Effective date: September 11, 2026
This Privacy Policy is written in English and may be translated into other languages at the discretion of the Company. The English text is legally binding and shall prevail in the event of any conflict between the text and its translation.
1. Who is responsible for processing your data and how to contact us
This Privacy Policy applies to all of our games, websites and related services, collectively referred to as the "Services". Your use of the Services after the effective date is subject to this Privacy Policy.
Please read the following text to learn more about how we use your personal information.
Pursuant to General Data Protection Regulation No. 2016/679 and applicable law ("GDPR"), as well as in accordance with the law on the protection of personal data Federal Law No. 152, "SmartThings" Limited Liability Company (referred to as "SmartThings" or "we") will be the data controller responsible for all personal data processed by us.
- Data Operator: "SmartThings" Limited Liability Company
- Email: [email protected]
- Address: Prospect Respublika, Building 24A, Baykonur District, Astana, Kazakhstan, 010000
2. What personal data do we collect and why?
We may collect, use and process your personal data in a variety of ways. In all cases, we try to protect your personal data. Each of the sections listed below describes how we receive and process your personal data.
2.1. Players of our games
We collect personal data from current, prospective and former players ("users") of our games.
A — Sources of personal data
We may receive your personal data from the following sources:
a) directly from you (for example, when you contact our support); and/or
b) automatically from your device through the game and the third-party software development kits (SDKs) integrated into it — see Section 2.2; and/or
c) from the platforms on which the games run (Apple App Store, Google Play), for example to verify a purchase.
B — Types of personal data collected and processed
We may collect the following categories of personal data about our users:
a) Data about the build version, game progress and in-game events. When you use the Services, we create a SmartThings-specific identifier for you; our partners may create their own identifiers;
b) Your IP address and unique mobile device identification numbers (for example, your device ID or advertising ID);
c) Data about your device such as manufacturer, model, operating system, CPU, RAM, language, time zone and current time;
d) Approximate geographic location data derived from your IP address (country or city level). We do not request access to the precise location (GPS) of your device;
e) Purchase history, including order details (purchase ID, amount spent, currency, date, time, offers used). We never receive your payment card details;
f) Data to combat fraud (for example, attempts to abusively claim rewards in games or fraudulent clicks on advertising);
g) Data for advertising and analytics purposes so that we can offer you better Services (for example, which ads were shown and whether you interacted with them);
h) Your email address and the content of your messages if you contact our support, and your feedback about your experience with us;
i) Other data that you choose to provide to us.
Our games do not require registration and do not ask for your name, email address or social network accounts.
C — Reasons and legal basis for collecting personal data
| We may use your personal information to: | Our legal basis for this: | Our legitimate interests in this regard are: |
|---|---|---|
| Provide you with our games and services, including saving your progress and delivering purchased content | Performance of a contract; legitimate interest | Efficient execution of our contractual and legal obligations; administrative reporting (including at the intra-group level) |
| Learn about how our games are used, fix crashes and improve performance | Legitimate interest | Understanding the market in which we operate; maintaining and improving the quality of our products; administrative reporting (including at the intra-group level) |
| Show advertising in our games, including personalized advertising | Consent (where required by law, for example the App Tracking Transparency prompt on iOS); legitimate interest | Funding free-to-play games through advertising |
| Provide safety | Legitimate interest | Security control, risk protection, fraud prevention; administrative reporting (including at the intra-group level) |
| Respond to your support requests | Legitimate interest | Efficient execution of our contractual and legal obligations; account management |
If you object to our use of your personal information for the above purposes, please email us at the address set out in Section 1.
D — Period of retention of personal data
We will only keep your personal data for as long as necessary for the purposes for which it was collected. Analytics and crash data held by our service providers are retained according to their retention settings (for Google Firebase Analytics, up to 14 months). Support correspondence is retained for up to 3 years after the request is closed. Game progress is stored on your device and is deleted when you uninstall the game.
2.2. Third-party services in our games
Our games integrate the following third-party SDKs. Each provider processes data under its own privacy policy, and we recommend that you read them:
- Google Firebase Analytics and Firebase Crashlytics (Google LLC) — gameplay events, purchase events, crash and performance reports, device information, device identifier, approximate location derived from IP address. Used for analytics and for diagnosing crashes. https://policies.google.com/privacy, https://firebase.google.com/support/privacy
- Unity LevelPlay (ironSource) and Unity Ads (Unity Technologies) — advertising identifier (IDFA on iOS, GAID on Android; only with your consent where required by law), device information, IP address and approximate location, ad interaction data. Used to display, measure and personalize advertising. https://unity.com/legal/privacy-policy, https://unity.com/legal/game-player-and-app-user-privacy-policy
- Unity In-App Purchasing together with the Apple App Store and Google Play billing systems — purchase history and receipt validation. Payment itself is processed by Apple or Google under their own terms; we never receive your payment card details.
2.3. Advertising and tracking
Our games are free to play and are funded by advertising.
On iOS, before the advertising identifier (IDFA) is shared with our advertising partners, we ask for your permission through the App Tracking Transparency prompt. If you decline, you will still see ads, but they will not be personalized based on your activity in other apps and websites. You can change your choice at any time in Settings → Privacy & Security → Tracking.
On Android, you can reset or delete your advertising ID and opt out of ads personalization in Settings → Google → Ads.
2.4. Children
Our games are not directed to children under the age of 13 (or under 16 in the EU/EEA), and we do not knowingly collect personal data from them. If you believe a child has provided us with personal data, contact us at the address in Section 1 and we will delete it.
2.5. Data deletion
You can request deletion of the data associated with your device by emailing [email protected] with the name of the game and your device model. We will forward the request to our service providers where applicable. Uninstalling the game deletes locally stored progress.
2.6. Representatives of our current or prospective corporate customers, business partners and suppliers
We may collect personal information about employees, officers, designees and others associated with current and prospective corporate clients, business partners and suppliers of SmartThings.
A — Data sources
We may receive your personal data from the following sources:
a) directly from you;
b) from your employer if you are an employee of our current or prospective client, business partner or supplier;
c) in the course of networking events in which we host, sponsor or participate, including on behalf of networking event hosts; and/or
d) from publicly available sources (for example, your company website or social networks such as LinkedIn).
B — Types of personal data collected and processed
a) name;
b) the address of the place of work;
c) business email address;
d) business phone number; and/or
e) position.
C — Reasons and legal basis for collecting personal data
| We may use your personal information to: | Our legal basis for this: | Our legitimate interests in this regard are: |
|---|---|---|
| Provide you with our products and services or receive products and services from you | Legitimate interest | Efficient execution of our contractual and legal obligations; administrative reporting (including at the intra-group level) |
| Establish and manage our relationships | Legitimate interest | Efficient execution of our contractual and legal obligations; account management; understanding the market in which we operate; administrative reporting (including at the intra-group level); filing or contesting claims |
| Learn about how our products and services are used or can be used | Legitimate interest | Understanding the market in which we operate; administrative reporting (including at the intra-group level) |
| Provide safety | Legitimate interest | Security control, risk protection, fraud prevention; administrative reporting (including at the intra-group level) |
| Communicate to you about our products, services and events that may be of interest to you by email or other electronic means | Legitimate interest | Promotion of our products and services; administrative reporting (including at the intra-group level) |
If you object to our use of your personal information for the above purposes, including direct marketing, please email us at the address set out in Section 1. When we use your email address to send you marketing information, we will ask for your prior consent if required by law.
Protection against automated submissions. The feedback form on our site is protected by Google reCAPTCHA, a service of Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA). When you send the form, reCAPTCHA analyses your interaction with the site (for example, IP address, browser and device information, mouse movements and time spent on the page) and returns a score that tells us whether the submission is likely to come from a person or a program; the content of the form itself is not passed to reCAPTCHA. The legal basis is our legitimate interest in protecting the site from spam and abuse. The processing is subject to the Google Privacy Policy and the Google Terms of Service.
D — Period of retention of personal data
We will only process your personal data for as long as is necessary for the purposes for which it was collected in connection with your business relationship with us, unless we have a legal right or obligation to retain the data for a longer period, or when this data is necessary for the establishment, assertion or defense of legal claims.
2.7. Site visitors
We may receive your personal data from the following sources:
a) directly from you (for example, when subscribing to services offered on our site, including, but not limited to, email newsletters, interactive services, hosted materials); and/or
b) from your device or browser through internet service providers, operating systems and platforms, and data analytics service providers. If you contact us, we may keep a record of your contact.
A — Types of personal data collected and processed
a) browser type;
b) information about the use of our site (for example, pages visited, geographic location, time spent on the site, online activities);
c) cookie data;
d) online marketing preferences; and/or
e) IP address.
B — Reasons and legal basis for collecting personal data
| We may use your personal information to: | Our legal basis for this: | Our legitimate interests in this regard are: |
|---|---|---|
| Provide you with the services of our website | Legitimate interest | Site management; promotion of our products and services; account management |
| Establish and manage our relationships | Legitimate interest | Understanding the market in which we operate; administrative reporting (including at the intra-group level); account management |
| Learn about visitor behavior on our site(s) and the performance of the site(s), including to check, maintain and improve the quality of our site, products and services | Legitimate interest | Site management |
| Maintain security (including protecting the confidentiality of personal information, preventing unauthorized access to and modification of our systems, and otherwise protecting personal information) | Legitimate interest | Security control, risk protection, crime prevention; administrative reporting (including at the intra-group level) |
| Provide advertising or marketing services, including informing you about our products, services and events that may be of interest to you, by email or other electronic means | Legitimate interest | Promotion of our products and services; administrative reporting (including at the intra-group level) |
| Learn about how our products or services may be used, including to test, maintain or improve the quality of our products and services | Legitimate interest | Understanding the market in which we operate; administrative reporting (including at the intra-group level) |
If you object to our use of your personal information for the above purposes, including direct marketing, please email us at the address set out in Section 1. Where we use cookies and similar technologies, we will ask for your prior consent where required by law. When we use your email address to send you marketing information, we will ask for your prior consent if required by law.
Protection against automated submissions. The feedback form on our site is protected by Google reCAPTCHA, a service of Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA). When you send the form, reCAPTCHA analyses your interaction with the site (for example, IP address, browser and device information, mouse movements and time spent on the page) and returns a score that tells us whether the submission is likely to come from a person or a program; the content of the form itself is not passed to reCAPTCHA. The legal basis is our legitimate interest in protecting the site from spam and abuse. The processing is subject to the Google Privacy Policy and the Google Terms of Service.
C — Period of retention of personal data
We will only keep your personal data for as long as necessary for the purposes for which it was collected in connection with your inquiries through our site or your use of our site.
2.8. Visitors to our offices
A — Sources of personal data
We may receive your personal data directly from you or from our records on our operating systems or on our platforms.
B — Types of personal data collected and processed
a) name;
b) official contact details;
c) organization;
d) role;
e) the time and date of your visit; and/or
f) image (for example, from CCTV cameras in our offices).
C — Reasons and legal basis for collecting personal data
| We may use your personal information to: | Our legal basis for this: | Our legitimate interests in this regard are: |
|---|---|---|
| Provide safety | Legitimate interest | Security control, risk protection, crime prevention |
| Keep a record of visitors to our offices | Legitimate interest | Administrative reporting |
If you object to our use of your personal data for the above purposes, please let us know by email at the address set out in Section 1.
D — Period of retention of personal data
We retain your personal data for as long as necessary to ensure the safety of visitors to our offices, and when it is no longer necessary (usually after 90 days), we delete it.
3. To whom we share your personal data
Our partners and service providers. We may disclose information about you to organizations that provide services to us, while obliging them by contract to keep your personal data confidential and comply with the GDPR, Federal Law No. 152 and other data protection laws.
We may share your information with the following types of service providers:
a) the analytics, crash reporting, advertising and in-app purchase providers listed in Section 2.2;
b) technical support providers who maintain our website and IT infrastructure;
c) software providers, including software-as-a-service solution providers, where the provider stores relevant personal data on our behalf;
d) professional advisors such as lawyers, accountants, tax advisors, auditors, insurance brokers;
e) providers who help us compile reviews of our products and services;
f) our advertising and marketing agencies and consultants, and organizations and online platforms that we have selected to conduct marketing campaigns on our behalf;
g) other service providers who help us provide our services.
Law enforcement and government departments. We may disclose your personal information as permitted by law to investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our intellectual property rights, situations that pose a potential threat to the physical safety of any person, violations of our terms and other agreements, or as required by law.
4. Transfer of personal data outside the EU/European Economic Area
We share your personal data with our affiliates and partners in the EU/EEA and outside the EU/EEA. In cases where the transfer of data outside the EU/EEA is not subject to an adequacy decision of the EU Commission, we rely on the safeguards described in Art. 46 and subsequent articles of the GDPR, as well as Federal Law No. 152 in the territory of the Russian Federation. First of all, these include the Standard Contractual Clauses approved by the EU Commission, which we have reinforced with additional safeguards such as individual risk assessments and additional contractual and technical security measures, including additional encryption or pseudonymization, to enable data transfer to SmartThings affiliates and partners outside the EU/EEA. The full text of the Standard Contractual Clauses approved by the EU Commission can be found at: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en
For more information about data transfers to third countries, as well as our security measures and additional protections, please email us at [email protected].
We share your personal data with external vendors or service providers that we engage to perform services or functions on our behalf and in accordance with our instructions. Where such suppliers are located in the EU, we ensure that they are contractually bound to comply with EU data protection regulations. In our contracts with these organizations, we also direct them to process personal data only in accordance with our instructions and only in order to provide the agreed services and protect the integrity and confidentiality of your personal data entrusted to them.
We may also disclose personal data to our advisers and consultants, law enforcement and other government departments (including tax and social security authorities), police, prosecutors, courts and judicial divisions. All such recipients are solely responsible for complying with EU data protection regulations.
Some of the suppliers we engage are located outside the European Economic Area. In cases where the EU Commission has not recognized these areas as providing adequate protection for personal data, we rely on the safeguards described above. You can request a copy of these agreements by sending an email to the address provided in Section 1.
5. Your rights
You have the right to receive information from us about how we handle your personal data, to see copies of all personal data we hold, and to request that we change, correct or delete your personal data from our systems. You can also restrict or object to the processing of your data and, where processing is based on consent, withdraw that consent at any time. To exercise any of these rights, email us at [email protected]. You also have the right to lodge a complaint with your local data protection authority.
6. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. When we do, we will change the effective date at the top of this page. Material changes will be announced in the game or on our website before they take effect.