Privacy Policy

1. Who we are

White Whales Games, Inc. ("White Whales Games", "we", "us") develops and publishes mobile games. For the purposes of the EU General Data Protection Regulation (GDPR), the UK GDPR and similar laws, we are the controller of the personal data described in this policy.

Registered address: [registered address]. Contact: privacy@whitewhales.games.

EU representative (Article 27 GDPR): [name and address, if required]. UK representative: [name and address, if required].

2. Scope

This policy applies to all mobile games and apps published or operated by White Whales Games that link to it (together, the "Games"), and to our website whitewhales.games. You can find our current Games on our website and on our developer pages on the App Store and Google Play. Some Games may be listed on the app stores under a partner or affiliated publisher account. This policy still applies to them.

Apple, Google and the advertising partners listed below also process data under their own privacy policies. We link to them in section 7.

3. Information we collect

Information collected automatically when you play

• Device and app information: device model, operating system and version, language, time zone, country (derived from IP address or store settings), app version, and a coarse location derived from IP address. We do not collect precise GPS location.
• Identifiers: an install or app-specific identifier we create, Firebase installation ID, IP address, and, only where you allow it, the advertising identifier of your device (Apple IDFA or Google Advertising ID).
• Gameplay and usage data: sessions, levels played, scores, progress, settings, in-game currency and items, which ads were shown or clicked, and interactions with game features.
• Purchase data: what you bought, price, currency, time and the store transaction or receipt ID. Payments are processed by Apple or Google. We never receive your card or bank details.
• Diagnostics: crash reports, error logs and performance data.
• Attribution data: which ad campaign or link led to the install, where you allow it.

Information you give us

• Support and contact: if you email us, your email address, name (if you give it) and the content of your message.
• Consent choices: your privacy and advertising choices, and your answer to age questions where a game asks them.
• Job applications: if you apply for a role, the information in your application and portfolio.

Website

Our website does not use advertising cookies. Our hosting provider records standard server logs (IP address, browser, pages requested and time) for security and operation. Our pages load fonts from Google Fonts, which receives your IP address when the font is delivered.

4. How we use information

• To run the Games: save progress, deliver purchased items, restore purchases and provide game features.
• To show ads that keep the Games free, and to measure how ads perform.
• To show personalized ads, only where you allow it or where the law does not require consent.
• To measure which marketing campaigns bring players to our Games (attribution).
• To analyze and improve the Games: balance difficulty, fix bugs, test new features, set prices and decide which features and content to build next. We use automated analysis and optimization tools for this work. These tools work with aggregated or pseudonymized data and do not make decisions that have legal or similarly significant effects on you.
• To prevent fraud, cheating and abuse, including checking that purchases are genuine.
• To answer your support requests and communicate with you.
• To comply with legal obligations, for example tax and accounting rules for purchases, and to enforce our Terms of Service.

5. Legal bases (EEA, UK and Switzerland)

If you are in the European Economic Area, the United Kingdom or Switzerland, we rely on the following legal bases:

Where we rely on legitimate interests, we have balanced them against your rights. You can object at any time (see section 10).

6. Advertising, tracking and your choices

Our Games show ads through the AppLovin MAX mediation platform, which runs an auction among several ad networks to fill each ad slot. Ad networks may use your device identifiers and other information to show ads, to measure them and, where you allow it, to personalize them.

Your choices

• Consent screen (EEA, UK, Switzerland): the first time you play, we show a consent message based on Google's User Messaging Platform and the IAB Transparency and Consent Framework. You can accept, reject or manage your choices, and change them later from the game's settings menu.
• Apple devices: we only access your IDFA if you allow tracking in Apple's App Tracking Transparency prompt. You can change this in Settings, Privacy and Security, Tracking.
• Android devices: you can reset or delete your Advertising ID, or opt out of ads personalization, in your device settings under Google, Ads.
• US state privacy laws: you can opt out of targeted advertising and the "sharing" of personal data. See section 11.
• Remove ads: some Games offer an in-app purchase that removes most ads.

If you decline personalized ads, you will still see ads, but they will be less relevant to you.

7. Service providers and partners

We share personal data only as needed for the purposes above, with:

• App stores: Apple (App Store) and Google (Google Play), for distribution and payment processing.
• Advertising: AppLovin (MAX mediation) and the ad networks connected to it, which may include Google AdMob, Unity Ads, Liftoff, Meta Audience Network, Mintegral, ironSource and others. The current list of networks for each Game is available on request.
• Attribution: AppsFlyer, to measure which campaigns lead to installs.
• Analytics and diagnostics: Google Firebase (Analytics and Crashlytics).
• Consent management: Google User Messaging Platform, and other certified consent platforms where used.
• Infrastructure and game operations: cloud hosting, data storage, analytics and optimization providers, including Glaium, which provides our data and optimization platform. These providers act as our processors under written contracts and may not use your data for their own purposes.
• Authorities and advisers: where required by law, to protect rights and safety, or to our professional advisers.
• Business transfers: if we sell, merge or transfer a Game or our business, the data related to it may transfer to the new owner, who will be bound by this policy or tell you about any changes.

Partner privacy policies: AppLovin, Google and Firebase, AppsFlyer, Apple.

We do not sell personal data for money. Some sharing with ad networks for targeted advertising may count as "selling" or "sharing" under certain US state laws. You can opt out (section 11).

8. International transfers

Our team and partners operate in several countries, including the United States, the European Union and Brazil. Your data may be processed outside the country where you live. When we transfer personal data out of the EEA, the UK or Switzerland, we use safeguards such as the European Commission's Standard Contractual Clauses (and the UK Addendum), or rely on adequacy decisions such as the EU-US Data Privacy Framework where the recipient is certified. You can ask us for a copy of the safeguards.

9. How long we keep data

• Gameplay and account data: for as long as you play, and up to 24 months after your last activity, then deleted or anonymized.
• Purchase records: as long as required by tax and accounting law (usually up to 10 years).
• Crash reports and analytics events: up to 14 months, then deleted or aggregated.
• Support emails: up to 3 years after the request is closed.
• Consent records: as long as needed to prove consent.

Aggregated or anonymized data that can no longer identify you may be kept longer.

10. Your rights

Depending on where you live, you may have the right to:

• access the personal data we hold about you and get a copy;
• correct inaccurate data;
• delete your data;
• restrict or object to our processing, including processing based on legitimate interests and processing for direct marketing;
• receive your data in a portable format;
• withdraw consent at any time, without affecting earlier processing;
• opt out of targeted advertising, the sale or sharing of personal data, and profiling;
• not be discriminated against for exercising your rights.

How to exercise your rights: email privacy@whitewhales.games with the name of the Game. Because we do not ask for your name, we may need your in-game player ID (shown in the game's settings) to find your data. We will reply within one month (GDPR), 45 days (US state laws) or 15 days (LGPD, Brazil), as applicable. You can also delete the Game from your device and reset your advertising identifier.

Complaints: you can complain to your local data protection authority. In the EEA, find yours at edpb.europa.eu. In the UK, the ICO (ico.org.uk). In Brazil, the ANPD. We would appreciate the chance to help you first.

11. California and other US states

This section applies to residents of California and other US states with comprehensive privacy laws (such as Colorado, Connecticut, Virginia, Utah, Texas and Oregon).

• Categories collected in the last 12 months: identifiers (device and advertising IDs, IP address), commercial information (purchases), internet or network activity (gameplay and ad interactions), coarse geolocation, and inferences used for game balancing and advertising.
• Sources: your device, the Games, app stores and our advertising and attribution partners.
• Disclosure: to the categories of recipients in section 7, for the purposes in section 4.
• Sale and sharing: we do not sell personal data for money. Disclosures to ad networks for cross-context behavioral advertising may be a "sale" or "sharing". We do not knowingly sell or share data of consumers under 16.
• Sensitive personal information: we do not collect it.

Do Not Sell or Share My Personal Information: use the privacy option in the game's settings, turn off tracking on your device as described in section 6, or email privacy@whitewhales.games. We honor Global Privacy Control signals on our website. You can use an authorized agent to make a request. If we deny your request, you can appeal by replying to our decision.

12. Children

Our Games are designed for a general audience and are not directed at children under 13 (or the higher age of digital consent in your country, up to 16 in the EEA). We do not knowingly collect personal data from children below these ages. If a Game asks for your age and you are below the applicable age, we will disable personalized ads, attribution and any data sharing that requires consent, and show only contextual ads.

If you believe a child has given us personal data, contact privacy@whitewhales.games and we will delete it.

13. Security

We use technical and organizational measures to protect personal data, including encryption in transit, access controls, pseudonymization of identifiers in our analytics, and contracts with our service providers. No system is completely secure, so we cannot guarantee absolute security.

14. Changes to this policy

We may update this policy as our Games, partners or the law change. We will post the new version here with a new effective date, and, for important changes, tell you in the Games or ask for your consent where required.

15. Contact us

White Whales Games, Inc.
[registered address]
Email: privacy@whitewhales.games

See also our Terms of Service.