1. Introduction

Publisher (“we,” “us,” “our”) develops, publishes, and operates social games for web and mobile devices (collectively, the “Services”). This Privacy Policy explains how we collect, use, store, share, and protect personal information about you (“user,” “you”) when you access or use our Services. This Policy applies globally and complies with GDPR, CCPA/CPRA, and other applicable data protection laws.

1.1 Data Controller

Publisher is the data controller responsible for the collection, use, and disclosure of your personal information under applicable data protection laws.

2. What Information We Collect About You

We collect information in three ways:

(1) directly from you; (2) automatically through your use of the Services; (3) from third-party sources.

2.1 Information You Provide Directly

We collect information when you:
Create or update an account
Contact customer support
Make in-app purchases
Participate in surveys, contests, or promotions
Connect to social media platforms
Send messages or upload content

2.2 Information Collected Automatically

When you use the Services, we automatically collect:
Device information (model, OS, unique device IDs: IDFA, GAID, IMEI)
IP address
approximate geolocation (derived from IP)
Usage data (gameplay, clicks, session length, viewing activity)
Error logs and performance data
Information from cookies and similar tracking technologies

2.3 Information

From
Third Parties
We may receive information from:
Social platforms (Facebook, Google, Apple) if you log in via third-party accounts
Payment processors (Apple, Google, Amazon)
Advertising and analytics partners
Publicly available sources

2.4 Categories of Personal Information Collected

Category
Examples
Name and contact info
name, username, email, phone, address
Account credentials
password, account ID, social login ID
Payment & purchase info
order details, transaction history (we do not receive full card numbers)
Device & identifiers
IP, IDFA, GAID, MAC address, device type
Usage data
gameplay activity, clicks, session logs, interaction history
Geolocation
approximate location (city/country level)
Content & communications
profile photos, chat messages, support tickets
Inferences
preferences, user behavior derived from usage data

3. Mobile IDs, Cookies, and Other Tracking Technologies

We use cookies, web beacons, mobile advertising IDs, and similar technologies to:
Operate and maintain the Services
Remember preferences
Analyze usage and improve performance
Serve relevant advertising (with consent)
Prevent fraud and ensure security

Mobile advertising IDs (IDFA/GAID) are generated by your device OS and used by analytics and ad partners. You can reset or opt out of ad tracking in your device settings. We do not share mobile information with third parties for unaffiliated marketing without your explicit consent.

4. How We Use Your Information

We use your information only for the following purposes:
Purposes of Use
Categories of Personal Information
EU/UK Lawful Basis
Provide products and services
Name, contact details, device information, usage data, payment information
Performance of a contract / Legitimate interests
Process virtual goods and service transactions
Payment information, purchase information, account information
Performance of a contract
Protect user safety, anti-fraud, anti-cheat, cybersecurity
All categories of personal information
Legitimate interests / Legal obligation
Protect legal rights, respond to lawsuits and law enforcement requests
All categories of personal information
Legitimate interests / Legal obligation
Comply with laws and regulatory requirements
All categories of personal information
Legal obligation
Business operations (billing, customer service, internal management)
All categories of personal information
Performance of a contract / Legitimate interests / Legal obligation
Product optimization, development and research
All categories of personal information
Legitimate interests
Personalization and experience improvement
All categories of personal information
Consent / Legitimate interests
Customer support and inquiries
All categories of personal information
Legitimate interests
Send service information, notifications, confirmations, technical messages
All categories of personal information
Legitimate interests
Marketing and promotional communications
All categories of personal information
Consent
Personalized advertising display
All categories of personal information
Consent

5. How We Disclose Your Information

We may share your information with:
Service providers (hosting, analytics, customer support, payment processors)
Affiliated companies
Advertising and marketing partners (with consent)
Social media platforms (at your direction)
Law enforcement or regulators (as required by law)
Successors in interest (in case of merger, acquisition, or asset sale)

We do NOT sell your personal information for monetary consideration.

6. Your Rights and Choices

Depending on your location, you may have the right to:
Access the personal information we hold about you
Correct inaccurate information
Request deletion of your personal information and account
Restrict or object to processing
Data portability
Withdraw consent
Opt
out of targeted advertising

7. How to Exercise Your Rights

Notice at Collection: At or before the time of collection, you have a right to receive notice of our practices, including the categories of personal information and sensitive personal information to be collected, the purposes for which such information is collected or used, whether such information is sold or shared, and how long such information is retained. You can find those details in this Privacy Policy by referring to the relevant sections above. Right to Know: You have a right to request that we disclose to you the personal information we have collected about you. You also have a right to request additional information about our collection, use, disclosure, or sharing of such personal information. Note that we have provided much of this information in this Privacy Policy. You may make such a “request to know” by contacting us at hugewinslots@citrusjoy.com. Right to Request Deletion: You also have a right to request that we delete personal information under certain circumstances, subject to a number of exceptions. To make a request to delete your personal information and/or account (the only online method for deletion requests, which is fully trackable), please follow the steps below carefully:

Send an email to: hugewinslots@citrusjoy.com

Use the exact subject line: Request to Delete My Personal Information and Account Include the following required information in the email body (to verify your identity and ensure we process the correct account):

Your full name (as associated with your account)

Your account username / in-game User ID

The email address registered to your account

The exact name of the game/service you are using

A brief statement confirming your request to delete your personal information and associated account (e.g., “I request the deletion of my personal information and my Publisher account associated with the above details”) After submitting your request: We will send a verification email to your registered email address within 2 business days to confirm your identity. You must reply to this verification email within 7 business days to finalize your deletion request; failure to do so will result in the request being cancelled. Processing timeline: Once your identity is verified, we will process your deletion request within 45 business days. If we need to extend the processing time (up to an additional 45 business days), we will notify you via email with the reason for the extension. What happens after deletion: All your personal information (excluding data we are required to retain by law, such as payment records for tax/compliance purposes) will be securely deleted. Your account, game progress, virtual items, and all associated data will be permanently lost and cannot be recovered. We will send a confirmation email once the deletion is complete. Right to Opt-Out/Do Not Sell or Share My Personal Information: You have a right to opt out from future “sales” or “sharing” of personal information as those terms are defined by the CCPA. Note that the CCPA defines “sell” and “personal information” very broadly, and some of our data sharing described in this Privacy Policy may be considered a “sale” under those definitions. In the past 12 months, we have sold or shared all of the above categories of personal information. To opt-out from “sales” or “sharing” of personal information, please email your request to hugewinslots@citrusjoy.com with the subject line: Opt-Out of Personal Information Sale/Sharing, and include your full name, registered email, and account username/User ID. We do not knowingly sell the personal information of minors under 16 years of age. Right to Limit Use and Disclosure of Sensitive Personal Information: You have a right to limit our use of sensitive personal information for any purposes other than to provide the services or goods you request or as otherwise permitted by law. We collect and process the contents of your communications on our Services for the purpose of facilitating those communications, to provide customer service and respond to user complaints regarding violations of our Terms of Service. If you have any questions regarding our use of such sensitive personal information, please contact us at hugewinslots@citrusjoy.com.

7.1 Authorized Agent Requests

You may designate an authorized agent to submit privacy rights requests on your behalf. We require written authorization and may require you to verify your identity directly to protect your information from unauthorized requests.

8. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, including providing the Services, complying with legal obligations, resolving disputes, preventing fraud, enforcing agreements, and establishing legal claims. Retention periods are determined based on:

The nature and sensitivity of the personal information;

The purpose(s) for processing;

Applicable legal, regulatory, and contractual requirements;

User expectations and relevant statutes of limitations. When retention is no longer required, we securely delete, destroy, or anonymize the information.

9. Data Security

We implement commercially reasonable technical and organizational measures to protect your personal information from unauthorized access, loss, misuse, or disclosure. No security system is 100% secure, and we cannot guarantee absolute security.

10. International Data Transfers

Your information may be transferred to and processed in countries other than your own, including the United States. We ensure appropriate safeguards are used for such transfers, including EU standard contractual clauses.

10.1 Lawful Bases for EEA and UK Users

If you are located in the European Economic Area (EEA) or the United Kingdom, we process your personal information only on the following lawful bases under GDPR: Performance of a contract: To provide and operate the Services you request. Legitimate interests: To operate, secure, improve, and personalize the Services. Legal obligation: To comply with applicable laws and legal processes. Consent: For marketing, personalized advertising, and certain tracking activities. You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

11. Children’s Privacy

Our Services are not intended for, and we do not provide any services to, children under the age of 16. We explicitly prohibit children under the age of 16 from accessing or using any of our Services, creating an account, or providing any personal information to us.

12. Third-Party Websites and Services

The Services may contain links to third-party websites or services. We are not responsible for their privacy practices. We encourage you to review their privacy policies.

13. Changes to This Policy

We may update this Policy periodically. Material changes will be posted in the Services or via email before they take effect.

14. Contact Us

If you have questions or concerns about this Privacy Policy, please contact us at: Email: hugewinslots@citrusjoy.com

14.1 Complaints

If you are in the EEA or UK, you may lodge a complaint with your local data protection authority if you believe our processing violates applicable data protection laws.