PRIVACY POLICY

1. GENERAL

1. UAB "Kinelija" ("we", "us", or "our"), a company based in Vilnius, Lithuania, acts as a data controller for the personal data you provide when using our games and applications ("Games"). We are committed to protecting your privacy and processing your personal data in accordance with applicable data protection laws, including the EU General Data Protection Regulation (GDPR).
2. This Privacy Policy (together with our Terms of Service) explains how we collect, use, store, and protect your personal information. By using our Games, you consent to the practices described herein.
3. We may update this policy from time to time. Please review this page periodically for the latest version. Continued use of our Games constitutes acceptance of any changes.
4. Our Games are distributed via third-party platforms (e.g., app stores, social networks). You are responsible for reviewing and accepting those platforms’ terms and privacy policies before use.

2. WHAT DATA WE COLLECT

1. Usage data: access times, session duration, in-game actions, and feature interactions.
2. Device & technical data: device type, operating system, browser (name/version), IP address (anonymised where feasible), and unique device identifiers.
3. Social platform data (if applicable): public profile information (e.g., username or player ID) when you log in via platforms such as Google, Apple, or Facebook. We do not access or store sensitive social profile details without explicit consent.
4. Communication data: records of emails or support tickets if you contact us.

3. PURPOSES OF PROCESSING

1. To provide, operate, and maintain our Games;
2. To improve functionality, performance, and security of our Games;
3. To personalise your experience (e.g., saving progress, adapting gameplay);
4. For marketing and promotional communications (only with your consent, where required by law);
5. To comply with our legal obligations (e.g., fraud prevention, regulatory reporting);
6. To detect, investigate, or prevent fraudulent, abusive, or illegal activity.

4. DATA RETENTION & DELETION

1. We retain your personal data only as long as necessary—typically for the duration of your use of the Games plus up to 12 months of inactivity—unless a longer retention period is required by law.
2. You may request deletion of your personal data at any time by emailing us at [email protected].
3. Alternatively, you may submit a deletion request via our in-game support system (Settings → Support).
4. We will process verified requests within 30 days, unless retention is legally mandated.

5. DISCLOSURE OF YOUR PERSONAL INFORMATION

1. We do not sell, rent, or trade your personal data.
2. We may share data with:
   1. Trusted service providers (e.g., cloud hosting, analytics, customer support), who process data on our behalf under GDPR-compliant data processing agreements;
   2. Third parties in connection with a merger, acquisition, or sale of assets—your data may be transferred as part of such transaction, always with continued protection;
   3. Public authorities or legal entities where required by law, to enforce our rights, or to protect the safety of our users, our company, or the public (e.g., fraud prevention).
3. When Games integrate with social platforms (e.g., leaderboards, friend invites), limited non-sensitive identifiers (e.g., username) may be shared within the platform to enable functionality—subject to your platform permissions.

6. INTERNATIONAL DATA TRANSFERS

1. While Kinelija is based in the EU (Lithuania), some service providers may process data outside the European Economic Area (EEA).
2. In such cases, we ensure an adequate level of protection through EU-approved mechanisms, such as Standard Contractual Clauses (SCCs).
3. You may request further information about international transfers by contacting us.

7. COOKIES & TRACKING TECHNOLOGIES

1. We use cookies and similar technologies (e.g., local storage) to:
   • Remember preferences and login state;
   • Analyse usage to improve performance and user experience;
   • Enable essential features (e.g., game progress saving).
2. You can manage or disable cookies via your browser or device settings. Note: disabling essential cookies may limit Game functionality.
3. Third-party services (e.g., analytics, ad networks) may place their own cookies. We do not control these; please refer to their privacy policies.
4. For guidance on managing cookies, visit www.aboutcookies.org.

8. YOUR RIGHTS UNDER GDPR

1. As an EU/EEA resident, you have the right to:
   • Access, correct, or delete your personal data;
   • Restrict or object to processing;
   • Data portability;
   • Withdraw consent at any time;
   • Lodge a complaint with a supervisory authority (e.g., the State Data Protection Inspectorate of Lithuania).
2. To exercise any rights, contact us at [email protected]. We may verify your identity before responding.

9. SECURITY

1. We implement appropriate technical and organisational measures (e.g., encryption, access controls) to safeguard your data.
2. While we strive to protect your information, no digital transmission or storage system is 100% secure.

10. CONTACT

1. Questions, requests, or concerns regarding this Privacy Policy should be sent to:
   📧 [email protected]
   📍 Kinelija, Vilnius, Lithuania
2. We aim to respond to all legitimate requests within 30 days.