PRIVACY POLICY

Pax Animi Games (“we”, “us”, “our”) develops and publishes mobile games. This Privacy Policy explains how we collect, use, disclose, and protect information when you download or play our games, use our websites, or otherwise interact with our services (collectively, the “Services”). It also explains your choices and rights under laws such as the GDPR (EEA/UK), and major U.S. state privacy laws.

1. Who We Are

Data controller (for GDPR/UK GDPR purposes): Pax Animi Games (Istanbul, Türkiye). Email: info@paxanimigames.com. Website: paxanimigames.com. If we appoint a Data Protection Officer (DPO) or an EU/UK representative where required, we will publish their contact details here or on our website.

2. Scope

This policy applies to information processed in connection with:

3. Information We Collect

We collect information in three ways: (a) information you provide, (b) information collected automatically, and (c) information from third parties.

3.1 Information you provide

3.2 Information collected automatically

3.3 Information from third parties

4. How We Use Information and Legal Bases

We process information for the purposes below. If you are in the EEA/UK, we rely on the legal bases listed (GDPR/UK GDPR).

Purpose Examples of processing Typical GDPR legal basis
Provide and run the Services Deliver gameplay, save progress, enable core features, provide customer support, process IAP entitlements. Contract (Art. 6(1)(b)) and Legitimate interests (Art. 6(1)(f))
Analytics and product improvement Measure performance, understand feature usage, run A/B tests, fix bugs. Legitimate interests (Art. 6(1)(f)) or Consent (Art. 6(1)(a)) depending on local rules and technology used
Advertising and attribution Show ads, frequency cap, prevent fraud, measure campaigns, attribute installs. Consent (Art. 6(1)(a)) for personalized ads where required; Legitimate interests for non-personalized ads, security, and measurement where permitted
Security and fraud prevention Detect cheating, abusive behavior, and attacks; enforce rules; protect users and our systems. Legitimate interests (Art. 6(1)(f)) and Legal obligation (Art. 6(1)(c)) where applicable
Legal compliance and enforcement Comply with lawful requests, tax/accounting, respond to claims. Legal obligation (Art. 6(1)(c)) and Legitimate interests (Art. 6(1)(f))
Communications and marketing (optional) Send updates, offers, and surveys. Consent (Art. 6(1)(a)) or Legitimate interests (Art. 6(1)(f)) depending on context and local rules

Where we rely on legitimate interests, those interests typically include: improving our games, keeping the Services secure, preventing fraud, and understanding high-level performance. You may object in certain cases (see Section 9).

5. Your Choices and Controls

You can control how we and our partners process information:

6. How We Share Information

We share information with the following categories of recipients:

Third-party partners process data under their own privacy policies. We recommend reviewing the privacy documentation of the SDKs present in a given game. We can provide a current SDK list per title on request.

7. International Data Transfers

We are based in Türkiye and use vendors around the world. Your information may be processed in countries other than where you live, including the United States and South Korea. Where required (e.g., for transfers from the EEA/UK), we use appropriate safeguards such as Standard Contractual Clauses, and where applicable, reliance on an adequacy mechanism like the EU-U.S. Data Privacy Framework for certified recipients.

8. Data Retention

We keep information only as long as necessary for the purposes described in this policy, unless a longer period is required or permitted by law.

You may request deletion (see Section 9). Some information may be retained to comply with legal obligations or to establish, exercise, or defend legal claims.

9. Your Rights (EEA/UK and Similar Jurisdictions)

If you are in the EEA/UK (or another region with similar laws), you may have the right to:

To exercise these rights, email us at info@paxanimigames.com. We may need to verify your identity and ask for information that helps us locate your data (e.g., in-game user ID).

10. U.S. Privacy Notice (California and Other States)

This section provides additional disclosures for U.S. residents where required by applicable state laws.

10.1 Categories of personal information

Depending on how you use the Services, we may collect the categories described in Section 3. Under some U.S. laws, these categories may include:

10.2 Disclosures, targeted advertising, and ‘sale’/‘share’

We do not sell personal information for money. However, some privacy laws define ‘sale’ or ‘sharing’ broadly to include certain disclosures for targeted advertising. If a game uses third-party advertising SDKs, we may disclose identifiers and advertising data to ad partners for targeted advertising and measurement. You can opt out using the controls in Section 5, and by contacting us.

10.3 Your U.S. privacy rights

Depending on your state, you may have rights to:

To submit a request, email info@paxanimigames.com. We will respond as required by law and may request verification information. We will not discriminate against you for exercising your rights. If we are required to honor a universal opt-out preference signal (such as Global Privacy Control) for our web properties, we will do so where technically feasible.

11. Children’s Privacy

Our Services are not directed to children under 18. We do not knowingly collect personal information from children under 18, and we do not knowingly serve interest-based advertising to children under 18. If you believe a child provided us personal information, contact us at info@paxanimigames.com and we will take appropriate steps to delete it.

12. Security

We use reasonable administrative, technical, and physical safeguards designed to protect information (e.g., access controls, least-privilege permissions, encryption in transit where supported by vendors, and internal policies). No method of transmission or storage is 100% secure.

13. Changes to This Policy

We may update this policy from time to time. We will post the updated version with a revised ‘Last updated’ date. If changes are material, we may provide additional notice in the game or on our website.

14. Contact

Questions, requests, or complaints: