Privacy Policy

MERGE JOURNEY

Effective Date: February 9, 2025

Last Updated: February 9, 2025

Operator: New Version Limited

Location: New Zealand

Contact: mergejourney-support@newversion.tech

1.0 INTRODUCTION AND SCOPE

1.1 WELCOME

Welcome to 2248 Merge Journey ("the App," "we," "us," or "our"). This Privacy

Policy explains how New Version Limited, a New Zealand company, collects, uses,

and protects information when you use our mobile puzzle game.

1.2 SCOPE

This Privacy Policy applies to:

(a) The 2248 Merge Journey mobile application

(b) All versions available on iOS App Store and Google Play Store

1.3 COMMITMENT TO PRIVACY

We are committed to protecting your privacy and complying with applicable data

protection laws, including:

(a) New Zealand Privacy Act 2020

(b) General Data Protection Regulation (GDPR) for EU users

(d) Children's Online Privacy Protection Act (COPPA) for users under 13

1.4 AGE RATING

This App is rated 4+ (All Ages) and is designed to be family-friendly. We take

special care to protect the privacy of children who use our App.

2.0 INFORMATION WE COLLECT

2.1 INFORMATION COLLECTED AUTOMATICALLY

When you use the App, we automatically collect minimal information necessary

for the App to function:

(a) Anonymous User Identifier

A randomly generated unique ID (UUID) that identifies your game progress

without revealing your personal identity. This is NOT linked to your

name, email, or any personally identifiable information.

(b) Country/Region

Derived from your device's locale settings for leaderboard placement.

We do NOT collect your precise location or GPS coordinates.

Operating system version (e.g., iOS 16, Android 13) for compatibility

purposes only. We do NOT collect device identifiers, hardware serial

numbers, or advertising IDs.

2.2 INFORMATION YOU PROVIDE

You may optionally provide:

(a) Display Name

A username you choose to appear on leaderboards. This can be any name

and does not need to be your real name. Default is "Guest" followed

by random numbers.

(b) Avatar Selection

Your choice of avatar image from our provided options.

2.3 GAMEPLAY DATA

We store your gameplay progress:

(a) High scores and current game score

(b) Level progression

(d) Unlocked themes and power-ups

(e) Achievement progress

(f) Friend connections (via friend codes only)

2.4 INFORMATION WE DO NOT COLLECT

We want to be clear about what we DO NOT collect:

(a) Real names or legal identity information

(b) Email addresses or phone numbers

(d) Photos, videos, or biometric data

(e) Contacts or address book information

(f) Precise GPS location

(g) Device advertising identifiers (IDFA/GAID)

(h) Social media account information

(i) Payment or financial information

(j) Chat messages or voice recordings

3.0 HOW WE USE YOUR INFORMATION

3.1 PRIMARY USES

We use the information we collect to:

(a) Provide and maintain the App's core functionality

(b) Save and sync your game progress across sessions

(d) Enable friend features via friend codes

(e) Improve App performance and fix bugs

(f) Ensure compliance with our Terms of Use

3.2 LEGAL BASIS FOR PROCESSING (GDPR)

For users in the European Economic Area, we process your data based on:

(a) Legitimate Interests

Operating the App and providing gameplay features

(b) Legal Compliance

Complying with applicable laws and regulations

3.3 DATA MINIMIZATION

We follow the principle of data minimization and only collect information that

is strictly necessary for the App to function. We do not collect any additional

data for marketing, profiling, or behavioral analysis purposes.

4.0 ADVERTISING AND THIRD-PARTY SERVICES

4.1 GOOGLE ADMOB

We use Google AdMob to display advertisements in the App:

(a) Banner Ads

Small advertisements displayed at the bottom of the game screen

(b) Rewarded Video Ads

Optional advertisements you can choose to watch to earn virtual gems

4.2 COPPA-COMPLIANT ADVERTISING

Because our App is rated 4+ and may be used by children, we configure Google

AdMob with the following child-directed settings:

(a) Tag for Child-Directed Treatment (TFCD) is ENABLED

(b) Tag for Users Under Age of Consent (TFUA) is ENABLED

(d) Only contextual, non-personalized ads are shown

4.3 GOOGLE ADMOB DATA COLLECTION

Google AdMob may collect limited technical data to serve contextual ads:

(a) IP address (for general location and fraud prevention)

(b) Device type and operating system

Google AdMob does NOT collect or use data for personalized advertising in our

App due to our child-directed settings.

For more information about Google's data practices, please visit:

https://policies.google.com/privacy

4.4 SUPABASE CLOUD BACKEND

We use Supabase to store and sync your gameplay data:

(a) Your anonymous user ID and display name

(b) Game progress (scores, levels, gems)

Supabase servers are located in secure data centers. Data is encrypted in

transit and at rest. For more information, visit: https://supabase.com/privacy

4.5 NO OTHER THIRD-PARTY SERVICES

We do not use any other third-party analytics, tracking, or advertising

services beyond those listed above. Specifically, we do NOT use:

(a) Facebook SDK or Meta tracking

(b) Google Analytics or Firebase Analytics

(d) Customer data platforms

(e) Social media login services

5.0 DATA STORAGE AND SECURITY

5.1 LOCAL STORAGE

Your game data is stored locally on your device using secure encrypted storage

(Hive database). This allows you to play offline and protects your data if you

lose internet connectivity.

5.2 CLOUD STORAGE

Your game progress is also synced to our secure cloud servers (Supabase) to:

(a) Enable gameplay across multiple devices

(b) Restore your progress if you reinstall the App

5.3 DATA ENCRYPTION

(a) All data transmitted between the App and our servers uses TLS 1.3

encryption (HTTPS)

(b) Data stored in our cloud database is encrypted at rest

5.4 DATA RETENTION

We retain your gameplay data for as long as you use the App. If you request

deletion or uninstall the App and do not use it for 24 months, we may delete

your cloud data. Local data is removed when you uninstall the App.

5.5 SECURITY MEASURES

We implement appropriate technical and organizational measures to protect

your data:

(a) Secure cloud infrastructure with access controls

(b) Regular security updates and monitoring

6.0 CHILDREN'S PRIVACY (COPPA COMPLIANCE)

6.1 COMMITMENT TO PROTECTING CHILDREN

2248 Merge Journey is designed for all ages, including children under 13. We

are committed to complying with the Children's Online Privacy Protection Act

(COPPA) and similar international laws protecting children's privacy.

6.2 NO PERSONAL INFORMATION FROM CHILDREN

We do not knowingly collect personal information from children under 13 (or

the applicable age in your jurisdiction). The information we collect (anonymous

ID, display name, gameplay data) does not constitute "personal information"

under COPPA because:

(a) User IDs are randomly generated and not linked to any identity

(b) Display names are user-chosen nicknames, not real names

(d) We do not enable direct communication between users

6.3 INTERNAL OPERATIONS EXCEPTION

Our minimal data collection falls under the FTC's "internal operations"

exception, which permits collection of persistent identifiers (like anonymous

UUIDs) when used solely for:

(a) Supporting internal operations of the App

(b) Maintaining and analyzing App functionality

6.4 NO BEHAVIORAL ADVERTISING

We do not engage in behavioral advertising or targeted advertising based on

users' activities. All advertisements shown in the App are contextual and not

personalized to individual users.

6.5 PARENTAL RIGHTS

Parents and legal guardians have the right to:

(a) Review information collected from their child

(b) Request deletion of their child's data

To exercise these rights, please contact us at:

mergejourney-support@newversion.tech

Please include "COPPA Parental Request" in your subject line and provide

verification of your relationship to the child.

6.6 PARENTAL CONSENT

Because we do not collect personal information from children, parental consent

is not required to use the App. Parents are encouraged to supervise their

children's use of mobile applications.

7.0 YOUR PRIVACY RIGHTS

7.1 ALL USERS

Regardless of your location, you have the right to:

(a) Access the data we hold about you

(b) Request correction of inaccurate data

(d) Object to data processing

(e) Withdraw consent (where applicable)

7.2 EUROPEAN USERS (GDPR RIGHTS)

If you are in the European Economic Area, you have additional rights:

(a) Right to Access (Article 15)

Request a copy of your personal data

(b) Right to Rectification (Article 16)

Request correction of inaccurate data

Request deletion of your data ("right to be forgotten")

(d) Right to Restrict Processing (Article 18)

Request limitation on how we use your data

(e) Right to Data Portability (Article 20)

Receive your data in a structured, machine-readable format

(f) Right to Object (Article 21)

Object to processing based on legitimate interests

(g) Right to Lodge a Complaint

File a complaint with your local data protection authority

7.3 CALIFORNIA USERS (CCPA RIGHTS)

If you are a California resident, you have the right to:

(a) Know what personal information we collect

(b) Know whether your personal information is sold or disclosed

(d) Access your personal information

(e) Request deletion of your personal information

(f) Equal service and price (non-discrimination)

Note: We do NOT sell personal information to third parties.

7.4 NEW ZEALAND USERS (PRIVACY ACT 2020 RIGHTS)

If you are in New Zealand, you have the right to:

(a) Access your personal information

(b) Request correction of your personal information

7.5 EXERCISING YOUR RIGHTS

To exercise any of these rights, please contact us at:

mergejourney-support@newversion.tech

We will respond to your request within 30 days (or sooner if required by law).

8.0 DATA RETENTION AND DELETION

8.1 RETENTION PERIOD

We retain your data for as long as you actively use the App. "Active use"

means opening the App at least once within a 24-month period.

8.2 AUTOMATIC DELETION

If your account is inactive for more than 24 months, we may automatically

delete your cloud data. Local data on your device remains until you uninstall

the App.

8.3 HOW TO DELETE YOUR DATA

You can request deletion of your data at any time by:

(a) Email Request

Send an email to mergejourney-support@newversion.tech with the subject

"Data Deletion Request" and include your User ID (found in Settings)

(b) Uninstall the App

Uninstalling the App removes all local data. To also delete cloud

data, please send us an email request before uninstalling.

8.4 DELETION TIMELINE

Upon receiving a valid deletion request:

(a) We will acknowledge your request within 7 days

(b) We will delete your data within 30 days

8.5 DATA THAT CANNOT BE DELETED

Some data may be retained after deletion for:

(a) Legal compliance and audit purposes

(b) Fraud prevention

Such retained data will be anonymized and not linked to you.

9.0 INTERNATIONAL DATA TRANSFERS

9.1 DATA LOCATION

Your data may be processed and stored in:

(a) New Zealand (our company location)

(b) United States (Supabase cloud servers)

9.2 TRANSFER SAFEGUARDS

When we transfer data internationally, we ensure appropriate safeguards:

(a) Standard Contractual Clauses (SCCs) for EU data transfers

(b) Compliance with the NZ Privacy Act 2020

9.3 YOUR CONSENT

By using the App, you consent to the transfer of your data to countries

outside your own, which may have different data protection laws.

10.0 CHANGES TO THIS POLICY

10.1 NOTIFICATION OF CHANGES

We may update this Privacy Policy from time to time. When we make material

changes, we will:

(a) Update the "Last Updated" date at the top of this policy

(b) Display a notice in the App for significant changes

10.2 REVIEW

We encourage you to review this Privacy Policy periodically to stay informed

about our data practices.

10.3 CONTINUED USE

Your continued use of the App after changes to this Privacy Policy constitutes

acceptance of the updated policy.

11.0 CONTACT INFORMATION

11.1 QUESTIONS AND CONCERNS

If you have any questions, concerns, or requests regarding this Privacy Policy

or our data practices, please contact us:

Email: mergejourney-support@newversion.tech

Mailing Address:

New Version Limited

New Zealand

Please include "Privacy Inquiry" in your subject line.

11.2 RESPONSE TIME

We aim to respond to all privacy-related inquiries within:

(a) 7 days for general questions

(b) 30 days for formal rights requests (or sooner if required by law)

11.3 DATA PROTECTION OFFICER

For GDPR-related inquiries, you may contact our data protection contact at:

mergejourney-support@newversion.tech

END OF PRIVACY POLICY

New Version Limited

New Zealand

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