This policy applies to our websites and apps

This privacy policy (“Privacy Policy”) applies to all apps and websites published by Animaccord DTC Ltd (“Company”, “us”, “we”), registered in the Republic of Cyprus with company number ΗΕ 402587 and located at 82 Griva Digeni, Stephanie House, office 202, 3101, Neapolis, Limassol, Cyprus, and describes how we collect, store and use information when you use our websites and apps.

The Company collects, stores, and uses your information as a data controller in connection with, and in order to provide and develop games, mobile applications, services and websites (collectively referred to as the “Services”) in accordance with this Privacy Policy

By using the Services, you and your parent/guardian (for themselves and on your behalf) agree to be bound by the our Terms of Service (TOS) and our Privacy Policy. If you do not understand and agree to the TOS or Privacy Policy, you may not access or otherwise use the Services.

Categories of information we collect


Category	Examples
Identifiers	A username generated by a user, application language, system language, platform name, application version,
Commercial Information	Records of past in-app purchases made through our Services
Usage	Records of app usage and activities within the games, such as minigames played, stars earned, items acquired, and similar usage logging; a list of chats, chat history
Geolocation Data	Region and time zone

See below for more specific details concerning the information we collect, why we collect it, how it’s used, and your rights with regard to your information.

The information we collect

We collect all of the following types of information (collectively “Information”). Additionally, from here on, any reference to “children” means individuals under the age of 13 in the United States, or under the age threshold specified by your country of residence for distinguishing children online.

Children's Information: We collect what is reasonably necessary for us to provide children with access to our Services, such as an account ID, password, device information, and payment status. The data we collect may include the following types of information:

“Personal Information” is information about an individual which could potentially be used to identify, contact, or locate that person or their computing device (for example, their account name, device ID, information volunteered to a virtual agent or chatbot, IP address, or online username).

“Anonymous Information” is non-personal information that, by itself, does not identify a specific individual or device (for example, broad demographic information, anonymized usage data, or an anonymized tally of active players).

“Parent Information” is information specific to the parent or adult guardian overseeing a child’s account or device usage. For example, if necessary we collect a parental email address in order to obtain adult permission to save a child’s account and provide an interface for the parent or guardian to manage the account. We may collect this information from the child or the parent.

Other information: If you or your child uses our websites, we may collect information about the browser or IP address used to identify the country of origin. We may be able to see which site you visited that linked to ours, or which site you visit next. We may collect passive information about what in-game activities players engage in and how long they play. We only use this information to support our internal operations, and we don’t share this information with third parties unless it’s necessary to support our internal operations, and the third party has been reasonably certified as compliant with all relevant children’s online data protection laws.

Note on Financial Information: When you make in-app purchases in our apps, we do not collect or have any access to your name and billing information. This information is collected and stored by your platform (e.g. Apple's Game Store or Android's Google Play) or your platform's payment processor.

You can review your child's Personal Information by emailing us. You may also request that we no longer collect Personal Information from your child, or have us delete your child's Personal Information we have collected. To do so, email us atdpo@dtclab.pro.

How we collect information

We collect Information directly. For example, if you or your child submits Information to us in the course of using our Services, or otherwise contacts us directly.

We collect Information passively. We use a variety of internal and third-party tools to passively monitor user activity in our products, which we use to improve our products and provide services to you. See “Third Parties” below for details about these tools, the Information collected, and how we use it.

How we use information

How we use children's Personal Information. Unless permitted by law, we do not store or use a child’s Personal Information without obtaining specific parental consent. In the following circumstances we may not request this parental consent:

If we are only going to use the Information one time to respond to a direct request;
If we are using the Parent Information submitted by a child to request the parent’s consent to store the child’s Information (for example, if a child provides their parent’s email address for this purpose)
If there is an exception permitting this under applicable law, such as the U.S. Children's Online Privacy Protection Act (COPPA) and the EU General Data Protection Regulation (GDPR). For example, the Company or its Service Providers may collect personal information such as IP addresses and other persistent identifiers, from children under 13 strictly to support Animaccord’s internal operations and/or legitimate interests, such as analytics and to serve players with contextual advertisements.

How we use parent and guardian Personal Information. We may use the Personal Information that users provide to notify parents or guardians that their children have registered on our site, and ask if they consent to their child using our sites and apps. We may also use their Information to communicate with them about child accounts. If we do not get this consent within 14 days, the email used to register the account will be deleted.

We use Information to improve our products and services. We use Information to make our websites and apps better, and to customize our users’ experience with us. For example, we use geolocation information we infer from your IP address to customize our Services for your language and region.

We use Information for security purposes. We may use any Information we collect to protect our company, our users, and our products.

We use Information for marketing purposes. For example, we may use Parent Information to send adults details about new Animaccord apps or videos. With their permission, we may use Parent Information to send adults product offers or information we think they will find interesting.

We use Information as otherwise disclosed and permitted by law. For example, we use Information internally to provide our Services and respond to users’ requests.

Third Parties

We may share Information with certain third parties.

Legal: We will share Information if we're required by law to do so; for example, in response to a court order or subpoena. We may share Information if a government agency or investigatory body makes a lawful request that will benefit and protect our users; for example, we may share Information with investigators if we are investigating potential cybersecurity threats.

Virtual Agent Service Providers: Some game features allow players to interact with virtual agents or chatbots through typed or spoken text input, and those inputs may contain personal information. These inputs (text and/or vocal recordings converted to text) may be shared with third-party providers of speech-to-text data analysis and Large Language Model (LLM) chat functionality, and will be used solely to process player requests and respond to the player. These inputs are not stored any longer than is strictly necessary for this purpose.

Business Transfers: As we continue to develop our business, we may reorganize as a business entity, acquire entities, subsidiaries, or business units, or enter into joint ventures with third parties. In any of these types of transactions, any information you provide may be one of the transferred business assets (subject to any pre-existing privacy notice unless you consent otherwise). You understand and agree that we reserve the right to transfer any information collected from you in the case of any such transfer. In such event, we will use reasonable efforts to notify you before information about you is transferred and becomes subject to a different privacy policy.

We share information with third parties who provide services on our behalf. As developers of interactive apps and media, it is important for us to know how users interact with our websites and games. We and our Service Providers will collect your Location Information, Device Information, and Advertising IDs so that we can deliver our Services to our users, measure, analyze, and improve performance of the Services, and to continually update and improve our Services. For example, we will use this information to assess the difficulty level of games, fix any bugs or errors in the games, evaluate the demographic of our users, and to determine whether or not our Services need to support a new device type.

We contractually require all Service Providers to treat your personal information as confidential information and to ensure their data protection practices comply with applicable laws and best practices regarding the handling of children’s data. However, we do not have direct control over how Service Providers use your personal information and we cannot guarantee that our Service Providers will use your personal information as required in our contract with them. For this reason, we are not responsible for our Service Providers' misuse of your personal information, and we encourage you to review their individual Privacy Policies.

Following is a list of our Service Providers with access to your information, including the identifiers they collect and why we employ them:

Vendor	Collects	Function & Reason
Apple	App installs, app events, purchases.	App distribution via the Apple\s App Store.
Google	IP address, information associated with user location, browser type, user activities, browser type, user messages, push notifications, app installs, app events, purchases.	App distribution via the Google Play store, advertising network, TTS (text to speech) service provider, push notification provider to run advertising of apps and within apps, track app installs, provide text to speech service, send push notifications to users.
Digital Ocean	IP addresses not identifiable with end users.	Server hosting.
Unity	Advertising identifier, including device, information associated with location, user activities, user purchases.	Advertising network and data analytics to run advertising within apps, track user behavior within apps, including both non-purchase and purchase events.
OpenAI	Communication information (user messages), log data, usage data, Includes name of the device, operating system, device identifiers, and browser.	STT (speech to text) and LLM (large language model) provider to enable voice chat within apps.
Resemble AI	User messages, IP address, type of device, operating system, browser, non-identifiable request IDs.	TTS (text to speech) provider to enable voice chat within apps.

Please contact these companies directly with questions about their privacy policies or data collection and use practices.

Cookies

We use cookies and other tracking technologies to improve your browsing experience on our websites, to analyze our website traffic, and to understand where our visitors are coming from. By browsing our website, you consent to our use of cookies and other tracking technologies.

You may be able to control online ‘cookies’ and tracking tags through your internet device or web browser. How you do so depends on your browser or access device, and the type of cookie. Certain web browsers can be set to reject cookies. NOTE: If you block cookies on your browser, certain features on our sites may not work.

California Privacy Rights

Since 2005, California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding disclosure of personal information to third parties for their direct marketing purposes. You are hereby notified that we do not share our customers’ personal information with unaffiliated third parties for direct marketing purposes.

The California Consumer Privacy Act (CCPA) also provides California residents with specific rights regarding their personal information. You have the right to request that the Company disclose to you certain specific information about our collection and use of your personal information over the past 12 months.

To exercise your rights to access, data portability, and deletion under the CCPA, please submit a verifiable consumer request to us by either:

Emailing our Data Protection Officer at dpo@dtclab.pro
Submitting your request through postal mail at this address:

Animaccord DTC

Attn: Data Protection Officer

82 Griva Digeni, Stephanie House, office 202

3101, Neapolis, Limassol, Cyprus

Only you or a person registered with the California Secretary of State that is authorized to act on your behalf may make a verifiable consumer request in connection with your rights under the CCPA. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within any 12-month period. The verifiable request must include the following:

Sufficient information for us to reasonably verify that you are the person about whom we collected personal information, or that you are the authorized representative of that person, and;
A description of your request, with sufficient detail for us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information unless we can verify your identity or your authority to make the request, and confirm that the information requested relates to you.

We will only use the personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request, and to research and fulfill the requests that are verified.

California Privacy Rights for Minor Users

Since January 1, 2015, California Business and Professions Code Section 22581 permits you, if you are a California resident under the age of 18, to view, correct, or remove information provided by you or publicly posted by you. You are hereby notified that none of our Services enable users to publicly provide or post Information.

For users in the European Union and Brazil

Legal Basis for Processing. Our legal basis for collecting, using, and sharing your personal information will depend on the purpose for which we use your personal information. Typically, we will rely on the following legal bases for processing your personal information: (i) your consent; (ii) where our processing is in our legitimate interest or in the legitimate interest of our Ad Partners or Service Providers; or (iii) where our processing is necessary to perform a contract with you (e.g. to make our Services accessible to you). If we rely on your consent to process your personal information, you have the right to withdraw your consent at any time.
Your Personal Information Rights. If you would like to exercise your rights of access, rectification, erasure, restriction of processing, data portability, and/or your right to object to the processing of your personal information, please submit your request to dpo@dtclab.pro. If you would like to opt-out of your personal information being shared with our Ad Partners, your mobile Device may give you the option to opt-out of receiving Targeted Ads on all apps on your Device. On Android Devices, you may opt-out by enabling the "Opt out of Ads Personalization" setting. On iOS Devices, you may opt-out by enabling the "Limit Ad Tracking" setting.
Transfer of Personal Information Outside of the EU and Brazil. Because our Service Providers are located in countries outside of the European Union and Brazil, your personal information will be transferred to other countries that may not offer the same level of data protection as the laws of your country of residence. We rely on model contractual clauses for such transfers.
How to File Complaints. If you believe your rights under the GDPR have been violated, you may lodge a complaint with the supervisory authority of your country of residence. For contact information for your supervisory authority, please visit here.

Security

At Animaccord the security of your Information and the protection of our players is a top organizational priority. However, no data system (including the internet itself) is 100% secure. We cannot promise that your use of our Services will be entirely without risk. We encourage players to use caution when using the internet, including Animaccord Services.

Parents, there are important steps you can take to protect kids online too. To learn more about how to protect your child online, see this helpful information provided by the FTC. Please also read this bulletin.

Where we store information

Information we store may be stored both within and outside of the United States. If you live outside of the United States, you understand and agree that we may transfer your information to the United States or another country. Animaccord DTC and our Services are subject to E.U. laws, which may not afford the same level of protection as those in your country.

Data Retention

We keep Personal Information for as long as is appropriate or necessary for the practices described in this Policy, including accessing and servicing accounts, providing help to players, communicating with parents and guardians, resolving disputes, and as is required by law.

Hyperlinks

If you access a link to a site outside of those we provide, you may be exposed to websites we do not control, including sites intended for adults. This Privacy Policy does not apply to websites or apps outside of our control, and we are not responsible for the privacy practices of third parties. Read the privacy policies provided by other sites and apps carefully.

Policy Updates

From time to time we may change our privacy policies. We will notify you of any material changes to our Privacy Policy and TOS as required by law. We will also post an updated copy on our website. Please check our site periodically for updates.

If you have any questions, comments or concerns regarding our TOS, our Privacy Policy, or practices, please contact us at:

Animaccord DTC

Attn: Data Protection Officer

82 Griva Digeni, Stephanie House, office 202

3101, Neapolis, Limassol, Cyprus

Email: dpo@dtclab.pro