Privacy Policy

Last updated June 2026

This is the Privacy Policy (“Policy”) of PocketHaven Games Ltd. (“PocketHaven”, “Company” “we”, “us”, “our” or any first-person reference in this document). This policy is aimed to help you understand how we collect, process, use, share and protect personal data about you and what are your rights regarding your personal data, whenever you engage with our games, websites, apps or any other services we provide (together: the “Service”).

Where necessary, additional information in relation to specific products and services is presented alongside such products and/or services regarding processing of your personal data.

We collect Personal Data in a number of ways depending on how you use the Service. This may include any information that is provided by you and/or that is received as part of the provision of the Services and/or as a result of your use of the Services, including on the website and/or the applications, as well as information that we receive from third parties such as platform providers, payment providers, analytics partners, advertising partners and social media platforms, to the extent applicable. All Personal data collected will be protected in accordance with laws applicable to us and subject to the legal or regulatory obligations and/or requirements that apply to us.

The Policy applies to information that is identified or reasonably identifiable to natural persons (“Personal Data”). You are not legally obligated to provide us with any Personal Data, however failure to provide it may impede our ability to provide some or all of our services to you. If you do not agree to our processing practices of your personal data, please refrain from playing our games or using any of our Services.

What Personal Data do we collect and how do we collect it?

Information you provide directly

We may collect some contact details, including first and last name or e-mail address in order to create and set up your account in our games or log you in to the games, thus allowing the provision of the Services to you. Such information will be provided directly by you. We may also collect such contact information for other purposes such as for competitions, surveys and other activities, only if you are willing to participate in such activities.

You may be able to add information about your user account in the game, such as your date of birth, your nationality, the place where you live, a profile picture and your avatar name. It is up to you whether you seek to provide this information. Some features in our games have the option to create a player profile that includes for example your avatar name and profile picture, and which may potentially be accessed, read or watched by other users of the Service.

Information we collect automatically and technical information

Gameplay information: while you play our games, whether using your account or as a guest, that is, even if you have not created and set up your account, we automatically collect analytical information so we can improve the gaming experience, and certain information generated from the in-game activities performed within the game, including but not limited to, game progress such as levels and scores and collected game points and items, the duration of gametime such as length of game sessions and the time they take place, interactions with other players, purchases you make in the game and other choices you make in the game, such as how you interact with certain features or pop-ups presented in the game, information about public comments, pictures or videos you may post on your profile or other players' profiles or game boards, including chat rooms in player message boards, and communications with our customer support service.

Device data: we may also automatically collect technical, device, advertising and usage information relating to your access to and use of the Service, such as device type, operating system, IP address, device identifiers, performance data, session information and interactions with features, content, advertisements or notifications, and attribution or ad interaction data received through analytics attribution and advertising partners.

Information relating to use of technologies: we employ various technologies, such as cookies, web beacons, SDK and similar technologies, that allow us to monitor the activity on our game apps and websites for purposes of facilitating your browsing, improving the efficiency of the Services, customizing the Services to your personal preferences as well as for statistics and the advertising and marketing of the Services. For mobile applications we may use cache, device identifiers and similar technologies. For browser applications, we may use cookies and similar technologies. These technologies may collect information, such as the duration of your visit on the site/page/screen, your browsing method and the actions performed therein. As mentioned above, the use of cookies facilitates your browsing experience by identifying you when you revisit our websites. Additionally, the cookies will monitor your activities and automatically collect information such as: IP address, connection dates, duration of your visit, version of the operating system, type of browser, country location, domain name and point of access to the Service, and other digital identification codes.

Some of these technologies are provided by third parties. Those third parties may use cookies, web beacons, and other storage technologies to collect or receive information from the website and elsewhere on the internet and use that information to provide measurement services and targeted ads. For example, we may work with partners such as advertising platforms or networks including Singular, Meta, TikTok, MixPanel, AppLovin and Unity. This usage is also subject to those third parties’ terms of use and privacy policies. We use third-party advertising services, including AppLovin and Unity, for the purposes of displaying advertisements, measuring campaign performance, and improving our marketing activities.

In this context, AppLovin and Unity may collect information regarding your activity on the website/application, such as interactions with content and advertisements, device characteristics, unique identifiers (such as IP address and advertising identifiers), as well as information regarding actions taken (such as views, add-to-cart events, or purchases).

For more information about AppLovin, please visit their website (Privacy Policy - Legal Information | AppLovin), where you can opt out of AppLovin’s collection and processing of information.

For more information about Unity, please visit their website (https://unity.com/legal/privacy-policy), where you can opt out of Unity’s collection and processing of information.

The settings of your device/computer may be updated or modified to completely or partially block the use of cookie files. However, if you choose to block cookies, some of the Services may not be available to you or you may be required to reenter your personal information. Such modification of settings is your responsibility.

You can also opt out from these tools during your browsing, for example by using the following websites:

http://www.aboutads.info/choices/

http://www.youronlinechoices.eu/

Google also offers an add-on for browsers that prevents it from collecting information.

Payment information

If you conduct purchases within the games, we receive the transaction details such as your email address and purchase details, from the third-party platform or store (such as Facebook, Apple, or Google). For certain users, we may also offer direct-to-consumer purchase options through a payment partner or checkout solution made available through a browser-based flow within our games. In such cases, payment-related information may be collected and processed by the relevant third-party payment processor, in accordance with their privacy terms and applicable payment standards, including PCI-DSS standards where applicable.

Information from third parties

We may receive Personal Data from third parties in connection with the Service, including from platform providers, app stores, payment processors, analytics providers, advertising and attribution partners, social media platforms, and other users where they invite you or interact with you through social features. This may include platform identifiers, profile information, purchase confirmations, advertising data, attribution data, and other information made available to us by those third parties subject to your settings and their privacy practices.

Information on others

If you provide us with information on others, it is your responsibility to verify that this is done in accordance with the provisions of the applicable laws. The provision of information about others is subject to their approval and the terms of this policy.

How do we use personal data, for what purposes and legal basis

We use your personal data for the purpose of providing the Services, including for creating your account in the game and enabling identification and log-in to the games; for personalizing and adjusting your game experience; for informing about updates in the games and special events and sales, for improving our Services; for our operational purposes; for contacting you and responding to public inquiries; for providing customer service; for marketing including targeted advertising (further details in the chapter of “Advertisements and direct marketing” below); for compliance with applicable laws, procedures and policies; for implementing information security, for handling privacy applications such as requests for access, rectification and deletion; for statistics and research; for prevention of fraud, cheating and/or illegal activities, and protection of legal rights and legitimate interests of ours and of others, all subject to the provisions of any applicable law.

Legal Basis for processing

We collect personal data for various purposes, such as providing our Service, creating your account, personalizing your gameplay experience, enabling in-game purchases, providing technical support, and improving our Services. Many privacy laws, such as the General Data Protection Regulation (GDPR), require us to identify a lawful basis for processing personal data. Thess legal bases determine why and how we are allowed to use your personal information. The lawful basis we rely on depends on the applicable laws in your location and the nature of your interactions with our Services.

The primary legal grounds we use include:

Contractual necessity, where processing is required to fulfil our obligations

• under the contract with you;

Your consent, where you have explicitly agreed to the processing of your

• information;
• Legitimate interests, where processing supports our or a third party’s legitimate purposes without overriding your fundamental rights and freedoms; or
• Legal or regulatory compliance, where processing is necessary to meet our legal obligations.

Sharing personal data with third parties and cross border transfer

As part of the Services, we may transfer your personal data to third parties, including to countries outside the place where you live, where the law providers lesser level of protection to personal data, for the purposes set out in this privacy policy and specifically in the following cases:

For providing our Service, we utilize and engage with service providers,

• processors and suppliers that provide us with services (such as companies processing credit card payments, cloud service providers, companies that provide support and maintenance for equipment, software providers, accountants, lawyers, banks, customer service centers and telecommunications companies.As part of the sale of the Company’s business (in part or in whole) or a merger, or during negotiation of such sale, provided that such third party meets the provisions of the law concerning protection of privacy and information security.
• Where social features are available, certain profile information and gameplay-related content may be visible to or accessible by other users, depending on the relevant feature and your settings. This may include, for example, your nickname, profile image, leaderboard position, used gear, guild or friends-related information, level, power and other user-generated content you choose to make available through the Service.
• For the realization of legitimate interests that we have, such as the prevention of frauds.
• Under a court order instructing the Company to do so or as required by law.
• For complying with our legal obligations and comply with law enforcement provisions.
• For defense in legal claims.

Such transfer of personal data will be subject to the third party’s undertaking to maintain the privacy and information security at a level that is appropriate for the type of information being transferred and in accordance with applicable laws.

Links to third parties

On our apps or website, links to external sources may appear, such as advertisements, banners, links etc. Should you choose to access such links, once you click on them you will be subject to the terms and conditions and the privacy policies of such websites/pages/applications. It is hereby clarified that you are fully responsible for the use of such external websites/pages/applications.

Advertisements and direct marketing

As mentioned above, your information may also be used for the marketing and personal advertising purposes of the Company or anyone on its behalf, as well as of third parties that are provided in cooperation with us, including personalized advertising.

Promotional and marketing ads, personalized or others, will be delivered to you by email or text messages if you have given your consent, when applicable, in which case, the ads could be personalized to you using information we have collected about you and your interests from our games you play and from your interactions online with other apps and websites. We may also deliver through our apps or in-game notifications if you allow in your app the authorization to receive push notifications.

. You will receive push notifications of updates as well as occasional offers of various products or services that may be of interest to you, based on your preferences and/or your use of the application.

You can request to be removed from the mailing list of advertisements by contacting us, by written application to the Company at the e-mail address that is specified in the mailing or through the “contact” page of the Website. Please be advised that even after you opt out from the mailing list you will continue to receive messages that the Company is required and/or permitted by law to deliver to you without requiring your consent.

Exercising your rights with relation to your personal data

Subject to the law where you live, you may have some rights with relation to your personal data, and apply to the Company in writing, as described below to exercise such rights:

• access the personal data that is kept by the Company in your regard. If you are a resident of California and the California Consumer Privacy Rights (CPRA) applies, this right specifically includes the right to know the categories of information we collected about you, the sources from which the information is collected, the purposes for which the information is being used, and the categories of third parties to whom the business has shared your information.

rectify the information if you find that the information that we have about you is

• incorrect or inaccurate.
• You may be entitled to request that we erase your personal data, under certain conditions.
• Under certain laws, you may have the right to opt-out of: a sale or sharing of your personal information (e.g., for targeted advertising); the use of sensitive personal information for non-essential purposes; automated decision making with your personal data.
• request that your personal information be provided in a portable and readily usable format.
• request that your personal data be restricted (i.e., stored but not processed) in certain circumstances.
• object to the processing of your personal data in certain circumstances.

to lodge a complaint with the competent Data Protection Authority in your

• jurisdiction.

When you make such requests, we may ask you to verify your identity so we can properly identify you and review your request in accordance with law. We will let you know our conclusions and fulfil your requests in accordance with the applicable laws.

Information security

We implement information security measures tailored to the nature of the data we manage and in compliance with applicable legal requirements. These measures adhere to industry standards and best practices to safeguard the information in our systems. However, no security system is completely immune to breaches. While we make efforts and take reasonable steps to protect the data and information systems, we cannot be held liable for damages resulting from unauthorized access or breaches beyond our control. We also emphasize the importance of your role in maintaining security by using strong passwords and protect them and keeping your software updated.

Data Retention

We retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, comply with legal obligations, resolve disputes, enforce our agreements, and as otherwise permitted or required by applicable laws. If you request deletion of your accoung or in-game user profile, we will take steps to delete or de-activate the relevant account or user information within our active systems, subject to verification and applicable law. However, certain information may be retained where permitted or required by law, including for security, fraud prevention, compliance, recordkeeping, internal analytics and de-identified or anonymized purposes. The specific retention period may vary depending on the type of data and the applicable legal or regulatory requirements.

Children

Depending on the law where you reside, the applicable law may regulate the protection of children’s privacy. We make efforts to comply with applicable laws, including such laws which set requirements for handling children’s personal data. Our Services are generally not directed to children under the age of 13 unless specifically stated otherwise. Certain games may be intended for or accessible to minors and may include age gating or other aged-based controls. Where required, we may apply different Personal Data collection, limiting certain features, all in accordance with applicable law.

If you are a parent or guardian and believe that your child has provided us with personal information without your consent, please contact us at support@pockethavengames.com. We will take appropriate steps to investigate and, where necessary, delete or restrict the relevant information.

Changes and updates to this Policy

The Company may update and/or change this privacy policy from time to time, as necessary and at its sole discretion. Please pay attention to such changes or updates, which you may view on the privacy policy that is available online. If we make material changes, we will make efforts to inform you about the new updates, and if required by law, we will send a notice to your e-mail address and create in game pop-ups.

Contact

You may directly contact the Company in any matter relating to the aforesaid policy in the following:

E-mail: support@pockethavengames.com