We are committed to fully complying with all applicable laws and regulations. If any provision of this document conflicts with applicable legislation, the relevant legislative requirements will prevail. Kulachi Games treats the protection of your personal and non-personal information as a matter of the highest importance.

If you are considered a minor under applicable law (typically under 18 years of age in countries such as Australia and the United States, although this age threshold may vary depending on your jurisdiction), you must obtain permission from a parent or legal guardian before providing any personal information to us. We may collect Non-Personal Information, such as a device identifier or other persistent device-related identifiers, which may be associated with a child’s use of our Websites.

We reserve the right to modify or update this Privacy Policy at any time without prior notice. Any changes will become effective from the date they are published on our website.

Collection of Information

If you voluntarily provide Personal Information to us for any purpose and through any method, we will collect and use that information solely for the purpose for which it was provided.

We may collect details about the device you use to access our software, applications, or services. This may include information such as device model, operating system, screen resolution, and other relevant technical specifications.

When you use in-game communication features (such as messaging, chat, posting, or similar functions), we may collect the Personal Information you share as well as the necessary Personal Information of the intended recipient(s) in order to enable that communication. We do not collect information transmitted outside of our Websites or Apps functionality (for example, via external email or text messaging services).

We may also gather information about how you use our software, applications, or services, including usage duration, features accessed, and interactions with other users.

If you enable push notifications, we may collect and use Personal or Non-Personal Information, including device identifiers, to send notifications to your device.

Additionally, any Personal Information you choose to disclose in public forums, comment areas, or chat features within our services may be collected.

Use and Disclosure of Information

We may use Non-Personal Information to analyze how our Websites and Apps are used. This helps us better understand gameplay patterns, user preferences, and behavioral trends so that we can improve user experience, personalize gameplay, deliver tailored in-game offers or notifications, and enhance our services overall.

Non-Personal Information may also be used for administrative purposes, analytics, statistical analysis, research, service optimization, and security. In particular, such information may be used to:

  • Address customer support requests

  • Prevent cheating, fraudulent activity, or other unlawful conduct

  • Deliver advertising aligned with user interests

We will not use or disclose your Personal Information except:

  • To provide or offer products and services to you

  • For purposes you would reasonably expect

  • Where required or permitted by law

  • Where you have provided authorization or consent

This may include sharing information with professional advisors such as legal counsel, accountants, or other business consultants.

Third-Party Analytics and Advertising Services

We work with third-party analytics and advertising providers. Their privacy practices are governed by their own privacy policies. These providers include:

We encourage you to review their respective privacy policies for further information.

Advertising

Usage data and Non-Personal Information, including advertising identifiers, may be used to:

  • Track advertisement clicks

  • Evaluate advertising campaign performance

  • Control the frequency of ad displays

  • Deliver advertisements relevant to your interests

Depending on your device and operating system, you may have the ability to limit or reset the use of your device’s advertising identifier for interest-based advertising through your device settings.

Our Websites and Apps may contain advertising content. We and our advertising partners may use technologies such as cookies, tracking pixels, and web beacons within advertisements to collect Non-Personal Information.

Demographic data such as age or gender may also be used to ensure that advertising content is appropriate.

International Transfers

Your information may be transferred to, stored in, or processed in countries outside your country of residence, subject to applicable legal requirements.

How We Use the Information We Collect

We collect and use information to better understand your needs and improve our services, including for:

  • Internal record maintenance

  • Product and service enhancement

  • Security management

  • Public profile integration where social media features are used

  • Analysis of application usage and behavioral data

  • Providing updates or information about the App that may be relevant to you

We only process information to the extent necessary to fulfill the purposes for which it was collected.

Legal Basis for Processing (GDPR)

Where the General Data Protection Regulation (GDPR) applies, we process personal data in accordance with the relevant legal bases.

Age Verification

We process age-related data to determine whether a user is a child or an adult for data protection compliance purposes. This processing is necessary for compliance with legal obligations under Article 6(1)(c) of the GDPR.

Log, Device, Usage, and Consumption Data

Such data is processed to:

  • Provide and deliver requested products and services

  • Maintain and operate the App and gameplay experience

  • Send technical updates, administrative notices, and security alerts

  • Personalize and improve the App

  • Analyze trends, user behavior, and engagement

  • Provide contextual advertising to children (as defined under GDPR, COPPA, and other applicable laws)

  • Provide personalized advertising to adult users who have consented to sharing advertising identifiers

Processing for advertising and personalization is based on legitimate interests under Article 6(1)(f) of the GDPR. Disclosure of advertising identifiers for behavioral advertising is based on user consent under Article 6(1)(a).

Information from Other Sources

We may process information obtained from third parties to provide and deliver requested services and related communications.

Your Rights Under GDPR

In certain cases, our response period may extend up to three months as permitted under Article 12 of the GDPR.

Right of Access (Article 15)

You may request confirmation of whether we process your data and request access to:

  • Processing purposes

  • Categories of data involved

  • Recipients or categories of recipients

  • Data retention periods

You may also request a copy of your personal data, subject to limitations related to intellectual property or trade secrets.

Right to Object (Article 21)

You may object to processing based on legitimate interests where your particular situation justifies it. We will cease processing unless overriding legitimate grounds exist or processing is required for legal claims.

Right to Rectification and Erasure (Articles 16 & 17)

You may request correction of inaccurate data.
You may also request deletion of personal data where:

  • Consent has been withdrawn and no other legal basis applies

  • You object and no overriding grounds exist

  • Processing is unlawful

  • Deletion is required for legal compliance

  • The data is no longer necessary

  • Data was collected in connection with information society services

The right to erasure may be restricted where retention is required for legal compliance or legal claims.

Right to Restriction (Article 18)

You may request restriction of processing under certain circumstances. Where granted, processing will occur only with your consent, for legal claims, or for important public interest reasons.

Right to Withdraw Consent

If you withdraw consent, your license to use the App will automatically terminate.

If you would like, I can now:

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