PRIVACY POLICY FOR TAPCLAP Games

Last updated: 15.04.2025

We are TAPCLAP LTD (“TAPCLAP”). In this document we’ll refer to ourselves as “TAPCLAP,” “we,” or “us.”

In this Privacy Policy (“Policy”) you will find:

  • What information we collect about you
  • How we might use that information
  • What information we might share with others
  • Your rights and choices about that information

By accepting this Policy, you expressly agree to the provision, processing and storage of your Personal Data within the scope and on the terms specified in this Policy. You acknowledge and agree that you have reached the age allowing you to enter into such binding agreement in the country of your residence or domicile, or that you have your parent or legal guardian’s permission (if required by applicable law). Child is a person that has not reached the minimum age required to provide the consent for Data collection and processing in accordance with applicable laws of the resident country. Our Games do not target children.

Data processing is carried out by us solely for the purposes defined by this Policy. Please note that you have the right to withdraw consent at any time, in the manner specified by this Policy.

This Privacy Policy applies to the Games and our official portals indicated below only. TAPCLAP does not control and is not responsible for third-party resources to which you can go through our Games and our official portals.

 

  1. Data Controller and Contact Information

    The Controller for the purposes of the GDPR and other applicable data protection or data privacy laws, as well as other data protection requirements in respect of the TAPCLAP Games, is:

    TAPCLAP LTD

    28th October Avenue, 335,
    Office W704, 3106 Limassol Cyprus
    Contact detail for Data protection issues:
    28th October Avenue, 335,
    Office W704, 3106 Limassol Cyprus
    privacy@tapclap.com

    This Policy extends to the following TAPCLAP Games (hereafter “Games”):

    • “Mansion Tale: Merge Secrets”,
    • “Guru Match 3D”,
    • “Raspberry Jam”,
    • “Spell Blast”,
    • “Candy Valley”,
    • “Pirate Treasures”,
    • “Artnum - Color by Number”,
    • “Cross Stitch Masters”,
    • “Sea Battle Heroes”,
    • “DesignVille”
    which is distributed:

    Through online stores such as the Apple App Store, Google Play, Amazon Appstore, etc.
    By publishing on our websites (“Website”).
    By publishing on social media sites such as Facebook etc.

    This Policy also extends to our corporate website https://tapclap.com and our Games’ related activities on social media.

    Source of Data we collect

    • Information we receive from external resources or/and generate as a result of your use of the Game. For example when authorizing via social media or any other external accounts you provide us with some data from these accounts automatically in accordance with the extent of information shared by those platforms or external accounts based on your permissions and their privacy policies.
    • Data you provide by yourself. For example when you provide information to our support services. We are not responsible for the relevance, correctness, completeness or quality of the information you provide. When you place the data indicated independently, we proceed from the presumption of your good faith, accepting the specified information as relevant, correct, complete and reliable. If you indicate inaccurate and (or) irrelevant information, access to a number of Services may be limited for you, and technical support and support services regarding the processing of personal data is suspended until the confirmation of your ownership of the specified information. These measures are necessary to ensure the protection of your data.
    • Information we receive from our advertisers and promotional partners that we work with to help us deliver ads and personalized content to you and recognize you across browsers and devices. This may include pseudonymous advertiser identifiers that some advertisers or other third-party ad platforms choose to share with us. We do not collect information about you from publicly available sources.

  2. Personal Data we collect, purposes and legal basis

    Type of Data Examples of Data Purpose Our legal basis
    Platform profile you use to start the Game Platform profile name, user profile image, account creation date, language, timezone, currency, friends list (in case when you connected to your social media accounts) To create user accounts, enable gameplay, perform analytics to ensure Game functionality, to provide customer support Contract under GDPR Art. 6 (1) (b)
    Game experience In-game progress linked to your internal game ID: coins, items, player level, etc.; your game settings; your activity in game such as overall time played and latest session date To operate and improve the Game, maintain its security, and perform analytics to ensure Game functionality, to provide customer support Contract under GDPR Art. 6 (1) (b)
    App events Your interactions within the game such as user interface interactions, social interactions, session data, error logs To ensure that the Game functions properly on your device, for analytic purposes, to make improvements to the Game, to provide customer support Contract under GDPR Art. 6 (1) (b)
    Device information Your device information such as your device’s hardware model and operating system, unique device identifiers (such as IP Address), network information, information about where you accessed the Game To ensure that the Game functions properly on your device, for analytic purposes, to make improvements to the Game, to provide customer support Contract under GDPR Art. 6 (1) (b)
    Advertising information Your device’s unique Advertising ID (such as IDFA, Google Advertising ID or other identifiers) or similar information that may be collected on portions of the Game that display advertisements; marketing campaign information To personalize advertisements to your interests In connection with our legitimate interests Our legitimate interests are to render and improve our games in an effective, safe and harmless manner. Our intent is to provide everyone with a fair and balanced experience under GDPR Art. 6 (1) (f).
    Purchase information Information about your purchases made within the Game, including the items purchased, transaction ID, date, amount, currency, and price To facilitate purchases within the Game and ensure your account is credited appropriately, to perform analytics, to maintain Game security, provide returns and customer support, improve Game experience, and ensure better transparency Contract under GDPR Art. 6 (1) (b)
    Information you provide directly via our public emails Email address, including additional information such as name, attachments, and other shared details when sending an email To provide Game support and respond to other inquiries In connection with our legitimate interests Our legitimate interests are to render and improve our games in an effective, safe and harmless manner. Our intent is to provide everyone with a fair and balanced experience under GDPR Art. 6 (1) (f).
    Information you have posted on various gaming forums and websites concerning the Game Internal game ID, information related to your Game experience, your device information To provide Game support and distribute compensations and rewards Contract under GDPR Art. 6 (1) (b)
    Information you send through in-game data transfer, including when participating in competitions, contests, and tournaments and responding to surveys Internal game ID To distribute rewards Contract under GDPR Art. 6 (1) (b)

  3. Sharing Personal Data with Third Parties

    We share your personal data to suppliers or agents working on our behalf in order to provide you the best services we can offer, ensuring that they are contractually obligated to keep your personal data confidential and will comply with the GDPR and other relevant data protection laws.

    We may share your information with the following types of third parties:

    • analytical services that help us develop and improve the Game.
    • advertising and promotional agencies and those organisations or online platforms selected by us to carry out marketing campaigns on our behalf to advertise our own products that may be of interest to you;
    • advertising and promotional agencies and those organisations or online platforms selected by us to deliver ads and promotional messages that may be of interest to you;
    • third party software providers, including “software as a service” solution providers, where the provider hosts the relevant personal data on our behalf;
    • professional advisers such as solicitors, accountants, tax advisors, auditors and insurers, where necessary in the course of the professional services that they render to us.

    We may share your personal data with our affiliates and partners we mentioned above in the European Union (“EU”)/European Economic Area (“EEA”) and outside the EU/EEA. If the transfer of data outside the EU/EEA is not regulated by an EU Commission sufficiency decision, we base on the legal guarantees set out in Article 46 et al. Seqq. GDPR. This mainly includes EU Commission-approved Standard Contractual Clauses, which we have strengthened with additional security measures such as additional individual risk assessment, additional contractual guarantees, and technical guarantees, including multi-factor authentication data access, additional encryption, security threat detection systems, to enable international transfers with our affiliates and partners outside the EU/EEA. Learn more about the EU Commission’s approved Standard Contractual Clauses.

    We may disclose your personal data as permitted by law to investigate, prevent, or act regarding illegal activities, suspected fraud, violation of our intellectual property rights, situations involving potential threats to the physical safety of any person, violation of our Terms and Conditions or other agreements, or as required by law.

  4. How long we collect and process your Personal Data

    We process your data for as long as it is necessary to fulfill the purposes for which it was collected and used, and as long as it is required to provide you with our services. Your data will continue to be processed until you withdraw your consent for us to process your personal information at any time.

  5. Your Data Protection rights

    • Right to access to your data, i.e. the right to require free of charge information whether your Personal Data is retained, access to and/or to provide duplicates of the Personal Data retained. We provide the duplicate of the Personal Data retained within 30 (thirty) days upon your request. If the request is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee.
    • Right to request the rectification, i.e. you may ask us to change any information retained, if you consider it’s not correct
    • Right to erasure your data, i.e. the right to delete your Personal Data. Usually we delete your Personal Data within 30 (thirty) days upon your request subject to provision of the in-game ID or other additional information in order to identify you and prevent fraud. You can also erase your data via in-game setting “Delete account”/”Delete progress”. As a result you will lose access to the Games, your in-game progress etc. Even after deletion of your Personal Data we may retain data which are required for our compliance with the requirements of applicable laws (e.g. tax and accounting requirements) or for our detection, investigation and prevention of cheating in the Game and Terms and Conditions violations or to resolve disputes and enforce our agreements.
    • Right to restrict processing your data, e.g. if we no longer need the personal data but you need us to keep it in order to establish, exercise or defend a legal claim or you have objected to us processing your data, and we are considering whether our legitimate grounds override yours, during this process you may restrict processing.
    • Right to object to processing your data, it means if you object we will no longer process your Personal Data unless there are compelling and prevailing legitimate grounds for the processing or the data are necessary for the establishment, exercise or defense of legal claims.
    • Right to data portability, i.e. right to have the personal data transmitted directly from one controller to another, where technically feasible, and only applies when our lawful basis for processing your information is consent or for the performance of a contract and when we are carrying out the processing by automated means.
    • Right to withdraw the consent to processing your data, apply when the processing of your data is based on your consent. Withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
    • Right to lodge a complaint with a supervisory authority, can be exercised in the Member State of your habitual residence, place of work or place of the alleged infringement.

    Opt-out of direct marketing

    You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your Android or iOS device and selecting:

    • “limit ad tracking” (Apple iOS), or
    • “opt-out of interest-based ads” (Android).

    For personalized in-game offers opt-out, you can use the options provided in the Games’ settings.

    You may also visit https://aboutads.info/choices or https://youronlinechoices.eu (for individuals in the EU) to learn more about interest-based advertising and how to opt-out of this form of advertising on your web browser by companies participating in the Digital Advertising Alliance (“DAA”) self-regulatory program.

    If you would like to exercise any of those rights or report security vulnerabilities in the Game please email us at privacy@tapclap.com. We may ask for additional info to verify that you’re the owner of that data.

  6. Cookies

    We and our partners, such as marketing and analytics partners, may use “cookies,” which are text files placed on the computers of users of the Games and website to help us analyze how you use the Games and website, as well as similar technologies (e.g., web beacons, pixels, ad tags, and device identifiers) to recognize the use of the Games and website across different devices and our services. These are also used to improve our services, marketing, analytics, or website functionality. The use of cookies is standard on the internet. You will be prompted to provide your consent for cookies when visiting our website. You may adjust your browser settings to prevent the reception of cookies or to provide notification whenever a cookie is sent to you. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to access the full functionality of our Games and websites.

    Website traffic volume and information pertaining to the Games, such as the number of visitors to a given game or website on a daily basis, is typically referred to as “tracking data.” This type of indirectly collected information is gathered through various means, such as an IP address, which is a number that is automatically assigned to your computer whenever you use online resources. Web servers — the computers that “serve up” web pages — automatically identify computers by their IP addresses. When you visit any of our websites, our servers log the computer’s IP address.

    We may update this Privacy Policy to reflect changes to our data and information privacy practices.

PRIVACY POLICY TERMS AND CONDITIONS