PRIVACY POLICY
LAST UPDATED: AUGUST 27, 2025
This Privacy Policy explains how
ZeptoLab UK Limited ("ZeptoLab"
or "we") collects, uses,
shares and otherwise processes your personal information when you play any of
our games including, without limitation, Bullet Echo, Cut the Rope,
Overcrowded: Tycoon, Robotics!, Downhill Smash, Evo Pop (“Games”), or use our websites (“Websites”)
and related services (collectively, “Services”).
This Privacy Policy explains your
rights over your personal information, like your name and contact details. It
tells you how we collect, store, use, and share your information. Depending on
where you live, you might have different options for controlling how your
information is handled, and this Privacy Policy will explain those choices.
Our Services contain links to
other apps and websites that may also collect and use information
about you in accordance with their own separate rules. Please read
the notices and information on their apps or websites to
find out more about how and why they do this.
We may update this Privacy Policy from
time to time. If we make material changes, we will provide a prominent notice
in the Games or on the Websites before the changes take effect. Where required
by law, we will seek your consent for such changes. This Privacy Policy states
its effective date at the top.
1.
INFORMATION WE COLLECT
We aim to minimise how much Personal
Information we collect from users when they play the Games or visit the Websites.
For the purposes of this Privacy Policy, Personal Information refers to
data that relates to you as an identified or identifiable natural person. It may
include, for example, your name, your e-mail address or your gender. Anonymous
or de-identified information, which we are not able to identify you, does not
qualify as Personal Information.
We collect Personal Information that
you provide to us. We also collect a
variety of information indirectly, through your use of our Games and Websites.
This information may include, but is not limited to, anonymised browser and
device information (both software and hardware), data collected through
automated electronic interactions, application usage data, demographic
information, geographic, geo-location information, statistical and aggregated
information. Statistical or aggregated information does not directly identify a
specific person, but it may be derived from Personal Information.
Personal Information we collect when
you play the Games or use our Services includes the following:
|
Account Data |
When setting up
a game profile or an account within the Game, you may be asked to provide Personal
Information including, but not limited to, your in-Game name, in-Game
password and email address. |
|
Advertising
IDs, Location Information, and Device Information |
We use these
only where you have given your consent in the EEA, UK and Switzerland.
Consent is collected and managed via Google’s Consent Management Platform,
certified under the IAB Transparency and Consent Framework. You can change
your choices at any time in the in-game privacy settings or via Cookie
Settings on our Websites. Where you do not consent, we will serve only
contextual, non-personalised ads. For more information about Analytics and
Advertising, please see Section 4. |
|
Content Data |
We may obtain your Personal
Information when you register for and use the Games features, such as chats,
or when you provide feedback about our Games. These data include Information
sent through the “game-chat” functionality in the Games or information that
you post on the pages of social media operated by ZeptoLab, and on the
Websites. |
|
Name and email
address, Location Information, Device Information |
You have the
option to contact our customer support team directly from some of our Games,
via email or by filling out a contact form on the Websites. When you do, we
will collect and use this information to manage and respond to your requests. |
|
Name, email
address, and phone number |
If you apply
for a job with ZeptoLab through www.zeptolab.com, we will collect and use this
information to process your application. We may also use this information to
contact you in connection with your application. |
In addition to the specific purposes
mentioned above, we use Personal Information for the following purposes, as
allowed by law:
Improving Your Experience. We use it to improve your experience by keeping our Services running
smoothly, by making ongoing improvements, and by providing customer support and
fixing technical issues
Ensuring Safety. We use it to ensure safety, which includes detecting and preventing
security threats or illegal activity, fixing bugs, controlling access to
features, and protecting the safety and security of our users and of the platform
itself.
Legal Compliance. We use Personal
Information to comply with legal requirements and to
ensure adherence to our internal policies and Terms of Use.
You don’t always have to provide your
Personal Information, but without it, some features or Services might not be
available to you.
2.
HOW YOUR PERSONAL INFORMATION IS
COLLECTED
Communications. When you communicate with us via
Customer Support, either via our Websites or Games, we collect the contact
information you provide us with. If you contact us through the Games, we also
collect Device Information and Cookies to respond to your messages. If the
communication relates to an error or problem you are having with the Games, we
will also collect usage data for diagnosis and improvement.
Information you generate when using
our Websites or Games. Each time you access and use our Websites and Games, we collect
Device Information, Cookies and usage information. We collect content
information where you upload it to the Game or interact with the content
available on the Game, for example, by interacting on message boards or
contacting Customer Support. We collect Device Information, Cookies, and usage
information by using cookies, analytics tools and other similar technologies.
Please see our Cookie notice for further details.
Information we collect through
monitoring the use of our Games and Websites. Each time you access and use our
Games and Websites, we collect information about that access and use, including
Device Information, content information, Cookies, and usage information.
Location Information. We collect your Location Information
on an ongoing basis while you have the Games installed on your device.
Additional information. We otherwise collect through our
Games and Websites, where we have your consent to do so.
Direct Marketing. We collect and record Direct
Marketing information when we add you to our marketing database or you request
to change your direct marketing preferences.
Public Information. Our Services may include message
boards, forums, and chat areas where users can share ideas and communicate with
one another. Please note that any messages posted in these areas become
publicly accessible online; you do so at your own risk and bear sole
responsibility for any information you disclose. Your nickname and game
statistics may also appear in game replays and other videos created and shared
online by ZeptoLab or other players. We
advise against including any personally identifiable information in your
nickname. To update your nickname, please contact Customer Support.
Financial Information. When you make in-app purchases in the
Games, we do not collect or have any access to your name and billing
information. This information is collected and stored by platforms (e.g.
Apple's App Store or Android's Google Play) or platforms' payment processors.
Offline Games. ZeptoLab offers a limited selection
of Games with offline-only functionality, which may be made available through
third parties. Offline Games do not collect or process personal information.
3.
CHILDREN'S PERSONAL INFORMATION
Our Services are designed for a
general audience and are not specifically aimed at children.
We do not knowingly collect Personal
Information from any child, or process such information, without parental
consent. For the purpose of this Privacy Policy, a child means any individual
who is under the age of 18 (or the minimum legal age to consent to the
collection and processing of Personal Information where this is different under
applicable law).
If you are a parent or guardian and
believe we have collected your child’s information in violation of applicable
law, please contact us at privacy@zeptolab.com. We will delete this information in
accordance with applicable law.
4.
SHARING YOUR PERSONAL INFORMATION
For other companies providing a
service on our behalf. We may share your information, including personal details, with
third-party companies such as agents, contractors, or service providers ("Service Providers"). These
companies are used to perform specific tasks for us, and they are only
permitted to use your information to fulfil those tasks. They are not allowed
to use it for any other purposes, including selling your Personal Information.
We ensure that any company we work with is capable of safeguarding your
information appropriately. A current list of our Service Providers is available
here.
We update these lists periodically.
For Legal Reasons. We may share your Personal
Information, as allowed or required by law, where:
●
We need to follow a court order or legal process related to the
Games, Websites or Services.
●
If law enforcement, regulators, or public authorities (like
schools or child services) ask for it.
●
If we think sharing the information could help stop a crime.
●
When the law requires us to share it.
For Business Transfers and Mergers. We may share your Personal
Information with third parties if we sell, transfer, or merge parts of our
business or assets. Likewise, if we acquire or merge with another business,
your Personal Information may be included in that process. In such cases, the
new owners may use your data in the same way as set out in this Privacy Policy.
For Analytics. As an online business, understanding
how you interact with our Websites and Games is essential. We, along with some
of our Service Providers, collect your Location Information, Device
Information, usage information and Advertising IDs to deliver our Game and
Website services, measure and analyse performance, improve functionality, and
continuously update and develop our Games and Websites. For example, we use
this information to assess the difficulty levels of Games, fix bugs or errors,
evaluate the demographics of our users, and determine whether support is needed
for new device types. Additionally, if you have connected your Game account to
your social media account, we will use the information described in Section 1
of this Privacy Policy to conduct further analytics.
For Advertising. We may share Personal Information collected
from or about you with third-party advertising and/or advertising measurement
companies (“Ad Partners”) in order
to select relevant advertisements for you, or to measure and improve the
effectiveness of our advertising. In accordance with applicable laws, we offer
our users choices regarding whether their data is disclosed for this purpose.
The data shared for these purposes includes Advertising ID, Location
Information and Device Information. Depending on where you live, additional
rights may apply. For information about specific regions, please visit Section
11 of this Privacy Policy. Since some of our Ad Partners technologies manage
the collection and usage of Personal Information from your device themselves,
we recommend reviewing their individual privacy policies. You can find a list
of our Ad Partners here.
Third-Party
Websites and/or Apps. We may run ads to promote our Games on third-party websites
and/or apps. When we run our own ads on third-party websites and/or apps,
Service Providers help us optimise and measure the performance of our ads and
use their own tracking technologies to track Game installs and clicks and/or
impressions of our ads. In some cases, we will share your hashed or anonymised
Advertising ID with our Ad Partners so that the Ad Partner can help us market
and promote our Games. In these cases, Ad Partners perform as ZeptoLab's
Service Providers, and we contractually require such Ad Partners to only use
your Personal Information on our behalf. If you wish to opt-out of your Personal
Information being shared with Ad Partners in this way, please contact us
at privacy@zeptolab.com.
5.
COOKIES AND SIMILAR TRACKING
TECHNOLOGIES
Among other standard internet
technologies, we use cookies to improve our Websites and Games. A cookie is a
small text file placed on your computer or device when you visit our Websites
or access the Games, and it helps us enhance functionality and performance by
remembering your actions and preferences so that, for example, you do not need
to re-enter login details each time you visit.
Types of
Cookies:
● Session cookies:
These are temporary and are deleted when you close your browser or app.
●
Persistent cookies: These remain on your device for a set
period and are used to remember your preferences for future visits.
●
Third-Party cookies: Set by external domains or services, such as
advertisers, that track user behaviour across multiple sites or apps.
When you visit our Websites or access
our Games from within the European Economic Area (EEA), a cookie banner will
appear asking for your consent. You can manage your cookie preferences by
clicking on "Manage Cookie Preferences" in the banner. Once you make
your selection, we will store your choices in a cookie on your device to
remember your preferences for future visits. To learn more, please check out
our Cookie notice.
6.
HOW TO DELETE COOKIES AND OPT OUT OF
TARGETED ADVERTISING AND ANALYTICS
If you do not wish to receive targeted advertising on your mobile device, you can adjust your device settings to limit tracking across applications. On Android devices, this can be done by enabling the “Opt out of Ads Personalisation” setting. On iOS devices, tracking permissions are managed in the Privacy and Security settings, where you may disable the option “Allow Apps to Request to Track” or adjust permissions for individual applications. In addition, some Ad Partners may offer their own opt-out mechanisms, which are described in our Ad Partner list. Please note that if you opt out of targeted advertising, you will still receive contextual ads that are not based on tracking.
You can disable cookies in your
browser settings, but some parts of the Services may then not function
properly. You can also adjust your browser settings to limit certain tracking
by means of cookies.
7.
WHERE YOUR PERSONAL INFORMATION IS
PROCESSED
We process Personal Information in the
United Kingdom, the European Economic Area, the United States and in other
countries where our service providers are located. Whenever we transfer Personal
Information outside the United Kingdom or the European Economic Area, we ensure
that it remains protected to a standard consistent with applicable law.
Transfers are made either to countries that have been formally recognised as
providing adequate protection or, where this is not the case, under contractual
safeguards approved for use in the United Kingdom and the European Union. These
measures are designed to ensure that your Personal Information continues to
benefit from a level of protection essentially equivalent to that required in
the United Kingdom and the European Economic Area.
8.
HOW LONG IS YOUR PERSONAL INFORMATION
STORED
It will depend on the purpose for
which we originally collected it. We will not retain Personal Information for
longer than is necessary for our business or for legal requirements. In some
circumstances, you can ask us to delete your data: see Section 11 of this
Privacy Policy for further information.
Once we no longer have a legal right
to hold your personal data, we will delete it or, in some circumstances, we
will anonymise your Personal Information (so that it can no longer be
associated with you) for research or statistical purposes, in which case we may
use this information indefinitely without further notice to you. If you do not
use the Services for a period of 90 days, then we may delete your personal
data.
9.
SECURITY OF YOUR PERSONAL INFORMATION
We implement appropriate technical and
organisational measures to protect personal data, including encryption in
transit, access controls based on least privilege, network security monitoring
and vendor due diligence. Where we store data at rest, we apply encryption. We
regularly test and review our security measures. No system is perfectly secure,
but we take measures consistent with legal requirements and industry practice.
10.
FEATURES AND TOOLS
Push
notifications. After downloading a Game, you will be
asked to accept or refuse push notifications. If you accept push notifications,
we will collect and use push notification tokens to send you Game-specific
notifications on your mobile Device. You may disable push notifications at any
time by going to your Device settings.
Social media.
The Websites and
Games may include integrated social media features and tools, such as the
Facebook "Like" and the YouTube "Share This" buttons. These
features may collect information on your IP address, which website you are
visiting, and may set a cookie to enable the feature to function properly.
Social media features and tools are hosted by third parties, and your
interactions with these integrated social media features and tools are governed
by the privacy policy of the company providing it.
11.
THIRD PARTIES AND THEIR PRIVACY
POLICIES
Throughout the Services, you may see
links to third-party websites or applications. We are not responsible for the
privacy practices of these third-party sites, and when accessing their sites,
we encourage you to read their privacy policies.
12.
YOUR RIGHTS
We will only use your Personal
Information when we have a lawful basis to do so. Our lawful basis for each
purpose for which we use your Personal Information is specified below. Most
commonly, we will use your Personal Information in the following circumstances:
Consent. Where you have freely consented before
the processing in a specific, informed and unambiguous indication of what you
want. You can withdraw your consent at any time by contacting us at privacy@zeptolab.com.
Performance of a
contract. Where
we need to process your Personal Information to perform a contract with you
(i.e., our Terms and Conditions) or where you ask us to take steps before we
enter into a contract with you. Where we rely on the performance of a contract
and you do not provide the necessary information, we will be unable to perform your
contract.
Legitimate
interests. Where
it is necessary for our legitimate interests (or those of a third party) and
your interests and fundamental rights do not override those interests. We have
a legitimate interest in processing your Personal Information, for example, to
support product and service development, enhance security, prevent fraud,
manage corporate operations, comply with laws, and conduct non-targeted
marketing.
Legal obligation.
Where we need to
use your Personal Information to comply with a legal or regulatory obligation.
Where we rely on legal obligation and you do not provide the necessary
information, we may be unable to fulfil a right you have or comply with our
obligations to you, or we may need to take additional steps, such as informing
law enforcement or a public authority or applying for a court order.
Delivery and
improvement of our Games
|
Purpose or activity |
Type of information |
Lawful basis for processing |
|
To permit you
to install the Games and register you as a new Game user |
Identity Contact Device |
Legitimate
interests (delivering our Games to you) |
|
To take steps
towards providing you with access to the Games at your request, to process
and fulfil in-Game purchases and deliver Services to you, including sending
you communications |
Identity Contact Transaction Device Location |
Performance of
a contract |
Account
management and profiling
|
Purpose or activity |
Type of information |
Lawful basis for processing |
|
Combining the
information we collect about you into a single customer account profile |
Contact Direct
marketing |
Legitimate
Interests (to publicise and grow our business) |
Direct marketing
|
Purpose or activity |
Type of information |
Lawful basis for processing |
|
To send you
direct marketing communications, including via push notification |
Contact Device Direct
Marketing |
Consent Unless we can
rely on the soft opt-in and you have not opted out, in which case we rely on
Legitimate Interest (to publicise and grow our business) |
Troubleshooting,
improvement and security
|
Purpose or activity |
Type of information |
Lawful basis for processing |
|
To administer,
monitor and improve our business, Services and the Games including
troubleshooting, data analysis and system testing |
Identity Contact Device |
Legitimate
interests (for running our business, provision of administration and IT
services, network security, maintaining the security of our Games, providing
a secure service to users and preventing fraudulent and other misuse of our
Games) |
|
Applying
security measures to our processing of your personal data, including
processing in connection with the Games |
All Personal
Information under this Privacy Policy |
Legal
obligation (applying appropriate technical and organisational measures under
Article 32 of the UK GDPR and the EU GDPR) |
|
Otherwise
monitoring use of the Games and deploying appropriate security measures |
Contact Security Transaction |
Legitimate
interests (running our business, provision of administration and IT services,
network security, maintaining the security of our Games and services,
providing a secure service to users and preventing fraudulent and other
misuse of our Games) |
Rights and
obligations
|
Purpose or activity |
Type of information |
Lawful basis for processing |
|
To comply with
our other legal obligations, including compliance with tax legislation,
judicial, law enforcement and government authorities' requests |
All Personal
Information under this Privacy Policy |
Legal
obligation |
Cookies and
personalisation
|
Purpose or activity |
Type of information |
Lawful basis for processing |
|
To deploy and
process data collected via Cookies that are strictly necessary, as set out in
the Cookie notice. |
Cookies |
Legitimate
interests (delivering and securing the Games and our Services) |
|
To deploy and
process data collected via Cookies that are not strictly necessary, as set
out in the Cookie notice |
Cookies |
Consent |
|
To deliver
(personalised) advertisements to you |
Personalisation |
Consent |
Other
communications
|
Purpose or activity |
Type of information |
Lawful basis for processing |
|
To notify you
of changes to the Games, your purchases and our terms and conditions for
ongoing contracts |
Contact |
For ongoing or
prospective contracts, Performance of a contract Otherwise,
Legitimate interests (in servicing our users and prospective users) |
|
To notify you
of updates to this Privacy Policy |
Contact Transaction |
Legal
obligation (to inform you of our processing under Articles 13 and 14 of the
UK GDPR and the EU GDPR) |
|
To respond to
your requests to exercise your rights under this notice |
As relevant to
your request |
Legal
obligation (complying with data subject requests under Chapter 3 of the UK
GDPR and the EU GDPR) |
|
To enable you
to participate in a prize draw or competition (where applicable, please also
see the separate prize or competition privacy notice) |
Contact Direct
Marketing Competition |
Performance of
a contract (once you have entered) |
|
To ask you to
complete a survey and process your response (where applicable, please also
see the separate privacy notice) |
Contact |
Legitimate
interests (to analyse how users use our products or Services and to develop
them and grow our business) Unless you have
previously opted out, where we will rely on Consent |
|
To otherwise
respond to your enquiries, fulfil your requests and to contact you where necessary |
As relevant to
your enquiry or request |
Legitimate
interests (service our users and prospective users) |
For users in
the EEA, the United Kingdom, Switzerland, and Brazil. You have the following rights
regarding your personal data:
●
Access: Request a copy of the data we hold about you.
●
Correction: Ask us to fix any incomplete or inaccurate data.
●
Deletion: Request that we delete your data if there’s no reason
for us to keep it, or if we've processed it unlawfully. We may need to retain
some data for legal reasons, and we’ll inform you if that’s the case.
●
Objection: Object to our processing of your data if it's based on
our legitimate interests or used for direct marketing. In some cases, we may
refuse if we can prove compelling reasons to continue.
●
Restriction: Ask us to suspend the processing of your data in
certain cases, like if you need us to verify its accuracy or if you need it for
legal claims.
●
Data Portability: Request that we transfer your data to you or a
third party in a machine-readable format. This applies to data we process
automatically, based on your consent or a contract.
●
Withdraw Consent: Withdraw your consent at any time. This won’t
affect the legality of processing before the withdrawal, but it may impact
services we can provide.
●
Complaint: If you're unhappy with how we handle your data, contact
us first, but you also have the right to file a complaint with your local data
protection authority.
You can exercise any of these rights
by contacting us at privacy@zeptolab.com.
For users in
specific U.S. States. If you are a resident of California,
Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New
Jersey, Oregon, Texas, Utah, or Virginia, you have specific rights, as
applicable, regarding the Personal Information we hold about you.
Subject to exceptions, you may have
some or all of the following rights under applicable law:
●
The right to confirm whether we are processing your Personal
Information, and in some regions, confirm the categories of data we have
processed.
●
The right to know what Personal Information we have collected
about you, including the categories of Personal Information, the categories of
sources from which Personal Information was collected, the business or
commercial purposes for collecting, selling, or sharing Personal Information,
the categories of Personal Information we sold, shared, or disclosed for a
business purpose, and the categories of third parties to whom we disclosed Personal
Information.
●
The right to access the specific pieces of Personal Information we
have about you or obtain a copy in a portable and readily usable format.
●
The right to request deletion of your Personal Information.
●
The right to correct inaccuracies in your Personal Information.
●
The right to opt out of the sale of your Personal Information.
●
The right to not be discriminated against for exercising any of
your rights.
●
You may appoint an authorised agent to submit requests on your
behalf. Except for opt-out requests, we will require written proof of the
agent’s authorisation to do so and may verify your identity directly.
To make a verifiable consumer request,
please contact us via email at privacy@zeptolab.com. We may ask for proof of identity to
verify your request.
13.
ZEPTOLAB'S CONTACT INFORMATION
If you have any questions regarding
this Privacy Policy, our privacy practices, or our use of your Personal
Information, you may contact us at:
ZeptoLab UK Limited
27 Old Gloucester St, Holborn, London WC1N 3AX