Privacy Policy

Happy Cake Games Last updated: June 12, 2026

This Privacy Policy ("Policy") explains how Happy Cake Games ("we," "us," "our," "Company") collects, uses, shares, and protects personal data in connection with our games, websites, and related services (collectively, the "Services").

By accessing or using our Services, you acknowledge that you have read and understood this Policy. Before we begin processing your personal data, you will be presented with an explicit consent prompt for the processing of your personal data. If you do not agree with this Policy, please do not use our Services.

Controller / Company details

Happy Cake Games
Nijverheidsweg 18
3641 RR Mijdrecht
The Netherlands

Representative: Daniel Varentsov, CTO
Email: daniel@happycakegames.com

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1. Personal Data We Collect

The data we collect depends on how you interact with our Services.

1.1 Information You Provide Directly

• Account information: nickname, username, Player ID, email address, date of birth, gender (where applicable)
• Profile content: avatars, profile pictures, in-game messages
• Customer support data: your inquiry content, attachments (text, images), and your Player ID / device ID used to identify your account
• Forum and chat content: messages exchanged in public forums, in-game chat, or private conversations with other players
• Survey, contest, and sweepstakes data: contact details such as name and address, provided voluntarily

1.2 Information Collected Automatically

• Identifiers and device information: device ID, advertising ID (IDFA/GAID/OAID), device brand, model, OS version, browser type and version, language and settings
• Network and log information: IP address, network type, connection status, and information used to detect abnormal or fraudulent behavior
• Application information: package name, app version, signature, and process information used to detect abnormal app behavior
• Geolocation data: approximate or precise location, depending on your device permissions, used for matchmaking, regional content, and troubleshooting
• Usage data: gameplay progress, session length, in-game actions, pages visited on our websites, referring URLs
• Sensor data: motion, location, and environment sensor data, where permitted, used for anti-cheat and security purposes
• Cookies and similar technologies: see Section 4

1.3 Payment Information

When you make in-app purchases, transactions are processed through third-party platforms (e.g., Apple App Store, Google Play). We may receive limited transaction details (amount, date, product purchased) but we do not collect or store your full payment card information.

1.4 Information from Third Parties

• Third-party login/social services (e.g., Apple Game Center, Google Play Games, Facebook): if you connect these accounts, we may receive your user ID, profile name, and friends list, subject to your settings on those platforms
• Data brokers and aggregators: supplemental demographic or interest data
• Service providers and analytics/advertising partners: device and usage data collected via SDKs integrated into our apps

1.5 Inferred Information

We may infer demographic data (such as estimated age range, gender, or interests) and approximate location (based on IP address) from the data described above.

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2. How We Use Your Data

We do not carry out automated decision-making or profiling that produces legal effects or similarly significantly affects you.

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3. Sharing and Disclosure of Personal Data

We do not sell your personal data for monetary consideration. We may share data in the following circumstances:

• With your consent, including for third-party marketing purposes you opt into
• Service providers and vendors performing work on our behalf (customer support, hosting, analytics, security/anti-cheat), under contractual confidentiality obligations
• Advertising and analytics partners via SDKs and cookies (see Section 4) — this may constitute a "share" under certain US state laws (see Section 7)
• Legal and safety reasons: to comply with law, respond to lawful requests from authorities, or protect the rights, property, or safety of Happy Cake Games, our users, or others
• Business transfers: in connection with a merger, acquisition, financing, or sale of assets, with notice to you of any material change in how your data is handled
• Public areas: information you post in forums, chat, or public profiles may be visible to other users and is not protected by this Policy once posted

Third-Party Service Providers

We cannot control these third parties' practices; please review their policies directly.

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4. Cookies, Mobile IDs, and Similar Technologies

We and our partners use cookies, web beacons, SDKs, and mobile advertising identifiers to:

• operate and secure our Services (required, cannot be disabled)
• analyze performance and usage (functional/analytics)
• personalize and measure advertising (advertising)

Your Choices

• Browser cookies: manage via your browser settings
• Mobile advertising IDs: iOS — Settings > Privacy & Security > Tracking; Android — Settings > Ads > Opt out of Ads Personalization
• Industry opt-outs:

- EU: https://www.youronlinechoices.com - US: https://optout.aboutads.info and https://optout.networkadvertising.org

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5. International Data Transfers

Storage location of primary personal data depends on your region:

• Personal data of users in the European Union / EEA is stored and processed on servers located within the EU.
• Personal data of users in the Russian Federation is stored and processed on servers located within the territory of the Russian Federation, in accordance with Russian Federal Law No. 152-FZ "On Personal Data" (Art. 18(5)).

In addition, certain categories of data may be transferred to third-party analytics, advertising, and infrastructure providers (see Sections 3 and 4), some of which are located outside your region (e.g., in the United States). Such cross-border transfers are limited to what is necessary for the operation of the relevant SDKs and services (analytics, advertising, anti-fraud) and are accompanied by appropriate contractual safeguards from those providers.

Where personal data is transferred outside the EEA/UK/Switzerland, we rely on appropriate safeguards, including the European Commission's Standard Contractual Clauses, and we take additional measures as required to ensure your data remains protected to a standard consistent with this Policy and applicable law.

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5.1 Additional Terms for Users in the Russian Federation (152-FZ)

For the purposes of compliance with Russian Federal Law No. 152-FZ "On Personal Data" dated 27.07.2006:

• Data operator: Daniel Varentsov (CTO, Happy Cake Games), acting as the person responsible for organizing the processing of personal data.
• Roskomnadzor notification registry number: ВСТАВИТЬ_ТЕКСТ
• Purposes of processing: limited to basic operational purposes — user authentication and identification, account and Service operation, and customer support.
• Retention: personal data is retained until the user deletes their account, after which it is deleted or anonymized, except where longer retention is required by applicable law.
• Consent: processing is based on the user's consent, obtained via an explicit consent prompt presented at registration/first use of the Service.
• Cross-border transfer: primary storage is located within the Russian Federation; transfers outside the RF are limited to interactions with the third-party SDKs (analytics/advertising/anti-fraud) listed in Section 3.

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6. Your Rights (EEA/UK and Beyond)

If GDPR or the UK GDPR applies to the processing of your data, you have the right to:

• Access your personal data and obtain a copy
• Rectify inaccurate or incomplete data
• Erase your data ("right to be forgotten"), subject to legal exceptions
• Restrict processing in certain circumstances
• Data portability: receive your data in a structured, machine-readable format
• Object to processing based on legitimate interests or for direct marketing
• Withdraw consent at any time, without affecting prior lawful processing
• Lodge a complaint with your local Data Protection Authority (in the EU) or the ICO (UK, www.ico.org.uk)

Legal bases for processing: consent; performance of a contract; compliance with legal obligations; and our legitimate interests (e.g., security, service improvement), balanced against your rights.

To exercise any of these rights, contact us at daniel@happycakegames.com. We will respond within the timeframes required by applicable law (generally one month under GDPR).

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7. US State Privacy Rights

If you are a resident of California, Colorado, Connecticut, Virginia, Utah, or another US state with a comprehensive privacy law, you may have the right to:

• Know/Access: request what personal information we collect, use, and disclose about you
• Delete: request deletion of your personal information, subject to exceptions
• Correct: request correction of inaccurate information
• Opt out of:

- the "sale" or "sharing" of personal information for cross-context behavioral advertising - targeted advertising - certain profiling

• Limit use of sensitive personal information
• Non-discrimination for exercising these rights
• Appeal a denied request

We do not sell personal information for monetary consideration, but advertising/analytics SDKs operating on our Services may constitute a "share"/"sale" under broad state-law definitions. You can opt out by adjusting your device's ad-tracking settings or emailing daniel@happycakegames.com with subject "Privacy Rights Request."

Do Not Track: We do not currently respond to browser "Do Not Track" signals, as no common industry standard exists.

To exercise your rights or appeal a decision, email daniel@happycakegames.com. We will acknowledge appeals within 45 days.

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8. Children's Privacy

Our Services are not directed to children, and we do not knowingly collect personal data from:

• children under 13 (US, COPPA),
• children under 16 in the EEA (or a lower age, not below 13, where permitted by Member State law), or
• individuals under the applicable age of digital consent in their jurisdiction,

without verifiable parental or guardian consent.

If we learn we have collected personal data from a child without appropriate consent, we will take steps to delete it promptly. Parents/guardians who believe their child has provided personal data to us may contact daniel@happycakegames.com to request deletion.

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9. Data Retention

We retain personal data only for basic operational purposes, namely user authentication and identification and the operation of your account and the Services.

Data is retained until you delete your account. After account deletion, we will delete or anonymize your personal data, except where retention of specific categories of data is required by applicable law (e.g., transaction records or customer support correspondence may be retained for up to 3 years after the support request is resolved, for legal compliance purposes).

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10. Security

We implement technical and organizational measures appropriate to the risk, including:

• encrypted communications between our servers and databases
• access restrictions to systems storing personal data
• regular staff training on data protection
• a designated point of contact for privacy matters (see Section 11)

No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

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11. Contact Us

For any questions, requests, or complaints regarding this Policy or your personal data:

Happy Cake Games
Nijverheidsweg 18
3641 RR Mijdrecht
The Netherlands

Contact: Daniel Varentsov, CTO
Email: daniel@happycakegames.com

EEA/UK residents also have the right to lodge a complaint with their local supervisory authority, or with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens, www.autoriteitpersoonsgegevens.nl), without prejudice to any other remedy.

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12. Changes to This Policy

We may update this Policy from time to time. Material changes will be communicated via the Services or by email, and the "Last updated" date will be revised accordingly. Continued use of the Services after changes take effect constitutes acceptance of the updated Policy.

© Happy Cake Games. All rights reserved.