Privacy Policy
Last updated: 21 March 2026
1. Introduction
Twimler Group Limited ("Twimler", "we", "us" or "our") is a mobile game developer founded in 2012, committed to openness, community, global reach and fair play. This Privacy Policy explains how we collect, use, disclose and safeguard your personal information when you use our mobile applications, websites and related services (collectively, the "Services").
By accessing or using our Services, you agree to the terms of this Privacy Policy. If you do not agree, please discontinue use of our Services immediately.
2. Data Controller
For the purposes of applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR) and the EU General Data Protection Regulation (EU GDPR), the data controller responsible for your personal data is:
Twimler Group Limited
United Kingdom
If you have any questions about how we process your data, please contact us.
3. Changes to This Policy
We reserve the right to update this Privacy Policy at any time and for any reason. When we do, we will revise the "Last updated" date at the top of this page. We encourage you to review this policy periodically to stay informed about how we protect your information. Your continued use of the Services following the posting of changes constitutes your acceptance of those changes.
4. Information We Collect
We may collect the following categories of information:
4.1 Information You Provide
- Account and profile details when you register or connect through social media platforms.
- Social media data: if you choose to connect a social media account (such as Facebook), we may collect your name, user ID and profile picture.
- Communications you send to us, such as support enquiries or feedback.
- Contact information: if you use a feature to invite others to try our games, we may collect the contact information you provide for that purpose.
4.2 Information Collected Automatically
- Device information: device model, operating system and version, unique device identifiers and mobile network data.
- Usage data: gameplay statistics, feature interactions, session duration and in-app purchase history.
- Location data: approximate geographic location based on your IP address or, with your consent, more precise location data.
- Advertising identifiers: such as your IDFA (iOS) or GAID (Android), collected with your consent for personalised advertising.
- Push notifications: we may request permission to send you push notifications regarding updates, promotions or game-related alerts. You can opt out at any time through your device settings.
4.3 Cookies and Tracking Technologies
Our website and Services may use cookies, pixels, SDKs and similar tracking technologies to collect information about your interactions. These technologies help us analyse usage patterns, deliver relevant advertisements and improve our Services. You can manage cookie preferences through your browser settings. For in-app tracking, you can adjust your preferences through your device's privacy settings.
4.4 Third-Party SDKs
Our mobile applications may integrate third-party software development kits (SDKs) for analytics, advertising, crash reporting and social features. These SDKs may collect data independently in accordance with their own privacy policies. We encourage you to review the privacy practices of any third-party services integrated into our apps.
5. Legal Basis for Processing
We process your personal data in accordance with applicable data protection laws. Our legal bases for processing include:
- Consent: where you have given clear consent for us to process your personal data for a specific purpose, such as personalised advertising or push notifications.
- Contract performance: where processing is necessary to provide the Services you have requested, including processing in-app purchases and managing your account.
- Legitimate interests: where processing is necessary for our legitimate business interests, such as improving our Services, conducting analytics, ensuring security and preventing fraud, provided these interests are not overridden by your rights.
- Legal obligation: where processing is necessary to comply with a legal or regulatory requirement.
6. How We Use Your Information
We use the information we collect for the following purposes:
- To provide, maintain and improve our Services.
- To process in-app purchases and other transactions.
- To personalise your gaming experience and deliver relevant content.
- To communicate with you regarding updates, promotions and support.
- To conduct analytics and research to enhance gameplay and performance.
- To display targeted advertisements, where you have given consent.
- To detect, prevent and address fraud, abuse and security issues.
- To comply with legal obligations.
7. Sharing of Information
We may share your information with the following categories of third parties:
- Service providers: companies that perform services on our behalf, such as payment processing, data analysis, email delivery, hosting services, customer support and marketing assistance.
- Advertising partners: with your consent (in accordance with GDPR Article 6(1)), we share advertising identifiers with advertising networks to deliver personalised advertisements.
- Legal and regulatory: when required by law, regulation, legal process or governmental request.
- Business transfers: in connection with a merger, acquisition or sale of assets.
8. Data Retention
We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy any legal, accounting or reporting requirements. When determining the appropriate retention period, we consider the amount, nature and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process your data, and applicable legal requirements.
If you delete your account, we will delete or anonymise your personal data within a reasonable timeframe, unless we are required to retain it for legal or regulatory purposes.
9. Data Security
We implement commercially reasonable technical and organisational measures to protect your personal information against unauthorised access, alteration, disclosure or destruction. However, no method of electronic storage or transmission over the internet is completely secure, and we cannot guarantee absolute security.
In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours and, where required, inform affected individuals without undue delay.
10. Your Rights
Depending on your jurisdiction, you may have the following rights regarding your personal data:
- Access: request a copy of the personal data we hold about you.
- Rectification: request correction of inaccurate or incomplete data (GDPR Article 16).
- Erasure: request deletion of your personal data, subject to certain exceptions.
- Restriction: request that we limit the processing of your data in certain circumstances.
- Objection: object to the processing of your data for specific purposes.
- Portability: request a copy of your data in a structured, machine-readable format.
- Withdraw consent: where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of processing carried out prior to withdrawal.
To exercise any of these rights, please contact us. We will respond to your request within 30 days. You may also delete your account data through the account settings within our applications.
You also have the right to lodge a complaint with a supervisory authority. If you are based in the United Kingdom, you may contact the Information Commissioner's Office (ICO) at ico.org.uk. If you are based in the European Union, you may contact your local data protection authority.
11. Advertising and Opt-Out
We may display personalised advertisements within our games using third-party advertising networks. You can opt out of personalised advertising by adjusting your device settings:
- iOS: go to Settings > Privacy & Security > Tracking, and disable "Allow Apps to Request to Track".
- Android: go to Settings > Privacy > Ads, and select "Delete advertising ID" or "Opt out of Ads Personalisation".
Please note that opting out of personalised advertising does not mean you will stop seeing advertisements — they will simply be less relevant to your interests.
12. California Privacy Rights
If you are a resident of California, you have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA):
- Right to know: you may request details about the categories and specific pieces of personal information we have collected, the sources of collection, the business purposes for collection, and the categories of third parties with whom we share your data.
- Right to delete: you may request that we delete the personal information we have collected about you, subject to certain legal exceptions.
- Right to opt out of sale or sharing: we do not sell your personal information. If we share personal information with third parties for cross-context behavioural advertising, you have the right to opt out.
- Right to non-discrimination: we will not discriminate against you for exercising any of your privacy rights.
To exercise these rights, please contact us.
13. Do Not Track
Some browsers offer a "Do Not Track" (DNT) signal. There is currently no universally accepted standard for how companies should respond to DNT signals. At this time, our Services do not respond to DNT signals. However, you can manage your tracking preferences through the opt-out mechanisms described in Section 11 above.
14. Children's Privacy
Our Services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. If we become aware that we have inadvertently collected such information, we will take prompt steps to delete it. If you believe that a child under 13 has provided us with personal information, please contact us so that we can take appropriate action.
15. International Data Transfers
Your information may be transferred to and processed in countries other than your country of residence. We ensure that appropriate safeguards are in place to protect your data in accordance with applicable data protection laws, including the use of standard contractual clauses approved by the relevant authorities where required.
16. Contact Us
If you have any questions or concerns about this Privacy Policy, please visit our Contact page.