Privacy Policy

Last updated: 19 September 2026

1. Introduction

This Privacy Policy applies to all mobile applications and games published by SKILOS GAMES LTD, Neofytou Nikolaidi & Theodorou Kolokotroni, Onisiforou Center, 2nd floor, Agios Theodoros, 8011, Paphos, Cyprus.

We respect your privacy and are committed to protecting your personal data. This Policy explains how we collect, use, process, share, and safeguard information when you use our Services.

By downloading, accessing, or using our Services, you acknowledge that your information may be processed as described in this Privacy Policy.

2. Who are we?

SKILOS GAMES LTD is a Cyprus-based game development company. This Privacy Policy explains how we collect, use, and protect your personal data as you play our games.

If you are not an adult, please get permission from your legal guardian before using our games. For any questions, contact us by email at support@skilosgames.com.

We have not appointed a statutory Data Protection Officer, as our size and activities do not currently require one under the GDPR. For any data protection query — including requests you would otherwise direct to a Data Protection Officer — contact us at support@skilosgames.com.

Data Controller

3. What data do we collect, and why?

Our Services do not require you to create an account, and we do not directly collect your name or email address in order for you to play. The table below sets out what is collected on our behalf, and why.

Data processing overview

We do not collect GPS coordinates or any other precise geolocation data from your device. The only location-related data we process is coarse, IP-derived location (such as country or region), as noted in the table above.

We do not currently offer user accounts or social login (for example, via Facebook), so we don't collect profile, friends-list, or login data of that kind. If we introduce features like this in the future, we will update this Policy before they launch.

4. Legal bases for data processing

We process your personal data only when necessary to provide and improve the Services. Our legal bases include:

• Contract: for processing in-app purchases.
• Legitimate interests: for security, fraud and cheat prevention, and improving the Services.
• Consent: for the use of advertising identifiers and any advertising or analytics processing that relies on your permission (e.g. personalised ads). Under the GDPR and the ePrivacy Directive, this processing relies on consent rather than legitimate interest, and you can withdraw it at any time (see Section 7).
• Legal obligations: to comply with applicable law, such as tax reporting.

5. How do we share your data?

We do not sell your personal data. However, to provide you with our services, we may share your data under the following circumstances:

1. Service Providers and Partners:
   • Technical/Customer Support Providers: Companies that help us operate and maintain the Services.
   • Cloud/Hosting Services: Providers that securely store and process data on our behalf.
   • Analytics and Advertising Partners: Third parties that assist us in understanding usage patterns and delivering relevant ads (subject to your consent).
   • Software Providers: Partners offering services in accordance with our instructions and contractual obligations regarding data protection.
   Our current partners include:
   • Singular
   • Unity
   • Unity Game Player & App User Privacy Policy (covers ironSource/LevelPlay)
   • Google Privacy & Terms
   • Google Play Services Terms
   • Firebase Privacy and Security
   • Amplitude
   We update this list whenever we add or remove a partner.
2. Affiliates and Business Transfers: Data may be shared within our corporate group or transferred in connection with mergers, acquisitions, or asset sales, subject to confidentiality agreements.
3. Legal and Regulatory Requirements: We may disclose data to comply with legal obligations, respond to lawful requests, or protect the rights, property, or safety of our users or the public.
4. International Transfers: When data is transferred outside the EEA — for example, to our US-based partners such as Google and Amplitude — we ensure appropriate safeguards are in place, such as Standard Contractual Clauses and, where the recipient is certified, reliance on the EU-U.S. Data Privacy Framework (including its UK extension and the Swiss-U.S. Data Privacy Framework, where applicable). Where Brazil's LGPD or Korea's PIPA applies to you, we rely on equivalent safeguards recognised under those laws for any similar cross-border transfer of your data.

6. Data retention

We keep personal data only as long as necessary for the purposes above, or as required by law:

• Advertising & analytics data — retained by our partners under their own policies; aggregated or anonymised data may be kept indefinitely unless you opt out.
• Transaction data — kept for up to 7 years where required for tax or accounting purposes.
• Support data — kept for the duration of the support case, or as required by law.

7. How can you control your data?

Depending on where you live, you may have the right to:

• Access a copy of the data we hold about you;
• Correct inaccurate or incomplete data;
• Delete your personal data;
• Restrict or object to our processing of your data;
• Withdraw consent where processing relies on it (e.g. personalised advertising) — the quickest way is the Privacy Settings button in the Service's own settings menu;
• Data portability: receive the data you've provided us in a structured, commonly used, machine-readable format, under the GDPR and similar laws;
• Lodge a complaint with a data protection supervisory authority. If the GDPR applies to you, our lead supervisory authority is Cyprus's Office of the Commissioner for Personal Data Protection; you may also complain to the supervisory authority in your own EU/EEA country of residence.

If Korea's PIPA applies to you, you may also have the right to request temporary suspension of processing under that law.

You can review and change your advertising and analytics consent choices at any time using the Privacy Settings button in the Service's own settings menu — withdrawing consent this way is as simple as giving it. You can also limit tracking at the device level, by resetting or opting out of your advertising identifier (see Section 3). To exercise any other right above, email support@skilosgames.com; we may ask you to verify your identity first, and we aim to respond within 30 days.

8. How do we protect your data?

We take reasonable technical and organisational measures to help protect data against unauthorised access, alteration, or loss, including data encryption in transit and at rest where applicable, restricting data access to authorised personnel, and periodically reviewing our practices.

9. Children's privacy

Our Services are not directed at children under the age of 13 (or the minimum digital age of consent in your jurisdiction, if higher). We do not knowingly collect personal data from children under 13.

If we learn that we've inadvertently collected personal data from a child under 13, we will promptly delete it. Parents or legal guardians who believe we've done so can contact us at support@skilosgames.com and we will take appropriate action.

10. California privacy rights

California residents have additional rights under the CCPA and CPRA, including the right to know what personal data we've collected about you in the past 12 months, the right to delete it (subject to legal exceptions), the right to correct inaccurate data, the right to opt out of any sharing that could count as a "sale" under these laws (we don't sell data), and the right not to be treated differently for exercising these rights. To exercise them, contact support@skilosgames.com.

11. Changes to this policy

We may update this Privacy Policy from time to time — for example, as we release new games, features, or advertising partners. Where a change is significant, we'll let you know through the Services or another appropriate channel. We'll always update the "Last updated" date above.

12. Contact us

If you have questions, concerns, or requests about this Privacy Policy or our data practices, contact us at:

This Policy is written in English. In the event of any discrepancy between translations, the English version prevails.