Privacy Policy

What this policy covers

This policy covers every Cubeage game and the Cubeage account that runs across them, on every platform we publish on, including games first published under an earlier publisher name. It covers personal information we collect through the games, our websites and our support channels.

It does not cover the App Store, Google Play, or other services you reach from our games. Those companies decide what they collect under their own privacy policies.

Who we are

Cubeage Limited, a company incorporated in Hong Kong, is responsible for your information under this policy (the "data controller" or "data user"). You can reach us through the contact page or at the email address in the last section.

What we collect

• Account: your player id, the display name you choose, the language you play in, and the sign-in methods you link (Apple, Google, Game Center, Play Games or an email address). A guest account holds only the device key that keeps it on your device.
• Game data: your progress, the virtual items you hold and how you gained and spent them, which games your account has played, and anything you post in a game’s chat or community channel.
• Purchases: what you bought, when, the price and currency, and the order or transaction reference, from Apple, Google or Sylphx Money, and any refund or chargeback of it. Card and bank details do not reach us.
• Rewarded ads: when you finish a rewarded ad, the ad unit and the transaction id, so the reward is granted once.
• Analytics: events your game sends about play — sessions, playtime, progress, purchase attempts and your consent choices — with your account id.
• Support: the messages you send us, the email address you write from, and the account or order they are about.
• Security: sign-in and account events, an irreversible hash of your IP address, identifiers for the device you signed in from, signals our anti-cheat and fraud checks use, and a push token if you allow notifications.
• Our websites: your language and theme choices, and a sign-in cookie while you are signed in. These are necessary for the site to work, so they do not need consent.

You give us your account details because we need them to provide the service: without them we cannot run your account or deliver what you buy.

Why we use it, and on what legal basis

Where the law asks us to name a legal basis (for example in the European Economic Area and the United Kingdom), it is the one shown for each use:

• Creating your account, signing you in, saving and syncing progress, taking payment, delivering and restoring purchases, and running the games, events and notices — to perform our contract with you.
• Keeping play fair and the service secure: detecting cheating, collusion, fraud, chargebacks and refund abuse, limiting abuse, and applying the steps in our terms — our legitimate interests in a fair and secure service and in protecting our revenue.
• Answering Apple’s questions about a refund you asked it for — our legitimate interests, and the agreement in our terms.
• Understanding how the games are used, fixing faults and improving them — our legitimate interests in developing our games; where a game reads or stores information on your device for this, your consent where the law requires it.
• Choosing the offers and prices you see in a game — our legitimate interests in selling our games, or your consent where the law requires it.
• Showing rewarded ads and measuring our advertising campaigns — your consent where the law requires it, otherwise our legitimate interests.
• Answering support requests — to perform our contract with you, and our legitimate interests in helping players.
• Sending marketing messages — your consent.
• Keeping records for tax and accounting, and meeting legal duties — legal obligation.
• Enforcing our terms of service, and establishing, exercising or defending legal claims — our legitimate interests.
• Selling or reorganising all or part of our business — our legitimate interests.

Where we rely on legitimate interests, we have weighed them against your rights and freedoms; you can ask us for details of that assessment.

Who else handles your information

We share personal information with:

• Sylphx Money — payments, receipts, entitlements, refunds and order records.
• Sylphx Support — the help centre and your support conversations.
• Sylphx Signal — analytics.
• Apple and Google — the App Store and Google Play, in-app purchases, refund decisions, and the sign-in methods they provide (Apple and Game Center; Google and Play Games).
• Google AdMob — rewarded ads, in the games that have them.
• Tenjin — campaign measurement, in the games that use it.
• Our hosting, network and communications providers.
• Our professional advisers, auditors and insurers.
• A buyer or successor, and its advisers, if we sell or reorganise all or part of our business.
• Courts, regulators, law enforcement and others, where the law requires it or where it is needed to protect our rights, our players or others, including to prevent fraud.

We do not sell your personal information for money. Where a game shows personalised ads or measures campaigns, some US state laws treat the ad partner’s use of the data as "sharing" or "targeted advertising"; you can opt out of it in the game under Settings → Privacy. We may change these providers as the service develops.

Ads, consent and marketing

• Where a game has ads, they are rewarded ads you choose to watch.
• In games that need it, Google’s consent flow and Apple’s App Tracking Transparency ask you before personalised ads or tracking. Declining does not stop you playing.
• You can change your choices at any time in the game under Settings → Privacy.
• We send you service messages about your account and purchases — sign-in codes, order notices, security warnings and changes to our terms. Marketing messages need your consent, and you can withdraw it at any time.

Automated decisions

Automated systems check play and purchases for cheating, collusion, fraud and refund abuse. They can restrict trading or purchases, or suspend an account, because that is needed to run a fair game under our contract with you. You can ask for a person to review such a decision, give your side, and contest it, through the contact page.

How long we keep it

• We keep your information while your account exists, and afterwards for as long as we need it for the purposes above.
• You can delete your account at any time. After a 30-day grace period, in which you can cancel, we delete the account and its data in every game.
• We keep what we need after that: purchase, refund and chargeback records for tax, accounting and disputes, and the records we need to prevent fraud, refund abuse and ban evasion, meet legal duties, and establish or defend legal claims. Where we can, we keep them without your personal details.
• Analytics events are kept for a limited period and then deleted or reduced to totals that do not identify you.
• Deleted data can remain in encrypted backups until they expire and are overwritten.

Your rights

• Delete your account and its data: delete my account.
• Access or correct your information: ask us with your player id.
• Change your analytics, ads and personalised-offer choices: in the game, under Settings → Privacy. Withdrawing consent does not affect what we did before.
• Complain to us, or to the data protection authority where you live.

In the European Economic Area, the United Kingdom and Switzerland you also have the right to have your information erased, to restrict our use of it, to receive it in a portable form, and to object to our use of it where we rely on legitimate interests. You can object to direct marketing at any time.

We answer within the time the law of your market sets. We may need to confirm your identity first. Where the law allows, we may charge a reasonable fee for, or refuse, a request that is manifestly unfounded, excessive or repetitive, and we may keep information the law allows us to keep.

How we protect it

We use technical and organisational measures appropriate to the risk, such as encryption in transit, hashed or sealed secrets, and access limited to the people who need it. No system is completely secure. If you believe your account is no longer safe, tell us at once. Where a personal data breach happens, we notify the regulator and you as the law requires.

Where your information is processed

We are a Hong Kong company, and we and our providers process information in Hong Kong and in other countries, which may have different data protection laws from yours. Where the law requires it, we protect those transfers with safeguards such as standard contractual clauses.

Children

Our games are not made for children under 13, and there is no child account. We do not knowingly collect personal information from a child under 13, or under the age of digital consent where the child lives, without a parent or guardian’s consent. If we learn we have, we delete it.

A parent or guardian can contact us with the order number to have a child’s account and data deleted. Refunds for purchases are handled by Apple and Google under their own policies.

Market-specific information

• Hong Kong: you can ask for access to and correction of your personal data under the Personal Data (Privacy) Ordinance by emailing our data protection contact in the last section. We may charge a fee for a data access request that is not excessive, as the Ordinance allows.
• Taiwan: we collect and use personal information for the purposes of online game services, consumer and customer management, e-commerce, marketing with consent, information security and statistics, for the period stated in this policy, in the places and with the recipients it names. You have the rights under article 3 of the Personal Data Protection Act. If you do not provide the information an account needs, we cannot provide the service.
• United States: depending on your state, you may have the right to know, access, correct and delete personal information, to opt out of targeted advertising and profiling, and to appeal our decision on a request. We do not discriminate against you for using these rights. We do not knowingly sell or share personal information of consumers under 16.

Changes to this policy

We may update this policy. The date at the top shows the current version. Where the law requires it — for example before we use your information for a new purpose — we tell you in the game or by email first.

How to contact us

For anything in this policy, including a data request or a complaint, write to our data protection contact at support@cubeage.com.

Cubeage Limited (Hong Kong).