Privacy Policy

Last updated: 12 August 2026

This Privacy Policy explains how CREATY GLOBAL OÜ ("CREATY GLOBAL", "we", "us", or "our") collects, uses, stores, shares, and otherwise processes personal data when you use our mobile applications and games (collectively, the "App").

The App may be offered as a free-to-play game with optional in-app purchases. We process certain information to operate the App, provide requested features and services, maintain security, improve gameplay and performance, provide customer support, measure usage, and, where permitted, display advertising.

We may update this Privacy Policy from time to time. If we make material changes, we will revise the "Last updated" date and, where required by applicable law, provide additional notice or request renewed consent.

Publication note: Before publishing this policy, confirm that the third-party SDKs, analytics tools, advertising partners, login providers, and other services listed below are actually used in the relevant App. Remove any service that is not used and add any material service that is missing.

1. Data Controller

For purposes of the General Data Protection Regulation ("GDPR") and other applicable data protection laws, the controller of personal data processed under this Privacy Policy is:

CREATY GLOBAL OÜ Registry code: 17049750
VAT number: EE102771062
Registered address: Harju maakond, Tallinn, Kesklinna linnaosa, Vesivärava tn 50-201, 10152, Estonia
Email: creaty.global.production@gmail.com

2. Information We Collect

2.1 Information collected automatically through the App

When you access or use the App, we may automatically collect the following categories of information:

The exact data collected may vary between our Apps, platforms, device settings, age restrictions, and the permissions or consent choices you make.

2.2 Information from third-party platforms and services

If you choose to connect to or sign in through a third-party platform or service, such as Apple Game Center, Google Play Games, Google Sign-In, or another supported provider, we may receive information made available by that provider in accordance with your settings and the authorization process.

Depending on the service, this may include:

Your use of those third-party services is also governed by their own terms and privacy policies.

Relevant policies may include:


3. How We Use Information and Our Legal Bases

We process personal data only where we have an appropriate legal basis under applicable law.

3.1 Performance of a contract

Where processing is necessary to provide the App or a feature you request, we rely on Article 6(1)(b) GDPR.

This may include processing necessary to:

3.2 Legitimate interests

Where appropriate, we rely on our legitimate interests under Article 6(1)(f) GDPR, provided those interests are not overridden by your rights and freedoms.

This may include processing necessary to:

3.3 Consent

Where required by law, we rely on your consent under Article 6(1)(a) GDPR, including, where applicable, for:

You may withdraw consent at any time through the relevant in-app settings, device settings, consent interface, or by contacting us. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

3.4 Legal obligations

We may process information where necessary to comply with a legal obligation under Article 6(1)(c) GDPR, including applicable tax, accounting, regulatory, legal-process, and record-keeping obligations.


4. Advertising

Some Apps may contain advertising.

Where applicable, we may use advertising partners to:

Where platform rules or applicable law require consent before accessing an advertising identifier or tracking a user across apps or services, we will request that consent before engaging in such processing.

Advertising partners we use may include, depending on the particular App:

The actual advertising partners may differ from App to App. The privacy practices of third-party advertising providers are governed by their own policies.


5. Analytics, Hosting, and Other Service Providers

We may engage service providers that process personal data on our behalf to support the operation, hosting, analytics, authentication, customer support, security, and maintenance of the App.

Depending on the App, these providers may include:

We require processors acting on our behalf to process personal data only in accordance with our instructions and applicable data protection requirements.


6. Sharing of Information

We may disclose personal data to the following categories of recipients where legally permitted:

We do not disclose more personal data than reasonably necessary for the relevant purpose.


7. Social Features

The App may offer social, multiplayer, leaderboard, sharing, or other integrated features.

Information you choose to share using such features may become visible to other users or to the public depending on the feature and the settings of the third-party platform involved.

You should not use social features unless you satisfy the minimum age requirements applicable to the App, the third-party service, and your jurisdiction.


8. Data Retention

We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:

Where we no longer have a lawful reason to retain personal data, we delete or anonymize it.

Unless a longer period is required or justified for one of the reasons above, we generally aim to delete or anonymize personal data no later than three (3) years after your last interaction with the relevant App or CREATY GLOBAL, subject to the nature of the data and the relevant legal requirements.


9. International Data Transfers

CREATY GLOBAL OÜ is established in Estonia. Some of our service providers and partners may be located outside the European Economic Area ("EEA"), or may process data in countries outside the EEA.

Where personal data is transferred outside the EEA, we use appropriate safeguards as required by applicable law. Depending on the destination and recipient, these may include:

You may contact us for additional information about the safeguards applicable to a particular transfer.


10. Security

We use reasonable administrative, technical, and organizational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.

No method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.


11. Push Notifications

With your permission, we may send push notifications or alerts to your device concerning gameplay, service updates, promotions, events, or other App-related information.

You can disable push notifications at any time through your device settings. Where required by applicable law, promotional notifications will be sent only with appropriate consent.


12. Children

Our Apps are not intended for children below the minimum age specified for the relevant App, platform, or jurisdiction.

Unless a particular App expressly states otherwise, users must be at least 13 years old, and we may apply a minimum age of 16 years in the EEA for features or processing for which we choose to require that age.

Where an App is directed to children or where we knowingly process children's personal data, we will apply additional protections required by applicable law and relevant platform rules.

If you believe that a child has provided personal data to us contrary to applicable law or the rules of the relevant App, please contact us at creaty.global.production@gmail.com.


13. Your Rights in the EEA, UK, and Certain Other Jurisdictions

Depending on where you live and subject to applicable legal conditions and exceptions, you may have the following rights:

Right of access

You may request confirmation as to whether we process your personal data and obtain access to that data and related information under Article 15 GDPR.

Right to rectification

You may request correction of inaccurate personal data and completion of incomplete data under Article 16 GDPR.

Right to erasure

You may request deletion of personal data in circumstances provided by Article 17 GDPR.

Right to restriction

You may request restriction of processing in circumstances provided by Article 18 GDPR.

Right to data portability

Where processing is based on consent or a contract and carried out by automated means, you may have the right to receive personal data you provided to us in a structured, commonly used, machine-readable format and to transmit it to another controller under Article 20 GDPR.

Right to object

Where we rely on legitimate interests, you may object to processing on grounds relating to your particular situation under Article 21 GDPR.

You may object at any time to processing for direct marketing purposes.

Right to withdraw consent

Where processing is based on consent, you may withdraw that consent at any time under Article 7 GDPR.

Right to lodge a complaint

You may lodge a complaint with the competent data protection supervisory authority. If CREATY GLOBAL OÜ is your relevant controller in Estonia, you may also contact the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon).

We generally respond to valid GDPR rights requests without undue delay and within one month, subject to any lawful extension permitted for complex or numerous requests.


14. California Privacy Rights

This section applies only to the extent the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA/CPRA"), applies to our processing of your personal information.

Depending on the circumstances and subject to applicable exceptions, California residents may have rights to:

Sale and sharing

We do not sell personal information in the ordinary sense of exchanging personal information directly for money.

However, certain disclosures of identifiers or activity information to advertising or measurement partners may qualify as a "sale" or "sharing" under California law even when no money is exchanged.

Where applicable, California residents may exercise the right to opt out by using the privacy or consent controls provided in the relevant App or by contacting us at creaty.global.production@gmail.com.

We do not knowingly sell or share the personal information of consumers under 16 without the affirmative authorization required by applicable California law.

Verification of requests

We may need to verify your identity before fulfilling certain privacy requests. We will request only information reasonably necessary for verification and may be unable to fulfil a request if we cannot reasonably verify the requester or associate the request with relevant data.


15. Data Deletion Requests

You may request deletion of personal data by contacting us at:

creaty.global.production@gmail.com

Please include enough information for us to identify the relevant App and, where possible, the device, account, player ID, or other identifier associated with your request.

We may retain certain information where required or permitted by law, including for legal compliance, fraud prevention, security, accounting, dispute resolution, or the establishment, exercise, or defense of legal claims.


16. Exercising Your Rights

To exercise a privacy right described in this Privacy Policy, contact us at:

creaty.global.production@gmail.com

When handling a request, we may ask for information reasonably necessary to:

If the App does not require a traditional user account and we collect only device-linked or automatically generated identifiers, our ability to identify data relating to a particular person may be limited. We will not collect substantially more personal data solely for the purpose of identifying a requester where applicable law does not require us to do so.


17. Changes to This Privacy Policy

We may modify this Privacy Policy to reflect changes in our Apps, technologies, business practices, service providers, or legal requirements.

We will post the updated version and revise the "Last updated" date. Where required by law, we will provide additional notice or obtain renewed consent before material changes take effect.


18. Contact

For privacy questions, requests, or complaints, contact:

CREATY GLOBAL OÜ Registry code: 17049750
VAT number: EE102771062
Registered address: Harju maakond, Tallinn, Kesklinna linnaosa, Vesivärava tn 50-201, 10152, Estonia
Email: creaty.global.production@gmail.com

If you are located in the EEA, you also have the right to contact the competent data protection supervisory authority regarding unresolved concerns.