Privacy Policy - MANOGARU LIMITED
Effective date: May 8, 2026
1. What this policy covers
This Privacy Policy explains how MANOGARU LIMITED ("Company", "we", "us", or "our") handles information when you install, play, or otherwise use the mobile games we develop and publish (the "Games"). The Games may be made available via the Amazon Appstore, Google Play, the Apple App Store, and other mobile platforms in the United States, the European Union/EEA, and other regions where the Games are offered.
If you choose to use a Game, you agree that we may process information as described here. If you do not accept this Policy, please do not install or use the Games.
2. Information we may process
We try to keep data collection proportionate to what is needed to run, secure, and improve the Games. Depending on the specific Game and your interactions, the following categories can apply.
2.1 Details you submit to us
• Support requests: If you contact us, you may provide your name, email address, and the content of your request. We use this to respond, troubleshoot, and resolve issues.
• Player content and communications: Where a Game includes chat, community tools, or reporting/feedback features, we collect the content you send (for example, messages, feedback, and reports) to provide the feature, handle moderation where necessary, and improve the player experience.
• Purchase confirmations: In-app purchases and subscriptions are processed by the relevant app store or platform. We do not receive or store full payment card information. We typically receive limited confirmation data (such as a receipt or transaction identifier) so we can deliver content, support purchases, and help prevent fraud.
2.2 Data collected automatically when you use a Game
• Device/app identifiers and settings: such as device type/model, OS and version, language settings, app version, and device or platform identifiers (for example, device ID, advertising ID, or Android ID).
• Gameplay and usage events: how you interact with the Game (for example, session duration, features used, levels completed, scores, and other gameplay events), along with technical diagnostics like crash reports and performance logs.
• Network signals: IP address and approximate location derived from it (such as city/country), ISP, and connection type (Wi‑Fi/mobile). We primarily use this for analytics, security, and troubleshooting (for example, to investigate outages or latency).
• Advertising identifiers: If a Game contains third-party ads, we may collect your device advertising identifier and share it with ad partners for ad delivery, measurement, frequency capping, and fraud detection. Advertising identifiers generally do not include your name, but can be used to recognize a device.
2.3 Information provided by third parties
In some situations, third parties provide information that helps us operate the Games and understand acquisition and usage patterns, for example:
• Marketing attribution: We use AppsFlyer Ltd. to measure marketing performance. AppsFlyer may provide reports and event-level attribution data about installs and in-app activity (for example, campaign/source information).
• Advertising reporting: If a Game includes third-party ads, we may receive aggregated and/or de-identified statistics about ad delivery and outcomes (for example, impressions, clicks, conversions, and fraud-related signals).
• Hosting/infrastructure: We use infrastructure and hosting providers (including AWS and Hetzner). In connection with operating, maintaining, and securing our services, we may receive operational logs, alerts, or performance metrics generated by these providers, which can include technical identifiers such as IP address and timestamps. These providers process data for us under contractual data protection terms. AWS also states that customers control content stored in AWS services, AWS does not access or use customer content without agreement, and AWS does not use customer content for marketing or advertising.
2.4 Data minimization and sensitive information
We do not intentionally collect sensitive personal information (such as government IDs, health data, biometric data, or full payment card details). Our collection is focused on technical, gameplay, and diagnostic information needed to provide and improve the Games.
3. How we use information
We use information for purposes such as:
• Delivering and operating the Games: enabling gameplay, saving progress, authenticating device/account where applicable, and supporting multiplayer/social features (if included).
• Improving performance and experience: analyzing gameplay and technical data to fix bugs/crashes, improve device compatibility, balance gameplay, and build new features and content.
• Advertising (for ad-supported Games): serving ads (personalized or contextual/non-personalized depending on your settings and location) and measuring ad performance.
• Purchases, integrity, and fraud prevention: delivering purchased content and using identifiers/transaction signals to detect fraud, refund abuse, cheating, or other harmful behavior; enforcing our Terms; and protecting the player community.
• Communications: sending service-related messages (support responses, security notices, and material updates). Where permitted and where you have consented, we may also send marketing messages; you can opt out at any time.
• Support operations: responding to questions, restoring access where possible, and resolving billing or technical issues.
• Legal compliance: meeting applicable legal requirements and responding to lawful requests from public authorities.
Where required by law, we rely on appropriate legal bases, including: (i) performance of a contract with you (our Terms of Service), (ii) your consent (for example, where consent is required for personalized advertising or optional features), and (iii) our legitimate interests (such as maintaining and improving the Games, ensuring security, and understanding marketing effectiveness), unless those interests are overridden by your rights and interests.
4. Sharing, partners, and SDKs
We use third-party services to help run the Games, perform analytics/telemetry, measure marketing, and serve ads. These partners may collect certain device information automatically as described above and process it under their own privacy policies. We encourage you to review their notices to understand their practices.
4.1 AppsFlyer Ltd. (attribution and measurement)
We integrate the AppsFlyer SDK to evaluate campaign effectiveness and understand how users discover and engage with our Games.
AppsFlyer may process: advertising identifiers (including platform advertising IDs where available), device/app details (device type, OS, app version), IP address in limited contexts (for attribution and fraud prevention), and in-app events related to installs and interactions.
AppsFlyer acts as our processor/service provider for attribution, analytics, measurement, and fraud prevention, and processes information under our instructions. AppsFlyer states it does not sell personal data.
4.2 Pavetra LTD (telemetry, analytics, crash reporting)
We use the Pavetra LTD SDK for telemetry, analytics, and crash reporting so we can monitor stability, diagnose errors, and improve gameplay and performance.
Pavetra LTD (501,5 Andrea Kalvou Str, Limassol, CY) may process technical and diagnostic data (for example crash logs, stack traces, and error reports), device information (device model, OS, app version), and in-app event data related to gameplay and app usage.
Pavetra LTD provides these services as our processor and processes information in accordance with our instructions.
4.3 Advertising partners and third‑party links
We do not provide ad partners with information that directly identifies you by name or email. Ad partners usually receive device identifiers and contextual data needed to deliver ads and measure results. If you click an ad or a link inside a Game, you may be taken to a third-party site/app; any information you provide there is governed by that third party’s privacy policy, not this Policy.
5. Advertising controls and preferences
If you want to limit interest-based advertising, you can use controls available on your device/platform, for example:
• iOS/iPadOS: Settings > Privacy > Advertising, then enable “Limit Ad Tracking” (or the equivalent available for your iOS version).
• Android: Settings > Google > Ads, then enable “Opt out of Ads Personalization” (or the equivalent available for your Android version).
These controls signal participating ad networks not to use your advertising identifier for personalized ads. You may still see ads, but they are more likely to be contextual or less tailored.
You can also contact us at manugarulimited.games@gmail.com to request help with ad choices or to exercise the rights described below. Where required by law or by this Policy, we may disable personalized ads for your device, provide non-personalized ads, or offer another alternative (such as an ad‑free option where applicable).
6. Cross-border data transfers
We operate internationally. Accordingly, personal data may be transferred to, stored in, or accessed from countries other than where you live. Depending on the Game and operational needs, we may process data using infrastructure providers (including AWS and Hetzner) in Germany and the United States.
If you are in the EEA or the UK, transfers to countries that do not provide an “adequate” level of protection are protected using appropriate safeguards, which may include:
• Standard Contractual Clauses (SCCs) adopted/approved by the European Commission;
• Recognized privacy frameworks such as the EU‑U.S. Data Privacy Framework where applicable; and
• Additional technical and organizational measures (for example, encryption in transit, access controls, and data minimization).
You can request more information about transfer safeguards by contacting us at manugarulimited.games@gmail.com.
7. Your rights
Your privacy rights depend on where you live. Below is an overview of common rights and how to make a request.
7.1 EEA/UK and similar jurisdictions
If you are in the EU/EEA, the UK, or a jurisdiction with similar laws, you may have the right to:
• Access your personal data and receive information about our processing;
• Correct inaccurate or incomplete data;
• Request deletion (erasure), subject to legal exceptions;
• Request restriction of processing in certain circumstances;
• Object to processing based on legitimate interests (including profiling) and object to direct marketing;
• Request data portability where technically feasible; and
• Withdraw consent at any time where we rely on consent (this does not affect processing before withdrawal).
You may also lodge a complaint with your local data protection authority. We encourage you to contact us first so we can try to address your request or concern.
To exercise these rights, contact us using the details in the Contact section. We may need to verify your identity (for example, by confirming information we already have) before fulfilling the request. We generally respond within a reasonable timeframe and in line with applicable law (often within 30 days).
7.2 California privacy rights (CCPA/CPRA)
If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), may provide the following rights (subject to conditions and exceptions):
• Right to know: Request disclosure of the categories and specific pieces of personal information collected about you in the past 12 months, sources, purposes, and categories of third parties with whom we share it.
• Right to delete: Request deletion of personal information we collected from you, subject to exceptions (for example, completing a transaction, security, or legal compliance).
• Right to opt out of sale/sharing: Opt out of certain disclosures of identifiers and usage data for cross-context behavioral advertising that may be considered a “sale” or “sharing” under California law.
• Right to correct: Request correction of inaccurate personal information we maintain about you.
• Right to non-discrimination: Exercise your rights without unlawful discrimination (for example, we will not deny service because you exercised a privacy right).
• Shine the Light: Request certain information about disclosures of personal information to third parties for their direct marketing purposes. We do not share personal information for third parties’ direct marketing unless you have explicitly consented.
We do not sell personal information for money. However, some advertising-related disclosures may be considered a “sale” or “sharing” under California law. To opt out, you can (a) use any in-game privacy controls or a “Do Not Sell or Share My Personal Information” option if available, (b) limit ad tracking in your device settings, and/or (c) contact us at manugarulimited.games@gmail.com.
Submitting requests: Please email us and include “California Privacy Rights Request” in the subject or message body. We will take steps to verify your identity or authority (including for authorized agents) and will respond within the timeframes required by law (generally 45 days, with a possible extension where permitted).
8. Children’s privacy
Our Games are not intended for children. We do not knowingly collect personal data from children under 13 (or under 16 in the EEA where a higher age of consent applies). By using the Games, you represent that you are old enough to consent to data processing in your jurisdiction.
If we learn that we collected personal data from a child without appropriate consent, we will delete it. If you believe a child has provided us personal data, please contact us so we can investigate and remove the data.
Some Games may be rated for a general audience. We encourage parents and guardians to supervise children’s gameplay. We do not use children’s data to profile or target them with advertising. For Games directed to children or mixed audiences, we comply with applicable laws such as COPPA and obtain verifiable parental consent where required.
9. Security measures
We apply administrative, technical, and physical safeguards designed to protect information against unauthorized access, loss, misuse, or alteration. Examples may include encryption in transit, firewalls, secure server infrastructure, and access controls.
No transmission or storage method is completely secure. Please protect your device and any accounts you use. If we become aware of a data breach affecting your personal data, we will notify affected users and authorities as required by law.
10. How long we keep information
We keep personal data only for as long as needed for the purposes described in this Policy, unless a longer period is required or permitted by law. For example:
• While you actively use a Game, we may retain information tied to your account or device to provide the service (such as progress and settings).
• Aggregated or anonymized information that cannot reasonably identify you may be retained longer for analytics and game improvement.
• If you request deletion, we delete information where required and feasible, but may keep certain records where needed for legal obligations or legitimate business purposes (for example, proof of purchase).
• Backups may persist for a limited period as part of routine disaster recovery, and we use measures intended to prevent deleted data from being restored for active use.
When information is no longer necessary, we securely delete it or de-identify it so it is no longer associated with you.
11. Contact
If you have questions about this Policy or want to exercise your privacy rights, you can contact us. We typically reply within 30 days.
Email: manugarulimited.games@gmail.com (use subject line “Privacy Inquiry”).
App store contact: You can also use the developer contact mechanism provided in the store listing (for example, “Contact Developer”). Messages submitted through a store may be forwarded to our support email.
When writing to us, please include the Game title and any relevant identifiers (if available) so we can locate your request and respond accurately.
12. Updates to this Policy
We may revise this Policy from time to time as our practices, technology, or legal requirements change. If changes are significant, we may provide notice in the Game and/or update the effective date above. Continued use of the Games after an update means you accept the revised Policy to the extent permitted by law.
If you do not agree with an updated Policy, you should stop using the Games and you may request deletion of your personal data as described above.
By playing our Games, you acknowledge that you have read and understood this Privacy Policy.