Last update: December 01, 2022

This Privacy Policy explains the manner of collection and processing by GAMING FACTORY S.A. of the user’s personal data during the use of its mobile applications (hereinafter the “App”).

The App comprises a free game (it is also possible to buy available in-game items). For the purpose of sustaining top quality and providing a superior gaming experience we process the user’s information particularly to streamline the entire App-related experience and to support internal activities.

We shall update this Privacy Policy on an occasional basis. We will inform the user of any modifications by updating the date visible at the top of the document and, depending on concrete amendments introduced, another notice or request for the user’s renewed consent.

Collection of information

Information is collected on an automatic basis via the app

The following information is collected during the user’s access or use of the App:

  • Log Information: We collect log information regarding the user’s use of the App, including the type of device, features, access times and IP address.
  • Device Information: Information is stored regarding the device used by the user to access the App. This also regards information about the device producer, model, OS, time zone, and language.
  • Device identifiers: We collect online identifiers of the user’s device to access the App. This regards: IDFA, Google Ads ID, Google Device ID, Game Center ID, and Google Play Account ID, Epic Account Services.
  • Usage Information: Information is stored on the user’s use of the App. This includes game progress, scores, achievements, and interactions between players of the app.
  • Consumption information: We collect information regarding the user’s consumption routines concerning the use of the App, including purchases, both in virtual and real currencies, and the collection of virtual goods.

Information derived from other sources

When the user logs into the App via a third-party site or platform like Facebook, Apple Game Center, or Google Sign-In, we receive information from that site or platform, including the user’s screen name, profile information, and friend lists, in-line with the authorization procedures determined by such third party site or platform, under the condition that the user has consented to this provision of information.

Find out more about access to the user’s data by third-party sites or platforms in the privacy policy:

  • Facebook:
  • Game Center:
  • Google Play Games:
  • Epic Account Services:

When using a third-party site or platform to log into the App, the user certifies that their access and use of such features is compliant with the relevant terms and regulations and that the user meets the minimum age limits prescribed for such third-party site or platform by the relevant legislation.

Use of information – purpose and legal basis

The collected information is used for the following purposes in accordance with the legal provisions for each type of personal data:

Information regarding log, device, usage, and consumption as well as device identifiers are processed as follows:

  • delivering the requested items and services and sending data to the user;
  • delivering the App and game experience;
  • providing technical notices, updates, alerts, and support and administrative notifications;

The above-mentioned processing is key for the performance of a contract to which the user is a party for the purpose of supporting the App’s functioning, facilitating the delivery of requested items and services, and enabling maintenance and updating as per Article 6(1)(b) of the GDPR.

  • Providing relevant updates about the App;
  • personalizing the App and providing customized content;
  • keeping track of App-related trends, usage, and activities;

The above-mentioned processing is accounted for by our legitimate interests in providing advertisements and content that could be of interest to the user and better the quality of our services as per Article 6(1)(f) of the GDPR.

  • providing users that have consented to share their advertising IDs with our ad network partners (as specified in “Sharing of Information”) for the purpose of delivering customized advertisements in the App.

The above-mentioned processing is accounted for by our legitimate interests in delivering ads and content that could be of interest to the user as per Article 6(1)(f) of the GDPR. The disclosure of the user’s advertising ID to third parties in relation to behavioral advertising is based upon the user’s consent as per Article 6(1)(a) of the GDPR (more information in Sharing of Information).

  • The purpose of processing information from other sources is:
  • providing and delivering the requested items and services and sending relevant notices;

The above-mentioned processing is essential for the execution of a contract to which the user is a party for the purpose of facilitating the delivery of requested products and services, more information is in Section 6(1)(b) of the GDPR.

  • linking or combining information received by us from other sources to understand the user’s needs better and deliver improved service;
  • delivering notices and updates about the App that could be of interest to the user;

The above-mentioned processing is accounted for by our legitimate interests in delivering content that could be of interest to the user and bettering our services as per Article 6(1)(f) of the GDPR (otherwise called “the balancing-of-interest rule”).

The user’s information is processed solely in the scope necessary to achieve the purposes for which the information has been collected.

Storage of information

GAMING FACTORY S.A. shall store the user’s personal information for the time necessary to deliver the App to the user or otherwise satisfy the above-mentioned purposes, unless there is a need for further storage to establish, exercise, or defend a legal claim or in relation to relevant law, including accounting rules.

The user’s personal information shall be either disposed of or made anonymous immediately after it no longer serves any of the abovementioned purposes and no later than three (3) years after the termination of the user’s interaction with GAMING FACTORY S.A.

Sharing of information

The user’s information is disclosed to the following types of recipients, based upon legal foundations identified in sections 6(1)(b), 6(1)(c), and 6(1)(f) of the GDPR (for more information, see description of legal bases above):

  • social networks, more information available under “Social Sharing features”;
  • third parties, if disclosure of the user’s personal data was required by relevant law, ruling, regulation, legal process or in association with, or in the course of negotiations of, any merger, sale of company assets, financing or acquisition of all or a part of our establishment by another party;
  • the authorities, if it is believed that the user’s actions are not in line with the spirit or language of our policies or if the disclosure of such information is needed to protect the rights, property and safety of GAMING FACTORY S.A.  or other parties;
  • other players for the purpose of delivering certain in-app features, e.g. leaderboards, if the user logs into the App via a third-party service;

Furthermore, if the user has consented as per Section 6(1)(a) of the GDPR, we shall share the user’s device identifiers to advertising network enterprises for purposes of serving behavioral advertisements within the App. The following advertising network firms could be a part of this process:

  • Facebook, Inc.
  • Google LLC
  • Unity Technologies
  • IronSource
  • Applovin Corporation
  • Vungle, Inc.
  • Epic Games, Inc.

The use of shared information by the user’s recipients shall not be covered by this Privacy Policy. In the case of any questions regarding the processing of information performed by such third parties, please review their relevant privacy policies.

As regards our processing, we use processors of data such as server hosting providers, technical service providers for the purpose of supporting in-house activities, user login services, and analytics service providers:

  • Tenjin, Inc.
  • Facebook Analytics (Facebook, Inc.)
  • Firebase (Google LLC)
  • Epic Games, Inc.

Social sharing features

The App features social sharing features as well as other integrated tools (e.g. the Facebook “Like” button) for the purpose of sharing actions taken by users in the App with other media. The user must meet the minimum age limit indicated by the relevant legislation in individual jurisdictions for the purpose of using any sharing features featured in the App. The use of such features allows sharing information with the user’s friends on social media or with the public, depending on the chosen user settings selected by the provider of the feature.


The App can be used by users aged 13 and above, with the exception of the European Economic Area, where the App can be used by users aged 16 and above. If the user consents to the terms of this Privacy Policy when using the App, the user declares that they are 13 (or 16, depending on the relevant age limit) or older.

In the case of any questions regarding GAMING FACTORY S.A. privacy policies related to children under the applicable age limit, please contact

Transfer to third countries

As regards the processing of information, under certain circumstances the user’s personal data will be conveyed to non-EEU recipients.

The user’s personal data is transferred solely to entities in third-party countries with relevant safeguards to ensure that their data protection complies with this Privacy Policy and applicable law.

As a consequence, the transfers of data will occur solely as follows:

  • If the entity has the certification to comply with the principles regarding data protection as part of the US-EU Privacy Shield Framework (“Privacy Shield”) (find out more about the entities certified in Privacy Shield at, or
  • If standard data protection clauses have been employed by the European Commission with the entity, which will offer sufficient safeguards in reference to the protection of privacy and fundamental rights and freedoms of individuals.


GAMING FACTORY S.A. shall pursue reasonable measures for the protection of the user’s personal data from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction.

Push notifications

Push notifications or alerts shall be sent to the user’s mobile device to provide game-related notices, service updates, marketing communications, and other relevant notifications if the user has consented to such notifications. These notices can be deactivated by changing the notification settings on the user’s device.


Rights of EEU residents

We process and answer the user’s requests promptly and in any event within one month of our receipt of the request unless in view of a complex request, an extended period is required. In such a case, our response time can extend to three months as foreseen by Article 12 of the GDPR.

Rights of data subjects:

  • User’s right to request access
  • The right to object
  • Right to rectification
  • The right to restriction
  • The right to withdraw consent
  • The right to data portability
  • Rights of California residents
  • Right to opt-out
  • Right to be informed
  • Right to disclosure
  • Right to deletion
  • Right to equal services and prices

How can the user’s right be exercised? If the user would like to use any rights described below, they may contact us at any time at kontakt@gamingfactory.


If the user has any questions, please contact GAMING FACTORY S.A at:


Address: Powązkowska 15, 01-797 Warszawa, Poland