Last Updated: September 21, 2026
1. INTRODUCTION
1.1 This Privacy Policy (“Policy”) explains how palmjoy (“we”, “us”, or “our”), represented by Sebastian-Alexandru MASEK, established in Romania, collects, uses, discloses, and otherwise processes personal data of users in connection with the mobile game Тени Пика (the “Game”) and related services (collectively, the “Services”).
1.2 We are committed to protecting your privacy in accordance with applicable data protection laws, including:
the EU General Data Protection Regulation (EU) 2016/679 (“GDPR”);
Romanian Law No. 190/2018 on the implementation of the GDPR;
other applicable laws and regulations on privacy and data protection.
1.3 “User”, “you”, or “your” means an individual who accesses or uses the Services.
1.4 This Policy explains:
what personal data we collect and when;
the purposes and legal bases for processing;
use of cookies and third-party SDKs;
how we share, transfer, and disclose your data;
your rights and how to exercise them;
data retention periods;
children’s data;
international data transfers;
changes to this Policy and contact information.
2. DATA CONTROLLER
2.1 The data controller responsible for your personal data is:
palmjoy
Representative: Sebastian-Alexandru MASEK
Country: Romania
Email: palmjoygames@gmail.com
2.2 For any questions about this Policy or your personal data, please contact us at the email above.
3. WHEN WE COLLECT PERSONAL DATA
3.1 We may collect personal data when:
(a) you download, install, or use the Game;
(b) you create an account or log in, including as a guest;
(c) you make in-game purchases or transactions;
(d) you contact customer support;
(e) you participate in surveys, events, or promotions;
(f) you interact with advertisements or third-party services integrated into the Game;
(g) you use cookies or similar technologies within the Services.
4. WHAT PERSONAL DATA WE COLLECT
4.1 We may collect the following categories of personal data:
(a) Account and profile data: username, nickname, email address, password (stored in hashed form), profile picture, and similar information you provide.
(b) Device and technical data: IP address, device identifier, advertising identifier, operating system, device model, app version, language, network type, and crash logs.
(c) Gameplay data: game progress, levels, scores, achievements, in-game actions, and preferences.
(d) Transaction data: purchase history, order IDs, and payment confirmation details. We do not store full payment card details; payments are processed by the relevant app store or payment provider.
(e) Support and communication data: messages, emails, and other correspondence with us.
(f) Usage and analytics data: how you use the Services, session duration, feature usage, and similar information.
(g) Marketing and communication preferences: your choices regarding receiving promotional communications.
4.2 We may also receive data from third parties, such as:
(a) platform providers (e.g., Google Play, Apple App Store);
(b) analytics and advertising partners;
(c) payment processors;
(d) social media platforms, if you choose to link your account.
5. LEGAL BASES FOR PROCESSING
5.1 Under the GDPR, we process your personal data on one or more of the following legal bases:
(a) Performance of a contract: to provide the Game and Services you request (Art. 6(1)(b) GDPR).
(b) Consent: where you have given us explicit consent, for example for certain marketing or advertising activities (Art. 6(1)(a) GDPR). You may withdraw consent at any time.
(c) Legitimate interests: to improve the Services, ensure security, prevent fraud, and conduct analytics, provided your rights and freedoms are not overridden (Art. 6(1)(f) GDPR).
(d) Legal obligation: to comply with applicable laws and regulations (Art. 6(1)(c) GDPR).
(e) Vital interests: to protect your vital interests or those of another person where necessary (Art. 6(1)(d) GDPR).
6. COOKIES AND SIMILAR TECHNOLOGIES
6.1 We use cookies, web beacons, SDKs, and similar technologies to operate and improve the Services, analyze usage, and provide personalized advertising where permitted.
6.2 You can manage cookie preferences through your device or platform settings. Disabling certain cookies may affect the functionality of the Game.
6.3 Our Services may integrate third-party SDKs for analytics, advertising, crash reporting, and consent management. These providers may collect and process data in accordance with their own privacy policies. We encourage you to review their policies.
7. HOW WE USE YOUR PERSONAL DATA
7.1 We use your personal data for the following purposes:
(a) to create, manage, and secure your account;
(b) to provide, operate, maintain, and improve the Game and Services;
(c) to process purchases and maintain transaction records;
(d) to communicate with you about your account, updates, and support requests;
(e) to personalize your experience and provide relevant content;
(f) to conduct analytics, research, and development;
(g) to detect, prevent, and address fraud, cheating, abuse, and security incidents;
(h) to comply with legal obligations and enforce our terms;
(i) to send marketing communications where you have consented or where permitted by law. You can opt out at any time.
8. HOW WE SHARE, TRANSFER, AND DISCLOSE PERSONAL DATA
8.1 We do not sell your personal data. We may share your data with:
(a) Service providers: hosting, analytics, customer support, payment processing, advertising, and technical service providers.
(b) Platform providers: Google Play, Apple App Store, and other distribution platforms.
(c) Legal and regulatory authorities: when required by law, court order, or valid governmental request.
(d) Business transfers: in connection with a merger, acquisition, reorganization, or sale of assets.
(e) Affiliates: where necessary for the operation of the Services, subject to this Policy.
8.2 All third parties processing data on our behalf are required to protect your data and use it only for the purposes for which it was disclosed.
9. INTERNATIONAL DATA TRANSFERS
9.1 Your personal data may be processed on servers located within the European Economic Area (EEA) or in other jurisdictions where we or our service providers operate.
9.2 Where personal data is transferred outside the EEA, we implement appropriate safeguards, such as the European Commission’s Standard Contractual Clauses (SCCs) or other lawful transfer mechanisms under Chapter V of the GDPR.
9.3 You may request a copy of the applicable safeguards by contacting us at palmjoygames@gmail.com.
10. DATA RETENTION
10.1 We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected or as required by applicable law.
10.2 Typical retention periods:
(a) Account data: while your account is active; after deletion, data is deleted or anonymized within 30 days, unless a longer period is required by law.
(b) Transaction records: up to 5 years, or as required by tax and accounting laws.
(c) Support records: up to 3 years from the closure of the request.
(d) Marketing consent records: until consent is withdrawn, plus 3 years.
(e) Technical logs and analytics data: up to 24 months in aggregated or anonymized form, unless a longer period is required by law.
11. DATA SECURITY
11.1 We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, destruction, alteration, or disclosure. These measures may include encryption, access controls, secure storage, regular software updates, and security audits.
11.2 While we strive to protect your data, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee absolute security.
12. YOUR RIGHTS
12.1 Under the GDPR and applicable Romanian law, you have the following rights:
(a) Right of access: to obtain confirmation of whether we process your personal data and receive a copy.
(b) Right to rectification: to correct inaccurate or incomplete data.
(c) Right to erasure: to request deletion of your personal data under certain circumstances.
(d) Right to restriction of processing: to limit how we use your data.
(e) Right to data portability: to receive your data in a structured, commonly used, machine-readable format and transmit it to another controller.
(f) Right to object: to object to processing based on legitimate interests or for direct marketing.
(g) Right to withdraw consent: where processing is based on consent, you may withdraw it at any time.
(h) Right to lodge a complaint: with a supervisory authority.
12.2 To exercise your rights, contact us at palmjoygames@gmail.com. We will respond within one month, extendable by two further months where necessary.
12.3 You also have the right to lodge a complaint with the Romanian supervisory authority:
National Supervisory Authority for Personal Data Processing (ANSPDCP)
B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, 010336 Bucharest, Romania
Website: www.dataprotection.ro
Email: anspdcp@dataprotection.ro
13. CHILDREN
13.1 The Services are not intended for children under the age of 16. We do not knowingly collect personal data from children under 16.
13.2 If you are under 16, you may use the Services only with verifiable parental or legal guardian consent, where required by applicable law.
13.3 If we become aware that we have collected personal data from a child under 16 without proper consent, we will delete such data as soon as possible. If you are a parent or guardian and believe your child has provided us with personal data, please contact us at palmjoygames@gmail.com.
14. CHANGES TO THIS POLICY
14.1 We may update this Policy from time to time. Changes become effective when the revised version is posted or otherwise made available.
14.2 For material changes, we will provide notice as required by applicable law. Your continued use of the Services after changes take effect constitutes acceptance of the updated Policy.
15. CONTACT INFORMATION
For any questions, requests, or concerns regarding this Privacy Policy or your personal data, please contact:
palmjoy
Representative: Sebastian-Alexandru MASEK
Country: Romania
Email: palmjoygames@gmail.com