Privacy Policy

Last Updated: April 16, 2025

Welcome to Funtomika! This Privacy Policy describes how Funtomika (“Funtomika,” “we,” “us,” or “our”) collects, uses, shares, and protects personal information when you access or use our mobile games, websites, and related services (collectively, our “Services”). This policy applies to your use of Funtomika games (on mobile devices or any other platform) and our website at funtomika.com. By using our Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree to the practices described in this policy, please do not use our Services.

Contents

Information We Collect

We collect various types of information from you or about you when you use our Services. This includes:

Information You Provide to Us
  • Contact Information: When you reach out to us (for example, via our contact form) or create an account, we may collect personal identifiers like your name, email address, phone number, and other contact details.
  • Account and Profile Data: If our games allow account creation or social login, we collect the information you provide, such as a username, password, profile avatar, and any details you choose to provide in your profile. If you link a social media account (e.g., Facebook, Google, or Apple Game Center), we may receive information like your profile name, email, friend list (if you consent), and other information from that platform.
  • User Communications: When you provide feedback, fill out surveys, or contact our customer support, we collect the information you submit (such as your inquiries, feedback, and any contact details included).
  • User-Generated Content: If you participate in community features of our games (such as in-game chat, forums, multiplayer interactions, or posting content), we collect the content you create or share, like chat messages, posts, or any other material. Keep in mind that content you share in public or social areas may be visible to other players, so please do not include information you wish to keep private.
  • In-Game Purchases: If you make a purchase within our games, we collect information related to the transaction. This can include the items purchased, the cost, and transaction IDs. Financial information (like credit card numbers) is processed by the app store or payment processor (e.g., Apple App Store or Google Play) and is not received directly by Funtomika. We do receive confirmation of payment and basic details to fulfill your purchase (for example, to deliver the in-game item or currency you bought).
Information Collected Automatically
  • Device Information: We automatically receive data about the device and software you use to access our Services. This includes details like device type (e.g., smartphone, tablet), operating system and version (e.g., iOS or Android and version number), hardware model, unique device identifiers (such as your Advertising ID, e.g., Apple’s IDFA or Google’s GAID), language setting, and network or browser type (for web access).
  • Usage and Gameplay Data: We collect information about how you interact with our games and website. This includes gameplay events and statistics (levels completed, scores, achievements, and other in-game actions), features or screens you access, clicks and navigation on our website, the date and time of your activities, session length, and frequency of play. We also collect crash and error logs if the app malfunctions, which help us diagnose and fix issues.
  • Log and Connection Data: When you use our Services, certain information is logged automatically. This can include your IP address (which may give a general indication of your location, such as city or country), your device’s time zone and precise time of access, and information about your internet service (ISP or mobile carrier). If you visit our website, we log information like the pages you visited, the page that referred you to our site (e.g., a link from a search engine), and your browser type.
  • Cookies and Similar Technologies: On our website, we use cookies and similar tracking technologies to collect information about your browsing activities over time (see Cookies and Tracking Technologies section for details). In our mobile apps, we use software development kits (SDKs) and device identifiers that function similarly to cookies to remember your preferences and track your interactions with the app.
  • Approximate Location: We may infer your approximate location from your IP address or device settings. This is generally not precise (for example, we might know the region or country you are in, but not your exact coordinates). We use this to tailor content to your region (such as language or regional game events), for analytics (understanding where our players are), and to comply with regional requirements (for instance, showing you appropriate privacy notices or complying with local laws).
Information We Receive from Third Parties
  • Social Media and Platform Integrations: If you choose to sign in or connect to our Services via a third-party platform (such as Facebook, Google, or Apple), that platform may send us information that you authorize. This can include your name, email, profile photo, friend list, and other information you’ve made available on that platform. We use this information to streamline account creation and login, and to enable social features (like finding friends who also play our games).
  • Advertising Partners: Our advertising partners (for example, Unity Ads, Google AdMob, or Facebook Audience Network) may provide us with information about your interactions with ads in our games or ads for our games on other platforms. For instance, if you installed our game after clicking an advertisement, the ad network might inform us about the ad campaign and performance. They might also share general information about ad engagement within our games (such as how many users viewed or clicked ads) to help us measure the effectiveness of our advertising.
  • Analytics Providers: We use third-party analytics tools (e.g., Google Analytics, Unity Analytics, Firebase) that collect data about the usage of our Services and report it to us. These providers might collect information such as how often users open the game, which in-game events occur, or how users progress through our content. This information is provided to us in aggregate form and helps us understand trends and user behavior on a broad scale.
  • App Stores and Payment Processors: When you purchase or download our games through an app store (like Google Play or Apple’s App Store), we may receive certain information from that platform. This can include data like your country, device type, and whether a purchase was successfully completed. Payment processors might also provide us with verification of transactions or subscription status (e.g., that you have an active subscription to a service in our game). This information helps us grant you the purchased content and provide customer support.
  • Other Sources: We might receive information from other third parties such as marketing partners or researchers. For example, we could receive demographic or interest information (like age group, or general interests) about our user base from a marketing analytics firm to help us better tailor our services or advertising. If we combine such information with data we collect directly from you, we will treat the combined information under this Privacy Policy and take any steps required by law.

How We Use Your Information

We use the collected information for various business and operational purposes, including:

  • Providing Our Services: To operate our games and services and provide you with the content and features you request. This includes maintaining your accounts, allowing gameplay (e.g., matchmaking with other players, saving your progress, and displaying leaderboards), and delivering customer support.
  • Improving and Developing Games: To analyze how players interact with our games so we can improve design, fix bugs, optimize gameplay balance, and develop new content or features. For example, usage data might inform us that a certain level is too difficult and needs adjustment.
  • Personalizing User Experience: To tailor our Services to your interests and preferences. This can include remembering your game settings, showing you targeted in-game offers or promotions based on your activities, and customizing content (like offering you a special in-game item on your birthday if we have that information).
  • Processing Transactions: To handle payments and fulfill purchases you make. We use purchase information to ensure you receive the content or virtual currency you bought. We also maintain records of transactions for accounting and to help address any issues (like items not received or refund requests).
  • Communicating with You: To send you updates and information about the Service, such as important announcements about game updates, changes to terms, or alerts about account or security issues. With your consent where required, we may also send you marketing communications (like newsletters, promotions, or offers for our other games). You can opt-out of marketing emails or messages by following the unsubscribe instructions provided or contacting us.
  • Providing Support: To respond to your inquiries, troubleshoot problems, and help resolve any issues you are experiencing. For example, if you contact us about a lost account or technical problem, we will use your information to assist you.
  • Analytics and Research: To use data analytics in order to monitor and analyze usage and trends and to improve our Services and player experience. For instance, understanding how players progress through our game can inform what new levels or features to develop next.
  • Advertising and User Acquisition: To facilitate advertising (both of our games within our apps and of third-party products or services) and measure its effectiveness. For example, we use information to ensure you don’t see the same ad too many times, or to show you ads that are more likely to be relevant to you. We also use data to figure out which advertisements attract new players to our games (user acquisition analytics).
  • Preventing Fraud and Cheating: To keep our platform safe and fair. We monitor player activity and interactions to prevent fraud, cheating, abuse, and other activities that could negatively affect the experience for players or violate our Terms & Conditions. This includes enforcing our rules, banning players who violate policies, and using anti-cheat technologies.
  • Ensuring Security: To protect our Services and players. We may use your information to verify accounts, detect suspicious activity, and mitigate threats. For example, we might use certain data to confirm that a login attempt is legitimate or to detect patterns of abuse.
  • Legal and Regulatory Compliance: To comply with our legal obligations. For instance, keeping transaction records for tax purposes, complying with content regulations, or honoring your data privacy rights requests.
  • Other Legitimate Business Purposes: We may use information for other legitimate purposes such as internal audits, developing new products, training, or any other purpose disclosed to you at the time of collection or for which you provide consent.

(Applicable if you are located in the European Economic Area (EEA), United Kingdom, or other regions with similar data protection laws.)

We only process your personal information when we have a valid legal basis to do so. Depending on the circumstance, one or more of the following bases may apply:

  • Performance of a Contract: Processing is necessary to perform the contract we have with you. In other words, to provide the Services you have requested. For example, when you use our games, we must process your data to deliver the game and its features (this is our contract with you, even if it’s not a formal signed document).
  • Legitimate Interests: We process data as needed for Funtomika’s legitimate interests, or those of a third party, provided those interests are not outweighed by your rights and interests. For instance, it is in our legitimate interest to understand usage patterns (so we can improve our games), to secure our Services, and to conduct marketing in a limited way. We always consider the impact on your privacy and provide safeguards to ensure that your personal information is protected.
  • Your Consent: In certain cases, we rely on your consent to process your personal information. For example, we will seek your consent before collecting precise geolocation data or before sending certain marketing communications. If we rely on consent, you have the right to withdraw it at any time, which will not affect processing already carried out while we had your consent.
  • Legal Obligation: We will process personal information when we need to comply with a legal obligation. For example, we might retain data to meet tax record-keeping requirements or respond to lawful requests by public authorities.
  • Protection of Vital Interests: In rare cases, we may process data to protect someone’s life or safety (vital interests). For instance, if we become aware of a situation that poses an imminent threat to someone’s life and we have relevant information, we might provide it to authorities.
  • Public Interest: If ever applicable, we could process data in the public interest or exercise of official authority. This is uncommon in the context of our Services, but an example might be if we were compelled to provide data for a public health inquiry or similar public interest situation.

If you have questions about the legal basis of how we process your personal data, you can contact us for more information (see the Contact Us section).

How We Share Your Information

We do not sell your personal data to third parties. However, we may share or disclose your information to third parties in certain circumstances, as outlined below. In all cases, we share only the information that is reasonably necessary for the third party to carry out its purpose. We also ensure appropriate contracts and safeguards are in place to protect your data when shared.

Service Providers and Vendors

We engage trusted third-party companies to perform tasks on our behalf and help us provide our Services. These third parties provide services such as:

  • Cloud Hosting & Infrastructure: We use cloud storage and server providers to host our website, databases, and game services. This means personal data (like your game progress or account info) might be stored on their servers. Examples include web hosting companies or cloud computing platforms.
  • Analytics Services: We work with analytics providers (like Google Analytics, Unity Analytics, or similar) to process usage data for insights. These providers act under our instructions to analyze data about our app/website usage and report back to us.
  • Customer Support Tools: If we use third-party systems to manage customer support requests or communications (for example, a support ticketing system or live chat service), those systems will process whatever information you provide when seeking help (such as your email and the details of your issue).
  • Marketing and Email Services: We may use vendors to send out marketing communications, surveys, or notifications on our behalf. These providers would handle email addresses or other contact data solely for sending communications that you have agreed to receive or that relate to the Service.
  • Payment Processing: Although purchases are handled by app stores, in some cases we might use separate payment processors (for example, if we sold merchandise on our site). These processors would receive necessary personal information to process payments (like billing info), though for in-app purchases this is generally managed by the platform (Apple, Google) rather than directly by us.

Each of our service providers is contractually obligated to use the shared data only for the purpose of providing their specific service to us and to implement security measures to protect your information. They are not allowed to use your data for their own unrelated purposes.

Advertising Partners

We allow third-party advertising networks to show ads in our games and on our website. These companies help us monetize our games by displaying ads to players. To do this, they may collect certain information about your device and how you use our Services, as described in the Advertising section of this policy.

Our advertising partners include companies such as Unity Technologies (Unity Ads), Google (e.g., AdMob, Google Ads), Meta (Facebook Audience Network), and other ad networks. They may receive identifiers like your Advertising ID, as well as data about ad impressions and clicks within our app. This information helps ensure you receive relevant ads and helps the advertisers measure the effectiveness of their campaigns (for example, knowing if an ad was viewed or if you clicked on it).

These partners might also use the data they collect to improve their own services and for their own purposes, according to their privacy policies. For instance, an ad network may use information about the ads you see across various apps to build a profile of your interests for ad targeting in other contexts. We recommend reviewing the privacy notices of these partners to understand their practices. We work only with partners that abide by relevant privacy laws and offer transparency and controls to users.

Analytics Partners

We share data with third-party analytics providers who help us understand how users interact with our games and website. For example, we might send certain gameplay events or usage statistics to these providers (like level completion rates or user engagement metrics). The analytics partners process this data and provide us with reports and dashboards that aggregate user trends.

Typically, data shared with analytics services is aggregated or anonymized, focusing on trends rather than individual behavior. However, some analytics processes might use unique identifiers to distinguish unique users across sessions. Rest assured, we do not share your name, contact info, or other directly identifiable data with these analytics tools.

These partners are permitted to use the information only to provide services to us and are required to keep it confidential. They do not share it with other parties or use it for their own purposes, except in a form that does not identify you (e.g., aggregated statistics across many apps).

Social Media and Community Features

Our Services may integrate with social networks or offer community features, and in such contexts some sharing of information occurs:

  • If you use social media login or share features, the social network (like Facebook) will receive information that you are using our Services and may receive additional info depending on what you share (for example, if you post gameplay achievements to your Facebook feed).
  • When you add friends or connect with others in the game, some of your profile information (like your username, avatar, and in-game stats) may be visible to those friends or other players. Similarly, if the game includes leaderboards or multiplayer matchmaking, your in-game name and scores may be visible to other players.
  • Any content you submit on public forums or chat rooms related to our Services can be read, collected, or used by others. For instance, if you post strategy tips on a community forum we host, that post will be public along with your username. We may republish public posts (for example, showcasing a great user tip), but we will respect the visibility settings of where it was originally posted.

Please exercise caution when sharing personal information in these public or social features, as information you disclose can be accessed by anyone who can see the chat, forum, or social platform.

Legal Compliance and Protection

We may disclose your information to third parties (such as lawyers, law enforcement agencies, courts, or regulators) if such disclosure is necessary to:

  • Comply with a legal obligation – We will share data when we are legally required to do so. This could be in response to lawful requests such as subpoenas, court orders, or legal processes, or to meet national security or law enforcement requirements.
  • Protect vital interests – In urgent situations, we might share information if we believe it's necessary to protect someone’s life, health, or safety (for example, imminent harm or risk of self-harm).
  • Enforce our rights – We may disclose information to enforce our Terms & Conditions or other agreements, or to collect any amounts owed to us.
  • Prevent fraud or technical issues – If we believe a user is committing fraud, hacking, or other crimes, we may share data with appropriate authorities or organizations to investigate and prevent harm.
  • Protect our company or others – We will share data as needed to protect the rights, property, or safety of Funtomika, our employees, our users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Such disclosures will be made in accordance with applicable laws. Whenever feasible and lawful, we may notify you of such sharing (for example, if we are not legally barred from doing so and if we have your contact information).

Business Transfers

If Funtomika is involved in a merger, acquisition, reorganization, bankruptcy, or sale of all or part of its assets, your information may be transferred as part of that transaction. We will ensure the confidentiality of any personal information involved in such transactions and provide notice before your personal data is transferred and becomes subject to a different privacy policy.

In any new entity, your information will still be used in a manner that is consistent with the privacy policy under which it was collected (unless you consent otherwise). If the prospective new owners intend to use your data for purposes not covered by this policy, you will be informed and, if legally required, given an opportunity to consent or opt-out.

Cookies and Tracking Technologies

Cookies are small text files that websites place on your device (computer, tablet, smartphone) as you browse. They are widely used to make websites work, or work more efficiently, as well as to provide information to the site owners. In addition to cookies, there are similar technologies like web beacons (pixel tags), local storage, and SDKs in mobile apps, which can be used to store or track information.

Here is how Funtomika and our partners use these technologies:

  • Essential Cookies (Website): These cookies are necessary for the website to function. They might remember your preferences (e.g., language selection) or keep you logged in (if our site has a login). Without these cookies, certain services on the website may not be available or may not remember your settings.
  • Analytics Cookies: We use analytics tools that set cookies to gather information about site traffic and performance. For example, we might use Google Analytics cookies to see how many users visit certain pages, how long they stay, and how they move through our site. This information helps us improve the website by understanding how users interact with it. The data collected is aggregated and anonymized; it does not include personal details like your name.
  • Advertising and Marketing Cookies: Our website may partner with advertising networks that use cookies to collect information about your browsing activities on our site and other sites over time. This information is used to show you ads that are more relevant to your interests (interest-based advertising). For instance, if you visit our game pages, you might later see ads for our games on other websites. We (or third parties) may also use cookies to measure the effectiveness of advertising campaigns – for example, to see if ads are being clicked or if they lead to game installs.
  • Mobile SDKs (In-App Tracking): In our mobile games, we use SDKs which are pieces of code provided by our analytics and advertising partners. These SDKs operate similarly to cookies but in the app environment. They can track things like app usage, events, and ad interactions. For example, the Unity Ads SDK in our game may track that a particular device watched an ad at a certain time and report that back to Unity’s servers.

Your Choices: You have several options to control or limit how cookies and similar technologies are used:

  • When you first visit our website, you may see a cookie notice or banner. We will request your consent for non-essential cookies (like analytics or advertising cookies) where required by law. You can accept or reject these as you prefer. Even if you accept, you can always change your mind by clearing cookies or using the options below.
  • Most web browsers allow you to manage cookies via their settings. You can usually find options to delete cookies, block them entirely, or block cookies from specific sites. Check your browser’s help documentation for instructions on how to do this. Please note that if you block cookies, some features of our site might not work correctly (for instance, your preferences might not be remembered).
  • For mobile apps, since cookies aren’t used in the same way, refer to the Advertising and Analytics section for how to opt out of interest-based ads and tracking in apps (such as using the device’s privacy settings).
  • To opt out of Google Analytics specifically on the web, Google provides an opt-out browser add-on which you can install. Similarly, you can use your browser’s Do Not Track (DNT) feature, although not all services honor DNT signals.

For more information about cookies and how to manage or delete them, you can visit websites like AllAboutCookies.org. Keep in mind that removing or disabling cookies does not mean you will no longer see ads; it only means the ads may be less relevant to you.

Advertising and Analytics

We use third-party advertising and analytics services to support our business. Here’s more detail on how these work and how you can opt out:

Third-Party Advertising in Apps: Our games may display ads delivered by third-party ad networks. These ads allow us to offer our games for free or at low cost. To show ads that are likely to be of interest, ad networks may use information about your device and your interactions with our app and other apps. This information can include your device’s advertising identifier, information about your usage of our game, and other apps installed on your device or usage context. The ad content you see may be based on your current game context (for example, showing an ad for a puzzle game if you are playing a puzzle game), or it may be generalized (random ads).

Interest-Based Advertising: Many of our advertising partners use interest-based advertising (also known as personalized or targeted ads). This means they try to show you advertisements that are relevant based on your inferred interests. For example, if you often play puzzle games, you might see ads for other puzzle or brain-training apps. Our partners achieve this by collecting data about your app usage over time and across different apps. They might also use information collected from other sources (like web browsing data linked to your advertising ID) to infer your interests.

Opting Out of Personalized Ads: You can opt out of interest-based advertising on mobile devices by adjusting your device settings:

  • On Android devices, go to Settings > Privacy > Ads (or Google > Ads, depending on your device) and select “Opt out of Ads Personalization.” On newer Android versions, you might see an option to “Delete advertising ID” which will disassociate your past activity from a specific ID.
  • On iOS devices, go to Settings > Privacy & Security > Tracking, and either globally disallow apps to request to track, or turn off tracking for specific apps. Additionally, you can go to Settings > Privacy & Security > Apple Advertising and turn off “Personalized Ads” to stop Apple from using your info for ads on their platforms. (Note: Apple’s own setting won’t affect third-party ad networks in our games, so the Tracking setting is the key control.)

Using these settings will instruct our ad partners to not use your data for targeted advertising. You will still see ads, but they should be more generic. Also note, if you reset your Advertising ID (an option on both Android and iOS), any profile associated with your previous ID will not be linked to the new ID.

Opting Out via Industry Tools: In addition to device settings, there are industry-wide opt-out mechanisms:

  • The DAA’s AppChoices app allows you to opt out of interest-based ads for many companies on mobile devices. You can download AppChoices for your device and select the companies you want to opt out from.
  • The Network Advertising Initiative (NAI) opt-out page lets you opt out of interest-based ads from NAI member companies. While geared towards web-based advertising, some of those companies also serve in-app ads.
These tools require an internet connection and rely on cooperation by participating companies. After you opt out, you should avoid clearing the app’s data or resetting your device’s identifier frequently, or you may need to opt out again.

Analytics Services: We use analytics services to gather data about the usage of our games and website. Examples include tracking how long a typical game session lasts, which features are used most, and what causes players to stop playing. This information is invaluable for improving our games. Analytics services may use unique device identifiers, cookies, or other methods to correlate game sessions from the same user across time. They provide us with reports that don’t identify you by name or email, but rather give overall patterns and trends. For example, an analytics report might tell us “X% of players who reach level 5 play again the next day.”

You generally cannot opt out of being included in these analytics aside from not using the Services, but the data used is at a high level and not used to target you. However, if any analytics provider offers its own opt-out (like Google Analytics offers a browser opt-out for the web), we will honor such choices. Also, where we use analytics that involve personal data and local laws require consent (e.g., for certain cookies in Europe), we will ask for your consent before enabling those analytics.

Advertising “Sale” of Data: As mentioned, we do not sell personal data in the traditional sense (for money). However, some privacy laws (like California’s CCPA/CPRA) have a broad definition of “sale” or “share” that can include sharing data for advertising purposes. If you have exercised an opt-out through the means described above, we will also treat that as a request to opt-out of any “sale” or “sharing” of your data under those laws. We do not knowingly “sell” the personal information of users under 16 in any case.

If you have any issues or questions about ads or analytics in our games, you can always contact us for more information (see Contact Us).

Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which we collected it, unless a longer retention period is required or permitted by law. The exact time period can vary depending on the type of data and the purposes of processing. Here are some general guidelines we follow:

  • Account Data: If you create an account for our Services, we will keep your account information while your account is active. If you decide to delete your account or stop using our Services, we will initiate deletion of your personal data associated with the account. In many cases, deletion will occur within a short period (for example, we might process account deletions on a periodic basis such as every 30 or 60 days). Note that if you simply uninstall the game but have not requested account deletion, your account data might remain on our servers (so that if you reinstall, you can continue where you left off).
  • Transactional Data: Purchase history may be retained for a longer period as needed for financial reporting and audits, as well as to handle any disputes or refunds. For instance, we might keep a secure record of in-game purchase transactions for several years to comply with accounting laws and to resolve later inquiries about those transactions.
  • Customer Support Communications: If you contacted us for support, we may retain those communications (including any email addresses or contact info provided) for a certain period, so we have a history of your issue in case of follow-ups, and to improve our support processes. Typically, support tickets might be kept for a year or more after resolution, depending on the nature of the issue.
  • Usage Data: Analytics data is often aggregated and anonymized, and may be kept indefinitely to allow long-term analysis of trends. Personal identifiers in raw logs (like IP addresses) may be retained for a shorter period (often a few weeks or months) unless needed longer for security analysis.
  • Legal Requirements & Disputes: We might need to retain certain information for longer periods if required by law or necessary to resolve disputes. For example, if we ban a user for fraud or abuse, we might keep information about that ban to prevent the user from circumventing the rules. Also, if a legal claim or investigation is in process, relevant data might be preserved until it is resolved.

Once the retention period expires or the purpose for collecting the data has been fulfilled, we will securely dispose of or anonymize your personal information. When we anonymize data, we remove or alter information so that it can no longer be linked to an individual. We use anonymized data for legitimate business purposes, such as improving our games and Services, since it no longer identifies users.

If you wish to request deletion of your personal data, please see the Your Rights and Choices section for information on how to do so. Keep in mind that after we delete data from our active systems, it may still reside in our backup archives for a short period until those are also cycled out.

Security

We implement a variety of security measures to safeguard your personal information from unauthorized access, disclosure, alteration, and destruction. We strive to follow best practices and continually improve our security protocols. Some of the measures we take include:

  • Encryption: We use encryption to protect sensitive data. For example, our website is served over HTTPS, which encrypts data between your browser and our servers. Within our systems, we may encrypt sensitive information (such as passwords, which are typically stored using one-way hashing algorithms).
  • Access Control: Access to personal data within our organization is restricted to employees and contractors who need that information to process it. They only access the data necessary for their job functions (principle of least privilege). We also employ authentication measures and, where appropriate, multi-factor authentication to prevent unauthorized access to our systems.
  • Security Testing and Monitoring: We regularly monitor our systems for possible vulnerabilities and attacks. We use firewalls and intrusion detection systems to guard our network. Periodic security audits and penetration tests (sometimes by third-party experts) help us identify and address potential weaknesses.
  • Employee Training: We train our staff about the importance of protecting personal data. Employees who handle personal data are instructed on best practices and are bound by confidentiality obligations.
  • Incident Response Plan: In the event of a security incident or data breach, we have procedures in place to respond promptly. This includes steps to contain the incident, assess its impact, and notify affected parties and authorities as required by law. We will also take steps to prevent future incidents by analyzing the cause and improving our safeguards.

Despite all our efforts, it's important to note that no system is completely secure. The internet is an inherently insecure medium, and there is always a possibility of a breach. We encourage you to also play a role in keeping your data secure: use strong, unique passwords and do not share your account details with others. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that your account has been compromised), please contact us immediately.

International Data Transfers

Funtomika is a global service, and your personal information may be transferred to, and processed in, countries other than your country of residence. These countries may have data protection laws that are different from the laws of your country, and in some cases may not be as protective.

Specifically, our game servers, databases, or service providers may be located in various countries. If you are located in the European Union, United Kingdom, or other regions with data transfer restrictions, know that we may transfer personal data to the United States or other jurisdictions outside of your own. For example, if you contact our support team from Europe, your inquiry and associated data might be handled by staff in the United States.

However, in every case of international transfer, we take steps to protect your information. These include:

  • Standard Contractual Clauses (SCCs): When we transfer EU/EEA, UK, or Swiss personal data to countries not deemed “adequate” by relevant authorities (like the European Commission), we often rely on SCCs in our contracts with the data importer. These are legal contracts approved by the European Commission that bind the recipient to protect your personal data according to EU standards.
  • Additional Safeguards: We may implement additional technical and organizational measures to supplement SCCs, such as encryption of data in transit and at rest and strict access controls, to further ensure data security during transfer and processing by the recipient.
  • Service Providers in Adequate Countries: Whenever feasible, we choose to work with service providers in jurisdictions that have strong data protection laws. Some of our providers might be in countries that the EU has officially recognized as providing an adequate level of protection (for example, Canada, or Japan, or others if applicable).
  • Your Consent in Some Cases: In the event we need to transfer your data in a way not covered by the usual safeguards, we would seek your explicit consent for that specific transfer (for instance, if you request a service that inherently involves sending your data to a third country, we will inform you and only proceed with your acknowledgment).

You can contact us to learn more about our international data transfer practices or to obtain a copy of the relevant safeguards we have put in place (such as a copy of the SCCs). Our contact information is provided in the Contact Us section below.

Your Rights and Choices

You have certain rights regarding your personal information, and we offer you choices about how we use and disclose it. These rights and options may vary depending on your location and applicable law, but we are committed to honoring the core privacy principles behind them. Key rights include:

Right to Access

You have the right to request a copy of the personal data we have collected about you. This is sometimes called a “data subject access request.” Upon request, and after verifying your identity, we will provide you with information about the personal data we hold about you, including the categories of data, the purposes it is used for, and the entities it has been shared with. You will receive this information in a format that is reasonably easy to understand. In most cases, access is provided free of charge, but allowed by law, we may charge a reasonable fee or refuse excessive/repetitive requests.

Right to Rectification

If you believe that any personal information we have about you is incorrect or incomplete, you have the right to request that we correct (rectify) or update it. For example, if you change your email address or discover that we have an incorrect spelling of your name, you can ask us to update our records. We will take reasonable steps to verify the accuracy of the new data you provide and make corrections promptly.

Right to Erasure (Right to be Forgotten)

You may request that we delete your personal data under certain circumstances. This right is not absolute, but we will honor it if:

  • The data is no longer needed for the purposes it was collected or processed.
  • You withdraw your consent (if the basis for processing was consent) and we have no other legal basis to continue processing.
  • You object to processing based on our legitimate interests and we do not have an overriding legitimate ground to continue.
  • We processed your data unlawfully or not in compliance with applicable law.
  • Erasure is required to comply with a legal obligation.
Note that in some cases we may retain certain information despite an erasure request if permitted or required by law. For instance, we might keep some transaction records to comply with financial laws, or keep a record of your request itself to demonstrate compliance. Also, deleting your data may mean you lose access to our Services (e.g., if it’s tied to an account) or lose progress in a game.

Right to Restrict Processing

You have the right to ask us to limit the processing of your personal information in certain situations. This means we would still store your data, but not use or share it further while the restriction is in place. You can request restriction if:

  • You contest the accuracy of the personal data – for a period enabling us to verify its accuracy.
  • The processing is unlawful but you oppose erasure and request restriction instead.
  • We no longer need the data but you need it preserved for the establishment, exercise, or defense of legal claims.
  • You have objected to our processing based on legitimate interests, pending verification of whether our legitimate grounds override yours.
If processing is restricted, we will inform you before lifting the restriction. We will also only process the restricted data for certain things, such as storing it, with your consent, for legal claims, or to protect others’ rights, as allowed by law.

Right to Object

You have the right to object to our processing of your personal data when that processing is based on legitimate interests (including profiling), or when it’s for direct marketing purposes.
Direct Marketing: If you object to processing for direct marketing, we will stop using your data for that purpose immediately. This includes profiling to the extent it’s related to direct marketing.
Legitimate Interests: If you object to processing that we base on legitimate interests, we will consider your objection and stop processing the data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or the processing is required for us to establish, exercise, or defend legal claims. For example, you might object to analytics processing; we would then evaluate if our need for analytics is overridden by your privacy concern, and if appropriate, we may cease or isolate your data from that processing.

Right to Data Portability

This right allows you to obtain a copy of certain personal data in a format you can move from one service provider to another (which can be particularly useful if you want to bring your data to a competing service). Specifically, you can request a machine-readable copy of the information you have provided to us in a structured, commonly used format (for example, a CSV file containing account information and gameplay statistics that you personally gave us). You can also ask, where technically feasible, that we transmit that data directly to another entity (this is often not simple, but we will do our best to accommodate requests). Note that portability applies only to data processed by automated means, and only where our processing is based on your consent or a contract you have with us.

Right to Withdraw Consent

If we are processing your personal data based on your consent, you have the right to withdraw that consent at any time. Withdrawing consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, and it won’t affect processing of your personal data under other legal bases (for example, if we have a legal obligation to keep records). If you withdraw consent for a specific feature (say, personalized ads or access to a particular data type), you may not be able to continue using that feature. We will inform you of any such consequences at the time you withdraw consent.

Rights Under Specific Jurisdictions

California (CCPA/CPRA): If you are a California resident, you have rights under the California Consumer Privacy Act (as amended by the CPRA) that overlap with the above, such as the right to know what personal information we collect, the right to access that information, the right to delete (with some exceptions), the right to opt-out of “sale” or “sharing” of personal information, and the right to non-discrimination for exercising your privacy rights. This Privacy Policy is designed to provide the information needed to exercise those rights (for example, see the Information We Collect and Sharing sections for the categories of data and third parties). You or your authorized agent can make requests to us as described below in the Contact Us section. We will verify requests and respond as required by law.
Other Regions: Likewise, if you are in a jurisdiction like Brazil or Canada that provides additional rights, we will respect those in accordance with applicable law. For instance, Brazilian users have rights under the LGPD similar to the ones described above, and Canadian users have rights under PIPEDA and related provincial laws to access and correct their data, etc.

Right to Lodge a Complaint

If you believe that we have infringed your data protection rights or any relevant privacy law, you have the right to lodge a complaint with a supervisory authority. For example, if you are in the EU, this would typically be the data protection authority in the country where you live or work, or where the issue occurred. If you are in the UK, it’s the Information Commissioner’s Office (ICO). In Canada, it’s the Office of the Privacy Commissioner, etc. We would, however, appreciate the chance to address your concerns directly before you approach a regulator, so we encourage you to contact us first, and we will do our best to resolve the issue.

Exercising Your Rights: To exercise any of the applicable rights mentioned above, please contact us using the information provided in the Contact Us section. We will need to verify your identity to process certain requests (to ensure that we don’t give your data to someone else). Verification might involve checking that the request comes from within the game or from the email associated with your account, or asking for additional information if necessary. We will respond to your request within the timeframe required by law (for example, within 30 days for GDPR, which may be extended, or 45 days for CCPA requests, extendable by another 45 days with notice). If we need more time or cannot fulfill your request, we will let you know the reason (e.g., certain data cannot be deleted due to legal obligations).

No Discrimination: We will not discriminate against you for exercising any of these rights. That means we won’t deny you our Services, give you a different level of service, or charge you a different price just because you exercised your privacy rights. Our game might, however, require certain data to function. So if you request deletion of essential data, features of the game might not work, but that’s a consequence of the service being unable to function without the data, not a punitive action.

Children’s Privacy

Our Services are intended for a general audience and we do not knowingly collect personal information from children without appropriate consent. The age at which someone is considered a “child” for data protection purposes varies by country. We treat anyone under 13 years of age as a child by default, but in some regions we apply a higher age threshold (for example, 16 in the European Union, as required by the GDPR in certain member states).

If you are under the age where you can provide consent in your country, you should only use our games and Services with involvement of a parent or guardian. We ask that individuals under 13 (or the relevant age in your country) not provide personal information to us. For example, you shouldn’t make purchases, sign up for newsletters, or send us support requests with personal data if you are below this age.

In the event we learn that we have inadvertently collected personal data from a child without proper consent, we will take steps to delete that information promptly. This may involve deleting the child’s account and any data associated with it. If you believe we might have any information from or about a child under the age of consent in your jurisdiction, please contact us immediately so that we can investigate and address the issue.

Parents or guardians: If you allow your minor child to use our Services, we encourage you to talk with them about online safety. You should also review this Privacy Policy and understand what information may be collected, used, or shared. If you wish to review or delete your child’s personal data, you can contact us to make that request (see Contact Us). We may require additional verification (to ensure the requester is indeed the child’s parent or guardian) before honoring such requests.

Our website and games may contain links to other websites, products, or services that are not owned or controlled by Funtomika. For example, our site might link to our social media pages (like a Facebook or Twitter page), or our games might present an advertisement that, if clicked, takes you to a third-party website or app store.

If you click on a third-party link or access an external service, you will be directed to that third party’s platform. We do not have control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services. This Privacy Policy does not apply to your activities on those external platforms.

We recommend that you review the privacy policy of every site or service you interact with. For example, if you go to an external community forum or a social network to discuss our game, any information you share there is governed by that site’s privacy policy. If you click on an ad in our game that leads to an advertiser’s site, any information you provide on that site would be handled according to the advertiser’s policy.

Nonetheless, if you have feedback about any third-party integrations in our Services (for instance, if you feel an integrated partner is not treating your data properly), we welcome that feedback as it helps us evaluate our own practices and partnerships.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make changes, we will revise the “Last Updated” date at the top of the policy. If the changes are material, we will take additional steps to bring them to your attention. This might include posting a notice on our website, sending an in-app notification, or emailing you (if we have your email on file) to let you know about the updated policy.

Your continued use of our Services after the effective date of the updated Privacy Policy will constitute your acceptance of the changes. If you do not agree to the changes, you should stop using our Services and, if applicable, delete your account or otherwise exercise your rights (e.g., request deletion of your data). We will always indicate when the Privacy Policy was last updated to help you determine whether there have been changes since your last review.

If we propose to use personal data in a manner that is significantly different from that stated in our policy at the time of data collection, we will notify users (via email or a prominent notice within the Service) and, where required by law, seek consent for the new uses.

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please do not hesitate to contact us. We are here to help and address any issues you may have. You can reach us in the following ways:

Funtomika Privacy Team
Via Website: Please submit your inquiry through our Contact Us page.

When you contact us, please provide as much detail as possible about your question or request. If you are contacting us to exercise one of your data rights, specify which right you are exercising and any relevant details (for example, the game you play, your account name, etc.), so we can effectively assist you. We will respond to your inquiry as soon as reasonably possible, and in any event within any timeframes required by law.