Privacy Policy for MINDUP d.o.o. Mobile Games
Effective date: 29 September 2025
This Privacy Policy describes how MINDUP d.o.o. (“MINDUP,” “we,” “our” or “us”) collects, uses, and shares information when you use our mobile games and related services (collectively, the “Service”). By playing our games or otherwise interacting with the Service you consent to the practices described in this Policy. This Privacy Policy applies to information processed through our games, associated websites and the support channels we provide. For questions about this Policy or your data rights, please contact us at contact@mindup-apps.com or by writing to MINDUP d.o.o., Olimje 41, 3254 Podčetrtek, Slovenia.
Definitions
- Service: The mobile games operated by MINDUP d.o.o., including the accompanying website and customer support.
- Personal Data: Information that identifies or relates to an individual, such as a name, email address, IP address or device identifier.
- Usage Data: Data collected automatically about how you interact with the Service, such as the date and time of game sessions, device type and operating system version, in-game actions, and diagnostic data.
- Cookies: Small files or mobile identifiers that recognise your browser or device and collect certain information. We use cookies, software development kits (SDKs) and device identifiers to support analytics, advertising and security features.
- Data Controller: The organisation responsible for determining the purposes and means of processing Personal Data. For this Service, MINDUP d.o.o. is the Data Controller.
- Data Processors: Third-party companies that process data on our behalf to help us operate and improve the Service (e.g., analytics providers, advertising networks). These processors are bound by contractual obligations to only use Personal Data as instructed by us.
- Data Subject: The individual whose Personal Data is collected (i.e., players and website visitors).
Information We Collect
Personal Data. We may ask you to provide certain Personal Data when you contact us (e.g., through customer support) or voluntarily provide feedback. Personal Data may include: Contact information – such as your name and email address when you contact our support team; Game progress or account information – if our games allow sign-in or user accounts (e.g., to save progress across devices); Payment or transaction data – only when you purchase in-app items; these payments are processed through the Google Play Store or Apple App Store and we do not store full payment card numbers.
Usage Data. When you use the Service, we automatically collect Usage Data, such as: Device and app information – including your device model, operating system, unique device identifiers (e.g., advertising IDs), and game version; Log data – date/time of play sessions, features used, levels reached, interactions with in-game advertisements and crashes; Performance and diagnostic data – information about device performance, game loading times and error reports.
Tracking Technologies. We and our partners use cookies and similar technologies to collect Usage Data. Cookies and device identifiers help us recognise returning players, remember settings and preferences, measure the effectiveness of advertisements, and detect fraud. By using the Service, you consent to our use of cookies and similar technologies as described in this Policy.
Third‑Party Information. Our games may integrate third-party SDKs for analytics, advertising, leaderboards or other features. These partners may collect information as described in their own privacy policies. We ensure that our partners do not sell personal and sensitive user data and that they process data in compliance with our instructions and applicable laws.
How We Use Information
We use the information we collect to: 1. Provide and maintain the Service. We process data to deliver gameplay, save your progress, and operate core features. 2. Improve and personalise the Service. We analyse Usage Data to understand player behaviour, balance game difficulty, and optimise gameplay. We may personalise in-game content and recommendations based on your interactions. 3. Display and measure ads. If our games include advertising, we and our advertising partners use device identifiers and Usage Data to show non-personalised ads and to limit ad frequency. We disclose in our game description whether the game contains ads. 4. Conduct analytics. We use analytics tools (e.g., Google Analytics) to track and monitor the use of the Service, diagnose technical issues, and measure the effectiveness of marketing campaigns. Analytics tools may share aggregated, anonymised data with other Google services. 5. Communicate with you. We respond to inquiries, provide customer support and send important notices (such as changes to our policies). We may also notify you of in-game events or promotions if you have opted in to receive these communications. 6. Comply with legal obligations. We process data to meet obligations under applicable laws; to cooperate with law enforcement and protect the rights and safety of users and the public.
Legal Basis for Processing
If you reside in the European Economic Area (EEA), we process your Personal Data under one or more legal bases: performance of a contract, legitimate interests (for example, to analyse and improve the Service), consent (where we ask for your permission), and compliance with legal obligations.
Sharing Information
Service Providers. We engage third-party companies to facilitate our Service, provide analytics, serve advertisements, or perform Services on our behalf. These providers may have access to your Personal Data only to perform these tasks and are obligated not to disclose or use it for other purposes.
Advertising Partners. When our games use AdMob by Google or other ad networks, those partners may collect device identifiers and Usage Data to deliver ads and measure their performance. You can opt out of ad personalisation via your device settings or through the links provided by Google.
Legal Requirements. We may disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency). We may also disclose information when we believe it is necessary to protect the rights, property or safety of MINDUP, our players or the public.
Business Transfers. If MINDUP is involved in a merger, acquisition or sale of assets, Personal Data may be transferred. We will provide notice before your data is transferred and becomes subject to a different Privacy Policy.
Data Retention
We retain Personal Data only for as long as necessary to fulfil the purposes outlined in this Policy. Usage Data is generally retained in aggregated form. When we no longer need to process Personal Data, we will delete or anonymise it. If we are required by law to retain certain data (e.g., for tax or accounting obligations), we will securely store it for the legally required period.
International Transfers
Your information, including Personal Data, may be transferred to and maintained on computers located outside of your state, province or country where the data protection laws may differ. We take appropriate measures to ensure that any transfer of Personal Data complies with applicable data-protection law, for example by using the European Commission’s Standard Contractual Clauses when transferring data outside of the EEA.
Security
We strive to use commercially acceptable means to protect your Personal Data. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee its absolute security. You can help keep your data safe by choosing strong passwords (where applicable) and keeping them confidential.
Your Rights
EEA. If you are located in the EEA, you have certain data protection rights under the GDPR: Right to access – You can request a copy of the Personal Data we hold about you. Right of rectification – You can request that we correct inaccurate or incomplete data. Right to erasure – You can ask us to delete your Personal Data where there is no good reason for us continuing to process it. Right to restrict processing – You may request that we suspend the processing of your Personal Data, for example to establish its accuracy or the reason for processing. Right to object – You can object to our processing of your Personal Data where we are relying on legitimate interests. Right to data portability – You may request to receive a copy of the Personal Data we hold about you in a structured, commonly used and machine-readable format and have it transferred to another controller. Right to withdraw consent – Where we rely on consent to process your data, you have the right to withdraw your consent at any time. To exercise these rights, please contact us at contact@mindup-apps.com.
California. Under the CCPA, residents of California may have the following rights: Right to know – You can request details about the categories of Personal Data we collect, the sources of that data, the business purpose for collecting or sharing it, and the categories of third parties with whom we share it. Right to delete – You can request that we delete Personal Data, subject to certain exceptions. Right to opt out – You can request that we do not sell Personal Data. We do not sell Personal Data. Right to non-discrimination – We will not discriminate against you for exercising any of your CCPA rights.
Other Jurisdictions. Residents of other jurisdictions may have additional rights under applicable laws. Please contact us to exercise any other rights you may have.
Children’s Privacy
Our games are designed for a general audience and are not directed to children under the age of 16. We do not knowingly collect Personal Data from anyone under 16. If you are a parent or guardian and you become aware that your child has provided us with Personal Data, please contact us so we can delete the information. For games targeted to children or subject to COPPA, we will comply with the specific parental consent and disclosure requirements.
Links to Other Sites
The Service may contain links to third-party websites or services that are not operated by us. If you click a third-party link, you will be directed to that party’s site. We strongly advise you to review the privacy policy of every site you visit, as we have no control over the content, privacy policies or practices of any third-party sites.
Changes to This Policy
We may update our Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the effective date at the top. For significant changes, we may also notify you via in-app messages or via email if you have provided an email address. We recommend that you review this Privacy Policy periodically for any changes, as continued use of the Service after changes have been posted signifies your acceptance of the revised Policy.
Contact Us
If you have any questions about this Privacy Policy or our data practices, please contact us: By email: contact@mindup-apps.com. By post: MINDUP d.o.o., 3254 Podčetrtek, Olimje 41, Slovenia.