9. Analytics, attribution and the events we sendWe use two categories of measurement partner:
- Firebase (Google) — Analytics, Crashlytics, Remote Config and Cloud Messaging. Product analytics, crash reporting, A/B experiments and push notifications. The Firebase project is held by LLC Karfarol Games, and Google acts as its processor.
- Singular (Singular Labs, Inc.) — mobile measurement and attribution. Tells us which marketing campaign led to an install and how those users behave afterwards, so we can measure what our advertising is worth. The Singular account is held by LLC Karfarol Games, and Singular acts as its processor.
The advertising accounts, by contrast, are held by
Mno Go Apps LTD (Section 8 and Annex A).
Both receive device and advertising identifiers, App and device data, and the gameplay and purchase events described in Section 6, subject to your consent choices.
We do not attach any age category, parental-consent status, health, financial or biometric data to these events, and we do not send free text you have typed into the App.
10. Payments and restoring purchasesAll payments are processed by
Apple or
Google through the in-app purchase systems of the App Store and Google Play. We do not receive, store or process your payment card details. Depending on the store and your country, Apple or Google may act as the seller of record — our Terms of Use explain who sells what where.
- Restore Purchases in the App asks the store whether your store account holds a valid non-consumable purchase. This is a check against Apple’s or Google’s servers using your store account. We keep no server-side record of your receipt and cannot look up your purchase history.
- Refunds are handled by the store. Where we handle a Google Play refund request ourselves, we process it through the Google Play Console, and we will hold your correspondence about it under Section 6.8.
- The App does not currently offer subscriptions. If we introduce one, we will update this policy before it becomes available.
11. Who we share data with11.1 Categories of recipients- Advertising networks, exchanges and mediation platforms — to select, deliver, cap and measure ads. Contracted by Mno Go Apps LTD and named in Annex A.
- Analytics and attribution providers — Google (Firebase) and Singular, contracted by LLC Karfarol Games.
- Each other. The two companies described in Section 1 share this data between themselves so that each can do its part. That involves personal data reaching LLC Karfarol Games in Georgia — see Section 13.
- Cloud and infrastructure providers — hosting for the systems on which we receive and analyse reports.
- The app stores — Apple and Google, in connection with distribution, payments and refunds.
- Professional advisers — accountants, auditors and lawyers, where necessary and under a duty of confidentiality.
- Authorities and courts, where we are legally required to disclose, or where disclosure is necessary to establish, exercise or defend legal claims, or to protect the rights and safety of users or the public. We will not disclose more than the law requires.
- A buyer or successor, if our business or the App is sold, merged or reorganised. Where this happens we will update this policy and, where the law requires it, give notice in the App before your data becomes subject to a different privacy policy.
Apart from these recipients, we do not share your personal data ourselves. Where an ad is filled through a
real-time auction, the exchange concerned passes the ad request — including your advertising identifier, IP address and approximate location — to the demand partners bidding in that auction. Those partners are identified in that exchange’s own vendor list, published on the exchange’s site and reachable from the privacy policy linked in Annex A, and in the vendor list shown in the consent screen.
11.2 Protection by third partiesWe share personal data only with third parties that are bound — by the data protection terms one of our two companies has accepted with each of them, and by the Apple and Google developer programme policies they participate in — to protect user data to a standard at least equal to the one described in this policy and required by those programmes.
Firebase and Singular act as processors for LLC Karfarol Games: they use the data only for the purposes it instructs, under the Firebase Data Processing and Security Terms and Singular’s data processing terms respectively.
Our advertising partners act as independent controllers. Mno Go Apps LTD contracts with them and accepts each partner’s data protection terms, but they use the data for the purposes set out in their own privacy policies, which are linked in Annex A. We do not integrate an SDK partner whose published terms fall below the standard above, and we remove SDK partners that do. Where an exchange passes the ad request to demand partners bidding in a real-time auction, we do not select those partners individually; they are bound by that exchange’s participation terms and appear in its vendor list.
We cannot control what an advertiser does on its own website after you tap its ad; that is between you and the advertiser.
11.3 The partners themselvesAnnex A names every advertising, analytics and attribution SDK integrated into the App, with a link to its privacy policy and, where one exists, its opt-out mechanism. In the EEA and the UK, the consent screen also lists the partners registered under the IAB Transparency and Consent Framework and lets you decide about them.
12. Selling and sharing of personal dataWe do not sell personal data for money.
However, several US state privacy laws define “sale” and “sharing” broadly enough to include the disclosure of identifiers and advertising data to advertising partners for cross-context behavioural advertising, even where no money changes hands. On that broader definition:
- We share, and may be deemed to sell, the following categories to our advertising partners for personalised advertising and advertising measurement: identifiers (advertising ID, device and installation identifiers, IP address), internet and app activity, advertising data, approximate location and inferences drawn from them.
- We do not sell or share the contents of your support correspondence.
- We do not knowingly sell or share the personal data of anyone under 18.
Do Not Sell or Share My Personal Information. Open
Settings → Privacy in the App and switch off
Personalised ads. That single control opts you out of sale, of sharing for cross-context behavioural advertising, and of targeted advertising. You can also refuse or withdraw consent on the consent screen, opt out of tracking on iOS, or email f@karfarol.com and we will apply it for you. There is no charge and no penalty: the App works the same either way.
Sensitive data. We do not deliberately collect special categories of data under the GDPR or sensitive personal information under US state law, and we do not use any signal to label users by ethnicity, nationality, religion or health. The language you choose to play in is collected as app-activity data; we do not treat it as an indicator of your origin and we do not ask our partners to do so.
Opt-out preference signals. Global Privacy Control and similar universal signals are browser technologies; there is currently no reliable equivalent inside a native mobile app. The in-App and device controls above are the mechanism we provide.
13. International data transfersOur two companies sit in different countries, and our partners operate globally, so your personal data is transferred across borders — including outside the EEA and the UK, to countries whose data protection laws differ from yours.
Depending on which partner serves a given ad or processes a given event, the destinations include
Cyprus, Georgia, the United States, Ireland, Singapore, India, Israel, Hong Kong SAR, China and Russia. Annex A identifies where each partner is based.
Between our own two companies. Mno Go Apps LTD is in Cyprus, inside the EEA. LLC Karfarol Games is in Georgia, which is
not covered by an adequacy decision of the European Commission or the UK government. Personal data therefore leaves the EEA when we share it between us, and also when the analytics, crash and attribution data collected from your device is made available to LLC Karfarol Games in Georgia through the Firebase and Singular accounts it holds. For both routes we have signed the European Commission’s
Standard Contractual Clauses (controller-to-controller module) and, for UK data, the
International Data Transfer Addendum, and we have carried out a transfer impact assessment.
To our processors. Firebase and Singular process on behalf of LLC Karfarol Games under terms that incorporate the Standard Contractual Clauses or, where the receiving entity is certified, the
EU–US Data Privacy Framework and its UK Extension.
To our advertising partners. Each of them acts as an independent controller and is responsible for the transfer safeguard it relies on. Each identifies that safeguard in its own privacy policy, linked in Annex A.
Where no other safeguard is available, we rely on an adequacy decision covering the destination, or on your explicit consent.
Please read this if it matters to you. Some of the advertising networks we mediate are based in, or belong to groups based in, countries for which there is
no adequacy decision — including China (Mintegral, and the group behind Pangle) and Russia (Yandex). You should be aware that the protection available in those countries may be weaker than in your own, and that local authorities may have access rights that could not be exercised in the EEA or the UK.
If you would prefer that your data not reach these partners, refuse or withdraw consent to personalised advertising (Section 8). You can ask us for a copy of the safeguards we rely on, including our Standard Contractual Clauses, by writing to f@karfarol.com.
14. How long we keep dataData | Retention |
Analytics events and identifiers (Firebase) | 365 days at user level, after which data is retained only in aggregate form that does not identify a device |
Attribution data (Singular) | 365 days |
Crash and diagnostic reports (Crashlytics) | 90 days — Firebase Crashlytics’ standard retention period |
Advertising data held by our advertising partners | Under each partner’s own retention policy — see the partner’s privacy policy, linked in Annex A |
Push notification token | Until you turn notifications off, delete the App, or the token expires |
Purchase records | For the period required by tax, accounting and consumer protection law — generally up to 4 years |
Support correspondence | 4 years |
Records of the consent choices you made | For as long as the consent is valid, and afterwards for a reasonable period to demonstrate compliance — generally up to 4 years |
Everything stored on your device | Until you delete it or uninstall the App — we hold no copy |
When a retention period ends, data is deleted or irreversibly aggregated so that it can no longer be linked to a device. To ask us to delete data
before the end of a retention period, see Section 16.
15. How we protect data- Data in transit between the App, our partners and our systems is encrypted using TLS.
- We deliberately minimise what we collect: no accounts, no name, no date of birth, no precise location, no payment details, and game progress kept on the device rather than on a server. The only contact detail we ever hold is an email address you choose to write to us from (Section 6.8).
- Access to the analytics, attribution and advertising consoles that hold this data is limited to the staff of the two companies who need it, protected by multi-factor authentication where the provider supports it, and reviewed when someone joins or leaves.
- We contract with our processors on written terms that require appropriate technical and organisational security measures, and we choose established providers that maintain recognised security programmes.
- Because we hold no accounts and no directly identifying data, the harm a breach of our systems could cause is limited by design.
No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If a personal data breach occurs that is likely to result in a risk to your rights and freedoms, we will notify the competent supervisory authority within 72 hours where required, and inform affected users where the law requires it. Because we hold no contact details for you, we do this by a notice in the App and on our website; if you do not open the App you may not see it.
16. Your rights16.1 If you are in the EEA, the UK or SwitzerlandYou have the right to:
- access the personal data we hold about you, and receive a copy;
- have inaccurate data corrected;
- have your data erased (“right to be forgotten”);
- restrict how we process it;
- object to processing based on our legitimate interests, and to object at any time to processing for direct marketing, including profiling for advertising;
- receive your data in a portable, machine-readable format;
- withdraw consent at any time, without affecting the lawfulness of processing before withdrawal;
- not be subject to a decision based solely on automated processing that produces legal or similarly significant effects (we take no such decisions — see Section 18);
- lodge a complaint with a supervisory authority (Section 16.5).
16.2 If you are in the United StatesDepending on your state of residence, you may have the right to know what personal data we collect and to receive a copy; to have it corrected or deleted; to opt out of its sale, of its sharing for cross-context behavioural advertising, and of targeted advertising; to opt out of profiling used to make decisions that produce legal or similarly significant effects; to limit the use of sensitive personal information; to appeal a refusal; and not to be discriminated against for exercising any of these rights. The App and its features work identically whether or not you exercise them.
These rights currently apply in California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Florida, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, Indiana, Kentucky and Rhode Island, subject to each state’s own thresholds and definitions. Residents of other states are welcome to make the same requests and we will handle them the same way.
To opt out of sale, sharing and targeted advertising, use the
Do Not Sell or Share My Personal Information control described in Section 12, or write to f@karfarol.com. You may use an authorised agent; we will ask for proof of their authority. We will confirm to you when your request has been processed.
Minnesota residents may additionally ask for a list of the specific third parties to which we have disclosed personal data; Rhode Island residents may ask which third parties we have sold, or may sell, personal data to. Annex A lists the partners that receive data from the App and is the basis of our answer to both. Where an ad is filled through a real-time auction we will also point you to the exchange’s own vendor list, and we will confirm the answer in writing on request.
16.3 If you are somewhere elseMany other countries — including Brazil, Canada, Japan, South Korea, Australia, Turkey, Saudi Arabia, the UAE and Georgia — give you comparable rights. Write to f@karfarol.com and we will apply the same process regardless of where you live.
16.4 How to make a request, and what we can actually doWrite to f@karfarol.com with the subject line “Privacy request”. We will respond within
one month (EEA/UK),
45 days (most US states), or the period your own law requires, and will tell you if we need an extension.
Because the App has no accounts, we cannot identify you from your email address. We locate your records by the identifiers our SDKs generate. Open
Settings → Privacy in the App, copy the privacy identifiers shown there, and include them in your message — those are the keys we use to find and delete your analytics and attribution records, and to produce a copy of them where our providers offer per-device export. Where a provider offers deletion but not export, we will tell you so and give you the categories of data we hold instead of a raw copy.
If you have already deleted the App, send us your advertising identifier, device model, App version, approximate first-use date and any store order number, and we will try to match them. If you have already deleted or reset your advertising ID, or refused tracking, the link between you and any remaining data may be gone, and we may be genuinely unable to locate anything to give you or delete. Where that is the case we will say so plainly rather than ask you for more identifying information than we need. We will never ask you to create an account in order to exercise a right.
For data held by an advertising partner acting as an independent controller, the fastest route is usually that partner’s own privacy contact or opt-out mechanism. Annex A gives the privacy policy for every partner and, where the partner offers one, its opt-out page. Tell us if you would like us to pass the request on instead, and we will.
We do not charge for handling requests. If a request is manifestly unfounded or excessive, particularly because it is repetitive, we may charge a reasonable fee or refuse it, and we will explain why and how to challenge that.
16.5 ComplaintsPlease raise any concern with us first at f@karfarol.com — most issues are resolved quickly. If you remain dissatisfied:
- EEA: complain to the supervisory authority of the country where you live or work, or where you believe the problem occurred. The list is at edpb.europa.eu/about-edpb/board/members_en. Because our publisher is established in Cyprus, you may also complain to the Office of the Commissioner for Personal Data Protection of Cyprus, dataprotection.gov.cy.
- United Kingdom: the Information Commissioner’s Office, ico.org.uk/make-a-complaint.
- Switzerland: the Federal Data Protection and Information Commissioner, edoeb.admin.ch.
- United States: your state Attorney General, or the California Privacy Protection Agency for California residents.
- Georgia: the Personal Data Protection Service of Georgia, personaldata.ge, which supervises LLC Karfarol Games.
17. ChildrenThe App is for adults (Section 3). We do not knowingly collect personal data from children, and we do not knowingly show personalised advertising to, or sell or share the personal data of, anyone under 18.
We are aware that word games appeal to people of all ages. If we learn that a user is a child, we will delete the personal data we hold about that device and take the steps described in Section 3. Parents and guardians who believe their child has used the App can write to f@karfarol.com, and we will act on the request without asking for more information than we need to find the data.
If we ever change the App’s audience — for example by publishing a version intended for families — we will publish a revised policy with the additional protections that the US Children’s Online Privacy Protection Act, the GDPR’s rules on children’s consent and the app stores’ families programmes require, before that version is released.
18. Automated decision-makingWe do not make decisions about you that produce legal effects or similarly significantly affect you on the basis of automated processing alone.
We do use automated processing in two limited ways, neither of which has that effect. Our advertising, analytics and attribution partners use automated and machine-learning systems to select and measure ads and to detect fraud, as described in their own privacy policies (Annex A). And we run automated A/B experiments through Firebase Remote Config that may show different users different feature layouts, level designs, offers or prices. Where an experiment affects the price of an in-app purchase, the price shown in the store’s billing sheet at the moment you confirm is always the price that applies, and you can decline it.
19. Changes to this policyWe may update this policy — for example when we add or remove an SDK, change an advertising partner, add a feature, or when the law changes. The “Last updated” date at the top shows when the current version took effect, and we keep the previous version available on request from f@karfarol.com.
Where a change materially affects how we use your personal data, we will give you at least
30 days’ notice in the App before it takes effect, and where the law requires it we will ask for your consent again. Section 23 of our
Terms of Use applies the same 30-day notice period to changes to those Terms that are material and adverse to you. Continued use of the App after that notice period means the updated policy applies to you. We never treat continued use as consent where separate consent is required.
20. Contact usSend anything about privacy to f@karfarol.com. Mno Go Apps LTD is our single point of contact and will handle your request whichever company holds the data.
Mno Go Apps LTD — publisher, and the entity named on the App Store and Google Play listings 27, 25 Martiou, D. MICHAEL TOWER, Office 105A, Egkomi, 2408 Nicosia, Cyprus Registration number: HE409188
LLC Karfarol Games — developer Tbilisi, Vake District, Z. Paliashvili str., N41, Georgia Identification number: 405653430
Privacy requests and questions: f@karfarol.com Support: f@karfarol.com Legal and complaints: f@karfarol.com
Annex A — Advertising, analytics and attribution partnersThese are the SDK partners integrated into the App. Advertising partners are contracted by Mno Go Apps LTD and act as independent controllers; Firebase and Singular are contracted by LLC Karfarol Games and act as its processors.
Partner | Role | Based in | Privacy policy | Opt-out / choices |
AppLovin MAX (AppLovin Corporation) | Mediation platform and advertising network | United States | applovin.com/privacy | How AppLovin shows you ads |
Google AdMob / Google Ad Manager (Google LLC; Google Ireland Limited for the EEA and UK) | Advertising network and exchange | United States, Ireland | policies.google.com/privacy | How Google uses data from partner apps |
Mintegral (Mintegral International Limited) | Advertising network | Hong Kong SAR, Singapore (group in China) | mintegral.com/en/privacy | Consent screen and device settings |
Pangle (TikTok Pangle, ByteDance group) | Advertising network | Singapore (group in China) | pangleglobal.com/privacy | Consent screen and device settings |
Yandex Mobile Ads (Yandex) | Advertising network | Russia | yandex.com/legal/confidential | Consent screen and device settings |
[TO COMPLETE before publication: other networks enabled in the AppLovin MAX dashboard] | Advertising network |
|
|
|
Firebase — Analytics, Crashlytics, Remote Config, Cloud Messaging (Google LLC) | Analytics, crash reporting, A/B testing, push notifications (processor) | United States | firebase.google.com/support/privacy | Consent screen; Settings → Privacy in the App |
Singular (Singular Labs, Inc.) | Attribution and marketing measurement (processor) | United States, Israel | singular.net/privacy-policy | Consent screen; Settings → Privacy in the App |
Where an exchange fills an ad through a real-time auction, the demand partners bidding in that auction are listed in that exchange’s own vendor list and, in the EEA and the UK, in the vendor list shown in the consent screen.