PRIVACY POLICY INTRODUCTION
Super Pickles Games sp. z o.o. is a Polish company developing games worldwide, with the registered headquarters in Warsaw at the following address: Targowa 56, 03-733 Warsaw, Poland (“we”, “our”, “ours”, etc.). We are committed to safeguarding the personal information of our users and other stakeholders (“you”, “your”, “yours”, etc.) while helping our customers, investors and society discover new worlds and learn new skills.
In this privacy policy (the “Policy”), we inform you of our privacy policies regarding the collection, use, and disclosure of your personal information. If you choose to use our Products, then you agree to the collection and use of information in relation to this policy. The personal information that we collect is used for providing and improving the Products. We will not use or share your information with anyone except as described in the Policy. The terms used in the Policy have the same meanings as in our Terms and Conditions accessible at: https://www.superpicklegames.com/termsandconditions. The Policy constitutes the integral part of the said Terms and Conditions.
If you wish to contact us in relation to questions regarding your personal information, we refer you to the “Contact Us” section below.
CHILDREN’S PRIVACY
The Policy do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13 years of age. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do the necessary actions.
WHAT DATA DO WE COLLECT?
Our applications store and process personal information that you have provided to us, to provide our Products. It’s your responsibility to keep your phone and access to the app secure. We therefore recommend that you do not jailbreak or root your phone, which is the process of removing software restrictions and limitations imposed by the official operating system of your device. It could make your phone vulnerable to malware/viruses/malicious programs, compromise your phone’s security features and it could mean that our applications won’t work properly or at all. The information we may collect about you will vary depending on how you interact and engage with us. It may include the following:
gameplay and usage data, including game scores, feature usage, timestamps, and gaming behaviors, device information, such as unique identifiers (UID), operating system details, carrier name, and technical specifications, location data for enhancing gameplay and ad targeting, ad interaction data, including frequency of ad displays, your interactions, and related metrics, demographic information such as age, gender, region, interests, and language,Internet Protocol (IP) address and device details, including device name and operating system version, user-generated content, such as nickname and player interactions within the Product, log data, including app configurations, timestamps of service use, and error reports, data collected through cookies, tracking pixels, and other analytics tools for service optimization, profiles and inferences derived from product usage, marketing outcomes, and survey data, commercial data, including in-app purchase history and revenue share metrics details about other websites visited for targeted advertising, audio, video, and other electronic data related to your activities within the Product, data from third-party analytical tools for understanding your behavior and enhancing service delivery, information shared during customer support or surveys for improving your experience and product development.
To collect this information, analytics tools and ad delivery technologies may employ various technologies, including server log files, network beacons, cookies, tracking pixels, and similar methods. They may also combine data collected from the Product with information gathered from our other products and services, as well as third-party websites, mobile products, demographic studies, advertising data, market surveys, and other research. It's important to note that this information, by itself, is not considered personal data. However, if we associate it with personal information, it will be treated as personal data in accordance with the Policy.
For a better experience, while using our Product, we may require you to provide us with certain personally identifiable information, including but not limited to country, region, city, gender, interest, age, language, nickname. The information that we request will be retained by us and used as described in the Policy.
Consent to monitoring: While using the Product, the Product may actively monitor the random access memory (RAM) of your computer for any unauthorized third-party programs. In the event that the Product detects such an unauthorized third-party program, it may relay this information to us. This information may include the your account name, Internet Protocol (IP) address, details about the detected unauthorized third-party program, and the date and time it was identified. Additionally, technical specifications of your computer and its operation may be included. This action may be taken with or without prior notice to you.
Cookies: Cookies are files with a small amount of data that are commonly used as anonymous unique identifiers. These are sent to your browser from the websites that you visit and are stored on your device’s internal memory. This Service does not use these “cookies” explicitly. However, the app may use third-party code and libraries that use “cookies” to collect information and improve their services. You have the option to either accept or refuse these cookies and know when a cookie is being sent to your device. If you choose to refuse our cookies, you may not be able to use some portions of this Service.
SHARING YOU INFORMATION AND SERVICE PROVIDERS
We do not share your personal data to any third party unless we have obtained your consent or have a valid legal reason to do so. Your personal information may be shared with the following types of recipients, including our affiliated companies within our group: our group companies, third-party service providers and partners, competent law enforcement body, regulatory, government agency, court or other third parties, actual or potential buyer, to any other person with your consent to the disclosure.
We may employ third-party companies and individuals due to the following reasons: to facilitate our service related to our Products, to provide the service on our behalf, to perform service-related services, orto assist us in analyzing how our service is used.
We want to inform you that the following third parties have access to your personal information. The reason is to perform the tasks assigned to them on our behalf. However, they are obligated not to disclose or use the information for any other purpose. The app does use third-party services that may collect information used to identify you. Below you can find hyperlinks to the privacy policies of third-party service providers used by the app – as follows:
Google Play Services,
AdMob,Google
Analytics for Firebase,
Firebase Crashlytics,
Facebook,
Unity,
Heroic Labs,
Apple,
App Store,
Google,
X,
Amazon Web Services,
Tableau,
AppsFlyer.
Android
IronSource
Smartlook
Links to other sites: Our Products may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
HOW WE USE YOUR DATA AND INFORMATION
We collect and process your data, including personal information, for the following purposes tailored to our game development and gaming services:
1. to provide gaming services: ensuring you can access and enjoy our games, features, and online services, including maintaining and enhancing gameplay functionality and in-game experiences,
2. to enhance security: protecting your account, our games, and services from errors, fraud, unauthorized activities, or violations of laws and regulations,
3. to manage accounts: verifying your identity, maintaining your gaming account, tracking in-game purchases or progress, and processing payments for in-app purchases or subscriptions,
4. to improve your gaming experience: personalizing game content, features, and recommendations based on your gameplay preferences and interactions,
5. for customer support: assisting with troubleshooting, resolving technical issues, and responding to your inquiries about our games or services,
6. for research and development: analyzing gameplay data, your feedback, and other insights to improve current games, develop new features, and create future games,
7. to enable social features: facilitating in-game communication, multiplayer interactions, and community-building among players,
8. to send communications: providing important updates about games, services, and policies, as well as sending marketing communications (e.g., special offers, updates about new games) with your consent,
9. for marketing and advertising: conducting customer segmentation and delivering targeted marketing and in-game promotions, ensuring ads are relevant to your interests,
10. to measure effectiveness: analyzing the performance of in-game ads and marketing campaigns to optimize strategies,
11. for legal and contractual obligations: fulfilling our legal responsibilities and enforcing our rights under agreements, including billing, collection, and compliance with laws,
12. for analytics: tracking gameplay behavior and preferences to improve our services and enhance your engagement with our games,
13. to meet your expectations: using the data for purposes you’ve consented to or requested, such as special offers or participation in beta testing,
14. for any other purpose: with your explicit consent or as otherwise required or permitted by applicable laws.
We process your data under applicable legal bases, including the necessity to perform a contract, our legitimate interests, compliance with legal obligations, and your consent, where applicable. Your personal information is not subject to automated decision-making, including profiling
DATA USAGE AND PROCESSING
We collect and use personal information only where we have one or more lawful grounds for doing so under applicable privacy laws. Such grounds may vary depending on where you are located, but generally include processing personal data:
TO PROVIDE REQUESTED PRODUCTS AND FEATURES
In order to provide our Products, we must collect and use certain personal data. This includes:
1. you profile data, which we use to establish and maintain your accounts, verify your identity, communicate with you about your orders and accounts; and enable you to make or receive payments (as and if applicable),
2. usage data, which is necessary to maintain, optimize, and enhance our Products,
3. transaction information,
4. information relating to customer support.
FOR PURPOSES OF OUR LEGITIMATE INTERESTS OR OTHER PARTIES
This includes using personal data to maintain and enhance your safety and security. For example, we use personal data to prevent use of our Products by users who have engaged in inappropriate or dangerous behavior, such as by retaining data of banned users to prevent their use of our Products.This also includes purposes such as combating fraud, improving our Products, direct marketing, research, and development; and enforcing our Terms and Conditions.In addition, it encompasses using personal data to the extent necessary for the interests of other people or the general public, such as in connection with legal or insurance claims, and to protect the rights and safety of others.
TO FULFILL OUR LEGAL OBLIGATIONS
We collect and use personal data to comply with applicable laws. We may also share data with law enforcement regarding criminal acts or threats to public safety, or requests by third parties pursuant to legal processes.
WITH YOUR CONSENT
We may collect and use personal data based on your consent. For example, we may collect personal data through voluntary surveys or through Products. Responses to mentioned surveys are collected on the basis of consent. You can give consent in writing, as well as verbally, electronically, or through authorized representatives. In certain circumstances, if applicable privacy laws allow, it’s also implied.
HOW DO WE TRANSFER AND STORE YOUR PERSONAL INFORMATION?
The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We store all your information behind firewalls on our secure servers. The safety and security of your data also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Products, you are responsible for keeping its password confidential. We ask each of you not to share your password with anyone. We value your trust in providing us your Personal Information, thus we are striving to use commercially acceptable means of protecting it. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.
We may transfer your personal data to third parties or affiliates located outside the country where you reside, including but not limited to the United States, United Kingdom, European Union member states. These countries may have different data protection laws than your jurisdiction, and in some cases, they may not provide the same level of data protection.
Whenever we share information outside of your domicile, we ensure that the transfer complies with local law so that your personal information is adequately protected. To ensure the continued protection and security of your personal data, we implement appropriate safeguards in accordance with applicable data protection laws. These safeguards may include the use of standard contractual clauses (like EU Model Clauses) approved by the relevant authorities or other measures designed to protect your privacy rights as binding corporate rules, privacy certifications, or adherence to codes of conduct to safeguard your personal data during international transfers.
As required under the applicable law, third parties are required to use appropriate safeguards to protect personal information, and they can only access the personal information that is necessary for performing their specific tasks.You may also request additional information regarding data transfers outside the European Economic Area and obtain a copy of the appropriate safeguards by exercising your rights set out in the “Contact Us” section below.
RETENTION AND DELETION OF YOUR PERSONAL INFORMATION
We retain your profile, transaction, and other personal information for as long as you maintain your account and except as otherwise permitted or required by applicable law or regulation, only for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
We may also retain certain information, if necessary, for purposes of safety, security, and fraud prevention. For example, if we deactivate your account because of unsafe behavior or security incidents, we may retain certain information about that account to prevent you from opening a new account in the future.
You may request deletion of your account at any time. Following such requests, we delete the data that it is not required to retain for purposes of regulatory, tax, insurance, litigation, or other legal requirements. For example, we retain location, device, and usage data for these purposes for a minimum of 5 years; while it retains such data, it may also use it for purposes of safety, security, fraud prevention and detection, and research and development. In certain circumstances, we may be unable to delete your account, such as if there’s an unresolved claim or dispute. Upon resolution of the issue preventing deletion, we will delete the account as described above.
If you decide that you no longer wish us to keep or use information or you want the information to be revised or updated, please feel free to contact us. We will remove or amend the information as appropriate in accordance with the Policy and applicable legislative and regulatory requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with a particular user. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to the relevant user or its consent.
YOUR RIGHTS
We operate in different jurisdictions which grant individuals different levels of protection in relation to the processing of personal information. We will honor your rights under the applicable law. To the extent provided under your local data protection laws, including the European data protection laws as applicable, your rights may include the following:
Right of access (‘an overview of your personal information’): the right to get an overview of your personal information that we process. Right to rectification (‘correct your personal information’): if your personal information is inaccurate or incomplete, the right to ask us to rectify or complete your personal information.
Right to erasure (‘right to be forgotten’): the right to request that we delete your personal information to the extent permitted by the applicable law. In certain circumstances, it may not be possible for us to accept your request; for example, when the processing is necessary to comply with a legal obligation, or if the processing is necessary for the performance of a contract. In some cases, your personal information is necessary in order to provide the Services and if you do not provide such information to us then you may be precluded from accessing and using the Services or using certain Services features.
Right to data portability (‘transfer your personal information’): the right to ask us to transfer your personal information directly to you. This applies to certain personal information if processed by automated means and with your consent, or based on a contract you have with us. On your request, and where technically feasible, we will transfer your personal information to another party of your choice.
Right to restrict processing: the right to request that we restrict or stop the processing of your personal information held by us for a certain period of time, or for an indefinite period. In certain circumstances, it may not be possible for us to accept your request; for example, when the processing is necessary to comply with a legal obligation, or if we can demonstrate compelling legitimate grounds otherwise.
Right to object: the right to object to the processing of your personal information. The reasons for an objection should relate to your particular situation, and be related to processing based on the legitimate interest condition. We will then no longer process the personal information, unless we can demonstrate compelling reasons otherwise. In certain circumstances, you have the unconditional right to object; for instance, in the context of direct marketing activities.
Withdrawal of Consent: the right to withdraw your consent to the processing of your personal information at any time; for instance, after you consented to us keeping you informed about our Services, you have the right to withdraw this consent at any time. Withdrawal of your consent will not affect the lawfulness of the processing of your personal data prior to the withdrawal.
To exercise your rights (if applicable) and/or for any other questions about the handling of your personal information, we refer you to the “Contact Us” section below.
If you feel we are unresponsive or disagree with our data privacy practices, you also have a right to lodge a complaint with a data protection supervisory authority, in particular in the Member State in the European Union where you are habitually resident where we are based or where an alleged infringement of data protection law has taken place.
ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS
If you are a resident of California, you have specific rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). This section outlines those rights and provides information on how you can exercise them.
Right to Know: You have the right to request information about the categories of personal information we have collected, the sources from which we collected the information, the purposes for which we use the information, and the categories of third parties with whom we share the information.How to Exercise: You can make a request to know by contacting us through the methods listed in the "Contact Us" section below.
Right to Delete: You have the right to request the deletion of your personal information that we have collected, subject to certain exceptions.How to Exercise: You can make a request to delete by contacting us through the methods listed in the "Contact Us" section below.
Right to Opt-Out of Sale: We do not sell your personal information to third parties for monetary value. However, you have the right to opt-out of any potential future sales of your personal information.How to Exercise: If you would like to opt-out, please contact us through the methods listed in the "Contact Us" section below.
Non-Discrimination: We will not discriminate against you for exercising your rights under the CCPA and CPRA. This includes denying you goods or services, charging you different prices, or providing you with a lower quality of goods or services. How to Exercise: If you believe we have discriminated against you for exercising your CCPA and CPRA rights, please contact us through the methods listed in the "Contact Us" section below.
For further details on our data practices, including the categories of personal information we collect and the purposes for which we use it, please refer to the main body of this Privacy Notice. If you have any questions or concerns specific to your rights as a California resident, please contact us using the information provided in the "Contact Us" section below.
If you are a California resident, you may designate an authorized agent to make a request to access or a request to delete on your behalf. To do so, you must: (1) provide that authorized agent written and signed permission to submit such a request; and (2) verify your own identity directly with us. Please note, we may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf. We will respond to your authorized agent's request if they submit proof that they are registered with the California Secretary of State to be able to act on your behalf, or submit evidence you have provided them with power of attorney pursuant to California Probate Code section 4121 to 4130. We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on their behalf, or are unable to verify their identity.
CHANGES TO THIS PRIVACY POLICY
We may update our Privacy Policy from time to time. Thus, you are advised to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. This policy is effective as of 18 June 2025.
CONTACT US
If you have any questions about this Policy, the personal information we hold on you, or you would like to exercise one of your data protection rights provided for under applicable privacy laws, please do not hesitate to contact us at contact@superpicklegames.com.If you feel we are unresponsive or disagree with our data privacy practices, you also have a right, depending on applicable law, to file a complaint with your local Data Protection Authority.