Privacy Policy

1. Who we are

The App is developed and published by GLANRA COMPANY LIMITED (“GLANRA”, “we”, “us”, “our”), located at 37/2/6 Street No 12, Quarter 3, An Khanh Ward, Ho Chi Minh City, Vietnam. For the purposes of data protection laws such as the EU/UK General Data Protection Regulation (GDPR), we are the controller of the personal data described in this policy, except where a third party acts as an independent controller (see Section 10).

This notice is the App-specific privacy notice referred to in the GLANRA Privacy Policy, which applies to all of our apps. For this App, this notice is the complete description of our practices; where the two differ, this notice applies.

You can reach us at any time at [email protected].

2. Information we collect

2.1 Information stored on your device

The App keeps a few settings in its own storage on your device so it works the way you left it: your chosen language, whether you have already seen the introduction and the rating prompt, how many times you have opened the App, your notification setting and the schedule of upcoming game reminders, and the game content packs you have downloaded (see Section 4). This information stays on your device and is not sent to us.

2.2 Information you send us

If you send us feedback (from “Send Feedback” in Settings, or after rating the App 1 to 3 stars), your email app opens with a message that you can review and edit before sending. If you send it, we receive your email address, your message, the star rating and the reasons you selected, plus the details the App pre-fills: operating system version, language and region setting, and App version. We use this only to respond and to improve the App.

2.3 Information collected automatically

When you use the App, we and our service providers (listed in Section 10) automatically collect:

• Device and app information: device model, operating system and version, App version, language, country or region, time zone, screen size, network type, and similar technical data.
• Identifiers: your device’s advertising identifier (the IDFA on iOS, only if you allow tracking; the Advertising ID on Android, unless you have deleted it), the identifier for vendor (IDFV) on iOS, app instance and installation IDs generated by Firebase and AppsFlyer, push notification tokens, and IDs generated by advertising SDKs.
• Usage data: which screens you open and how long you stay on them, which game you choose, buttons you tap (for example Settings, Retry or Home), the language you pick, how far you scroll through the game list, and when the App could not connect to the internet. We do not collect your scores together with your identity.
• Advertising data: which ads were requested, shown and clicked, estimated ad revenue, and attribution data (for example, which ad campaign led to the App being installed).
• Diagnostics: crash reports, error logs and performance data.
• Approximate location: a coarse location (such as country, region or city) derived from your IP address. It is used to show the right consent message, to serve and measure ads, and for aggregated analytics. The App does not request or use your precise (GPS) location.
• Push notification token: if notifications are enabled, Firebase Cloud Messaging and Apple (or Google) issue a token so we can send you notifications. The token is used only to deliver notifications.
• Content delivery data: game packs and introduction videos are downloaded from our content servers. Those servers receive standard request data (such as IP address and device and App information) that is needed to deliver the content.

2.4 What we do not collect

The App does not access your photos, contacts, calendars, health or fitness data, or precise location. It does not record video or audio, and it does not use face recognition or any other method to identify anyone.

3. Camera and hand/body tracking

• Why the App needs the camera. The games are controlled by moving your hands, and in some games your body, in front of the front camera. The live camera image is shown on screen while you play.
• How tracking works. On-device machine-learning models (Google MediaPipe) find the position of your hands or body in each camera frame. This produces temporary position points (for example, where your fingertip is) that exist only in your device’s memory while a game is running. Neither the camera frames nor these points are recorded, stored, uploaded, shared with anyone, or used to identify you, for advertising, for marketing, or for data mining.
• Microphone. The iOS App does not use the microphone. The Android App may ask for microphone permission together with camera permission, but it does not record, store or send any audio.

Camera access is optional. You can turn it off at any time in your device settings, but the games cannot be played without it.

4. Game content downloads

To keep the App small, the pictures, sounds and animations of each game are downloaded the first time you open that game, and the introduction videos are streamed from our content servers. The downloaded packs are stored in the App’s storage on your device (on iOS they are excluded from your device backups) and are removed when you uninstall the App. Downloads contain only game content; nothing about you is uploaded in this process beyond the standard request data described in Section 2.3.

5. Notifications

With your permission, the App can show two kinds of notifications:

• Game reminders are scheduled locally on your device (for example, a daily suggestion of a game to play). They are created by the App on your device and do not send any information to us.
• Push notifications (such as news about new games) are sent through Firebase Cloud Messaging and Apple Push Notification service or Google Play services, using the push token described in Section 2.3.

You can turn notifications off at any time in the App (Settings › Notifications) or in your device settings. Turning them off in the App cancels scheduled reminders and deletes the push token.

6. How we use information

We use information for the purposes below. If you are in the European Economic Area (EEA), the United Kingdom or Switzerland, the table also shows our legal basis under the GDPR.

We do not sell your personal information for money. We do not make decisions based solely on automated processing that have legal or similarly significant effects on you.

7. Advertising and tracking

The App shows banner, native, interstitial, app-open and rewarded ads, served by Google AdMob and, on Android, also by AppLovin MAX. These services can fill ads through other ad networks (“mediation”), which are listed in Section 10. These partners may collect the data described in Section 2.3 to serve ads, limit how often you see the same ad, measure performance, and detect fraud. If you have allowed it, they may also use this data to show ads that are personalized to your interests.

• iOS – App Tracking Transparency. The App asks for your permission before your data is used to track you across apps and websites owned by other companies. If you choose “Ask App Not to Track”, the IDFA is not shared, and you will still see ads, but they will be less relevant. You can change this at any time in Settings › Privacy & Security › Tracking.
• Android – Advertising ID. You can reset or delete your Advertising ID in your device settings (usually Settings › Privacy › Ads, or Settings › Google › Ads).
• Consent in the EEA, UK, Switzerland and some U.S. states. Where required, the App shows a consent message powered by Google’s User Messaging Platform (which uses the IAB Transparency & Consent Framework in the EEA/UK) before personalized ads are served. You can review or change your choices through the privacy settings option in the App, where available, or by contacting us.

Ads are provided by third parties. We do not control their content or the websites and apps they link to, and those have their own privacy policies.

8. Purchases

The App does not currently offer in-app purchases. If we add them in the future, they will be processed by the Apple App Store or Google Play under their terms and privacy policies. We will not receive or store your payment card, bank account or billing address details. The store would tell us only what you bought (product, price and currency, transaction identifiers, purchase dates and status), which we would use to unlock and restore features, prevent fraud, measure revenue, and meet legal obligations. We will update this policy before that happens.

9. How we share information

We share information only as described in this policy:

• Service providers that host game content and provide analytics, crash reporting, push notifications, remote configuration, attribution and consent management. They process data on our behalf and under our instructions.
• Advertising partners that serve and measure ads in the App. Some of them act as independent controllers of the data they collect under their own privacy policies.
• Apple and Google, for app distribution, ratings and platform features (for example SKAdNetwork/AdAttributionKit ad measurement on iOS and the Install Referrer on Android).
• Legal and safety reasons: when we believe in good faith that it is required by law or legal process, or that it is needed to protect the rights, property or safety of our users, the public or us.
• Business transfers: if we are involved in a merger, acquisition or sale of assets, information may be transferred as part of that deal, and it will remain subject to this policy or one that is at least as protective.

We work only with third parties that commit to protecting personal data with the same or equal protection as described in this Privacy Policy and as required by applicable law, the Apple App Store Review Guidelines and Google Play policies. We also require them to use the data only for the purposes for which it was shared.

10. Third-party services we use

This list reflects the current versions of the App and may change as we add or remove partners. Not every partner is used on every platform.

11. Data retention and deletion

When data is no longer needed, we delete it or make it anonymous.

12. Your choices and controls

• Camera: turn camera access on or off in your device settings.
• Tracking and ad personalization: see Section 7 (App Tracking Transparency on iOS, Advertising ID on Android, and the consent message where shown).
• Notifications: turn push notifications and game reminders off in the App under Settings › Notifications, or in your device settings, at any time.
• Local data: uninstalling the App removes its settings and downloaded game packs from your device.
• Withdraw consent: you can withdraw any consent at any time. This does not affect processing that already took place.

13. Your privacy rights

Depending on where you live, including under the GDPR, the UK GDPR, Vietnam’s personal data protection law and U.S. state privacy laws, you may have the right to:

• access the personal data we hold about you and get a copy of it;
• have inaccurate data corrected;
• have your data deleted;
• restrict or object to certain processing, including processing based on legitimate interests and direct marketing;
• receive your data in a portable format;
• withdraw consent at any time; and
• complain to your local data protection authority.

How to make a request. Email [email protected] with the subject “Privacy Request”. The App has no user accounts, so please include details that help us find your data, for example the email address and approximate date you contacted us. We may ask you to verify your request. We will respond within one month, or within the time required by the law that applies to you. Most usage and advertising data is held by our partners under device identifiers that we cannot link to you. In that case, we will explain how to contact the partner directly, and you can also use the device controls in Section 12.

14. U.S. state privacy notice

This section applies to residents of California and other U.S. states with comprehensive privacy laws.

• Categories we collect: identifiers (such as advertising and device IDs); internet or other electronic network activity (App usage and ad interactions); approximate geolocation; and inferences that advertising partners may draw about your interests. Camera input is processed only on your device and is not collected by us. We collect these from your device and from our partners, for the purposes described in Section 6.
• “Sale” and “sharing”: we do not sell personal information for money. However, allowing ad partners to collect identifiers and usage data for personalized, cross-context behavioral advertising may count as a “sale” or “sharing” under some state laws. To opt out, decline personalized ads in the consent message where it is shown, choose “Ask App Not to Track” on iOS, delete your Advertising ID on Android, or email us with the subject “Do Not Sell or Share”.
• Sensitive information: we do not collect biometric identifiers, and we do not use or disclose sensitive personal information to infer characteristics about you.
• Your rights: you may request to know, access, correct and delete your personal information, and to opt out as described above. You may use an authorized agent. We will not discriminate against you for exercising your rights.
• Retention: see Section 11.

15. Children

The App is a general-audience game and is not directed to children under 13, or under the minimum age required in your country to consent to data processing (for example, 16 in some EEA countries). We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us and we will delete it.

16. Security

We use reasonable technical and organizational measures to protect information, including encrypted connections (HTTPS) and integrity checks for downloaded game packs, and reputable, secure cloud providers. Camera data never leaves your device. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

17. International transfers

We are based in Vietnam. We and our service providers may process information in countries other than the one where you live, including the United States and other countries where our providers operate. Where the law requires it, we rely on appropriate safeguards for these transfers, such as the European Commission’s Standard Contractual Clauses or equivalent mechanisms.

18. Changes to this policy

We may update this policy from time to time, for example when we add features or partners. We will change the “Last updated” date above and, when changes are significant, give you notice in the App or on this page. If you keep using the App after an update, the updated policy applies.

19. Contact us

If you have questions or requests about this policy or your data, contact:

GLANRA COMPANY LIMITED
37/2/6 Street No 12, Quarter 3, An Khanh Ward, Ho Chi Minh City, Vietnam
Email: [email protected]
Telephone: +84 348 635 424
Support: glanraltd.com/support