Privacy Policy

Effective Date: 28th March, 2025

1. INTRO

We, Cozy Captain Limited, are a technology company specializing in designing, developing, and operating mobile games. This Privacy Policy outlines how and why we collect, store, use, disclose, and otherwise process personal data obtained through our website, online advertisements, and mobile games (together referred to as our "Services"). This Privacy Policy does not cover other types of data we collect, such as data gathered offline, from job applicants, or employees.

If you have any concerns about sharing your data with us or its use as described in this Privacy Policy, please refer to Section 6 (Control Over Your Information) and Section 7 (Requests to Exercise Privacy Rights) of this document, or contact our Data Protection Officer at contact@cozycaptain.co.uk.

2. WHAT TYPES OF PERSONAL DATA WE COLLECT AND HOW WE COLLECT IT

Personal Data Collected Directly from You

We may collect the following categories of personal data from you, depending on how you use our Services and your location:

• Contact Information, such as your country or region, name, surname, email address, or username.

• User-Generated Content, which includes any files, documents, videos, images, data, or information you upload or share through your communications with us or while using our Services.

• Profile and Gameplay Information, such as your screen name, avatar, or profile picture; in-game progress, scores, achievements, and payments (including details on what you paid for, the time of payment, and the amount); competitions you participate in; usage details for our Services; and membership or participation in teams, including messages shared in team forums.

• Survey Information, which includes feedback and ratings about our Services.

• Inferences, such as predictions about your interests and preferences derived from your usage of our Services.

• Parental Information, including your parent’s email address and a PIN, required only when you activate parental control settings within our Services.

Information We Collect Automatically

Depending on your interaction with our Services and your location, we may automatically collect and process the following types of personal data:

• Analytics Data, including a user ID linked to details about how you interact with our games, advertisements, and other Services; event and conversion data; information about your device; your Internet Protocol (IP) address; browsing history; operating system and version; browser type and version; and performance data such as crash logs, diagnostics, loading times, latency, framerate, and battery life.

• Device Data, such as persistent and non-persistent unique device IDs, Identifier For Advertisers (IDFA) on iOS, Google Advertising ID on Android, Identifier for Vendor (IDFV) on iOS, App Set ID on Android, and game center ID.

• Location Data, including your approximate location based on your IP address.

• Commercial Information, such as products or services purchased, considered, or other purchasing histories or tendencies.

Personal Data Collected from Third Parties

While most of the personal data we collect is directly from you through gameplay or interaction with our Services, we may also collect data from third parties in the following circumstances:

• Social Media: When you engage with our Services through social media platforms (e.g., "Liking" our official Facebook page, following us, or sharing content), we may receive information about you depending on your privacy settings on those platforms. This may include your name, profile picture, and friends list. Review and adjust your privacy settings on third-party services to manage the information you share publicly or link with our Services.

• App Marketplaces: When you download our applications or make in-app payments via the Apple App Store, Google Play, or other marketplaces, we receive data about your device, account, and payments. However, we do not have access to your credit card or bank account details. The personal data we obtain from these platforms depends on your privacy settings with the respective marketplace.

• Information from Authentication Services Linked to Our Services:

Certain parts of our Services may let you log in through a third-party social network or authentication service, such as Facebook, Google, or Apple. These services will verify your identity and may allow you to share specific personal data with us, including your name, email address, user ID linked to the third-party service, profile picture, and, for Facebook, the names and avatars of your Facebook friends who are already playing our games. The data we receive depends on the third party’s policies and your privacy settings on their platform. Where applicable, you can also view which friends are playing the same game and their progress (and they can see your progress), or access additional features within our games, such as inviting friends to play. You can opt not to share your email address by adjusting your preferences in the Facebook dialog box when linking your Facebook account to your Cozy Captain profile.

When logging in with Facebook, we will not post anything on your page without your permission, nor will we access information about Facebook friends who are not playing our games. If you prefer your Facebook friends not see your progress, you can disconnect your Facebook account from our games and update your app permissions in your Facebook settings. If you choose not to link your Cozy Captain profile to a Facebook, Google, or Apple account, the personal data we collect while you play our games will be linked to a randomly generated user ID rather than directly identifying information. However, we will still gather device-level identifiers and related data as described above. We recommend reviewing Facebook's Privacy Policy and periodically adjusting your privacy settings to ensure you fully understand how your Facebook data is shared.

• Other Sources:

We may also obtain personal data from publicly available sources, third parties with your prior consent, or as part of transactions such as mergers and acquisitions.

3. PURPOSES FOR PROCESSING YOUR PERSONAL DATA

We may process your personal data for the following purposes, depending on your interaction with our Services and your location:

• To personalize your in-game profile, provide our games (including social features like team play and competitions), activate paid services within the games, and deliver player support when needed.

• To optimize our games for your use and device, and to offer tailored in-game events, promotions, and offers.

• To manage our organization and day-to-day operations.

• To verify your identity and entitlement to products or Services when accessing them or contacting us.

• To request your feedback via surveys about our company, partners, or Services.

• To maintain the safety, security, and integrity of our property, Services, technology assets, and operations.

• To operate, enhance, and optimize our games and other Services.

• To customize our Services, understand user preferences, and improve the experience and enjoyment of our users.

• To provide access to specific areas, features, or functionalities of our Services, including multiplayer competitions and social elements.

• To communicate with you regarding Services-related information, such as confirmations, technical notices, updates, security alerts, and administrative or support messages.

• To enable communication between players in games or through our social media accounts.

• To address your comments or inquiries and deliver customer support services.

• To prevent prohibited or illegal activities, such as cheating or fraud, and to safeguard our players.

• To measure user interest in our Services.

• To ensure internal quality control.

• To comply with applicable laws, prevent fraud, and enforce our Terms of Service or defend our legal rights where necessary.

• To activate, verify, and enforce parental control settings.

• To fulfill contractual and legal obligations.

• To offer support via customer service channels when requested.

• To conduct internal research and analytics.

• To evaluate or participate in a reorganization, restructuring, merger, acquisition, or partial or full sale of our business or assets (“Business Transaction”).

• To engage in marketing activities outlined in this Privacy Policy.

4. DISCLOSURE OF YOUR PERSONAL DATA

We may share personal data with the following types of third parties and under the circumstances described below:

• Other Users in Your Online Community: If you participate in our online communities or send virtual gifts or items to other users within our Services, we may share your public profile information with other community members. This can include your screen name, profile picture or avatar, in-game scores and achievements, gifted items, and any other information you voluntarily make public.

• Contests, Sweepstakes, and Survey Providers: We may share personal data with third parties that assist us in conducting contests, sweepstakes, or surveys and in processing related responses.

• Service Providers: We may share your personal data with our service providers (data processors). These service providers include companies that (i) deliver IT and related services; (ii) provide customer service support; (iii) offer analytics and search engine services to enhance and optimize our Services; and (iv) perform other activities supporting our Services. Contracts with these providers prohibit them from using or disclosing personal data for purposes beyond performing services on our behalf or complying with legal obligations.

• Protecting Rights and Meeting Legal Obligations: We may access, preserve, and disclose your personal data to third parties, such as legal advisors or law enforcement, if we believe it is necessary or appropriate to:

(i) comply with legal requirements, such as court orders, subpoenas, or law enforcement or national security requests;

(ii) respond to your requests;

(iii) protect the rights, property, or safety of yourself, us, or others;

(iv) enforce our policies or contracts;

(v) collect amounts owed to us;

(vi) prevent physical harm, financial loss, or investigate/prosecute suspected illegal activity;

(vii) establish, exercise, or defend legal claims; or

(viii) act in good faith if disclosure is deemed necessary or advisable.

• Ad Networks and Advertising Partners: We collaborate with third-party ad networks and advertising partners to deliver ads and personalized content across external websites, services, and devices. These parties may collect information directly from your browser or device through cookies or similar technologies when you access our Services. Such data is used for targeted advertising, reporting, attribution, analytics, and market research. For more details, refer to Section 5 (Targeted Advertising). Where applicable laws permit, we may also share personal data with advertising partners to deliver information we think may interest you.

• With Your Consent: With your consent or at your direction, we may share personal data with third parties or publicly. For example, with your approval, we may feature your testimonial on our website or other Services.

• Sale of Assets and Change of Control: In connection with evaluating or entering into Business Transactions, we may disclose personal data to potential acquirers of our business assets and their representatives.

5. TARGETED ADVERTISING

We partner with third-party advertising networks and technology providers ("AdTech Providers") to display targeted online ads to users of other websites, games, and services. These ads are intended for users identified as having potential interest in our Services. To facilitate targeted advertising, we may share the following personal data with our AdTech Providers:

• Identifier For Advertisers (IDFA) and Google Advertising ID

• IP address

• Details of the Services you have used

• Dates and times of interaction with our Services

• Inferred interests

Our AdTech Providers use this data to show ads that are more relevant to user interests and provide advertising-related services like reporting, attribution, analytics, and market research. They may combine the data we share with other data they have collected about the same individuals through external websites and services that use the same AdTech Providers. This Privacy Policy does not govern the collection or use of personal data by our AdTech Providers. We recommend reviewing their privacy policies to better understand their practices.

6. CONTROL OVER YOUR INFORMATION

You have several options to manage how our Services handle your personal data:

Delete or Reset Our Services:

If you remove our games from your mobile device, we will stop collecting personal data via the games on that device. Additionally, any data related to our Services stored on your device (such as game progress) may be deleted. However, any personal data collected before you deleted the games may still be processed by us. You can also reset your mobile advertising identifier in your device settings, which will make you appear to us and our advertising partners as a new user unlinked to prior activities or data.

Deactivate Your Account:

To fully deactivate your account, you can unlink your Facebook account from our mobile games and remove the games from your devices. Be aware that deactivating your account will result in the loss of all game progress and any unspent virtual items, which may not be recoverable. We may still process any personal data collected prior to the deactivation of your account.

Change Access to Device Information:

You can manage our Services’ access to your device information via your device's "Settings" app. For example, you can revoke permissions for accessing network devices, location data, or integration with other apps.

Deactivate Push Notifications:

If you enable push notifications for our apps, we may occasionally send you updates, high scores, and other notifications of interest. You can disable these communications at any time by adjusting your mobile device’s notification settings.

Targeted Advertising:

• If you reside in the EEA, UK, Switzerland, or South Korea, we will ask for your consent to carry out the targeted advertising activities described in Section 5 (Targeted Advertising) when you first use our games. You can later withdraw this consent by navigating to Settings > Terms & Privacy.

• In the U.S., you can opt out of targeted advertising by accessing Settings > Terms & Privacy. While opting out prevents the use of your personal data for targeted ads, you may still see non-targeted ads for our products and Services.

• Additionally, you can block your device's ad identifier from being used for interest-based advertising or reset it via your device settings. The exact location of these settings may vary, but they are typically found under "privacy" or "ads."

• To modify your advertising preferences on Facebook, log into your Facebook account and update your settings there.

Submit a Request to Exercise Privacy Rights:

You may have privacy rights under the laws applicable to you or us. Refer to the next section for details on how to submit a privacy rights request.

7. REQUESTS TO EXERCISE PRIVACY RIGHTS

Depending on the privacy laws governing our use of your personal data, you may have the following privacy rights:

• Access to Personal Data: The right to access your personal data that we process.

• Correction or Deletion: The right to request correction of inaccurate or incomplete personal data or deletion of your data under certain conditions.

• Restriction of Processing: The right to request restrictions on processing your personal data under specific circumstances.

• Objection to Processing: The right to object to certain uses of your personal data under applicable conditions.

• Data Portability: The right to receive your personal data in a structured, commonly used format to facilitate its transfer to another service provider when certain criteria are met.

• Opt-Out Rights:

• Non-Discrimination: The right to not experience discriminatory treatment for exercising your privacy rights. Note, however, that if exercising such rights limits our ability to process your data (e.g., deletion requests), we may no longer be able to provide some Services or interact with you as before.

• Appeal Rights: If we deny your request to exercise your rights, you may have the right to appeal. If applicable, we will inform you of the denial, provide reasons, and offer instructions on how to submit an appeal.

• Withdrawal of Consent: When we process your personal data based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent will not impact the legality of our prior use of your personal data.

To submit a privacy rights request, please contact us using the details provided in the "Contact Us" section. In your request, clearly indicate the rights you wish to exercise and how we may assist. For security purposes, we may request additional information to verify your identity and ensure your request is valid. We may also seek clarification about the scope of your request to expedite our response. All requests will be handled in compliance with applicable laws.

Right to Opt Out of:

• Right to Non-Discrimination: You have the right not to face discriminatory treatment for exercising these rights. Please note, however, that exercising certain rights (such as requesting deletion of your data) may limit our ability to process personal data, potentially preventing us from offering certain products, services, or interactions.

• Right to Appeal: If we refuse to take action on a request to exercise your rights, you may have the right to appeal our decision. In such cases, we will notify you of the reasons for the denial and provide instructions on how to submit an appeal.

• Right to Withdraw Consent: In specific situations where we request your consent to process your personal data, you have the right to withdraw your consent at any time. Withdrawing your consent will not affect the legality of our prior processing of your personal data.

To submit a request to exercise your privacy rights, please contact us using the methods outlined in the Contact Us section below. In your request, specify which rights you wish to exercise and how we may assist you. We may require additional information to verify your identity and ensure you are authorized to make the request. These security measures are in place to prevent unauthorized disclosure or processing of your personal data. If necessary, we may reach out for further clarification about your request to expedite our response. We will handle all requests in compliance with applicable laws.

8. CHILDREN

We do not knowingly collect personal data from children aged 12 or under. If a child 12 or under has provided personal data to us, we encourage their parent or guardian to contact us to request removal of this data from our systems. If you suspect we may have collected personal data from or about children, please contact us directly.

If you are above the age of 12 but below 18 (or the age of majority in your jurisdiction if higher), you must obtain permission from your parent or legal guardian to use our Services. Parents can use parental controls in the "Settings" menu to enable or disable features such as chat, in-app purchases, or other functionalities. Once activated, these controls cannot be modified without a pre-set password. If we become aware that a user has not reached the age of majority, we may adjust how we handle their personal data to comply with relevant laws.

9. SECURITY

We employ physical, technical, electronic, and procedural measures to safeguard personal data from unauthorized processing. These measures include firewalls, data encryption technologies, internal data security protocols, and binding data protection agreements with organizations handling your personal data on our behalf.

However, no server, computer, communication network, or system, nor any data transmission over the internet, can be guaranteed to be completely secure. While we make every effort to protect your personal data, we cannot ensure or warrant the security of any data transmitted to us or through our Services.

10. THIRD-PARTY WEBSITES

Our Services may contain links to third-party websites, plug-ins, and applications. Unless we expressly adopt, refer to, or link to this Privacy Policy, it does not apply to the personal data practices of third-party websites, online services, or other third parties. We are not responsible for their handling of personal data. To learn about their practices, please refer to the privacy policies provided by these third parties.

11. RETENTION

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected or as required by applicable legal obligations. The duration of retention depends on the purposes for which the data is used and the timeframes needed to meet legal, regulatory, tax, accounting, or reporting requirements, establish or defend legal claims, or provide the data to courts, judges, or competent public authorities. Once the personal data is no longer needed for its intended purposes, we will delete it.

12. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy periodically and post the revised version on this page. Any updates will include a change to the date at the top of the Privacy Policy. If significant changes are made, we will notify affected individuals via email to their registered address, prominent announcements on our Services, or other suitable communication channels. The updated Privacy Policy will take effect on the date of publication.

13. CONTACT US

If you have questions about our privacy practices, how we process personal data, or if you wish to exercise your rights under applicable privacy laws, you can contact us at contact@cozycaptain.co.uk.

Address: 1 St Katharine’s Way, London, E1W 1UN