Privacy Policy: twibol

This privacy policy applies to the TWIBOL app for mobile devices (Android and iOS), together with any related services operated by Konstantin Oborotov, doing business as Tres Novem Studio (collectively, the “Application”). Konstantin Oborotov is hereby referred to as the “Service Provider”. The Application is published as Tres Novem Studio on Google Play and as Konstantin Oborotov on the App Store.

Contact details of the Service Provider:
Konstantin Oborotov (Tres Novem Studio)
Bulevar maršala Tolbuhina 14
11070 Belgrade, Serbia
tres.novem.studio@gmail.com

Information Collection and Use

The Android version of the Application displays advertising provided by Google AdMob. The iOS version currently does not display ads and does not collect the information described in this policy; if ads are added to it, this policy will be updated before that release.

To serve and measure ads in the Android version, the following information may be collected from your device:

• Your device’s IP address, from which your approximate location may be inferred
• Device information such as model, operating system, and language
• Your advertising identifier (Google Advertising ID)
• Interactions with ads, such as impressions and taps
• Diagnostic and performance data related to ad delivery

This information is collected by Google AdMob for advertising, analytics, and fraud prevention purposes. The Application does not collect it independently, and does not ask for your name, email address, or any account information. Game progress and high scores are stored locally on your device.

If you decline consent in the privacy message shown at first launch, ads are still shown but are non-personalized or limited.

Cookies and Tracking Technologies

The Application or its third-party SDKs may use cookies, SDKs, pixels, and similar technologies to support functionality, analytics, or service delivery. Where required by applicable law, the Service Provider will obtain consent before using non-essential tracking technologies.

Location Information

The Application does not request GPS or precise location access. Advertising partners may infer your approximate location from your IP address to select relevant ads and determine which privacy rules apply.

Your Rights

The Service Provider does not store personal data from the Application. The only personal data it may hold is email correspondence you send. You may request access to, correction of, or deletion of that data, or ask any question about your rights, by contacting the Service Provider at tres.novem.studio@gmail.com.

You can change or withdraw your advertising consent at any time in Settings → Privacy settings inside the game. Data collected by Google AdMob is controlled by Google, and you can manage it as described in the Google Privacy Policy. You also have the right to lodge a complaint with your local data protection authority.

Your U.S. State Privacy Rights

Depending on your state of residence (for example, California, Virginia, Colorado, or Connecticut), you may have the right to know what personal information is collected, the right to delete personal information, the right to opt out of the sale or sharing of personal information and of targeted advertising, and the right to non-discrimination for exercising these rights. Sharing your advertising identifier with Google AdMob to show personalized ads may be considered “sharing” or “targeted advertising” under these laws.

You can opt out at any time in Settings → Privacy settings inside the game. For other requests, contact the Service Provider at tres.novem.studio@gmail.com.

Third Party Access

The Application shares data with Google AdMob for the purpose of serving and measuring advertising. This includes your advertising identifier, IP address, device information, ad interactions, and diagnostic data. This data is not anonymized. The Service Provider may share your information with third parties in the ways that are described in this privacy statement.

International Data Transfers

The Service Provider or its third-party service providers may transfer personal data to countries outside your country of residence, including outside the European Economic Area (EEA). Google may process data in the United States and other countries. Where applicable law requires safeguards for international transfers, appropriate mechanisms are used, such as:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Adequacy decisions or other legally recognized transfer mechanisms
• Your consent, where required and legally permitted

Data protection laws in other countries may differ from those in your jurisdiction. Where required by law, the Service Provider will apply appropriate safeguards and obtain any consent required for the transfer.

Please note that the Application utilizes third-party services that have their own Privacy Policy about handling data. Below are the links to the Privacy Policy of the third-party service providers used by the Application:

• Google Privacy Policy (Google AdMob)
• How Google uses information from sites or apps that use its services

The Service Provider may disclose User Provided and Automatically Collected Information:

• as required by law, such as to comply with a subpoena, or similar legal process;
• when they believe in good faith that disclosure is necessary to protect their rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
• with their trusted services providers who work on their behalf, do not have an independent use of the information the Service Provider discloses to them, and have agreed to adhere to the rules set forth in this privacy statement.

Opt-Out Rights

You can withdraw or change your advertising consent at any time in Settings → Privacy settings inside the game. You can stop all further collection by uninstalling the Application. Uninstalling does not delete information already received by Google AdMob; see the Data Deletion section below for how to reset or delete your advertising identifier.

To request deletion of your personal data, to withdraw consent, or to exercise any of your rights, contact the Service Provider at tres.novem.studio@gmail.com.

Data Retention Policy

The Service Provider does not operate servers and does not store personal data collected through the Application. Data collected by Google AdMob is retained by Google in accordance with the Google Privacy Policy.

Email correspondence you send to the Service Provider is kept only as long as needed to respond to you, and you may request its deletion at any time.

Data Deletion

The Application has no user accounts, so the Service Provider cannot identify data relating to you specifically. To stop collection, uninstall the Application. To reset the advertising identifier already associated with your device, use Settings → Google → Ads → Reset advertising ID or Delete advertising ID on Android.

Children

The Application is not directed at children under 13 years of age, or such higher age as required by applicable law (up to 16 in some EEA countries). The Service Provider does not knowingly solicit data from children or market the Application to them.

Where parental or guardian consent is required under applicable law, the Application is not intended for use without that consent. The Service Provider does not knowingly collect personally identifiable information from children in violation of applicable law. In the event the Service Provider discovers that a child has provided personal information, the Service Provider will promptly delete it. If you are a parent or guardian and you are aware that your child has provided the Service Provider with personal information, please contact the Service Provider (tres.novem.studio@gmail.com) so that they will be able to take the necessary actions.

Security

The Service Provider does not operate servers that store your data. Data sent from the Application to Google AdMob is encrypted in transit, and Google applies its own security measures to the data it receives.

Data Breach Notification

If a data breach occurs that affects your personal data, the Service Provider will notify you in accordance with applicable legal requirements, including, where required, providing information about the nature of the breach and the steps being taken to address it.

Changes

The Service Provider may update this Privacy Policy from time to time. The Service Provider will notify you of material changes by posting the updated Privacy Policy with an effective date. Where required by law, the Service Provider will seek your consent to material changes before they take effect.

Previous versions of this Privacy Policy will be maintained and made available upon request by contacting the Service Provider at tres.novem.studio@gmail.com.

Your Consent

In the European Economic Area, the United Kingdom, and Switzerland, the Android version of the Application asks for your consent through a privacy message shown at first launch. If you decline, ads are still shown but are non-personalized or limited. Where processing is based on consent, you provide that consent by affirmatively opting in to the relevant feature or action. You may withdraw consent at any time without affecting processing carried out before withdrawal. Processing based on other lawful bases is carried out as described above.

Contact Us

If you have any questions regarding privacy while using the Application, or have questions about the practices, please contact the Service Provider via email at tres.novem.studio@gmail.com.