ROOTED FUN PRIVACY POLICY

Release Time:June 6, 2025

OUR MISSION

At Rooted Fun, we invite you to explore who we are and discover the best ways to connect with us.

◐ We provide a wide selection of free online games for users to enjoy. During your interaction with our services, certain personal data may be collected as part of the gameplay experience.

◐ Our official Google Developer name is SnowBall Studio. If you have any questions regarding our data practices, your privacy rights, or wish to file a complaint, please don’t hesitate to contact us at xumhinspirehk@gmail.com.

HOW WE COLLECT, USE, AND SHARE YOUR PERSONAL INFORMATION

We collect personal information directly from you—for example, when you register for an account or play our games.
◐ We also gather usage data generated during your interactions with our games, such as gameplay activities and system logs.
◐ If you log in through a social media platform, we may access certain profile details like your name, email address, and profile photo. We may also receive relevant data from external services, including social networks.

◐ We use your personal data to operate and deliver our games, offer customer support, assess user engagement, and continuously enhance the gaming experience.
◐ Your information also enables us to respond to your inquiries or support requests efficiently.
◐ Occasionally, we may contact you with promotional messages, push notifications, or targeted ads within the games. You may opt out of these communications at any time by adjusting your device or browser settings.

◐ To achieve the purposes outlined in this policy, we may share your data with third parties such as server hosts, customer support providers, and analytics platforms. We also collaborate with advertising partners to show relevant ads, and may share your data internally or as required by law.
◐ Your data may be processed in countries where our games are managed or supported, including the Philippines, the United States, and other primary operational locations.
◐ You have the right to access your personal information, request a copy, ask for it to be deleted, or restrict how it's processed. You may also object to our use of your data for specific purposes, such as personalized advertising.

UPDATE

Any updates or changes to this Privacy Policy will be published on the official Privacy Policy page of Rooted Fun.
◐ If we make significant modifications, we will notify you through announcements on our website or directly within the game interface.

INTRODUCTION

This Privacy Policy explains your choices and our practices regarding the handling of your personal data (referred to as "Information" below). References to “Rooted Fun,” “we,” or “us” indicate the service provider responsible for the Rooted Fun platform.

◐ As the data controller in certain regions, we decide why and how your Information is processed. The term "Information" includes any data that identifies or can identify you, especially in connection with: (a) our mobile applications ("Mobile Games"), and (b) games available for download via the official Rooted Fun website ("Website").

◐ By accessing or playing our Mobile Games or Website Games (together, the "Games"), you confirm that you agree to the terms and data handling rules described in this Policy.

◐ You acknowledge that we collect, use, process, and store your Information in accordance with this Policy.

◐ If you do not agree with the terms outlined here, please do not access or play any of the Games. Should you change your mind later, you can stop using the Games and exercise your rights regarding your Information as detailed in this Policy.

1. COLLECTION AND USE OF PERSONAL DATA

To ensure the smooth functioning of our application and deliver an optimal user experience, Rooted Fun may request access to specific permissions on your device.
◐ These permissions include:
(1) INTERNET – Required for connecting to the internet to support normal gameplay. (Necessary)
(2) AD_ID – Used to access advertising IDs for analytics and targeted advertising. (Not necessary)
(3) ACCESS_NETWORK_STATE – Used to check network status for performance analytics and ad optimization. (Not necessary)
(4) ACCESS_WIFI_STATE – Monitors Wi-Fi status for similar optimization purposes. (Not necessary)
(5) CAMERA – Enables users to take photos for customizing their game avatar. (Not necessary)
(6) READ_MEDIA_IMAGES – Grants access to stored images to allow avatar setup. (Not necessary)
(7) VIBRATE – Allows the app to use vibration features for gameplay effects. (Not necessary)

◐ We process a variety of personal data you provide directly, including registration information.
When you create a Rooted Fun account, you provide your email, password, date of birth, username, and avatar.
◐ If you contact our support team through live chat, we may collect your name, username, email address, and any extra details you share for assistance—such as your Game ID, team name, device type, advertising ID, transaction history, or language preferences.

◐ During gameplay, you may be asked to choose a username, which becomes part of your game profile.
◐ In some games, we offer communication features like chat, voice, or video calls. We may process metadata (timestamps, message content), although third-party services sometimes provide these features, meaning we may not access the content directly.

◐ Occasionally, we invite you to take part in surveys about your experience.
The types of data collected vary by survey, but may include your preferences, opinions, interests, usage habits, ratings, answers to questions, and even images or comments you submit.
◐ For account-related actions and identity confirmation, we may process your email address specifically associated with your Rooted Fun account.

◐ We automatically collect technical and usage information when you play our games.
This includes identifiers like IP address, advertising ID, Adjust ID, device ID, app-specific tokens, device details (model, OS, language), and broad location data (city/country).
◐ Cookies and similar technologies—such as web beacons, log files, scripts, or eTags—are used to enhance your experience. You may choose to disable these features, but this might affect game performance or features.

◐ We also collect gameplay data: Game ID, install/uninstall timestamps, play sessions, event timelines, user scores, ad interactions, promotional engagement, in-game purchases, and any indicators of cheating or modified app usage.

◐ Information may also be obtained from third-party platforms if you sign in using services like Facebook, Google, or Apple.
In such cases, we receive your profile name, picture, platform ID, email address (optional), and sometimes a list of your friends.

◐ For transactions made within the games, we receive details from payment providers, including your transaction ID, country, payment method, purchased items, transaction amount, currency, and time of purchase.

◐ Some games use analytics tools from external providers. These tools help us understand user behavior and improve game mechanics or events. The data includes your user ID and records of your in-game actions.

◐ Our advertising partners share data such as your user ID and how you interact with ads shown in our games. This helps us deliver more relevant promotions.

◐ We also receive insights from mobile measurement companies. This information helps us track marketing effectiveness and detect fraudulent activity, and may include ad IDs, IP addresses, locations, and transaction records.

◐ In games where communication features are handled by external providers, we may obtain certain data from them, including your third-party user ID, username, and, in some cases, the actual communication content.

2. CHILDREN

Our games are designed for individuals aged 18 and above. If you are under the age of 18 (referred to as a "Child"), we recommend obtaining permission from your parent or legal guardian ("Parents") before playing.
◐ It’s a good idea to read this Privacy Policy together with your Parents, as they can help explain anything that may be unclear. If you are a Parent and have concerns about your Child’s interaction with our games or have any questions, please feel free to contact us using the details listed in Section 8 below.

3. PERSONAL INFORMATION USAGE PURPOSES

◐ Game Access and Core Services:
We process your personal information to fulfill our agreement with you—this includes allowing you to register or log in (including as a guest), access and play our games, save your progress, interact with friends, and use communication tools such as in-game chat, voice, or video (where applicable). We also manage in-app purchases through platforms like Google Play and the iOS App Store, along with storing purchase histories. The data involved includes registration info, in-game activity data, device identifiers, user-generated content, and game interaction records.

◐ Improvement, Monitoring, and Support:
We collect and use your data to enhance our games and monitor usage patterns, based on our legitimate interests. This may involve collecting gameplay behavior and technical data such as device type, battery level, Wi-Fi strength, OS version, and storage availability. When you contact customer support, we use your information to manage support cases, retrieve lost credentials, and resolve complaints—processing identifiers, device details, and other information shared through support channels.

◐ Analytics and Personalized Offers:
We analyze how users engage with our games and advertisements to better understand audience behavior and optimize performance. This includes anonymizing usage data, identifying audience groups, and conducting predictive analysis on player interests. We also show in-game promotions and offers tailored to your location, behavior, and device data, which aligns with our legitimate business interests.

◐ Advertising, Fraud Prevention, and Legal Compliance:
We present personalized or contextual advertisements both within and outside our games. Where legally required, we ask for your consent. You may manage or withdraw consent through game or device settings. We also use your data to prevent fraud, uphold user safety, monitor suspicious behavior, and enforce legal obligations—this may involve sharing data with third parties when necessary. Lastly, we may occasionally invite you to participate in surveys to help us improve our services, which involves processing registration and response data.

4. PERSONAL INFORMATION SHARING PURPOSE

◐ Game Interaction and Support Services:
Your in-game activities, profile details, and any content you choose to share via chat or other communication features may be visible to other users. Additionally, we work with service providers to help deliver and maintain our games—for instance, using cloud platforms like Amazon Web Services for data hosting and third-party tools like LiveChat (based in the United States) to manage customer support interactions.

◐ Analytics and Social Features:
To better understand user behavior and improve game performance, we collaborate with analytics and mobile measurement companies such as Adjust GmbH (Germany). We also integrate software from Facebook and Google to enable social features, such as connecting with friends, syncing profile pictures, or accessing your social graph within the game.

◐ Marketing and Advertising Partners:
We partner with user acquisition and advertising platforms to promote our services and deliver personalized content. This includes using Advertising IDs, Facebook IDs, and participating in features like Facebook’s Custom Audience or Lookalike Audience programs. Advertising identifiers and user attributes may also be shared with advertisers to serve targeted ads and assess their effectiveness.

◐ Payment and Internal Affiliates:
When processing in-game purchases, we rely on third-party payment providers such as Google (for Android users) and Apple (for iOS users), who handle your transaction data in accordance with their privacy terms. Additionally, we may share your information with affiliated companies within our corporate group to support internal operations and shared services.

◐ Legal Compliance and Business Transactions:
We may disclose your personal data if legally obligated or when necessary to enforce our terms, respond to legal proceedings, investigate fraud, resolve security issues, or protect user safety and rights. In the case of corporate changes such as mergers, acquisitions, restructurings, asset sales, or bankruptcies, your information may be included as part of the transferred business assets.

5.THIRD PARTY COLLECTION

◐ Use of Third-Party Services:
When you access our games through platforms such as Facebook or Google (collectively referred to as “Third-Party Services”), please be aware that these platforms may collect additional data about you. This could include both information you provide to them directly and data they gather based on your interactions with the game. These platforms operate under their own privacy policies and terms, which are separate from ours. Any links within our games that direct you to these services do not imply our endorsement or oversight of their content or practices.

◐ Independence of Third-Party Policies:
The data collection and processing carried out by Third-Party Services are not covered by this Privacy Policy. We do not control how these external services collect, use, or share your information, so we strongly recommend that you review their privacy policies directly to understand their practices and your available rights.

◐ Partner SDKs and Privacy References:
We also work with third-party partners whose software development kits (SDKs) may be embedded in some or all of our games. These SDKs may process your information in accordance with the respective partner’s policies. For details on how they handle your personal data and how to exercise your data subject rights, please refer to the linked privacy policies below. This list was most recently updated on June 6, 2025.

6.DATA SECURITY, TRANSFERS, AND RETENTION

◐ Protecting Your Information:
We take reasonable technical and organizational steps to safeguard your personal data and maintain its integrity. However, please note that data transmission over the internet can never be completely secure. To minimize risk, we apply additional protective measures and limit the amount of data we collect and process. For example, when you register and set your password, your information is stored securely in a protected database.

◐ International Data Processing and Transfers:
Your information may be processed in regions where our services are available, including but not limited to the United States, the Philippines, and other jurisdictions. If it becomes necessary to transfer personal data outside of the United Kingdom or the European Economic Area (EEA), we ensure such transfers are made to countries that are recognized for having adequate levels of data protection. In the absence of such recognition, we rely on standard contractual clauses approved by relevant authorities to safeguard your data during international transfers.

◐ Data Retention Practices:
We retain your personal data for as long as your account remains active or you continue using our games. After your last activity, we may store the data for up to three years to comply with our operational or legal requirements. When data is no longer needed, we ensure that it is either permanently deleted or rendered unrecoverable and irretrievable, including the secure erasure of electronic files.

7. YOUR RIGHTS

◐ Applicable Jurisdictions:
If you reside in the European Economic Area (EEA), the United Kingdom, Switzerland, Brazil, or are a legal resident of California in the United States, you are entitled to certain rights concerning your personal data. California residents should refer to Section 1 – California Privacy Rights. For all other applicable jurisdictions, the details and scope of these rights are explained below. To exercise any of these rights, please contact us at xumhinspirehk@gmail.com.

◐ Right to Access:
You have the right to request access to the personal information we hold about you, including details on how it is used and with whom it is shared. This right is subject to limitations—for instance, we may be unable to disclose information that would reveal trade secrets or the personal data of others.

◐ Right to Erasure:
You may request that we delete your personal information. However, there may be legal reasons for retaining certain data, such as compliance with legal obligations, protection against legal claims, or other overriding legitimate interests. If applicable, we will inform you of these exceptions. For data managed by external controllers like advertising partners or payment providers, we will make reasonable efforts to notify them, though we encourage you to contact them directly as per their privacy terms.

◐ Right to Object or Withdraw Consent:
You may withdraw your previously granted consent or object to our processing of your information where it relies on legitimate interests (see “How We Use Your Personal Information”). This includes the following options:

(1)To disable personalized ads: adjust settings via the website's privacy controls or, for mobile games, use in-app privacy settings.

(2)To opt out of marketing emails: click the unsubscribe link provided at the bottom of our emails.

(3)To turn off push notifications: update your preferences via your device or browser settings.

◐ Right to Data Portability:
You have the right to receive a copy of your personal information in a structured, commonly used, and machine-readable format. If feasible, you may also request that this information be transferred directly to another organization or service provider.

◐ Right to Correction:
If you believe the information we hold about you is incorrect or outdated, you can request that we update or correct it. We will take reasonable steps to ensure that any inaccurate or incomplete data is amended without undue delay.

◐ Right to Restrict Processing:
Under certain conditions, you may request that we temporarily restrict our processing of your personal information—for example, while a correction or objection request is being reviewed. During the restriction period, we may still store your data but will not use or share it unless required by law.

◐ Third-Party Data Controllers:
In cases where your information is managed by external providers (such as advertising networks or payment gateways), we will make a reasonable effort to relay your data-related requests. However, since we do not control those systems, we advise you to consult their privacy policies and contact them directly for deletion or access requests.

◐ How to Contact Us:
If you wish to exercise any of the rights listed above or have questions regarding your data, please reach out to us via email at xumhinspirehk@gmail.com. We will respond to your request in accordance with the applicable data protection laws.

8. CONTACT, COMPLAINTS, AND POLICY UPDATES

◐ How to Reach Us:
We welcome any questions, feedback, or requests you may have regarding this Privacy Policy. Please feel free to contact us at xumhinspirehk@gmail.com. We are committed to responding to your inquiries in a timely and transparent manner.

◐ Raising a Concern or Complaint:
If you have any concerns about how we collect, use, or protect your personal data, we encourage you to contact us at the same email address. We take all complaints seriously and will do our best to resolve your concerns as efficiently as possible.

◐ Policy Updates and Notifications:
We may revise or update this Privacy Policy from time to time. Any modifications will be made available via a designated link. If there are significant or material changes, we will notify you through our website and in-game messaging systems to ensure you are informed.

9. NO REAL MONEY

◐ All virtual assets and items available within the game are entirely fictional and hold no actual monetary value outside the game environment. They are intended solely for entertainment purposes within the game.

◐ Players are strictly prohibited from using these virtual items for any real-world transactions or activities aimed at generating actual financial value. Any attempt to assign real-world worth to in-game content is a violation of our terms.

SECTION FOR CALIFORNIA PRIVACY RIGHTS

◐ This Section applies specifically to individuals residing in California, in accordance with the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100–1798.199), including any future amendments or replacements ("CCPA"). The rights and obligations outlined here reflect the protections granted to California residents concerning the collection and use of their personal data.

◐ For the purposes of this Section, "Personal Information" means any data that identifies, describes, relates to, or could reasonably be connected, either directly or indirectly, to a particular individual or household, as defined under the CCPA. This does not include data legally obtained from public government sources, anonymized or aggregated information, or any other type of data that falls outside the CCPA’s coverage.

1. PERSONAL INFORMATION COLLECTION AND DISCLOSURE

◐ In the last 12 months, your interaction with the Games may have led us to collect and share several types of Personal Information. This includes identifiers such as your name, email, IP address, advertising ID, Rooted Fun ID, device identifiers, and profile images. If you signed up using a third-party account (e.g., Apple, Facebook, or Google), we may have also accessed your associated ID, display name, and avatar. We may also gather data related to your online activity, such as interactions with in-game events, features, or advertisements—typically obtained from external analytics or ad partners. Geolocation data, like city-level location, is acquired from your device or third-party logins. Commercial information, including purchase history or related details (e.g., Apple ID or Google billing region), is sourced from both you and payment processors.

◐ The sources of this Personal Information include direct input from you or your devices, advertising networks, analytics tools, and social platforms—limited to what you’ve allowed under applicable permissions. Each of these sources enables us to build a more relevant and personalized experience within the Games.

◐ We collect this data to serve various operational needs: to run and maintain our Games efficiently, to enhance game features and performance, to communicate important updates to users, to support personalized advertising, and to verify identity and prevent fraud. We also use this information to identify and resolve technical issues. For deeper details on how each type of data is used, refer to Section 3 of the main Privacy Policy.

◐ Your Personal Information may be shared with several categories of recipients. These include other users who can view your in-game profile and messages, corporate affiliates involved in game operations, marketing and ad partners delivering relevant promotions, and third-party service providers under strict contractual limits. We may also disclose your data to government bodies, law enforcement, or buyers if our business is transferred. Additional disclosure information can be found in Section 4 of the main Privacy Policy.

2.PERSONAL INFORMATION SALES & RIGHT TO OPT-OUT NOTICE

◐We may use third-party advertising and tracking tools within our Games to collect information about you, your devices, and your gameplay activities. This information is shared with selected third parties, such as advertising partners, who use it to deliver targeted ads to you. You have the option to opt out and control these technologies anytime by adjusting your Privacy Settings or, for some Mobile Games, through in-app settings. Alternatively, you can request to opt out by emailing us at xumhinspirehk@gmail.com. The California Consumer Privacy Act (CCPA) provides California residents with certain rights, subject to specific exceptions. If you are a California resident and no exemptions apply to you or your Personal Information, you may submit a verifiable request via email to obtain information about the types of Personal Information collected, sold, or shared about you in the last twelve months; the sources of such information; the purposes for collecting or selling it; the categories of third parties to whom it was disclosed; and the specific pieces of Personal Information gathered. You may also request deletion of your Personal Information. Exercising these rights cannot result in discriminatory treatment such as denial of goods, services, or different service quality, subject to legal limitations. We aim to respond to all verifiable requests within 45 days, with possible extensions of up to 45 additional days accompanied by an explanation.

◐To exercise your rights, please email us at xumhinspirehk@gmail.com. You can also opt out or modify your preferences via the Privacy Settings on our Website or within certain Mobile Games’ in-app options

◐Requests for access or deletion of Personal Information, whether made by you or an authorized agent, require us to reasonably verify your identity based on the information requested and applicable CCPA regulations. To assist with verification, please be ready to provide identifying details such as your User ID or in-game name so we can confirm your ownership of the account.

◐If you wish to authorize an agent to act on your behalf to submit requests for access, deletion, or opt-out, please notify us by emailing xumhinspirehk@gmail.com.

◐We do not rent, sell, or disclose your Personal Information to unaffiliated companies for direct marketing as defined under California’s "Shine the Light" law (Civil Code § 1798.83) unless you have granted permission. Additionally, because there is no universally accepted standard for responding to Do Not Track signals, we do not currently honor such requests.