Privacy Policy

Last Updated: March 18, 2026

This Privacy Policy governs the collection, use, storage, protection, sharing and disclosure of personal information by FLICKFUN ENTERTAINMENT LTD (hereinafter referred to as "we", "us", or "our"), a company registered in the United Kingdom with its registered address at L220, Beaconside Business Village, Stafford Enterprise Park, Weston Road, Stafford, United Kingdom ST18 0BF. This Policy applies to all users (hereinafter referred to as "you" or "users") who access, use or register for our official website, mobile and web-based casual mini-games (collectively referred to as the "Services").

We are committed to protecting the privacy and personal information of our users in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and other applicable UK and international data protection laws and regulations. This Policy clarifies our data processing practices and your rights regarding your personal information. By using our Services, you consent to the collection and use of your personal information in accordance with the terms of this Policy.

1. Information We Collect

We adhere to the principle of data minimization and only collect personal information necessary to provide, maintain and improve our Services, and to comply with legal obligations. We do not collect unnecessary personal information, and all data collection is conducted with transparency and your informed consent (where required by law).

• 1.1 Information You Voluntarily Provide: This includes account registration details (email address, username/password for premium features; limited authorized information if logging in via Apple ID), feedback/contact information (email and optional message content when reaching out to customer support), and voluntary personalized profile data (nickname, avatar—non-essential for basic use).
• 1.2 Automatically Collected Information: When you use our Services, we automatically gather limited technical and usage data to ensure stable operation and optimize user experience. This includes device/technical information (model, OS version, IDFV for iOS users—IDFA is only collected with explicit consent via Apple’s ATT prompt, network type, screen resolution, game client version), service usage data (game progress, mode preferences, time spent, crash/error logs for troubleshooting), and website usage data (pages visited, time on site, referral source for our official website, via anonymized tools). This data does not personally identify you unless combined with other information, and we do not use it for cross-app/platform tracking without consent.
• 1.3 Third-Party Collected Information: We only collaborate with trusted third-party service providers to assist in operating our Services, and they are bound by strict data protection agreements. For in-app purchases, payment processing is handled via Apple’s App Store IAP or reputable gateways—we do not store sensitive payment details, only receiving payment confirmation to fulfill purchases. For analytics, we use anonymized tools to collect aggregated, non-identifiable data (e.g., active user count, popular game modes) solely for service optimization.

2. Purposes for Using Your Information

We use collected personal information only for legitimate business purposes and in compliance with applicable law:

Provide and maintain our Services (enable access to casual mini-games, save progress for registered users, support leaderboard participation, send game-related notifications like bug fixes or new mode releases);

Optimize and improve our Services (analyze usage data to fix technical issues, enhance performance, develop user-aligned features and game modes);

Respond to inquiries and feedback (address questions, resolve game-related issues, follow up on comments or suggestions);

Process in-app purchases (verify transactions and fulfill virtual item/premium feature delivery via third-party processors);

Ensure service security (detect and prevent fraud, unauthorized access, and other security threats);

Comply with legal obligations (meet UK and international regulatory requirements, respond to valid requests from authorities or judicial bodies);

Send non-marketing communications (deliver important service alerts like account security notifications or policy updates). We do not send unsolicited marketing emails—any promotional communications require your explicit opt-in consent, with an easy unsubscribe option.

We will never use your personal information for purposes not stated in this Policy without first obtaining your explicit consent.

3. Sharing and Disclosure of Your Information

We do not sell, rent, lease or otherwise disclose your personal information to third parties for commercial or marketing purposes under any circumstances. We only share your information in limited, compliant scenarios:

With trusted third-party service providers (e.g., payment processors, analytics tools, customer support platforms) who perform services on our behalf. These parties are contractually required to protect your information, use it only for specified tasks, and not disclose it to others;

For legal and security purposes, if we believe disclosure is necessary to comply with a legal obligation (e.g., court orders, ICO requests), protect the rights, property or safety of our company, users or the public (e.g., prevent fraud or hacking), or enforce our Terms of Service or this Privacy Policy;

In the event of a business transfer (merger, acquisition, asset sale), your information may be transferred to the successor entity. We will ensure the successor is bound by this Policy and notify you of material changes to data processing practices;

With your explicit written consent for any other purpose not outlined above.

We do not share your personal information with advertisers or third-party marketers for targeted advertising, nor do we participate in cross-app/platform data sharing for marketing.

4. Storage and Protection of Your Information

4.1 Storage Period: We store your personal information only for as long as necessary to fulfill stated purposes or comply with legal obligations. Account registration information is retained until account deletion (permanently deleted within 30 working days of request); feedback/contact information is stored for 12 months after inquiry resolution (then anonymized or deleted); anonymized usage data is retained for up to 24 months for optimization; payment confirmation data is stored for 7 years to comply with UK financial record-keeping laws. Identifiable device information is deleted if you cease using our Services for 18 months or upon account deletion.

4.2 Storage Location: All personal information is stored on secure, compliant servers located in the United Kingdom. We do not transfer data outside the European Economic Area (EEA) unless required by law, and any cross-border transfer will comply with UK GDPR requirements (e.g., standard contractual clauses, adequate data protection guarantees).

4.3 Security Measures: We implement robust technical and organizational safeguards to protect your information from unauthorized access, disclosure, alteration or destruction. These include SSL/TLS encryption for data transmission, industry-standard encryption for sensitive information storage (e.g., hashed/salted passwords), access controls limiting employee access to minimum necessary data, regular security training for staff, firewall and intrusion detection systems for servers, periodic security audits and vulnerability scans, third-party security reviews, and a formal data breach response plan to investigate, contain and notify relevant parties per UK GDPR requirements. While we take all reasonable steps, no electronic storage/transmission is 100% secure, and you assume residual risk.

5. Your Rights Regarding Personal Information

Under UK GDPR and applicable UK data protection laws, you have the following rights regarding your personal information, and we will respond to valid requests free of charge within 30 working days:

Right of Access: Request a copy of your personal information and details on how it is used, shared and stored;

Right to Rectification: Request correction or update of inaccurate/incomplete personal information;

Right to Erasure ("Right to be Forgotten"): Request permanent deletion if the information is no longer necessary, you withdraw consent (with no other legal basis for processing), you object to processing (with no overriding legitimate interest), collection was unlawful, or deletion is required by law;

Right to Restrict Processing: Request limited processing if you contest information accuracy (until verification), processing is unlawful (but you decline deletion), you need the information for legal claims (after we no longer need it), or you object to processing (pending evaluation);

Right to Data Portability: Request your information in a structured, commonly used, machine-readable format (e.g., CSV, JSON) or transfer to another data controller (where technically feasible);

Right to Withdraw Consent: Withdraw explicit consent for processing (e.g., marketing, IDFA collection) at any time—this does not affect prior lawful processing. For IDFA, you can manage consent via iOS device settings;

Right to Object: Object to processing for direct marketing or legitimate business interests (we will cease processing unless we can demonstrate compelling overriding interests);

Right to Lodge a Complaint: File a complaint with the UK Information Commissioner’s Office (ICO) (website: www.ico.org.uk, phone: 0303 123 1113, address: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF) or Apple’s App Store feedback channel.

To exercise these rights, send a written request to our data protection team via email at dev@flickfunplay.com, including your full name, contact information, clear description of the right being exercised, and account username (if applicable). For requests on behalf of a minor or another person, provide proof of authority (e.g., guardian identification). We may request additional information to verify your identity.

6. Cookies and Similar Technologies

Our website and game clients may use first-party cookies and similar technologies (e.g., local storage) to enhance user experience, optimize services, and collect limited anonymized data—we do not use third-party cookies or cookies for targeted advertising/cross-site tracking. Necessary cookies support basic functionality (e.g., saving game progress, login status) and cannot be disabled. Analytics cookies collect anonymized usage data (e.g., pages visited, game modes played) for optimization. Preference cookies save personalized settings (e.g., volume, language) for consistent experiences.

You can control cookies via device/browser settings: web browsers allow blocking/deleting cookies or notifications for new cookies; mobile devices let you manage local storage via OS settings (e.g., iOS Settings > Privacy > Tracking; Android Settings > Privacy > Storage). Disabling necessary cookies may affect service functionality.

7. Protection of Minors

Our Services are not intended for children under 13. We do not knowingly collect personal information from minors under 13. If we become aware of unauthorized collection from a child under 13, we will immediately delete the information. Guardians may contact us at dev@flickfunplay.com to request deletion if their child under 13 provided information without consent. Users aged 13-17 should use our Services with guardian guidance and not share personal information without permission.

8. Changes to This Privacy Policy

We may update this Policy to reflect legal changes, data processing practices or service updates. Material changes will be prominently notified via in-game pop-ups, website banners, or registered email. Updated Policies take effect on the stated effective date—continuing to use our Services after this date constitutes acceptance of revised terms. We encourage regular review of this Policy.

9. Contact Us

For questions, concerns or requests related to this Policy, data processing or your personal information, contact our Data Protection Team via:

Email: dev@flickfunplay.com (primary contact, fastest response);

Postal Mail: L220, Beaconside Business Village, Stafford Enterprise Park, Weston Road, Stafford, United Kingdom ST18 0BF;

Phone: +44 7537 127543.

We will respond to inquiries in a timely manner and resolve issues related to your privacy.

FLICKFUN ENTERTAINMENT LTD is the data controller for personal information collected through our Services and is registered with the UK Information Commissioner’s Office (ICO) in compliance with UK GDPR requirements.