# Privacy Policy
Aqsin Sulxayev, an individual developer operating under the name "ActionLab" ("us", "we", or "our"), operates the website and the mobile applications and games published under the names "ActionLab" (Google Play) and "Aqsin Sulxayev" (Apple App Store) (together, the "Service"; each application an "App").
This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data. Not every App uses every service described below; each App uses only the services needed for its features.
We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used here have the same meanings as in our Terms and Conditions.
## Definitions
**Service** — the website and all mobile applications and games operated by Aqsin Sulxayev (ActionLab).
**Personal Data** — data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
**Usage Data** — data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a session).
**Cookies** — small pieces of data stored on your device (computer or mobile device).
**Data Controller** — the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information is, or is to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.
**Data Processors (or Service Providers)** — any natural or legal person who processes data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
**Data Subject (or User)** — any living individual who is using our Service and is the subject of Personal Data.
## Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Service to you. Depending on the App, the following third-party service providers may be used. Their privacy policies apply to the data they process:
- [Google Play Services](https://policies.google.com/privacy) (Android)
- [Google AdMob](https://support.google.com/admob/answer/6128543)
- [Google Firebase](https://firebase.google.com/support/privacy)
- [Meta (Facebook) SDK / App Events](https://www.facebook.com/privacy/policy/)
- [Unity](https://unity.com/legal/game-player-and-app-user-privacy-policy)
- [Apple App Store](https://www.apple.com/legal/privacy/) and [Google Play](https://policies.google.com/privacy) in-app payments
### Types of Data Collected
**Personal Data.** Our Apps do not require you to create an account, and we do not ask for your name, email address or phone number inside the Apps. While using our Service, certain information that may identify your device may be collected, including Cookies, device identifiers and Usage Data. If you contact us by email, we receive the email address and any information you choose to send.
**Usage Data.** We may collect information that your browser sends whenever you visit our website, or that is generated when you use the Service through a mobile device ("Usage Data"). This may include your device's Internet Protocol (IP) address, browser type and version, the pages or screens you visit, the time and date of your visit, the time spent on them, and other diagnostic data. When you use the Service through a mobile device, Usage Data may also include the type of device you use, your device's unique identifiers (such as the Android Advertising ID or Apple's IDFA/IDFV, where available and permitted), your device's IP address, your operating system and other diagnostic data.
**Game Progress and Settings.** Game progress, settings and purchase status are stored locally on your device. They are not sent to our servers and are removed when you uninstall the App.
**Location Data.** We do not request access to, use or store your precise location. Our advertising partners may infer an approximate location (for example, country or city) from your IP address to show relevant ads and comply with local laws. You can disable location services for any app at any time through your device settings.
**Tracking and Cookies Data.** We and our partners use cookies, software development kits (SDKs) and similar technologies to track activity on our Service and hold certain information. These may include an anonymous unique identifier. Other technologies, such as beacons, tags and scripts, may be used to collect and track information and to improve and analyze our Service. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent; however, if you do not accept cookies, you may not be able to use some portions of our website.
Examples of cookies and similar technologies we use:
- **Session cookies** — to operate our Service.
- **Preference cookies** — to remember your preferences and settings.
- **Security cookies** — for security purposes.
- **Advertising cookies and identifiers** — to serve advertisements that may be relevant to you and your interests, and to measure their performance.
## Use of Data
We use the collected data to:
- provide and maintain our Service;
- notify you about changes to our Service;
- allow you to participate in interactive features of our Service when you choose to do so;
- provide customer support;
- gather analysis or valuable information so that we can improve our Service;
- monitor the usage of our Service;
- show advertisements and measure their effectiveness;
- process and restore in-app purchases;
- detect, prevent and address technical issues.
## Legal Basis for Processing Personal Data Under the GDPR
If you are in the European Economic Area (EEA), the United Kingdom or Switzerland, our legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it. We may process your Personal Data because:
- we need to perform a contract with you (for example, to deliver an in-app purchase);
- you have given us permission to do so (for example, consent to personalized ads);
- the processing is in our legitimate interests and is not overridden by your rights;
- it is needed for payment processing;
- it is needed to comply with the law.
## Retention of Data
We retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy, and to the extent necessary to comply with our legal obligations, resolve disputes and enforce our legal agreements and policies.
Usage Data is generally retained for a shorter period, except when it is used to strengthen security or improve the functionality of our Service, or when we are legally obligated to retain it for longer. Data processed by third-party service providers is retained according to their own policies.
## Transfer of Data
Your information, including Personal Data, may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction, where data protection laws may differ from those of your jurisdiction.
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, and no transfer of your Personal Data will take place to an organization or a country unless adequate controls are in place, including the security of your data and other personal information.
## Disclosure of Data
**Legal Requirements.** We may disclose your Personal Data in the good-faith belief that such action is necessary to:
- comply with a legal obligation;
- protect and defend our rights or property;
- prevent or investigate possible wrongdoing in connection with the Service;
- protect against legal liability;
- protect the personal safety of users of the Service or the public.
We do not sell your Personal Data.
## Security of Data
The security of your data is important to us, but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
## "Do Not Track" Signals
We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track in the preferences or settings page of your web browser.
## Your Advertising Choices
- **EEA, UK and Switzerland:** where required, our Apps ask for your consent before showing personalized ads, using Google's consent tools. You can change your choice at any time through the privacy option in the App, when one is offered.
- **iOS:** where an App requests permission to track you across other companies' apps and websites (App Tracking Transparency), you can allow or deny it, and change your choice at any time in Settings → Privacy & Security → Tracking.
- **Android:** you can reset or delete your Advertising ID, or opt out of personalized ads, in your device's Settings → Google → Ads (or Settings → Privacy → Ads).
- You can also opt out of personalized Google ads at [Google Ads Settings](https://adssettings.google.com).
## Your Data Protection Rights Under the GDPR
If you are a resident of the EEA, the UK or Switzerland, you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data. If you wish to be informed what Personal Data we hold about you, or want it removed from our systems, please contact us.
In certain circumstances, you have the following rights:
- **Access, update or deletion** of the information we have on you.
- **Rectification** — to have your information corrected if it is inaccurate or incomplete.
- **Objection** — to object to our processing of your Personal Data.
- **Restriction** — to request that we restrict the processing of your personal information.
- **Data portability** — to be provided with a copy of your information in a structured, machine-readable and commonly used format.
- **Withdrawal of consent** — at any time, where we relied on your consent to process your personal information.
We may ask you to verify your identity before responding to such requests. You have the right to complain to a data protection authority about our collection and use of your Personal Data; for more information, please contact your local data protection authority.
## Data Deletion
Our Apps do not require an account. Game progress and settings are stored only on your device and are deleted when you uninstall the App. If an App offers an account, you can delete it and its associated data from within that App where available.
You can also request deletion of any data we hold about you at any time by emailing us at [CONTACT EMAIL] with the subject line "Data Deletion Request" and the name of the App. We will process your request within 30 days. Data held by third-party service providers (for example, advertising identifiers) can be controlled using the options in "Your Advertising Choices" above, or by contacting those providers directly.
## Service Providers
We may employ third-party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services, or to assist us in analyzing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose, except as described in their own privacy policies.
### Analytics
We may use third-party Service Providers to monitor and analyze the use of our Service.
**Google Analytics / Firebase Analytics.** Google Analytics is a web analytics service offered by Google that tracks and reports usage. Google uses the data collected to track and monitor the use of our Service. This data may be shared with other Google services, and Google may use it to contextualize and personalize the ads of its own advertising network. For more information, see the [Google Privacy & Terms](https://policies.google.com/privacy) page and [Firebase privacy information](https://firebase.google.com/support/privacy).
**Meta App Events.** Some Apps use the Meta (Facebook) SDK to measure app installs and app launches and the effectiveness of our advertising campaigns. Automatic event logging and advertiser-ID collection are limited where possible. For more information, see the [Meta Privacy Policy](https://www.facebook.com/privacy/policy/).
### Advertising
We may use third-party Service Providers to show advertisements to you to help support and maintain our Service.
**Google AdMob.** AdMob is provided by Google LLC. You can opt out of personalized ads by following Google's instructions: https://support.google.com/ads/answer/2662922. For more information on how Google uses the collected information, see "How Google uses information from sites or apps that use our services": https://policies.google.com/technologies/partner-sites, or the [Google Privacy Policy](https://policies.google.com/privacy).
### Payments
Some Apps offer paid products or services (for example, a one-time "Premium" or "Pro" upgrade). In that case, payments are processed by the app store.
We do not store or collect your payment card details. That information is provided directly to the app store, whose use of your personal information is governed by its own privacy policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council.
The payment processors we work with are:
- **Apple App Store In-App Purchases** — https://www.apple.com/legal/privacy/
- **Google Play In-App Billing** — https://policies.google.com/privacy
## Links to Other Sites
Our Service may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
## Children's Privacy
Our Service is not directed to children under the age of 13 (or the higher minimum age required in your country) ("Children"). We do not knowingly collect personally identifiable information from Children. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information.
## Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Effective date" at the top. For significant changes, we will also provide a prominent notice in our Service before the change becomes effective. You are advised to review this Privacy Policy periodically. Changes are effective when they are posted on this page.
## Contact Us
If you have any questions about this Privacy Policy, please contact us:
- By email: akshins.lab@gmail.com
- Developer: Aqsin Sulxayev (ActionLab)