Privacy Policy - Boomer or Zoomer

1. Introduction

This Privacy Policy is a legal agreement between you ("you", "your" or "user") and Dmytro Pavlov, an individual developer operating from Kyiv, Ukraine (referred to as "I", "me", or "my").

This Policy applies to all mobile games, applications, websites, and related services provided by the Company (collectively, the "Services" or "games", "apps", "websites" for individual categories). It explains how we collect, use, share, and protect your personal data when you access or use our Services.

Please read this Privacy Policy carefully to understand our policies and practices regarding your personal information and how we handle it.

2. Information We Collect and How

While using our Services, we may process certain personal data or personal information that can be used to identify you ("Personal Data", or "data" or "information" or "Personal Information"). The Personal Data we may process includes:

Basic Identifiers

such as mobile device IDs, advertising ID (iOS Identifier for Advertiser, Android Advertising ID), internal User IDs and IP address.

Commercial Information

such as in-app purchase history and subscription details.

Device Information

type and model of the device, operating system and version, screen resolution, application version, preferred language settings, time zone, connection type (such as Wi-Fi, 2G, 3G, 4G, 5G), and estimated internet speed as calculated by your device.

Usage Information

information about how you interact with our Services, such as date and time of usage, features used, gameplay activity, and data generated during service use (e.g., game progress, levels completed, content created).

Diagnostics

information that is collected about how our apps perform, such as crash logs, app performance data such as launch time, freezes and other diagnostic data collected for the purposes of measuring technical diagnostics related to the app.

Location Information

When you download and use our Services, we automatically detect your general location, namely country and region, through your IP address. We do not collect or store precise geolocation (e.g., GPS).

Contact Information

such as your name and email address when you provide it to us directly through an email or online form, the support feature embedded in our Services, or through another form of inquiry.

Reviews and Communications

We will also process personal data and metadata of public reviews in App Stores, comments, or contents of communication you have with us.

User-Generated & Community Content

Content you create or upload within our apps, or post on social networks, platforms such as the App Store or Google Play, or through direct contact with our social media pages. This content may include your name, social media username, profile image, or other identifiable elements. Our legal basis for this processing is your consent, which we obtain via the medium (e.g., in-app, email, social networks, or platforms) used to share the content.

AI Feature Inputs and Generated Content

When you use AI-powered features in our Services (where available), we collect the inputs, prompts, or instructions you provide ("User Inputs") to generate content. We also process the AI-generated content created from these inputs. User Inputs are processed through third-party AI service providers and may be used in anonymized form to improve our AI features and Services.

Cookies and similar data collection technologies

Although our mobile apps do not use traditional browser cookies, we and our third-party service providers may use similar technologies—such as mobile SDKs, local storage, device identifiers (e.g., Apple IDFA, Android Advertising ID), pixels, and performance beacons—to analyze performance, improve functionality, ensure security, personalize your experience, and detect fraud.

Some of these technologies may be used (with your consent, where required) to track you across our own apps and websites.

Our Services may also use similar technologies to support AI-powered features where available, including to manage feature access and monitor usage patterns for safety and improvement purposes.

Please note that, while your browser settings may allow you to transmit a "Do Not Track" signal when you visit websites, our mobile Services are not configured to respond to "Do Not Track" signals received from browsers.

We do not currently use third-party advertising networks in our apps.

3. Sources of Data

We collect personal information from a variety of sources, depending on how you interact with the Services. These sources may include:

Information you provide directly, such as when you contact us via email, submit a support request, complete a form, or otherwise communicate with us;
Information collected automatically, including when you access or use our Services, make in-app purchases or subscriptions, or engage with features that generate usage data;
Publicly available content, such as reviews, comments, or user-generated content you publish on app distribution platforms (e.g., the App Store or Google Play) or social media channels we operate;
Tracking and diagnostic technologies, such as mobile software development kits (SDKs), device identifiers, and similar tools used for analytics, crash reporting, and purchase management;
AI-powered features within our Services, when you submit inputs for content generation or other AI-assisted functionality;
Other third parties involved in supporting or operating our Services, including integrated service providers or platform partners.

4. Purposes for Which We Use Your Personal Data

Our mission is to constantly improve our Services and provide you with new experiences. As part of this mission, we use your personal data to operate, maintain, and enhance our apps and services in compliance with applicable laws. This includes the following purposes:

To make our services available — We process information necessary to enable core functionality, recognize returning users, apply saved preferences, and fulfill in-app purchases or subscriptions. This processing is carried out to perform our contract with you and based on our legitimate interest in operating our services.
To monitor and improve app performance — We use diagnostic and usage data (e.g., crash logs, session activity, and device information) to identify technical issues, analyze usage trends, and ensure the stability and security of our apps. This processing is based on our legitimate interest in maintaining and improving service quality.
To communicate with you — When you contact us (e.g., via email or through in-app support), we use the information you provide to respond to your inquiry, assist with issues (such as purchase errors), or follow up as necessary. This processing is based on our legitimate interest in supporting users and fulfilling our contract with you.
To analyze and improve our apps — We use third-party analytics tools to better understand how users engage with our services, evaluate app performance, and guide product development. These tools may collect data like device identifiers and usage metrics. In jurisdictions where required, this processing is based on your consent; elsewhere, on our legitimate interest in improving user experience.
For purchase management — We rely on third-party services to manage and validate purchases, handle subscriptions, and deliver entitlements such as premium access. This processing is necessary to fulfill our contractual obligations to you.
To detect and prevent fraud or misuse — We may process certain technical and usage data to identify, investigate, and mitigate fraudulent behavior, abuse of our services, violations of our Terms of Use, or other harmful activities. This processing is based on our legitimate interest in protecting our users and our platform.
To enable user-generated content — Some of our apps allow you to create or save custom content (such as charades packs). This content is stored locally on your device and may be processed to ensure functionality (e.g., save/load). We do not access or collect this content unless you choose to share it with us (e.g., via support email).
To provide AI-powered features — When available in our Services, we process User Inputs through third-party AI service providers to generate custom content based on your requests. We use this data to: (a) generate the requested content, (b) filter inappropriate requests, (c) improve our AI features and Services (using anonymized data), and (d) ensure compliance with our Terms of Use. This processing is based on our legitimate interest in providing and improving our services, and where required, your consent.
To comply with legal obligations — We may process your information as required by applicable law, regulation, court order, or to establish, exercise, or defend legal claims.

If we introduce new purposes for processing your personal data in the future, we will update this Privacy Policy accordingly and, where required by law, obtain your consent before doing so.

5. Sharing of Your Information

We don't sell your personal data. But in certain cases, we may share it with trusted third parties to help operate, improve, or protect our services. Here's when that might happen:

Working with service providers — We work with trusted third-party companies to help operate, support, and improve our apps. This includes analytics, hosting, customer support, purchase management, AI service providers for content generation features, and tools to measure how users find us and how our marketing performs. When you use AI-powered features (where available), your inputs are sent to third-party AI service providers solely to generate the requested content. We do not share personally identifiable information with these AI providers, only the content of your inputs. These providers act on our behalf and are contractually required to protect your data under applicable laws.
Legal reasons and safety — We may share your data when we believe it's necessary to: comply with the law, respond to legal requests, protect the safety of our users or others, enforce our terms, or prevent fraud and abuse.
If our business changes — If we're involved in a business deal like a merger, acquisition, or asset sale, your personal data may be part of that transfer. If that happens, we'll take steps to let you know as required by law.
With your permission — If you ask us to share your data or give us permission, we'll do so according to your request.

6. Retention of Personal Data

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, as outlined in this Privacy Policy, or as required to comply with legal obligations, resolve disputes, or enforce our agreements.

Different categories of data may be retained for different periods depending on the nature of the data and the legal or business purposes for which it was collected. We may also retain certain data for internal analytics and our legitimate interest in improving the functionality and performance of our Services.

Your personal data will be retained only for as long as permitted under applicable law and necessary for the specific purpose of collection. Once that purpose is fulfilled, the data will be deleted or irreversibly anonymized so that it no longer qualifies as personal data.

Any custom content you create within the app is stored locally on your device. We do not access or retain this content unless you choose to share it with us directly (e.g., via support email). This content is removed automatically when you uninstall the app.

AI Feature Data Retention

User Inputs submitted to AI-powered features are retained for up to 30 days for quality assurance and safety monitoring purposes, after which they are permanently deleted or irreversibly anonymized. AI-generated content that you save within our Services is treated as user-generated content and stored according to the applicable retention policies for such content. Anonymized input data may be retained longer for the purpose of improving our AI features and Services, but such data cannot be linked back to individual users.

You may also request the deletion of your personal data, subject to our legal obligations and technical feasibility. To make such a request, please contact us using the methods described in the Contact Us section.

In no case will we retain personal data for more than five (5) years from the date of collection, unless a longer retention period is required by applicable law.

7. International Data Transfers

Our Services are accessible globally, and some of the third-party providers we rely on may process personal data in countries outside your country of residence, including outside the European Economic Area (EEA).

When personal data is transferred across borders, we aim to ensure that it is processed in accordance with applicable data protection laws. Where required, we use safeguards such as Standard Contractual Clauses approved by the European Commission or rely on adequacy decisions, depending on the circumstances and the recipient country.

By using our Services, you acknowledge that your personal data may be transferred to countries whose data protection laws may differ from those in your jurisdiction. In such cases, we take reasonable steps to ensure that any transfers are conducted in a manner that seeks to provide an appropriate level of protection.

Where possible, we engage third-party service providers that have undergone security and compliance checks and that provide contractual assurances regarding the protection of personal data.

8. Age Limits

Our Services are intended for users of all ages. We do not knowingly collect or process personal data from children under the age of 13 (or the applicable age in your jurisdiction) without parental consent.

Parents or legal guardians are encouraged to monitor their children's access to devices and apps.

If you believe that a child has accessed our Services or submitted personal information without proper authorization, please contact us using the method provided in the Contact Us section. We will evaluate the request and take appropriate steps in accordance with applicable laws.

9. Your Privacy Rights

Under the General Data Protection Regulation (GDPR), you have certain rights regarding your personal data. These rights include:

Right to access: You have the right to request access to the personal data we hold about you.
Right to rectification: You have the right to request the correction of any inaccurate or incomplete personal data.
Right to erasure: You have the right to request the deletion of your personal data in certain circumstances.
Right to restrict processing: You have the right to request that we restrict the processing of your personal data in specific situations — for example, if you contest the accuracy of the data.
Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another data controller, where technically feasible.
Right to object: You have the right to object to the processing of your personal data in certain circumstances, including when we process your data for direct marketing or based on our legitimate interests.
Right not to be subject to automated decision-making: You have the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects or similarly significantly affects you.
Right to withdraw consent: If we process your personal data based on your consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.
Right to file a complaint: You have the right to lodge a complaint with the data protection authority in your country if you believe that our processing of your personal data violates applicable law.

To exercise any of the rights described above, you contact us using the methods described in the Contact Us section or by using the in-app support feature. Please note that we can only fulfill these rights with respect to personal data that we directly control and have access to.

We aim to respond to all verified requests within 30 days. If we require more time or cannot fulfill your request, we will inform you of the reason and any available options.

Please be aware that exercising certain rights (such as deletion or objection) may limit or prevent your ability to use some features of our Services. We will inform you of any such consequences before taking action.

10. Supplemental Privacy Notice and Rights for USA Residents

This section supplements our main Privacy Policy and applies to residents of certain U.S. states, including but not limited to California, Colorado, Connecticut, Utah, and Virginia, where applicable state privacy laws provide specific rights regarding the collection, use, and disclosure of personal information.

We do not sell your personal information in exchange for money. However, under some state laws, sharing limited personal data with third-party service providers (such as those for analytics, marketing, or AI-powered content generation) may be interpreted as a "sale" or "sharing" of personal information. When you use AI-powered features in our Services, your inputs are shared with third-party AI providers solely to generate content. If required under applicable law, you may have the right to opt out of such processing.

Your Privacy Rights

Depending on your state of residence and subject to certain legal exceptions, you may have the right to:

Access the categories and specific pieces of personal information we have collected about you;
Delete personal information we have collected, subject to legal exceptions;
Correct inaccurate personal information (where applicable).
Opt out of: the sale or sharing of personal data for targeted advertising; profiling in furtherance of decisions that produce legal or similarly significant effects.
Limit the use and disclosure of sensitive personal information (where applicable).
Not be discriminated against for exercising any of your privacy rights.

To exercise your rights, please contact us using the information in the Contact Us section. We may request additional information to verify your identity and the scope of your request. You may also authorize an agent to act on your behalf, subject to verification of the agent's authority and your identity.

We aim to respond to verifiable requests within the timeframe required by applicable law, generally within 45 days of receipt. If we need more time, we will inform you in writing.

Additional Notes for California Residents

Under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), California residents have the following additional rights:

To know the categories of personal information we have collected, the sources of that information, the purposes for which it is used, the categories of third parties with whom we share it, and the specific pieces of personal information we have collected (subject to verification).
To request deletion or correction of their personal information, with certain exceptions.
To opt out of the sale or sharing of their personal information for cross-context behavioral advertising.
To limit the use of sensitive personal information, if applicable, to those purposes authorized by law.

We only use or disclose sensitive personal information as necessary to provide our services, for security and fraud prevention, or as otherwise permitted by applicable law. We do not use it to infer characteristics about you.

To submit a request under the CCPA, please clearly indicate in your message that you are a California resident and include the phrase "California Privacy Rights Request."

11. Data Security

We take the security of your personal information seriously and apply reasonable technical and organizational measures to help protect it from unauthorized access, loss, misuse, or disclosure.

These measures are designed to uphold data protection principles, such as data minimization, and to integrate appropriate safeguards into our processing activities. Where applicable, we may use encryption and other industry-standard technologies to enhance data protection.

For AI-powered features, where available, we implement additional safeguards including content filtering, rate limiting, and monitoring systems to prevent misuse and ensure appropriate use of these features.

However, no method of transmission over the internet or electronic storage is entirely secure. While we strive to protect your information, we cannot guarantee its absolute security. If we become aware of a data breach that affects your personal information, we will notify you in accordance with applicable laws.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the features of our Services. When we do, we will revise the "Last Updated" date at the top of this page.

We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your personal data. If we make material changes that may affect your rights or how your data is processed, we may notify you within the app or through other appropriate means, depending on the nature of the changes and legal requirements.

By continuing to use our Services after such updates, you acknowledge and accept the revised Privacy Policy.

13. Contact Us

If you have any questions or concerns about this Privacy Policy or how we handle your personal data, please contact us using the in-app support feature in our Services, which is the preferred method for a timely response. You may also contact our team at:

support@boomerorzoomer.com