Privacy Policy

Last updated: May 21, 2026

This Privacy Policy describes how SCRAMBLY SRL ("we", "us", "our") collects, uses, and shares information when you play our mobile game (the "Game") on Android. By using the Game you agree to the practices described below.

The Game is intended for users aged 18 and older. We do not knowingly collect data from individuals under the age of 16.

1. Data Controller

SCRAMBLY SRL
Via della Zecca 1, Bologna, 40121, Italy
Email: [email protected]

2. Information We Collect

We do not require account registration to play the Game. The following data is collected automatically by the Game and/or third-party SDKs integrated into it:

• Google Advertising ID (GAID)
• Device model, OS version, and language settings
• IP address and approximate location (country / region)
• App install source and referrer information
• Gameplay events and session duration
• Crash reports and diagnostic data

Legal basis: Processing is based on our legitimate interests (Article 6(1)(f) GDPR) to operate, maintain, and improve the Game, deliver advertising, and measure campaign effectiveness.

3. How We Use the Information

• Serving ads — to display relevant advertisements within the Game
• Install attribution — to understand which marketing campaigns drive installs and measure their effectiveness
• Analytics — to measure gameplay behavior and improve the Game
• Fraud prevention — to detect and prevent fraudulent activity
• Bug fixing — to detect and resolve crashes and technical issues

4. Third-Party SDKs and Service Providers

The Game integrates the following third-party services which may collect and process data independently or on our behalf. Each provider operates under its own privacy policy:

AppLovin MAX may serve ads from its advertising network partners (including but not limited to Google AdMob, Meta Audience Network, Unity Ads, and others). These partners may use your GAID to serve personalized ads in accordance with their own privacy policies.

5. Advertising and Opt-Out

The Game displays advertisements provided by AppLovin MAX and its network partners. Ads may be personalized based on your Google Advertising ID (GAID).

You can limit ad personalization at any time on your Android device:

• Go to Settings → Google → Ads
• Enable "Opt out of Ads Personalization", or reset your Advertising ID

6. Data Sharing

We do not sell your personal data. We may share data in the following situations:

• With service providers listed in Section 4, for the purposes described above
• With business partners — certain pseudonymized data (e.g. device identifiers, attribution data) may be shared with advertising and measurement partners for campaign performance and fraud prevention
• Business transfers — in connection with a merger, acquisition, or sale of assets, with prior notice
• Legal requirements — when required by applicable law or valid requests from public authorities

7. International Data Transfers

Your data may be transferred to and processed in countries outside the European Economic Area (EEA), including the United States. Where such transfers occur, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) approved by the European Commission, to protect your data in accordance with applicable law.

8. Data Retention

We retain analytics and attribution data only for as long as necessary to fulfill the purposes described in this policy. Usage data is generally retained for a shorter period. Third-party providers retain data according to their own retention policies.

You may contact us at any time to request deletion of data associated with your device.

9. Children's Privacy

The Game is not directed at children. We generally consider individuals under the age of 16 to be children, in line with GDPR and applicable data protection laws. We do not knowingly collect personal data from individuals under 16.

If you are a parent or guardian and believe your child has provided personal data through the Game, please contact us at [email protected] and we will delete it promptly.

10. Your Rights (EEA / GDPR)

If you are located in the EEA, you have the following rights regarding your personal data:

• Right to access — obtain confirmation of whether we process your data and receive a copy
• Right to rectification — request correction of inaccurate data
• Right to erasure — request deletion of your personal data
• Right to restriction — request that we limit processing of your data
• Right to object — object to processing based on legitimate interests
• Right to data portability — receive your data in a structured, machine-readable format
• Right to lodge a complaint — with your local data protection authority
• Right to withdraw consent — where processing is based on consent

To exercise any of these rights, contact us at [email protected]. We will respond within one month of receiving your request. We may ask you to verify your identity before processing the request.

11. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will update the "Last updated" date at the top of this page. Continued use of the Game after any changes constitutes your acceptance of the revised policy.

12. Contact Us

SCRAMBLY SRL
Via della Zecca 1, Bologna, 40121, Italy
Email: [email protected]