.
  • Third-party platforms. In-app purchases are typically processed by the platforms (e.g. Apple App Store, Google Play, Amazon AppStore or Facebook). I do not collect or store your financial data, such as your credit card number or bank account. You are requested to provide payment details directly to the relevant platform. I may, however, receive limited non-financial data relating to the purchase (e.g. platforms may notify me if a purchase was successful). Any post-purchase processes are controlled by the platforms. I encourage you to review privacy policies and terms of service of the platforms for further information before making a purchase in the Services.
  • Advertising partners. From time to time, I may receive non-personal information from my advertising partners concerning the performance of my advertising campaigns (e.g. I may be provided with information from which ad network and advertising campaign the install of my Service originated from or data necessary to fight fraud (such as refund abuse in games or click fraud in advertising).
  • Third-party service providers. My analytics providers may provide me with information regarding your use of my Services (such as in-game events, your interaction with the Services and in-game advertisements, software errors, etc.) so that I could improve my Services.

I do not request or intend to collect any “special categories of information” such as data revealing racial or ethnic origin, political opinion, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Please, be cautious when sharing this information about yourself (or others) in my Services.

To perform the contract with you, which you enter into when you download or access my Services and accept my Terms of Use, I process data necessary to:
  • Allow you to use my Services
  • Facilitate, operate, provide and maintain my Services
  • Recognize you when you return to my Services
  • Verify and confirm payments in my Services
  • Provide and deliver in-app products and services you request
  • Send you Services-related communications
  • Respond to your comments and questions and provide player support
My legal basis for such processing of personal data is Art. 6 para. 1 lit. b) GDPR

To provide great Services to my players, I process personal data based on my legitimate interest to improve my Services in the following situations:
  • Develop and improve the Services and player experience
  • Manage my relationship with you
  • Provide social features as part of the Services
  • Customize your Services experience
  • Provide you my offers in the Services
  • Send you related information, such as updates, security alerts, and support messages
  • Enable you to communicate with other players
  • Show you contextual advertisements in my Services
  • Cross-promote my Services, meaning to promote one of my games while you are playing a different game of mine

My legal basis for such processing of personal data is Art. 6 para. 1 lit. f) GDPR

My games may include advertising for third party products and services. Advertising includes serving you generic non-personalized advertisements and providing you with personalized advertising experience.

To serve you generic non-personalized advertisements in the Services using third party advertising networks, it is generally necessary to process some data that may be considered as personal, such as your IP address or certain device identifiers. To do this, I rely on my legitimate interest in monetizing my Services.

My legal basis for such processing of personal data is Art. 6 para. 1 lit. f) GDPR

To serve you personalized advertisements in the Services using third-party advertising networks I will rely on your consent to process necessary data to:
  • Track the content you access in connection with the Services and your online behavior
  • Deliver, target and improve advertising in my Services
You can opt out of personalized advertising by following the instructions in section 5 below.
You can withdraw your consent at any time by contacting me using the details given in section 10 below.

My legal basis for such processing of personal data is Art. 6 para. 1 lit. a) GDPR

In order to keep the Services and its social features safe and fair, to fight fraud and ensure acceptable use otherwise, I have a legitimate interest to process necessary data to
  • Analyze, monitor and moderate use of the Services and its social features
  • Take action against fraudulent or misbehaving players
  • Track how my advertising campaigns perform and identify and prevent fraud for my advertising campaigns
My legal basis for such processing of personal data is Art. 6 para. 1 lit. f) GDPR
In all of the above cases and purposes, I may analyze, profile and segment all collected data and create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data, which me and my partners may use to provide and improve my Services. If such analyses require the processing of personal data (such as pseudonymized data), I do so based on my legitimate interest to improve my Services based on Art. 6 para. 1 lit. f) GDPR.
In limited cases I pay process your data where I need to do so to comply with a legal obligation, or if I receive an order from a court or regulatory authority.

My legal basis for such processing of personal data is Art. 6 para. 1 lit. c) GDPR

Apart from KDG, your data can be accessed by others in the following situations:

Social features are a core component of my Services. Other players and users may, for example, see your profile data, in-game activities and read the messages you have posted.

In order to combat fraud and illegal activity, I may exchange data with other companies and organizations and provide it to public authorities in response to lawful requests.

I may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of mine, my players or others.

I use third parties to help me operate and improve my Services. These third parties assist me with various tasks, including hosting and maintenance, on-going development, analytics, customer care, marketing, advertising. I may also share information with advertising partners who distribute advertising in my Services.

I share your personal data with these third parties only where I have a legal basis as set out above or where such third parties process data on my behalf based on a data processing agreement.

For further information, please, see my List of Partners and their privacy policies.

My Services are global by nature and your data can therefore be transferred and processed in other countries other than the country in which you are resident. Because different countries may have different data protection laws than your own country, I take steps to ensure adequate safeguards are in place to protect your data as explained in this Policy. Adequate safeguards that my partners may use include transfer of data to the jurisdictions, which are considered by the European Commission to be offering an adequate level of protection for personal data of EU residents or standard contractual clauses approved by EU Commission.

You can opt-out of personalized advertising on mobile applications by checking the privacy settings of your Android or iOS device.
Apple devices:
For iOS 14:
  1. Open Settings
  2. Select Privacy
  3. Select Tracking and disable “Allow Apps to Request to Track”
For iOS 13 and older:
  1. Open Settings
  2. Select Privacy
  3. Select Advertising and enable "Limit Ad Tracking"
Android devices:
  1. Open Settings
  2. Select Google
  3. Select Ads and enable "Opt out of Ads Personalization"
If you are interested in more information about personalized advertising and your choices in this regard, you may visit the following websites:

All of the opt-out tools described in this subsection are provided by third parties, not by me. I do not control or operate these tools or the choices that advertisers and others provide through these tools.

Please note that opting out does not mean that you will stop seeing advertisements in my Services, rather third-party advertising networks will show you contextual advertisements not tailored to your interests. Please, be aware that such actions may result in decrease of advertising quality and less enjoyable user experience.

In case I process personal data about you and if you are an EU resident or the resident of another jurisdiction that affords you the below rights you:

  • have the right to access data I hold on you;
  • may request me to make any changes and corrections to your personal data or restrict the processing if it is inaccurate or incomplete;
  • may request that your personal data is erased where I do not have a compelling reason to continue to process such personal data in certain circumstances;
  • may ask to transfer your personal data in accordance with your right to data portability;
  • may withdraw your consent where you have previously given your consent to the processing of your personal data. Note that withdrawal of your consent will not affect the lawfulness of any processing I conducted prior to your withdrawal, nor will it affect the processing of your personal data conducted pursuant to lawful processing grounds other than consent.
  • have the right not to be subject to a decision based solely on automated processing, (including profiling), which produces legal effects or could significantly affect you;
  • have the right to object to or restrict how I use or process your data in certain circumstances. Please, note in case of such a request I may not be able to provide you with all of my Services or the quality of my Services may be decreased;
  • right to lodge a complaint with a data protection supervisory body.

To submit a request, please, use the contact details in section 10 below.

Please, note that your request must:
  • provide sufficient information necessary to verify you as my user about whom I collected and processed personal data or to verify you as an authorized representative of such a user;
  • contain sufficient details describing your request to allow me to properly understand, review and respond to it;
I reserve the right not to respond to your request or provide you with personal data, in case I was unable to verify your identity or authority to make such a request.

Like most online services, I and my partners use cookies and similar technologies to provide and personalize the Services, analyze use, target advertisements and prevent fraud. You can disable cookies in your browser settings, but some parts of the Services may then not function properly.

For further information, please, read my Cookie Policy.

In order to help ensure a secure and safe player experience, I am continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration. Although I use commercially reasonable efforts to assure that your data remains secure when maintained by me, please, be aware that no security measures are perfect or impenetrable.

I keep your information only so long as I need it to provide my Services to you and fulfill the purposes described in this Privacy Policy. When I no longer need to use your information and there is no need for me to keep it to comply with my legal or regulatory obligations, I will either remove it from my systems or depersonalize it so that I cannot identify you.

I appreciate the need to provide extra privacy protections to users who are children. My Services are intended for use only by those aged 16 and over. I do not knowingly collect personal information from children under 16 years of age. In order to request the deletion of personal data, for any reason, please use the in-app support feature in my Services or contact me at the address provided in section 10 below and I will take reasonable measures to promptly delete such personal data from my records.

If you are a California resident, the California Consumer Privacy Act of 2018 (“CCPA”) gives you the right to request disclosure of information that I collect about you, to delete that information, and to opt-out of the sale of your personal information (if I sell such information).

This section describes how to exercise those rights and my process of handling those requests. I reserve the right to ask for reasonable information to verify your identity before I process your request.

You may submit your request via e-mail at
Please, note that your request must:
  • provide sufficient information necessary to verify you as my user about whom I collected and processed personal data or to verify you as an authorized representative of such a user;
  • contain sufficient details describing your request to allow me to properly understand, review and respond to it;

I reserve the right not to respond to your request or provide you with personal data, in case I was unable to verify your identity or authority to make such a request.

I do not “sell” data of my users as most people would typically understand this term. The definition of “selling” shall be interpreted in accordance with the meaning attributed to this term under CCPA. I do, however, share certain data with third-party advertising partners for the purposes of serving advertisements in my Services, fraud detection and prevention and advertising campaign management. Generally, the data collected is limited the user’s advertising ID, device identifiers and other technical information. Such data collection practices may fall under the definition of “selling” under CCPA.

You may submit once a year, free of charge, a verifiable request to disclose what personal information I collected, used or disclosed about you in the preceding twelve (12) months.

You have the right to request that I delete any of your personal information I collected and retained, subject to certain exceptions. Once I receive and verify your consumer request, I will delete your personal information from my records. However, I may deny your deletion request if retaining the information is necessary for me or my service providers under certain circumstances, which will be explained to you at the time of the denial, if any.

You have the right to opt-out of “sale” of your personal information, as defined by the CCPA. In certain circumstances I may share your information with my partners, who help me deliver advertisements in my games tailored to your interests. To learn what information I collect and how I share it with third parties for advertising purposes, please, see my List of Partners.

If you would prefer that your personal information is not shared with third parties in this way, please, visit “Do Not Sell My Personal Information”.

I may not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, I will not: (i) deny your my Services; (ii) charge you different prices or rates for my Services; (iii) provide you a different level or quality of Services; (iv) suggest that you may receive a different price or rate for Services or a different level or quality of Services.

You may exercise your CCPA rights by designating an authorized agent. If you would like to designate an authorized agent to make a request on your behalf, please, be sure that the agent can (i) demonstrate you have provided written permission for the agent to submit a request on your behalf and (ii) provide proof of his or her own identity. I reserve the right to require further reasonable information to verify the request. If the agent does not satisfy these requirements, I may deny the request.

Personal information is information that directly or indirectly identifies a particular consumer, household or device. I have collected, disclosed or sold the following categories of personal information from California consumers within the last twelve (12) months.
If you have questions about data protection, or if you have any requests for resolving issues with your personal data, you can contact me via e-mail at However, I may still redirect you to make the same request through the in-app support feature to verify you as my user and/or request additional information necessary for me to respond.

Thank you!
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