Privacy Policy

1. About this Policy

This Privacy Policy explains how Learnings Co., Limited ("Learnings", "we" or "us") collects, uses and shares information when you download, access or play our mobile games or use any related features that link to this policy (together, the "Service").

By using the Service, you agree to the practices described in this policy. If you do not agree with any part of it, please stop using the Service. When you use the Service, you represent that you are at least the minimum age for consenting to personal data collection under the law in your jurisdiction. Our Service is not intended for children. If you are under the minimum legal age required to consent to data processing in your jurisdiction, you must not download, access, or play our games, or provide any personal information to us. If you are a parent or guardian and believe your child has given us personal information without your consent, please email us and we will delete it.

2. What We Collect

We collect information in three ways: you share it with us, our systems collect it automatically when you use the Service, and we receive some of it from third parties. In each case, we collect only what is adequate, relevant and necessary for the features you actually use. If you play in an offline guest mode, your game data stays on your device and is not uploaded to our servers.

2.1 Information you share with us:

• Profile details: a nickname and an in-game avatar selected from the options provided in the game.
• Settings and preferences: such as language, sound or vibration options.
• Support and communication records: when you contact us, give feedback, or take part in a survey, contest or giveaway — including your email address, the content of your request, and any screenshots or attachments you choose to send.

2.2 Information our systems collect automatically:

• Identifiers: your player ID, device identifiers (such as IDFV or Android ID) and advertising identifiers (such as IDFA or GAID).
• Approximate location: the country, region or city derived from your IP address or device language. We do not collect precise GPS location, and we do not retain raw IP addresses.
• Device and technical data: your device model, operating system and version, system language, time zone, network and carrier, as well as app version, crash logs and performance data.
• Gameplay data: your progress, levels completed, scores, achievements, play time, and records of premium features and virtual items you have obtained.
• Usage and ad interaction data: when you play, how long a session lasts, which features you use, and whether ads are shown to or tapped by you — this is used for ad measurement, optimization and fraud prevention.
• Information collected through cookies, SDKs and similar technologies that help the Service work, stay secure and improve.

2.3 Information we receive from others:

• App stores: when you make a purchase or subscribe, the app store gives us the order or receipt ID, the item purchased, the time and the amount. We never see or store your card number or bank details — payments are handled entirely by the app store and its payment processors.
• Advertising and analytics partners: for example, if you installed the game after tapping one of our ads, the ad network tells us which campaign the install came from; partners may also share measurement and audience information with us, as permitted by law.

3. How We Use Information

We use the information described above for the following purposes:

4. When We Share Information

We share information only as described below and as permitted by law:

• Affiliates. We may share your information with companies within our corporate group where needed to operate and manage the Service. They are required to handle your information in the manner described in this policy.
• Technical Service Providers. We engage third-party service providers to perform functions for us, such as cloud hosting, data analytics, crash monitoring, customer support, email delivery and marketing support. They process your information only on our instructions and only to provide their services to us.

  Purposes	SDK Name	Company	Privacy Policy
  Push notifications and service-related messages	Amazon Device Messaging	Amazon.com, Inc.	Privacy Policy
  	Firebase Cloud Messaging	Google LLC	Privacy Policy
  Payment Processing	Google Play Billing	Google LLC	Privacy Policy
  	Amazon Appstore SDK	Amazon.com, Inc.	Privacy Policy
  Analytics	Firebase Analytics	Google LLC	Privacy Policy
  Crash/Error monitoring	Firebase Crashlytics	Google LLC	Privacy Policy

• Analytics and Interest-based Advertising Partners. We work with advertising and analytics partners to deliver ads and measure how they perform. For this we may share identifiers, device and technical data, IP address, and ad interaction data. Where the law requires your consent for this sharing, we will ask for it first. If you withdraw consent, you will still see ads, but they will not be tailored to your interests. You can change your choice at any time in the game's privacy settings. Our advertising partners include but are not limited to the following:

  SDK Name	Company	Privacy Policy
  Amazon Publisher Services	Amazon.com, Inc.	Privacy Policy
  AppLovin MAX	AppLovin Corporation	Privacy Policy
  AppsFlyer	AppsFlyer Ltd.	Privacy Policy
  BidMachine	BidMachine, Inc.	Privacy Policy
  Chartboost	LoopMe Limited	Privacy Policy
  Facebook Core	Meta Platforms, Inc.	Privacy Policy
  Fyber	Fyber	Privacy Policy
  Google Mobile Ads (AdMob)	Google LLC	Privacy Policy
  IronSource	Unity Technologies	Privacy Policy
  Meta Audience Network	Meta Platforms, Inc.	Privacy Policy
  MobileFuse	MobileFuse, LLC	Privacy Policy
  Moloco	Moloco, Inc.	Privacy Policy
  Unity Ads	Unity Technologies	Privacy Policy

• Merger, Acquisition, or Other Business Transaction. In addition, if our business is merged, acquired or restructured, your information may be transferred as part of that transaction, and we will require the recipient to handle it as described in this policy. We may also share information with anyone else if you ask us to or give us permission.
• Professional Advisors and Authorities. We may share information with our professional advisers, such as lawyers, auditors and accountants, where needed for their services to us; and with courts, regulators or public authorities where required by law, legal process or an enforceable governmental request, or where necessary to protect the rights, property or safety of you, us or others, or to enforce our terms.

5. How We Transfer Your Information

Due to the global nature of our operations, your personal data may be transferred to, stored in, and processed by our affiliated companies, service providers and advertising partners in countries outside your country of residence. Our data storage servers are located in the United States. Where the transfer of your personal data to a recipient located in a foreign country constitutes an international or cross-border transfer under applicable law, we rely on approved legal transfer mechanisms and implement appropriate safeguards to protect your data.

6. How Long We Keep Information

We keep your information only for as long as needed for the purposes described in this policy, or as required by law (for example, tax, accounting or anti-fraud rules), to resolve disputes or to enforce our agreements.

7. How We Protect Information

We use reasonable administrative, technical and physical measures to protect your information. However, no system is completely secure, and we cannot guarantee absolute security. If you believe your account or your interactions with us are no longer secure, please contact us immediately.

8. How to Exercise Your Rights

Depending on where you reside, applicable laws and regulations grant you various rights over your personal information, including but not limited to the right to know, the right to correct, the right to delete, the right to object and the right to restrict. To assert your applicable privacy rights, please contact us via the email address set forth in the "Contact" section below with the subject line "Privacy Rights Request". Once you have submitted your request, we will respond within the time frame required by applicable law. To protect your privacy and security, before fulfilling your request we are required to verify your identity against the personal information we already have on file. You can also exercise certain rights directly through the features provided in the app, such as account deletion and privacy settings.

9. Changes to this Policy

We may update this policy from time to time. The date at the top shows when it was last revised. If we make a change that materially affects your rights, we will provide additional notice. If you keep using the Service after an update takes effect, you accept the updated policy.

10. Contact

If you have any questions about this policy or our privacy practices, you can reach us in either of the following ways:

• By email: support@merrytapgames.com
• In the app: through the customer support button in the game's settings menu

11. Special Terms for Individuals in the EEA, UK, and Switzerland

11.1 Definitions.

• Personal information. References to "personal information" in this Privacy Policy should be understood to include a reference to "personal data" as defined in the GDPR. Under the GDPR, "personal data" means information about individuals from which they are either directly identified or can be identified. The personal information that we collect from and about you is described in greater detail in 'Personal information we collect'.
• Data Controller. A "data controller" is an entity that determines the purposes for which, and the manner in which any personal information is processed. Under this Policy, we are a data controller with respect to any personal information collected from individuals accessing or using the Service.

11.2 Legal Bases for Processing Your Personal Information.

11.3 International Transfer of Personal Information

We transfer your personal information subject to appropriate safeguards as permitted under the relevant data protection laws. The transfer of your personal information out of the Designated Countries is necessary for the performance of our contract with you, or the performance of a contract between us and another party that we entered into for your interest, or for important reasons of public interest. When transferring your personal information out of a Designated Country, we rely on legal transfer mechanisms such as Standard Contractual Clauses (available here). We may also rely on an adequacy decision of the relevant regulatory body confirming an adequate level of data protection in the jurisdiction of the party receiving the information, or derogations in specific situations.

11.4 Your Privacy Rights

Under the GDPR and the UK GDPR, you have the following rights:

• Right to Access. You have the right to obtain confirmation about whether we process your personal data and, if so, to access this data and information about how we process it.
• Right to Rectification. You have the right to have inaccurate personal data corrected or incomplete data completed.
• Right to Erasure ("Right to be Forgotten"). You have the right to request the deletion of your personal data, subject to applicable laws and regulations. You can make this request using any of the methods described in the "How to Exercise Your Rights" section.
• Right to Restrict Processing. You can request that we restrict the processing of your personal data in certain cases, for example, if you contest the accuracy of the data.
• Right to Data Portability. You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit this data to another controller.
• Right to Object. You have the right to object to the processing of your personal data in certain circumstances, particularly regarding processing for direct marketing purposes.
• Rights Related to Automated Decision-Making and Profiling. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects you.
• Right to Withdraw Consent. Where we process your data based on consent, you have the right to withdraw this consent at any time.
• Right to lodge a complaint. You have the right to lodge a complaint with your national data protection authority or equivalent regulatory body.
  • Details of EEA Supervisory Authorities here.
  • The Supervisory Authority in the UK is the Information Commissioner's Office (ICO), available here.
  • The Supervisory Authority in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC), available here.

11.5 Your Privacy Control

This sharing for personalized advertising is based exclusively on your consent, which we obtain and manage through a Consent Management Platform (CMP). You may withdraw or modify your consent at any time through the in-game privacy settings. If you withdraw consent, you will still see ads, but they will not be tailored to your interests.

12. Special Terms for Individuals in the United States

12.1 Your Privacy Rights

For individuals in the United States, depending on applicable law where you reside or are located, you may be able to assert certain rights identified below with respect to your personal information.

• Right to Know/Access.
• Right to Correct.
• Right to Delete.
• Right to Portability.
• Right Against Discrimination.
• Right to Opt-Out.
  • Right to Opt-Out of Automated Decision-making or Profiling.
  • Right to Opt-Out Sale.
  • Right to Opt-Out of Sharing for Targeted Advertising.
• Right to Appeal.
• Right to Obtain Third-Party List.

12.2 Opting out of Sharing/Targeted Advertising

Under the CCPA/CPRA, "sale" and "sharing" of personal information are defined broadly. While we do not sell your data in the traditional sense for money, our disclosure of certain personal data (such as advertising identifiers) to third-party advertising partners for cross-context behavioral advertising may be considered a "sale" or "sharing" under these laws. You can opt-out of the "sale" or "sharing" of your personal information for targeted advertising through the following methods:

• In our Apps: You can exercise your opt-out right at any time in the game's Settings -> Privacy Preference menu.
• On our Sites (via Browser): You can use an opt-out preference signal. The Global Privacy Control (GPC) signal is currently the only opt-out preference signal we can recognize. You can visit the Global Privacy Control official site to learn how to configure your device to send such signals.

12.3 Authorized Agents

Under some State Privacy Laws, you may enable an authorized agent to make a request on your behalf. However, we may need to verify your authorized agent's identity and authority to act on your behalf. We may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law.

12.4 California Notice

Because our Service is newly launched, references in this section to personal information collected, used, or disclosed in the "preceding 12 months" reflect the categories of personal information we intend to collect, use, and disclose going forward based on our planned business operations over the next 12 months.