Privacy Policy | Epic Labs

Summary of Privacy Policy Elements

Element	Summary
1. Collection of Personal Information	We collect personal information such as identifiers (name, email), geolocation, game usage data, device information, advertising IDs, and transaction data to provide, improve, and personalize the gaming experience. This information may be shared with third-party service providers to improve user experience.
2. Who We Share Your Personal Information With	Personal information may be shared with other players (e.g., profile, in-game activity), third-party vendors (e.g., cloud service providers, analytics partners), advertising partners, and payment processors (e.g., Apple, Google, Huawei). Personal information may also be shared with law enforcement agencies or during corporate transactions.
3. Third Party Privacy Practices	If accessing through third-party platforms like Google or Apple, those services may collect additional data. Privacy practices of third-party services apply separately, and we may use services like Facebook for social features like logging in and tracking game progress.
4. Security	While we implement security measures to protect your information, transmission over the internet is not completely secure, and we may take additional steps to safeguard it.
5. Where We Process Your Personal Information	We process your information in various countries, including the EEA, UK, US, and others. Transfers outside the UK or EEA are protected through standard contractual clauses or when adequacy decisions are in place.
6. How Long We Store Your Information	We retain personal information as long as you use our games and for up to three years after you stop interacting with them. We take steps to permanently delete data when appropriate.
7. Your Rights	If you’re based in the EEA, UK, Switzerland, or California, you have rights like access, erasure, objection to processing, and data portability. You can exercise these rights by emailing legal@epiclabs.app.
8. Contact & Complaints	For questions, comments, or complaints about the policy, you can contact us at legal@epiclabs.co.tz. You can also lodge complaints with data protection authorities.
9. Changes	Any updates or changes to this policy will be published here. Significant changes will be communicated through the website and in-game notifications.
10. Advertising and User Acquisition Partners	You can find the list of advertising and user acquisition partners integrated into our games and their privacy policies, which describe their practices and how you can exercise your rights.
11. Addendum 1 - California Privacy Rights	California residents have the right to request information about personal data collection, sales, or disclosures over the last 12 months, and to request the deletion of personal information. They cannot be discriminated against for exercising these rights.
12. Sales of Personal Information / Notice of Right to Opt-Out	We use third-party advertising and tracking technologies to collect and share data with partners for targeting ads. You can opt-out at any time via in-app settings or by submitting a request on our web form.
13. How to Exercise Your Rights	California residents can exercise their CCPA rights by emailing legal@epiclabs.app. Opt-out and preference updates can be done in-app for mobile games.
14. Verification	Requests for access or deletion of personal information must be verified, and you may need to provide identifying information like User ID or Game name to confirm your request.
15. Authorizing an Agent	To authorize someone to make a request on your behalf, email us at legal@epiclabs.app.
16. Shine the Light	We do not rent, sell, or share your personal information with non-affiliated companies for their marketing purposes unless we have your permission.

Introduction

This privacy policy (“Policy”) informs you of your choices and our practices in relation to your Information (as defined below). In this Policy, (“Epic Labs”), “we” or “us” refers to Epic Labs Ltd., a company incorporated in Tanzania with its office located at Kisangani Building, Dar Es Salaam, Tanzania. We choose why we need to use your Information and how it is used, which means we are considered the data controller in certain countries.

For the purpose of this Policy, “Information” means any information relating to an identified or identifiable individual. This includes Information relating to your use of our mobile games (“Mobile Games”). When you use the Mobile Games (the “Games”), you accept our rules and policies which set out how we handle your Information, and you understand we collect, process, use and store your Information as described in this Policy.

If you do not agree with this Policy, you must not play any of the Games. If you change your mind in the future, you must stop playing the Games and you may exercise your rights in relation to your Information as set out in this Policy.

1. Personal Information We Collect

We will process and use the following Information about you:
- Information collected via our customer support channels: when you interact with us via our customer support provider, we collect or ask you to provide
  - your complaint, game, game level data, version, platform, operating system, country and user ID, and
  - any information you choose to provide to allow us to assist you.
- Information you provide when using the Games: when you play the Games, we may ask you to choose a username or to rate the game.
Information we automatically collect or is generated about you when you play the Games:
- Identifiers: your IP address, device ID, unique Epic Labs ID, country and city level location data and device information (such as model, brand, language, and operating system).
- Information regarding your use of the Games: game ID, install and uninstall timestamps, date and time stamps of game events, game time, game progress, achieved scores, interactions with teams, advertising and promotions engagement, transaction records, evidence of you using cheating software or using modified versions of the Games.
Information received from third parties:
- Payment providers: When you make payments in our Games, we receive the following Information from our payment providers about your transactions: transaction ID, country, purchased item, currency, value, and payment timestamp.
- Analytics Information: we integrate analytics software from third party analytics providers in some of our Games. We then receive reports that help us optimise our in-game features and events to each user of our Games which include your user ID and information on your in-game activity.
- Advertising partners: we receive Information from third-party advertising providers, including advertising ID and Information on your interactions with advertising shown in on our Mobile Games.
- Mobile measurement partners: we receive information from mobile measurement partners to allow us to track performance of our marketing campaigns and to detect fraud in such campaigns. This includes advertising ID, IP address, device ID, device name and operating system, language and location.

Children

We take the protection of children’s personal information seriously.

Our Games are not intended for, and we do not knowingly collect personal information from, children under the age of 13 (or the minimum age required by local law in your country, such as in the European Economic Area or the United Kingdom, and in Brazil) without verified parental consent.

If you are under the applicable minimum age, please do not use our Games or provide any personal information to us unless your parent or legal guardian has reviewed and agreed to this Privacy Policy and provided verifiable consent.

If we become aware that we have collected personal information from a child without parental consent or legal basis, we will take immediate steps to delete that information.

For Parents and Guardians:

If you believe that we may have collected personal information from your child without your consent, or if you wish to review, correct, or request the deletion of your child’s personal information, please contact us at legal@epiclabs.app.

How We Use Your Personal Information

Our legal bases for processing your Information under the GDPR include your consent (where applicable), the performance of a contract, compliance with legal obligations, and our legitimate interests (where those interests are not overridden by your rights and freedoms).

We use your Information to:
- Provide you with the Games. We will use your Information to perform our contractual obligation towards you to allow you to create an account, play the Games, remember your progress, allow you to play Games with your friends and communicate with them via in-Game chat (if applicable). We will also use your Information to allow you to make purchases via Google Play or iOS App Store, and maintain a record of such purchases. The Information we process when doing so includes your Information you provide to us when playing the Games, identifiers, Information you generate and display when playing the Games, and Information regarding your use of the Games.
- Improve and monitor Game use. It is in our legitimate interests to improve our Games for our customers. When doing so, we may automatically collect information or generate Information about you when you play the Games, as well as Information about your device such as battery, device manufacturer, model and operating system.
- Provide you with support and to respond to your requests or complaints. If you reach out to us for support, we will use your Information to create a support account for you, respond and resolve your queries and complaints, facilitate support (e.g., retrieval of a game level). When doing so, we perform our contractual obligation towards you. The Information we process when doing so includes your game user ID.
- Conduct analytics. It is in our legitimate interests to analyse the use of and inform, our Games and advertising campaigns, and any other interaction or interest in the same. When doing so we will process Information we automatically collect or is generated about you when you play the Games or interact with advertising campaigns to (a) create anonymised and aggregated data; (b) create segments of users who show particular characteristics or interests; (c) conduct predictive analytics about your interests; and (d) to determine the levels you have played and how many times it took to complete a level in order to improve player satisfaction and improve level design.
- Provide you with advertising. We will present you with ads and suggestions in our Games and elsewhere. These may be ads relating to our own Games or other services you may be interested in. These ads and suggestions may be tailored specifically to you. Where it is required, we will only do so where we have your consent. In situations where your consent is not required, or where we provide contextual advertising, we do so based on our legitimate interests. If you no longer want to receive targeted advertising you can withdraw your consent in the Games settings, or if that option is not available, please see Opt Out of Targeted Advertising which explains how you can opt out and change your device settings. To tailor ads and to allow our advertising partners to tailor ads, we process Information we automatically collect or is generated about you when you play the Games and Information received from third parties.
- Prevent fraud, defend Epic Labs against legal claims or disputes, enforce our terms and to comply with our legal obligations. It is in our legitimate interests to protect our users against online abuse and other anti-social or illegal activity (e.g., when moderating conversation in our Games). Furthermore, it is also in our legitimate interest to protect our interests by (1) monitoring Game use to detect fraud or any other user behaviour which prejudices the integrity of our Games, (2) taking steps to remedy fraud and concerning behaviour, (3) defending ourselves against legal claims or disputes, and (4) enforcing our terms and policies. When doing so, we will process the Information relevant in such a case, including Information you provide us, Information we automatically collect about you, and Information which is provided to us by third parties.
- We do not collect, use, or process any biometric data, including facial recognition, voice data, or fingerprints, in any of our Mobile Games. Should this change in the future, we will update this Privacy Policy and request your consent where required by law.

Who We Share Your Personal Information With

We share your Information with selected third parties, including:
- Other players and users will see your profile Information and in-game activities, as well as any other Information you choose to share with them, such as leaderboards, chat data (if applicable).
- Vendors and service providers we rely on for the provision of the Games, for example:
  - Cloud service providers who rely on for data storage, including Amazon Web Services who are based in the U.S.
  - Customer support solution providers, who help us manage and respond to our customer questions and complaints. This includes companies who host our customer support function.
  - Analytics providers: we work with a number of analytics, segmentation and mobile measurement service providers who help us understand our userbase.
  - User acquisition: We work with a variety of user acquisition partners to help us report on the success of our marketing campaigns. We may use some of your Information to participate in Custom Audience and Lookalike Audience programmes, which enable us to display adverts to both existing and prospective players when they visit one of our partners’ websites.
- Advertising partners. We are an ad-supported service. Subject to your settings, we provide certain Information to advertisers who will use them to serve you with ads in our Games, and we measure who sees and clicks on their ads. We also share advertising identifiers, along with the interests or other characteristics of a device or the person using it, to help partners decide whether to serve an ad to that device or to enable them to conduct marketing, brand analysis, personalise advertising, or similar activities. For more information on how to limit or opt-out from personalized advertisement, please see our Opt Out of Targeted Advertising.
- Payment processors: We use payment processors such as Google (if you run Android on your mobile device), Apple App Store payments (if you run iOS on your mobile device). These payment processors are responsible for the processing of your Information, and may use your Information for their own purposes in accordance with their privacy policies as below:
  - Apple: please see the App Store & Privacy policy available on your Apple device.
  - Google: click here
  - Huawei: click here
  - Samsung: click here
- Companies who belong to the same group as Epic Labs. We share your Information with different entities which are part of our group of companies if any.
- Law enforcement agencies, public authorities or other judicial bodies and organisations. We disclose Information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to comply with a legal obligation, process or request; enforce our terms of service and other agreements, policies, and standards, including investigation of any potential violation thereof; detect, prevent or otherwise address security, fraud or technical issues; or protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organisations for the purposes of fraud protection).
- Change of corporate ownership. If we are involved in a merger, acquisition, bankruptcy, reorganisation, partnership, asset sale or other transaction, we may disclose your Information as part of that transaction.

3. Third Party Privacy Practices

If you access any Games through a third-party platform such as Google or Apple (“Third-Party Services”), you must understand that those Third-Party Services may collect other Information about you (including Information you share with them directly or about your use of the Games) in accordance with their own terms and privacy policies.

The privacy practices described in this Policy do not apply to Third Party Services. Any links in the Games to Third Party Services do not imply that we endorse or have reviewed the Third-Party Services.

If you access the Games via Facebook login, we will receive some of your Facebook account information such as basic profile information you have already provided to Facebook (your profile picture and friends list) and may be able to offer you additional functionalities, including inviting friends and seeing their Game progress.

In addition, you will be able to log in on multiple devices and synchronize your progress in our Games, across multiple devices on multiple platforms. To enable us to provide these in-game social features, we will receive and process your geolocation (country and city only), service provider, VPN, Facebook user ID, and Game behaviour such as current level, number of times it takes to complete each level, and other behaviour related to Game play.

7. Your Rights

If you are based in the European Economic Area (EEA), United Kingdom (UK), Switzerland, Brazil, South Korea, or are a legal resident of California (USA), you have certain rights in relation to your personal information.

California residents – please refer to Addendum 1 – California Privacy Rights.

EEA, UK, Switzerland, Brazil, and South Korea residents – the following rights may apply depending on your jurisdiction and applicable laws:

Access: Request access to the personal information we hold about you and receive details on how we use it and who we share it with.
Correction: Request correction of inaccurate or incomplete personal data we hold about you.
Erasure (Right to be Forgotten): Request deletion of your personal data in certain circumstances. We may retain data where required by law or for legitimate interests such as legal claims.
Restriction of Processing: Ask us to restrict processing of your data under specific conditions (e.g., accuracy checks or objection resolution).
Portability: Receive your data in a structured, commonly used, machine-readable format, or request its transfer to another provider (where applicable).
Objection or Withdrawal of Consent:
- Object to processing where based on legitimate interests.
- Withdraw consent at any time (this does not affect the lawfulness of prior processing).

Examples:

To stop personalized ads: adjust your preferences in the in-app settings.
To stop push notifications: modify your device or app notification settings.

Additional Rights for Brazil (LGPD)

Request anonymization, blocking, or deletion of unnecessary or excessive personal data.
Request information about public and private entities with which we share your data.
Receive clarification on the consequences of refusing consent.

Additional Rights for South Korea (PIPA)

Request access, correction, or deletion of personal information.
Suspend processing of personal data.
Withdraw consent at any time without affecting prior processing.

To exercise any of the above rights, please email us at legal@epiclabs.app. We will respond in accordance with applicable data protection laws and may request identity verification.

11. Addendum 1 - California Privacy Rights

The terms of this Addendum apply to residents of California under the California Consumer Privacy Act of 2018 (CCPA), as amended or superseded. For the purposes of this addendum, “Personal Information” means information that identifies, relates to, describes, or is reasonably capable of being associated with a particular consumer or household. Personal Information does not include publicly available information, deidentified or aggregated data, or information excluded from the scope of the CCPA.

Collection and Disclosure of Personal Information

Through your use of the Games, we may have collected and disclosed the following categories of Personal Information:

Identifiers: Name, email (if contacted support), IP address, device identifiers, advertising ID, Epic Labs ID, and third-party account IDs.
Internet or other electronic network activity information: Game usage data and ad interaction data.
Geolocation data: City-level location data.
Commercial information: Purchases made, postcode, state, and (if disclosed) billing address.

We collect this information from the following sources:

You and your devices.
Advertising networks and partners.
Analytics providers.
Social networks, as permitted.

We use personal information for the following purposes:

To operate and administer the Games.
To improve the Games.
To communicate with you.
To serve advertising.
For security and fraud detection.
To fix bugs and technical issues.

We may disclose personal information to:

Other players (if you use in-game chat).
Affiliated companies.
Marketing and advertising partners.
Service providers under strict contract obligations.
Regulators, courts, and law enforcement.
Entities acquiring our business.

12. Sales of Personal Information / Notice of Right to Opt-Out

Over the past 12 months, we have used third-party advertising and other tracking technologies on our Games to collect information about you, your device(s), and your use of our Games. We share that information with selected third parties such as advertising partners who use it to target advertisements to you online.

You can opt-out and exercise control over the use of these technologies at any time by adjusting the in-app settings. Alternatively, you can also submit your request to opt-out via legal@epiclabs.app.

Rights Under the CCPA

The California Consumer Privacy Act (CCPA) provides California residents with specific legal rights. These rights are not absolute and may be subject to certain exemptions. If no exemption applies to you or your personal information, you have the right to:

Submit a verifiable request for the following information covering the 12 months preceding your request:
- The categories of Personal Information about you that we collected, sold, or disclosed.
- The categories of sources from which the Personal Information was collected.
- The purpose for collecting or selling Personal Information about you.
- The categories of third parties to whom we disclosed Personal Information about you, and the categories of Personal Information disclosed (if applicable), including the purpose for disclosure.
- The specific pieces of Personal Information we collected about you.
Submit a verifiable request that we delete Personal Information we collected from you.
Be free from unlawful discrimination for exercising your rights, including not receiving a different level or quality of services, or being denied goods or services for exercising your rights under the CCPA, subject to certain limitations.

We aim to fulfil all verified requests within 45 days, as required by the CCPA. If an extension is necessary, we may take an additional 45 days and will provide an explanation for the delay.

Summary of Privacy Policy Elements

Introduction

1. Personal Information We Collect

Children

How We Use Your Personal Information

Who We Share Your Personal Information With

3. Third Party Privacy Practices

4. Security

5. Where We Process Your Personal Information

6. How Long We Store Your Information

7. Your Rights

Additional Rights for Brazil (LGPD)

Additional Rights for South Korea (PIPA)

8. Contact & Complaints

9. Changes

10. Advertising and User Acquisition Partners

11. Addendum 1 - California Privacy Rights

Collection and Disclosure of Personal Information

12. Sales of Personal Information / Notice of Right to Opt-Out

Rights Under the CCPA

13. How to Exercise Your Rights

14. Verification

15. Authorizing an Agent

16. Shine the Light