Privacy Policy | Fiboplay Games LLC

1. Introduction, Controller, and Scope

Fiboplay Games LLC ("Fiboplay", "we", "our", or "us") is a mobile-game studio established in the Republic of Armenia. This Privacy Policy explains how we collect, use, disclose, retain, transfer, and protect personal information when you visit fiboplay.com, contact us, request or receive game-development services, interact with our online advertising, or download, access, or play a Fiboplay mobile game (collectively, the "Services").

For personal information processed for our own purposes, Fiboplay is the controller or equivalent responsible entity. When we process personal information solely on documented instructions from a business client in connection with commissioned development services, that client may be the controller and Fiboplay may act as its processor or service provider. In those cases, the client's privacy notice and our written agreement with that client may also apply.

A particular game, feature, country, or service may provide an additional privacy notice when its practices differ from this Policy. Any such specific notice should be read together with this Policy and will control to the extent of a direct conflict for that specific processing activity.

2. Information We Collect

The information we collect depends on the Services you use, the features enabled, your device, and your location.

Information you provide

Contact and identity information, such as your name, email address, company, country or region, and the contents of messages you send to us.
Account and profile information, if a game supports accounts, such as a username, display name, profile image, account identifier, authentication information, and account preferences.
Support information, including correspondence, screenshots, diagnostic details, purchase information, and other information you provide when requesting assistance.
Project and business information when you contact us about commissioned development, including requirements, budgets, schedules, reference materials, files, feedback, contracts, and other information needed to evaluate or perform the work.
Survey, contest, promotion, or feedback information when you voluntarily participate in those activities.
User-generated content if a particular game allows you to upload, post, transmit, or share content.
Any other information you voluntarily choose to provide.

Information collected automatically

Device and technical information, such as device model, operating system and version, language, app version, browser type, network information, IP address, time zone, country or approximate region, and device or app identifiers.
Gameplay and usage information, such as game progress, levels attempted or completed, scores, session duration, interactions, settings, feature usage, events, and general engagement information.
Diagnostics and performance information, such as crash logs, error reports, loading times, latency, frame-rate or performance measurements, and other information used to identify and fix technical problems.
Advertising and attribution information, such as ad impressions, clicks, rewards, conversion events, campaign information, frequency, advertising identifiers, and information used to measure, limit, secure, or personalize advertising where permitted.
Purchase and entitlement information, such as product identifier, transaction or order identifier, purchase status, receipt or purchase token, subscription status, storefront, refund status, and related information received from the applicable platform.
Website information collected through cookies, local storage, pixels, SDKs, or similar technologies where used.

Information from third parties

We may receive information from app stores, platform providers, analytics and crash-reporting providers, advertising and attribution partners, authentication providers, social features you choose to connect, business clients, service providers, and other third parties where permitted by law. The exact sources depend on the game and features you use.

3. How We Use Information

Provide, operate, maintain, personalize, and improve the Services.
Create and manage accounts, save game progress, deliver features, synchronize data, and provide customer support.
Process and verify purchases, subscriptions, entitlements, refunds, and chargebacks.
Analyze gameplay, performance, crashes, audience engagement, and product usage.
Develop, test, balance, and improve games, features, content, and services.
Display, measure, limit, secure, personalize, and attribute advertising where allowed by law and your choices.
Send service-related notices, security alerts, support messages, and other communications necessary to operate the Services.
Respond to inquiries, prepare proposals, negotiate projects, perform commissioned development services, and manage business relationships.
Prevent fraud, cheating, abuse, unauthorized access, security incidents, and violations of our Terms of Service.
Comply with legal, tax, accounting, platform, regulatory, and contractual obligations and establish, exercise, or defend legal claims.
Evaluate or complete a merger, financing, acquisition, restructuring, sale, or transfer of all or part of our business or assets.

4. Legal Bases for Processing

Where applicable law requires a legal basis, we process personal information as necessary to perform a contract or take steps at your request before entering one; comply with legal obligations; pursue legitimate interests such as operating, improving, securing, supporting, and protecting the Services; establish, exercise, or defend legal claims; or based on your consent. Where we rely on consent, you may withdraw it at any time with future effect. Where we rely on legitimate interests, we consider those interests against your rights and reasonable expectations.

5. In-App Purchases and Subscriptions

Our games may offer in-app purchases, virtual currency, consumable items, premium features, ad-free options, subscriptions, or other digital content. Purchases made through the Apple App Store or Google Play are processed by the applicable store rather than directly by Fiboplay. We may receive limited transaction and entitlement information needed to activate, verify, restore, support, refund, or secure purchases. We do not receive your full payment-card number or app-store password from Apple or Google.

6. Advertising, Analytics, and Attribution

Some games may use advertising, analytics, crash-reporting, or attribution services, including services provided by Google, Google AdMob, Unity, Apple, and other providers identified in a game-specific notice or consent interface. Depending on the provider and your choices, these services may process device identifiers, IP address, approximate location, app activity, diagnostics, ad interactions, and conversion information.

Where required, we request consent before using information for personalized advertising, cross-app tracking, or non-essential tracking technologies. On Apple devices, a game may request permission through App Tracking Transparency before engaging in tracking that requires permission. If you decline personalized advertising or tracking, you may still receive contextual or non-personalized advertising.

7. Cookies and Similar Technologies

Our website and games may use cookies, local storage, SDKs, pixels, and similar technologies for essential functionality, security, preferences, analytics, performance measurement, and advertising. Where required, non-essential technologies are used only after you make the applicable consent choice. If we introduce material website analytics or advertising cookies, we will provide an appropriate cookie notice or consent-management interface describing the relevant technologies and choices.

8. How We Share Information

We may disclose information only as reasonably necessary for the purposes described in this Policy, including:

To hosting, cloud, communications, form-processing, customer-support, analytics, crash-reporting, security, payment-verification, advertising, attribution, and other service providers that support the Services.
To platform and technology providers, including Apple, Google, Google AdMob, Unity, Web3Forms, and other providers enabled in a particular game or on our website.
To advertising and attribution partners where permitted by law and consistent with your consent and opt-out choices.
To a business client when information is processed in connection with a commissioned project for that client.
To professional advisers, auditors, insurers, authorities, courts, or law-enforcement bodies when reasonably necessary to comply with law, investigate misconduct, protect rights or safety, collect amounts owed, or establish, exercise, or defend legal claims.
In connection with a merger, financing, acquisition, reorganization, insolvency, sale, or transfer of all or part of our business or assets, subject to appropriate safeguards.
With your direction or consent.

We do not sell personal information for money. Certain disclosures to advertising technology providers may nevertheless be treated as a "sale", "sharing", or use for targeted advertising under some privacy laws. Where those laws apply, we provide the required opt-out rights and controls.

9. International Data Transfers

Fiboplay is established in Armenia and our service providers may process information in Armenia, the United States, the European Economic Area, the United Kingdom, or other countries. Data-protection laws may differ between countries. Where required, we use legally recognized transfer mechanisms and contractual safeguards, such as adequacy decisions, standard contractual clauses, applicable addenda, or other valid transfer tools.

10. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Policy, including to provide the Services, maintain account or game-state information, comply with legal and accounting obligations, resolve disputes, prevent fraud, enforce agreements, and establish or defend legal claims.

Contact and project-inquiry information is generally retained for up to 24 months after the last meaningful interaction unless a longer period is appropriate for an active or anticipated business relationship.
Contract, invoicing, payment, tax, and accounting records may be retained for the period required by applicable law.
Account and gameplay information is generally retained while an account is active and for a reasonable period afterward, subject to deletion requests and legal exceptions.
Technical, analytics, advertising, attribution, and purchase data is retained according to operational need, legal requirements, and the applicable provider's configured retention periods.

When information is no longer needed, we delete, anonymize, aggregate, or securely isolate it as appropriate.

11. Security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure. We also seek appropriate confidentiality and data-protection commitments from service providers where required. No system, network, transmission, or storage method can be guaranteed to be completely secure.

12. Children's and Teen Privacy

Unless a game-specific notice expressly states otherwise, our Services are not intended to collect personal information from children under 13, and children under 13 should not create an account, submit personal information, or use features that collect personal information. If we learn that we collected personal information from a child in a manner that requires parental consent and valid consent was not obtained, we will take appropriate steps to delete or restrict that information.

If a particular game is directed to children or is designed as a mixed-audience service, we will apply age-appropriate design, parental notice and consent, advertising restrictions, data-minimization, retention, and other safeguards required by applicable law. Parents or guardians may contact us to request review or deletion of a child's information.

13. Your Privacy Choices and Rights

Depending on where you live, you may have rights to access, know, correct, delete, restrict, object to, or receive a copy of personal information; withdraw consent; opt out of targeted advertising, certain profiling, or certain disclosures; request review of certain automated decisions; appeal a denied privacy request; and complain to a competent data-protection authority.

Use privacy, consent, advertising, or account controls offered in the relevant game, where available.
Adjust advertising, tracking, permissions, notifications, and privacy settings on your device or app-store account.
Use account-deletion controls if the relevant game supports user accounts.
Contact us at legal@fiboplay.com to submit a privacy request. We may take reasonable steps to verify your identity and authority before acting on a request.

We will not discriminate against you for exercising privacy rights provided by applicable law.

14. United States Privacy Disclosures

Residents of certain U.S. states may have additional rights regarding access, deletion, correction, portability, targeted advertising, profiling, and the sale or sharing of personal information. Where an applicable state law treats advertising-related disclosures as a sale or sharing, you may opt out through the privacy controls provided in the relevant game or by contacting us. Where legally required and technically applicable, we will also honor recognized browser-based opt-out preference signals such as Global Privacy Control for the browser or device sending the signal.

If Fiboplay becomes subject to a law requiring a dedicated "Do Not Sell or Share My Personal Information" mechanism, we will provide that mechanism in the relevant Service and update this Policy accordingly. We do not knowingly sell or share for targeted advertising the personal information of users where doing so is prohibited without valid authorization.

15. EEA, United Kingdom, and Switzerland

If the GDPR, UK GDPR, or Swiss data-protection law applies, you may have rights including access, rectification, erasure, restriction, portability, objection, and withdrawal of consent. You may also lodge a complaint with your local supervisory authority. Where required, Fiboplay will identify and publish the contact details of an EEA representative and/or UK representative before relying on an offering of Services that triggers that representative requirement.

16. Account and Data Deletion

If a game allows account creation, we provide a method to request deletion of the account and associated personal information. Where required by applicable platform rules, this includes an in-app deletion path and an external web-based deletion route. We may retain limited information where required or permitted for legal compliance, security, fraud prevention, dispute resolution, purchase records, accounting, or legal claims. Account deletion may permanently remove game progress, virtual items, entitlements, and other account information and may not be reversible. Deleting an app from your device does not by itself delete information previously collected by us or our providers.

17. Third-Party Services

Third-party platforms, stores, websites, SDKs, payment systems, authentication services, advertising partners, and other services may process information under their own terms and privacy policies. This Policy does not govern independent processing by those third parties. Review the privacy information presented by the relevant provider, app store, device setting, consent interface, or linked service.

18. Commissioned Development and Business Clients

For commissioned game-development services, privacy responsibilities may also be governed by a proposal, master services agreement, statement of work, confidentiality agreement, or data-processing agreement. Where Fiboplay acts as a processor or service provider for a client, we process covered personal information according to the client's documented instructions and the applicable written agreement, subject to legal obligations.

19. Changes to This Policy

We may update this Privacy Policy to reflect changes to our Services, technologies, providers, legal obligations, or business practices. We will publish the updated version and revise the "Last updated" date. Where required by law, we will provide additional notice or obtain consent before a material change takes effect.

20. Contact Us

Questions, privacy requests, complaints, or concerns can be sent to legal@fiboplay.com.