PRIVACY POLICY
updated: 12 November 2026
This Privacy Policy explains how Naxeex Ltd. processes user personal data.
We attach great importance to the protection of your personal data, so take a moment to find out more about our Privacy Policy and contact us if you have any questions.
1. Terms and Definitions
1.1. For the purposes hereof, the following terms and definitions are used:
We (Naxeex) - Naxeex Ltd.
“You” or “User” means any individual who uses the Services.
Services - video games developed by Naxeex Ltd., as well as websites with the domain name “naxeex.com”.
2. Scope
2.1. This Policy applies to how Naxeex collects, stores, uses, shares and otherwise processes personal data in connection with the use of the Services.
2.2. The Services may contain links to third-party websites or applications. This Policy does not apply to those websites or applications. Please review their privacy policies to understand how they process your personal data.
2.3. Please read this Policy before using the Services. Accepting this Policy does not constitute consent to processing activities for which separate consent is required under applicable law. Your rights and choices regarding the processing of your personal data are described in section 9.
3. Data Controller
3.1. Naxeex Ltd. is the data controller, meaning that it determines the purposes and means of processing your personal data.
Our company details and contact information are provided below:
Company name: Naxeex Ltd.
Company registration number: HE407888
Address: 61, Spyrou Kyprianou, Mesa Geitonia, 4003, Limassol, Cyprus
Contact email (including privacy enquiries): naxeex.studio@gmail.com
4. Personal Data Collection
4.1. Personal data means any information relating to an identified or identifiable individual.
4.2. We collect personal data both directly and indirectly.
(1) Personal data are collected directly when you provide them voluntarily (e.g. when contacting us by e-mail).
(2) Indirect collection of personal data may occur automatically when accessing the Services.
4.3. We collect the following categories of personal data:
(1) game events: session start, advertising start, character’s death, window opening, etc.;
(2) user data: user device screen size, IP address and approximate location inferred from it, user device memory size, CPU and GPU models, user device model, used device ID, user device operating system and its version, user device language, user device time zone, user IDs, device advertising id, App Set ID, installation source and referral data;
(3) diagnostic data: crash reports, error logs and other technical information used to identify and resolve issues with the Services;
(4) purchase data: product purchased, price, currency, transaction identifier, purchase receipt and validation result;
(5) advertising data: ads shown, ad interactions and advertising revenue;
(6) support and correspondence data: your email address and any information you provide when you contact us.
4.4. The personal data we collect depends on the Services you use, the features you access and your privacy choices.
5. Personal Data Processing
5.1. “Processing” is understood as at least one of the following: collection, storage, modification, retrieval, disclosure, structuring, use, destruction as well as any other action with respect to your personal data.
5.2. The purposes, legal bases and retention periods for processing your personal data are set out below. Where the GDPR applies, the legal bases listed below are those we rely on under Article 6 of the GDPR.
| Data type | Processing purposes | Legal basis | Retention period |
|---|---|---|---|
| Game events | Analysing how the Services are used to assess and improve their functionality. | consent where required for analytics, otherwise our legitimate interest in improving the Services | Within 3 years from the last use of the Services. |
| User data | Providing and securing the Services, preventing fraud and improving the Services | Performance of a contract where necessary to provide requested functionality; our legitimate interests in securing and improving the Services and preventing fraud; consent where required for access to device information or local storage | Within 3 years from the last use of the Services. |
| Diagnostic data | Diagnosing errors and improving the Services | Our legitimate interest in maintaining reliable Services, or consent where required | Within 3 years from the last use of the Services. |
| Purchase data | Delivering and validating purchases, preventing fraud, purchase analytics and meeting accounting obligations | Performance of a contract for purchase delivery and validation; legitimate interests in fraud prevention; consent where required for analytics; compliance with applicable legal obligations | Within 3 years from the last use of the Services, except where applicable law requires longer retention. |
| Advertising data and related user, game event and purchase data | Delivering and measuring ads, attributing installs, measuring and optimising campaigns, building remarketing audiences and personalising advertising where permitted. | Consent where required; otherwise our legitimate interests in funding and measuring the Services, subject to applicable law and your rights | Within 3 years from the last use of the Services. |
| Support and correspondence data | Responding to enquiries and feedback, troubleshooting reported issues, and handling refund and data protection requests. | Our legitimate interest in handling correspondence and providing support, performance of a contract where necessary to address a purchase or service issue, and compliance with legal obligations where applicable, including when handling data protection requests. | Up to three years from the last communication about the matter. |
Where processing relies on legitimate interests, we balance those interests against your rights and freedoms. We obtain consent where required for storing or accessing information on your device; relying on a legitimate interest does not override that requirement.
5.3. We use third-party service providers acting as data processors to store and otherwise process your personal data on our behalf. These services include:
(1) Singular - mobile measurement platform, attribution and tracking. Privacy Policy: https://www.singular.net/privacy-policy/
(2) Google Analytics - usage data analytics. Privacy Policy: https://policies.google.com/privacy
(3) Google Firebase (Crashlytics and Remote Config) - data collection and storage, crash diagnostics and game settings personalisation. Privacy information: https://firebase.google.com/support/privacy
(4) Google Cloud BigQuery - data storage and internal analysis. Privacy information: https://cloud.google.com/privacy
(5) AppMetrica - usage data analytics. Privacy Policy: https://yandex.com/legal/confidential/en/
(6) Tenjin - mobile measurement platform, attribution and tracking; used in some games instead of Singular. Privacy Policy: https://tenjin.com/privacy/
6. Transfer and Disclosure
6.1. We work with advertising partners to show and measure advertising in our Services. Where these partners act as independent controllers, they process your personal data under their own privacy policies and determine the applicable retention periods in accordance with applicable law.
Depending on the game, our advertising partners may include:
(1) Google AdMob - Privacy Policy: https://policies.google.com/privacy
(2) AppLovin MAX - Privacy Policy: https://legal.applovin.com/privacy/
(3) Meta Audience Network - Privacy Policy: https://www.facebook.com/privacy/policy/
(4) Unity Ads - Privacy Policy: https://unity.com/legal/game-player-and-app-user-privacy-policy
(5) Liftoff/Vungle - Privacy Policy: https://liftoff.ai/privacy-policy/
(6) Pangle - Privacy policies: https://www.pangleglobal.com/privacy
(7) Mintegral - Privacy Policy: https://www.mintegral.com/en/privacy
(8) Gadsme - Privacy Policy: https://www.gadsme.com/privacy-policy
(9) Clever Ads Solutions (CAS) - Privacy Policy: https://cas.ai/privacy-policy/
(10) Adverty - Privacy Policy: https://www.adverty.com/privacy-policy/
Our mediation and advertising partners may also work with ad exchanges, demand-side platforms and other advertising buyers to select and serve ads in our games. Depending on the integration and your privacy choices, these participants may receive information as part of an ad request or auction.
Advertising partners may vary by game and change over time. Where a consent message is shown, it provides information about the partners and purposes covered by that message.
For eligible ad requests, we may share your full IP address with participating ad buyers so they can evaluate and bid on ad impressions. This sharing is subject to regional restrictions and applicable privacy choices.
For general information about advertising technology providers, see the following public lists:
- IAB Europe Transparency & Consent Framework — Global Vendor List: https://iabeurope.eu/vendor-list-tcf/
- Google Additional Consent — Ad Technology Providers List (CSV): https://storage.googleapis.com/tcfac/additional-consent-providers.csv
6.2. We work with advertising and marketing partners to promote our games, attribute installs, measure conversions and optimize advertising campaigns. Depending on the game, these partners may include Google Ads, Meta, TikTok, Mintegral, AppLovin and Clever Ads Solutions (CAS). They may receive device and advertising identifiers, installation and referral information, and data about in-app activity, purchases and advertising revenue, either directly through SDKs or through measurement and attribution providers such as Singular, Tenjin or Google Analytics for Firebase. Where enabled and permitted, this data may also be used to create advertising audiences and personalize advertising for our games. Processing is subject to applicable law, your privacy choices and the partners’ applicable terms and privacy policies.
The full list of our user acquisition partners is provided below:
(1) Google Ads - Privacy Policy: https://policies.google.com/privacy
(2) Meta - Privacy Policy: https://www.facebook.com/privacy/policy/
(3) TikTok - Privacy Policy: https://www.tiktok.com/legal/privacy-policy
(4) Mintegral - Privacy Policy: https://www.mintegral.com/en/privacy
(5) AppLovin - Privacy Policy: https://legal.applovin.com/privacy/
(6) Clever Ads Solutions (CAS) - Privacy Policy: https://cas.ai/privacy-policy/
6.3. Payments for in-app purchases are processed by the applicable app store, such as Google Play or the Apple App Store. We receive the purchase information described in section 4 to deliver and validate purchases and for the purposes described in section 5; we do not receive your full payment card details.
(1) Google Play - Privacy Policy: https://policies.google.com/privacy
(2) Apple App Store - Privacy Policy: https://www.apple.com/legal/privacy/
6.4. To ensure the provision of our services, your personal data may also be transferred to a legal entity created after reorganisation of Naxeex should it be necessary.
6.5. Please note that disclosure of your personal data may be required in accordance with the law and judicial procedures or at the request of public bodies of the country of your stay or other countries. Your personal data will be disclosed if it is necessary for the purposes of national security, law enforcement, protection of the rights and legitimate interests of Naxeex and third parties or for other substantial public interest purposes.
6.6. Our service providers and partners may process personal data outside your country, including outside the European Economic Area (EEA). Such countries may provide a different level of data protection. For international transfers subject to the GDPR or UK GDPR, we rely on an applicable adequacy decision or appropriate safeguards, such as Standard Contractual Clauses or applicable UK transfer arrangements. You can contact us using the details in section 9 for information about the destinations and safeguards applicable to your data and how to obtain a copy.
7. Personal Data Protection
7.1. We take appropriate technical and organisational measures to protect your personal data against unauthorised access or disclosure, loss, alteration or destruction. However, no system can guarantee absolute security.
7.2. Any personal data collected and processed hereunder shall be properly protected, including when disclosure is based on your consent or required by applicable law. Information is no longer personal data only when it has been rendered anonymous so that you are no longer identifiable.
8. Children's Personal Data
8.1. We may not always know a user’s age. As a result, the personal data we collect may include data relating to minors.
8.2. If you are a minor, please ask your parent or legal guardian to read and review this Policy with you.
8.3. By allowing a minor to use our Services, their parent or legal guardian confirms that they have read and understood this Policy and acknowledges it on the minor’s behalf.
8.4. If you are a minor and cannot review this Policy with your parent or legal guardian, or if you or your parent or legal guardian do not agree with the practices described in this Policy, please stop using our Services.
8.5. Reviewing this Policy or permitting a minor to use our Services does not replace any separate consent required by applicable law for the processing of personal data.
9. User Rights
9.1. Your rights regarding the collection and processing of your personal data are determined by applicable data protection law.
In accordance with applicable data protection law you may access, change and/or make additions to, delete, restrict processing of, receive a portable copy of, object to or withdraw your consent to the processing of your personal data as well as opt-in/opt-out and lodge a complaint to the supervisory authority.
9.2. To exercise your rights under applicable data protection law or ask any questions about the processing of your personal data, please contact us at naxeex.studio@gmail.com. When you exercise your rights regarding your personal data, we may need your in-game User ID to process your request. Depending on the game, tap the Settings (gear) icon and select Credits, or tap the information (i) icon in the main menu. Look for “Your User ID” at the end of the credits.
9.3. Naxeex reserves the right to verify your identity before exercising any rights at your request. In case we are not able to exercise any of your rights or provide any information, we will also explain the reasons to you.
9.4. If the GDPR applies to our processing of your personal data, you may withdraw your consent at any time where we rely on it. Withdrawal does not affect the lawfulness of processing carried out before withdrawal. You may also object to processing based on legitimate interests as described in section 9.7.
Where the in-game privacy form is available, go to Main menu > Settings > Privacy Options to change or withdraw your consent or object to processing based on legitimate interests for the purposes covered by the form.
9.5. If you use our Services in the European Economic Area (EEA), the United Kingdom or Switzerland, or in other regions where consent is required by applicable law (for example, under the GDPR), we obtain your consent before starting any activity for which consent is required. We request consent through a consent management platform, such as Google's User Messaging Platform. The applicable consent message identifies the relevant partners and processing purposes. Consent to personalized advertising is optional. Non-personalized or limited ads may still involve processing of personal data and are subject to applicable consent requirements.
9.6. On iOS, you can review and change app tracking permissions in Settings > Privacy & Security > Tracking. On Android devices that support these controls, you can reset or delete your advertising ID and manage available advertising privacy settings in your device settings. The available options and their location vary by device and software version. These controls do not stop all personal data processing or automatically delete previously collected data. You may also contact us to exercise your rights as described in section 9.2.
9.7. If the General Data Protection Regulation (GDPR) applies to our processing of your personal data, you have the right to:
- Access your personal data and receive a copy.
- Correct inaccurate personal data and complete incomplete personal data.
- Request deletion or restriction of processing in the circumstances provided for by the GDPR.
- Receive and transfer your data in a structured, commonly used and machine-readable format where the GDPR’s conditions for data portability are met.
- Object to processing based on legitimate interests on grounds relating to your particular situation. You may object at any time to processing for direct marketing, including related profiling.
- Withdraw consent at any time where processing is based on consent. This does not affect the lawfulness of processing before withdrawal.
- Lodge a complaint with a data protection supervisory authority, in particular in the EU Member State where you usually live or work, or where the alleged infringement occurred.
To exercise these rights with us, use the contact details in section 9.2. You can find the in-game options for changing or withdrawing consent in section 9.4.
If we correct or erase your personal data or restrict its processing under the GDPR, we notify the recipients to whom we disclosed that data, unless doing so is impossible or would involve disproportionate effort. If you ask, we will tell you who those recipients are.
10. US Privacy
This section supplements our Privacy Policy for US residents.
10.1. Personal Information We Collect and Use
Depending on the Services you use and your privacy choices, we collect the following categories of personal information. The descriptions below correspond to the information described in sections 4 and 5 of this Privacy Policy.
| Category | Information covered |
|---|---|
| Identifiers | Identifiers included in our user data, such as IP addresses, advertising IDs, device, installation and user IDs; your email address if you contact us. |
| Internet or other electronic network activity information | Game events, interactions with the Services and advertisements, and related technical usage and diagnostic information. |
| Commercial information | Purchase data, such as products purchased, prices, currencies, transaction identifiers and purchase validation information. |
| Geolocation data | Approximate location inferred from your IP address. We do not collect precise geolocation. |
When you contact us, we also collect the information you provide in your correspondence.
Further details about the information and its sources are provided in section 4 (Personal Data Collection).
We use this information to provide and secure the Services, deliver and validate purchases, diagnose problems, improve and personalise the Services, deliver and measure advertising and marketing campaigns, respond to enquiries and feedback, troubleshoot reported issues, and handle refund and data protection requests. The purposes applicable to each category are described in section 5 (Personal Data Processing).
We retain support and correspondence data for up to three years from the last communication about the matter. We retain other information for up to three years from your last use of the Services, except where applicable law requires longer retention of purchase information, as described in section 5.2.
Our service providers and other recipients are described in section 5.3 and section 6 (Transfer and Disclosure).
We do not collect sensitive personal information as defined under applicable US state privacy laws.
10.2. Sale, Sharing and Targeted Advertising
We disclose advertising identifiers and information about ad impressions and related revenue to advertising networks and mediation providers to deliver and measure ads in our games. For eligible ad requests, we may also share your full IP address with participating ad buyers so they can evaluate and bid on ad impressions, subject to regional restrictions and applicable privacy choices.
For campaigns promoting our games, we disclose advertising identifiers and information about app installs, in-game activity, in-app purchases, ad impressions and related revenue to user acquisition partners, directly or through measurement and attribution providers. We use this information to measure campaign performance and optimise campaigns for installs, in-app purchases and advertising revenue. We use app installs, in-game activity and in-app purchases to build remarketing audiences.
The categories of personal information involved are identifiers, internet or other electronic network activity information, and commercial information. Where partners use this information to select ads based on activity across different companies’ apps or websites, the disclosure may constitute “sharing” under applicable U.S. state laws or involve processing for targeted advertising under those laws. Certain disclosures may also constitute a “sale” under applicable law, including where no money changes hands.
Where applicable U.S. state law requires an opt-out option and our in-game privacy form is available, you can opt out of the sale or sharing of personal information or its use for targeted advertising under Main menu > Settings > Privacy Options. We apply your choice to restrict the use and disclosure of personal information for sale, sharing and targeted advertising. You may continue to see ads after opting out, and we may continue to process personal information for other purposes described in this Policy.
10.3. Your Rights and Requests
Depending on your state of residence, you may have some or all of the following rights:
(1) Access and portability: request confirmation that we process your personal information, access to it, and a portable copy.
(2) Correction: request correction of inaccurate personal information.
(3) Deletion: request deletion of your personal information, subject to applicable legal exceptions.
(4) Information about disclosures: request information about the personal information we disclose and its recipients.
(5) Advertising choices: opt out of sale, sharing or targeted advertising as described in section 10.2.
(6) Certain profiling: opt out of profiling used to make decisions producing legal or similarly significant effects, where applicable.
If you have questions or requests about your personal information, please contact us as described in section 9 (User Rights). We may need to verify your identity for access, correction or deletion requests.
Where permitted by applicable law, an authorised agent may contact us on your behalf about those requests using the details in section 9.
Where applicable, you may appeal our decision on your privacy request by contacting us through section 9.
You have the right not to face unlawful discrimination or retaliation for exercising your privacy rights.
11. Final Provisions
11.1. We may update this Policy from time to time. The updated version will be published on this page with a revised “updated” date. Where required by applicable law, we will provide additional notice or obtain consent.
11.2. This Policy describes our personal data practices. It does not replace the terms governing your use of the Services or limit your rights under applicable data protection law.
11.3. If any provision hereof is invalid or unenforceable, other provisions shall remain valid and enforceable to the fullest extent permitted by applicable law.
11.4. Failure to enforce your strict compliance herewith cannot be construed as our waiver of any provision hereof or any right hereunder.