Ace Games Studio
Privacy Policy

Ace Games Studio builds free-to-play mobile games for players around the world. This Privacy Policy explains what information we collect when you play our games, use our apps or visit our website, why we collect it, who we share it with, and the choices and rights you have over it.

We have written this policy to be readable rather than legalistic. If anything here is unclear, please email us at hr@acegames.live and we will explain it.

1. Who we are

Ace Games Studio ("Ace Games", "we", "us" or "our") is a mobile game development studio based in Pakistan. For the purposes of the EU General Data Protection Regulation (GDPR) and the UK GDPR, Ace Games Studio is the data controller for the personal data described in this policy.

If you are in the European Economic Area or the United Kingdom, we have appointed representatives you can contact directly. Their details are in Section 16.

1.1 Our Studio Partner network

Some Ace Games Studio games are published, on the App Store or Google Play, by an affiliated publishing company or an individual developer who operates under the Ace Games Studio brand and uses our shared backend, advertising and analytics systems (each, a "Studio Partner"). This is a normal part of how we run a portfolio of games, and it does not change how your data is handled.

This Privacy Policy applies to every game published under the Ace Games Studio brand, regardless of which entity is listed as the developer of record on the app store listing. Ace Games Studio is your single point of contact for any privacy question, request or complaint about any of these games — use the details in Section 15, and we will coordinate with the relevant Studio Partner on your behalf. See Section 6.6 for how data may be shared within this network.

2. What this policy covers

This policy applies to:

• Our games and apps — every mobile title published by Ace Games Studio or by a Studio Partner (Section 1.1) on the Apple App Store and Google Play.
• Our website — acegames.live, including the contact form.
• Business communications — email you send us about partnerships, publishing, careers or general enquiries.

2.1 Store privacy disclosures

Both app stores require us to publish a summary of our data practices alongside each game:

• Apple App Store — the "App Privacy" labels shown on each app's store listing.
• Google Play — the "Data safety" section shown on each app's store listing.

These summaries are maintained to be consistent with this policy. Where a store label and this policy appear to differ, the difference is an error on our part and we will correct it — please tell us at hr@acegames.live. Because the labels are per-app and this policy covers all of our games, a specific game may collect less than the full range described here, but never more.

3. Information we collect

3.1 In our games and apps

Our games do not require you to create an account, and we do not ask you for your name, email address, phone number or postal address in order to play.

Collected automatically to make the game work

• Device information — device model, operating system and version, screen resolution, language and country setting, and available memory. We use this to render the game correctly and diagnose crashes.
• Game progress data — level completion, in-game settings and preferences. Where this is stored only on your device, we never receive it.
• Crash and diagnostic data — technical logs generated when the app closes unexpectedly.
• IP address — processed transiently by our service providers to route network requests and to approximate your country for regional content and legal compliance. We do not use IP addresses to determine your precise location.

Collected with your consent, for analytics

• Gameplay events — which levels you reach, where you stop playing, which features you use, session length and frequency.
• Performance data — load times, frame rate issues and error rates.

We use this to understand which parts of a game are enjoyable and which are frustrating, so we can improve them.

Collected with your consent, for advertising

• Mobile Advertising Identifier — your Google Advertising ID (Android) or Identifier for Advertisers (iOS). These are resettable identifiers that you control from your device settings.
• Ad interaction data — which ads were shown to you, whether you viewed or clicked them, and whether an ad led to an app install.
• Coarse device and connection data — user agent, connection type, timestamp and approximate region, used by ad networks to select and measure advertising.

In-app purchases

Most of our games offer optional in-app purchases. When you make one:

• Apple or Google processes the entire transaction. We never receive or store your payment card number, bank details, billing address or app store account credentials.
• We receive a purchase receipt or transaction token from the app store, which we use to verify the purchase is genuine and to unlock the content you bought.
• We receive aggregated sales reporting from the app stores — such as total revenue by country and product — which does not identify individual purchasers.
• Where a game stores your purchase entitlement so it can be restored, this is linked to your app store account by Apple or Google, not by us.

3.2 On our website

Our website is a straightforward informational site. We do not run advertising on it.

• Contact form submissions — when you use the contact form, we collect the name, email address, subject and message you provide, along with the date and time of submission. We use this solely to read and respond to your enquiry.
• Server logs — our hosting provider records standard web server logs, including IP address, browser user agent, requested page and timestamp, for security and troubleshooting purposes.

We do not use advertising cookies, tracking pixels or third-party analytics on our website. See Section 13.

3.3 What we never collect

Across our games, apps and website, we do not knowingly collect:

• Precise GPS location
• Contacts, photos, microphone or camera data
• Payment card numbers or bank details — all in-app purchases are processed entirely by Apple or Google, and we never see your payment information
• Government identification numbers
• Special category data such as health, biometric, religious or political information

4. Why we use your information and our legal basis

Under the GDPR and UK GDPR we must have a lawful basis for each purpose. The table below sets these out.

Where we rely on legitimate interests, we have assessed that our interests do not override your rights and freedoms. You may object to this processing at any time — see Section 9.

5. Consent and how to change it

Depending on your device and where you live, you may see one or two separate permission requests. They serve different purposes, and where both apply to you, we only show personalised advertising if you say yes to both.

5.1 On iOS — App Tracking Transparency

On iOS 14.5 and later, Apple requires us to ask for your permission before accessing your device's advertising identifier (IDFA) for tracking across apps. This request appears worldwide, not only in Europe. If you select "Ask App Not to Track", we do not collect your IDFA and you will only see non-personalised advertising.

You can change this at any time in Settings → Privacy & Security → Tracking, either for a single app or for all apps at once.

5.2 In the EEA, UK and Switzerland — GDPR consent

The first time you open one of our games in a region that requires it, you will be shown a consent request asking whether you agree to data collection for analytics and for personalised advertising. These are presented as separate choices, and refusing is as easy as accepting.

On iOS, this is in addition to the Apple prompt: if you decline either one, personalised advertising is switched off.

5.3 On Android

You can delete or reset your advertising ID and opt out of ad personalisation in Settings → Google → Ads. Where a Families neutral age screen applies, the advertising ID is not collected at all for users below the applicable age.

5.4 Changing your mind

You can say no, and the game will still work in full. If you decline, you will continue to see advertising, but it will be non-personalised — chosen based on the app you are using rather than any profile about you.

• In our games — open the Settings screen and select the privacy or consent option to review and change your choices at any time.
• On the device — use the iOS and Android settings described above.

Withdrawing consent does not affect the lawfulness of processing carried out before you withdrew it.

6. Who we share data with

We do not sell your personal data. We share data only in the limited circumstances below.

6.1 Advertising partners

Our games are free because they are supported by advertising. When you consent to personalised advertising, these networks receive data through their own SDKs integrated into our games. Each acts as an independent controller for the data it collects, under its own privacy policy:

The "shown to children" column reflects our compliance with Google Play's Families Self-Certified Ads SDK Program. Only advertising networks that have self-certified under that programme are permitted to serve advertising to users who indicate they are under the applicable age. See Section 11 for how we separate these audiences.

This list reflects the partners integrated in our games as at the effective date of this policy. If we add or remove a partner, we will update this section.

6.2 Analytics and infrastructure providers

These providers process data on our instructions, as processors under Art. 28 GDPR:

6.3 App stores

Apple and Google distribute our games and process all purchases. They collect data under their own policies, and we receive only aggregated, anonymised reporting from them — such as total download counts and country breakdowns. We never receive your payment details.

6.4 Legal and safety disclosures

We may disclose data where we are legally required to do so, or where it is necessary to establish, exercise or defend legal claims, to enforce our Terms of Service, or to protect the rights, safety or property of Ace Games Studio, our players or the public. Where the law permits, we will notify you of such a request.

6.5 Business transfers

If Ace Games Studio is involved in a merger, acquisition or sale of assets, personal data may be transferred as part of that transaction. We will notify you before your data becomes subject to a different privacy policy, and you will retain your rights under this one until then.

6.6 Sharing within the Ace Games Studio network

Where a game is published by a Studio Partner (Section 1.1) rather than by Ace Games Studio directly, we may share limited operational data with that Studio Partner — such as aggregated install and revenue figures, crash and diagnostic reports, and the content of support or contact enquiries — so that we can operate, support and improve the game together. We do not share this data with a Studio Partner for that partner's own independent marketing purposes, and every Studio Partner is bound by the same data-handling standards described in this policy.

7. International data transfers

Ace Games Studio is based in Pakistan, and our service providers operate globally. This means your personal data may be transferred to and processed in countries outside the EEA and the UK, including Pakistan and the United States.

Pakistan has not received an adequacy decision from the European Commission or the UK government. Where we transfer personal data of individuals in the EEA or the UK, we rely on the following safeguards:

• Standard Contractual Clauses — the European Commission's SCCs (Decision 2021/914) and, for UK transfers, the UK International Data Transfer Addendum, incorporated into our agreements with service providers.
• Supplementary measures — including encryption in transit, access controls and data minimisation.
• Your explicit consent — where applicable, for optional analytics and advertising processing.

You may request a copy of the relevant safeguards by emailing hr@acegames.live.

8. How long we keep data

We keep personal data only as long as necessary for the purpose it was collected for.

9. Your privacy rights

If you are in the EEA, the UK or another region with comparable law, you have the following rights over your personal data:

9.1 How to exercise your rights

Email hr@acegames.live with the subject line "Privacy Request". Please tell us which right you wish to exercise and, where relevant, your device's advertising ID so we can locate the associated data. We may ask for information to verify your identity before acting.

We will respond within one month. If your request is complex, we may extend this by up to two further months and will tell you if we do. Exercising your rights is free of charge, unless a request is manifestly unfounded or excessive.

9.2 Account deletion

Our games do not require or offer an Ace Games Studio account, so there is no account to delete. If you want to remove the data associated with your device, you can reset your advertising identifier in your device settings and uninstall the game. If you have contacted us by email or through our website, email hr@acegames.live and we will delete that correspondence on request.

If we introduce accounts in a future title, we will provide an in-app account deletion option, as required by App Store Review Guideline 5.1.1(v) and Google Play's data deletion policy.

9.3 Complaints

If you believe we have handled your data improperly, we would like the chance to put it right — please contact us first. You also have the right to complain to a supervisory authority:

• In the EEA — the data protection authority in your country of residence, work or the place of the alleged infringement. A list is available at edpb.europa.eu.
• In the UK — the Information Commissioner's Office, ico.org.uk, helpline 0303 123 1113.

10. US state privacy rights

If you are a resident of California, or of another US state with a comprehensive privacy law (including Virginia, Colorado, Connecticut, Utah and Texas), you have additional rights.

10.1 California (CCPA / CPRA)

In the twelve months before the effective date of this policy, we collected the following categories of personal information as defined by the CCPA:

"Sale" and "sharing". We do not sell personal information for money. However, under the CPRA's broad definitions, allowing advertising partners to collect identifiers for personalised advertising may qualify as "sharing" for cross-context behavioural advertising. You have the right to opt out.

How to opt out: decline the consent request in the game, turn off App Tracking Transparency on iOS, opt out of ad personalisation on Android, or email hr@acegames.live with the subject "Do Not Sell or Share My Personal Information". We also honour Global Privacy Control signals sent by your browser on our website.

You additionally have the right to know, to delete, to correct, to limit the use of sensitive personal information (we collect none), and not to be discriminated against for exercising any of these rights. We will never degrade your gameplay experience because you exercised a privacy right.

You may use an authorised agent to submit a request on your behalf, subject to verification.

10.2 Other US states

Residents of other states with comprehensive privacy laws have rights to access, correct, delete and port their personal data, and to opt out of targeted advertising and profiling. Use the same contact route above. If we decline a request, you may appeal by replying to our decision, and we will respond within 45 days.

11. Children's privacy

Several of our games are declared as mixed audience — they are enjoyed by both children and adults. This means we treat children's data differently from adults' data, and we want to explain exactly how.

11.1 Age requirements

• Generally — the minimum age to use our Services is 13.
• In the EEA — where processing relies on consent, the minimum age is 16, unless the member state where you live has set a lower age (some allow 13, 14 or 15). Below that age, consent must be given or authorised by a parent or guardian.
• In the UK — the minimum age for consent-based processing is 13.

Throughout this section, "child" means a user below the applicable age in their country.

11.2 Our neutral age screen

Where a game is available to a mixed audience, we present a neutral age screen the first time you open it. This screen asks for your age or date of birth without encouraging you to enter a particular answer, and without implying that a certain answer unlocks additional content.

Your answer is stored on your device and determines how the rest of the game treats your data. We do not transmit the age you enter to advertising partners as a personal detail; we transmit only a signal indicating whether child-directed treatment applies.

11.3 What changes for users identified as children

AppLovin, Meta Audience Network, Mintegral and Pangle are never used to serve advertising to children. These networks are not participants in Google Play's Families Self-Certified Ads SDK Program, and we restrict them to users who have passed the age screen as adults.

Mediation. Where we use a mediation platform to allocate advertising across these networks, we pass the child-directed treatment signal through the mediation layer, so that requests for users below the applicable age are only ever filled by the self-certified networks named above.

11.4 Additional safeguards

• We apply the target audience declarations, content ratings and ad content restrictions required by Google Play's Families Policy and Apple's App Store Review Guidelines to every title we publish.
• Advertising shown to children is restricted to age-appropriate content ratings, and we do not permit ads that link to app stores for age-inappropriate apps, or that use manipulative or disruptive formats.
• We do not use children's data for behavioural advertising, remarketing, or the creation of audience segments.
• We do not knowingly enable children to make in-app purchases without parental authorisation. See our Terms of Service for parental control guidance.

11.5 How the two app stores differ

Apple and Google apply different frameworks to children's apps. We comply with both, and the stricter rule always wins where they overlap.

Apple's App Tracking Transparency framework applies to all of our iOS games regardless of age rating. We do not request tracking permission from users who have indicated they are below the applicable age, and where permission is not granted, no IDFA is collected and only non-personalised advertising is shown.

11.6 Parents and guardians

If you believe your child has provided us with personal information, or you want to review or delete information relating to your child, please email hr@acegames.live. We will verify the request and act on it promptly — normally within 30 days. You may also refuse to permit any further collection of your child's information, and you may do this without us discontinuing your child's use of the game.

Our practices are designed to comply with the US Children's Online Privacy Protection Act (COPPA), the Google Play Families Policy, the UK Age Appropriate Design Code, and Article 8 of the GDPR.

12. How we protect data

We apply technical and organisational measures appropriate to the risk, including:

• Encryption of data in transit using TLS
• Access controls limiting personal data to staff who need it for their role
• Storing contact form submissions outside the publicly accessible area of our web server
• Regular review of the SDKs and third-party code included in our games
• Collecting the minimum data needed for each purpose

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If a personal data breach occurs that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours and inform affected individuals where the law requires it.

13. Cookies on our website

Our website uses only strictly necessary cookies — a session cookie and a security token (CSRF) that allow the contact form to work and protect it from abuse. These do not track you, are not used for advertising, and cannot be switched off without breaking the site. Under the ePrivacy Directive and PECR, strictly necessary cookies do not require consent.

We do not use advertising cookies, tracking pixels, social media plugins or third-party analytics on our website. If this changes, we will update this policy and implement a consent banner before setting any non-essential cookie.

14. Changes to this policy

We may update this policy to reflect changes in our practices, our partners or the law. When we do, we will revise the "Last updated" date at the top of this page.

If we make a material change — for example, collecting a new category of data, adding a new purpose, or changing the legal basis for processing — we will provide prominent notice before the change takes effect, through an in-game notice or a notice on this website, and we will obtain fresh consent where the law requires it.

Previous versions of this policy are available on request.

15. Contact us

For any question, request or concern about this policy or your data:

16. EU and UK representatives

Under Article 27 of the GDPR and the UK GDPR, we have appointed the following representatives. If you are in the EEA or the UK, you may contact them on any matter relating to the processing of your personal data, in addition to or instead of contacting us directly.