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Privacy Policy for CoM Studios

Effective Date: 01/01/2025 · Last updated: 12/10/2026

At CoM Studios, we respect your privacy and are committed to protecting the personal data you provide. This Privacy Policy outlines how we collect, use, store, and safeguard your information when you access and use our services. By using our products and services, you agree to the terms of this Privacy Policy. In this policy, “the App” means any game or app published by CoM Studios, and some features described below (such as game progress, scores or in-game purchases) apply only to apps where they exist.

Information We Collect

We collect various types of information to provide and improve our services, including information that is provided by you and information we collect automatically.

1. Information We Collect Automatically Through the App 📱

When you access or use the App, we automatically collect general information about your usage:

  • Log Information 📝: We log information about your use of the App, including:
    • The type of device you use
    • Features you interact with
    • Access times
    • Your IP address
  • Device Information 🖥️: We collect information about the device you use to access the App, including:
    • Device manufacturer
    • Device model
    • Operating system (OS) of the device
    • Time zone of the device
    • Language settings of the device
  • Device Identifiers 🔑: We collect online identifiers related to your device, including:
    • IDFA (Identifier for Advertisers)
    • Google Ads ID
    • Google Device ID
    • Game Center ID (for iOS)
    • Google Play Account ID
  • Usage Information 🎮: We collect data relating to your use of the App, such as:
    • Progress and settings within the App (for example, game progress)
    • Scores and achievements (where applicable)
    • Interactions with other users or players (where applicable)
  • Consumption Information 💳: We collect data regarding your consumption habits in the App, including:
    • In-app and in-game purchases made with both virtual and real currencies
    • Receipt of virtual goods or premium features within the App

2. Information We Collect from Other Sources 🌐

If you log into the App using a third-party site or platform, such as Facebook, Apple Game Center, or Google Sign-In, we may access certain information about you from that platform, including:

  • Screen name
  • Profile information
  • Friend lists

This access is in accordance with the authorization procedures determined by the third-party site or platform, provided that you have granted consent for such sharing of information.

For more information on how third-party sites or platforms process your data, please review their respective privacy policies:

By logging into the App through a third-party site or platform, you confirm that:

  • Your use of these features is compliant with the applicable terms and policies of the third-party site or platform.
  • You meet the minimum age requirement as defined by the legislation in your jurisdiction for accessing and using such third-party services.

How We Use Your Information

We use the information we collect about you for the following purposes, in accordance with the legal bases for each type of personal data as described below:

1. Log-, Device-, Usage-, and Consumption Information and Device Identifiers 📊

We process this information for the following purposes:

  • 📨 To provide and deliver the products and services you request, and send you related information as requested or agreed with you.
  • 🛠️ To provide and maintain the App and your experience.
  • 🔔 To send you technical notices, updates, security alerts, and support and administrative messages.

Our processing for the above purposes is necessary for the performance of a contract to which you are a party, in order to support the operation of the App, facilitate the delivery of requested products and services, and enable maintenance and updates of the App, in accordance with Article 6(1)(b) of the GDPR.

  • 📰 To provide news and information about the App that we believe will be of interest to you.
  • 🎮 To personalize and improve the App, providing tailored content and features.
  • 📈 To monitor and analyze trends, usage, and activities in connection with the App.

Our processing for the above purposes is justified by our legitimate interests in providing advertisements and content of interest to you, as well as improving our services, in accordance with Article 6(1)(f) of the GDPR (the "balancing-of-interest" rule).

  • 📢 To provide users who have given consent to share their advertising IDs with our ad network partners, for the purpose of serving them with personalized advertisements in the App (behavioral advertising).

Our processing for the above purpose is justified by our legitimate interests in providing advertisements and content of interest to you, in accordance with Article 6(1)(f) of the GDPR. The disclosure of your advertising ID to third parties for behavioral advertising is based on your consent, in accordance with Article 6(1)(a) of the GDPR (see more below under "Sharing of Information").

Storage of Information

CoM Studios will store your personal data for as long as necessary to provide you with the App or fulfill the purposes described above, unless further storage is required to establish, exercise, or defend a legal claim or comply with applicable law, including accounting rules.

Your personal data will be deleted or anonymized as soon as it no longer serves the purposes mentioned above and, in any event, no later than three (3) years after your interaction with CoM Studios has ceased. ⏳

Sharing of Information 📤

We disclose information about you to the following categories of recipients based on the legal bases under Sections 6(1)(b), 6(1)(c), and 6(1)(f) of the GDPR (see a description of the legal bases above):

  • Social networks 🌐, see more under “Social Sharing features”;
  • Third parties ⚖️ if we are required to disclose your personal data by applicable law, rule, regulation, legal process, or in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company;
  • The authorities 👮‍♂️ if we believe your actions are inconsistent with the spirit or language of our policies or if the disclosure is necessary to protect the rights, property, and safety of CoM Studios or others;
  • Other players 🎮 in order to provide certain in-app features, such as leaderboards, if you log into the App using a third-party service;

Furthermore, if you have given your consent in accordance with Section 6(1)(a) of the GDPR, we share your Device identifiers with advertising network companies for the purpose of them serving behavioral advertisements to you within the App. We use or may use the following advertising network companies:

The recipients’ use of the disclosed information will not be covered by this Privacy Policy. If you have questions concerning the processing carried out by such third parties, you should review their privacy policy.

In connection with our processing, we use the following data processors such as server hosting providers, technical service providers for supporting internal operations, user login services, and analytics service providers:

Children 👶

Use of the App is limited to users aged 13 years and above, except in the European Economic Area, where the App is limited to users aged 16 years and above. If you are accepting this Privacy Policy and using the App, you warrant you are 13 (or 16, depending on what is applicable) or more years old.

If you have additional questions about CoM Studios‘s privacy practices related to children under the applicable minimum age, please contact us at info@comstudios.com.

Transfer to Third Countries 🌍

In connection with the processing, we will in certain circumstances transfer your personal data to recipients outside the EU.

We only transfer personal data to entities in third countries that have provided appropriate safeguards to ensure that their level of data protection is in agreement with this Privacy Policy and applicable law.

Consequently, the transfers will only occur based on the following safeguard:

  • We have entered into standard data protection clauses adopted by the European Commission with the entity, which is deemed to offer sufficient safeguards with respect to the protection of the privacy and fundamental rights and freedoms of individuals.

Security 🔒

CoM Studios takes reasonable measures to help protect information about you from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction.

Push Notifications 🔔

We send push notifications or alerts to your mobile device to provide app- and game-related information, service updates, promotional communications, and other related messages, if you have agreed to such notifications. You can deactivate these notifications by changing your notification settings on your device.

Does CoM Studios actually “sell” personal data? 💸

CoM Studios does not, and will not, provide your personal data in direct exchange for money. Therefore, in the literal sense, CoM Studios does not sell your data. However, we have disclosed some categories of personal data we collect, explained under ”Sharing of Information”, to third parties for business purposes as explained under ”Use of Information – Purpose and Legal Basis”.

To the extent this practice is interpreted to constitute a “sale” under the CCPA, please contact us at info@comstudios.com to exercise your right to withdraw your consent on sharing your personal data with third parties.

Data Deletion Request 🗑️

You may request CoM Studios to erase without undue delay your personal data when it is no longer necessary for CoM Studios to retain such data.

In order for your data to be erased, you can contact CoM Studios by info@comstudios.com with your request.

Right to Equal Services and Prices ⚖️

California residents are protected against any discrimination that a business might subject them to based on the exercising of their CCPA rights.

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you the App,
  • Charge you different prices or rates for the App, including through granting discounts or other benefits, or imposing penalties,
  • Provide you a different level or quality of the App,
  • Suggest that you may receive a different price or rate for services or a different level or quality of the App.

How to Exercise My Rights 📝

If you wish to use any of the rights described below, you may contact us at any time by emailing us at info@comstudios.com.

Mandatory Verification 🔍

We will need to verify your identity before processing your request. However, because you cannot create an account with the App, and you do not provide us with any information directly, we only collect information automatically, we may use limited verification methods.

To verify your identity, we will generally require the matching data in our systems to the information we can process when you are making a request. In certain circumstances, we may decline the request, mainly where we are unable to verify your identity, for example, if you disable cookies, change the device you used to access the App, or if you already requested us to delete your personal data.

Contact Us 📧

If you have any questions or concerns about this Privacy Policy, or if you wish to exercise your rights related to your personal data, please contact us at:

By using our services, you acknowledge that you have read and understood this Privacy Policy and agree to the collection and use of your information as described herein.