Trela Games LTD, Strovolou 77 street STROVOLOS CENTER office 301, Nicosia 2018 Cyprus (hereinafter: Trela Games and/or the Company and/or we and/or the Controller) takes care of your data and handles it honestly, transparently, entirely in accordance with applicable regulations as well as the best international practice in this area. The purpose of this Privacy Policy is to inform you of all the details of the processing and use of your personal data that may be collected when you use one of our company’s games and/or apps (hereinafter: games and/or apps and/or services and/or products), as well as the rights you have in connection with such processing of your data. This Privacy Policy also applies to the marketing and the display of targeted advertisements when using our games and/or apps, which you can learn more about in Section 4. Advertising and Marketing of this Privacy Policy.
By downloading, accessing and/or using our games and/or apps, you consent to the processing of your personal data in accordance with the terms set out in this Policy. Therefore, please read this Privacy Policy in detail, since it explains how and which of your personal data we collect, for what purposes and on what basis, as well as what rights you have in relation to the processing of your personal data and how you can exercise them.
Please note that some of our apps and games can be downloaded and used for free or can be purchased through the platforms listed in section 7. In-app purchases and sales of apps and games of this Policy. If you purchase one of our apps and games, your data related to the use of such apps or game will not be collected and processed for all the purposes specified in this Privacy Policy, so all provisions of this Privacy Policy do not apply to you. If you have purchased one of our apps or games, the following provisions of this Policy apply to the processing of your personal data:
so please read these provisions in detail in order to get familiar with all the aspects of processing of your personal data.
All terms used in this Privacy Policy in the masculine gender are also understood in the feminine gender and vice versa.
The Controller of your data is Trela Games LTD, Strovolou 77 street STROVOLOS CENTER office 301, Nicosia 2018, Cyprus. The contact details of the Controller are:
Registered seat: STROVOLOS CENTER office 301, Nicosia 2018
E-mail: office@trela.games
Contact details of the data protection officer:
For all questions regarding the processing of your personal data and in order to exercise your rights specified in this Privacy Policy, you can contact us at:
E-mail: dpo@trela.games
Registered seat: STROVOLOS CENTER office 301, Nicosia 2018, with the mandatory indication “for data protection officer”
When using our games and/or apps, we collect certain information about you. You can find more details regarding this further down in this section of the Privacy Policy.
In accordance with regulations, personal data is any data relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
We collect and process your data so that we can enable you to use our apps and games, in order to improve our products and services and thus provide a better user experience, for analytical and research purposes, to fulfill our legal obligations, to act on your requests, as well as for other purposes specified in this Privacy Policy.
We do not require users to provide us with personal data such as first and last name, e-mail address, phone number, etc. in order to use our games and apps. We can process this personal data only if provided by you when sending any request, in which case we will process it only for the purpose of acting on such a request and will not use it for any other or additional purposes.
When downloading our games and apps, we will ask you to enter your month and year of birth to determine your age. This information is necessary to comply with our legal obligations regarding the processing of children’s data. We do not store or process data about the month and year of your birth, this data only serves to verify your age.
However, when using our games and apps, we automatically collect non-identifiable information such as your age group (18-24, 25-34, 35-44, 45-54, 55-64, 65+ ), your gender (male or female), your general interests (such as sports, entertainment, news, etc.), device identifiers and other technical data related to them, including but not limited to the type and model of mobile device you use to interact with our games and apps, the unique identification number and IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, the country and region from which you access our products and services (whereas we do not collect data about the precise location of the device in real-time), what language your device is in, advertising ID number, data about interactions with ads as well as information on how you use apps and games (such as data about which apps and games you use, game progress, duration of play, purchases made within the app or game, whether there were technical problems in the functioning of the same, etc.).
We also automatically collect data provided by Facebook, Google or any third-party service you use when logging in (authentication) to our games. For more information regarding what data is provided by the services you use when logging in, please see their privacy policies.
Additionally, we also process your data when you contact us for any reason, whether for technical support related to the use of our games or apps, when sending any request, etc.
We may also process your personal data to improve safety and security when using our games and apps (detection and prevention of abuse, fraud, security risks, etc.).
We also process your data if you click on a link advertising our products on third-party websites, apps, platforms, etc., in which case we collect data about you related to your interaction with marketing material (click or tap), installed games or apps, country and city, as well as the previously mentioned device identifiers.
Our apps and games allow in-app purchases and may be for sale on some markets or platforms. When you buy our apps or games or make purchases within them, we do not collect data about you, since the entire transaction is carried out by the platform through which you made the purchase, and we only have generic data about such purchases, based on which we cannot identify any user. Only in the event that you contact us directly in connection with the completed purchase, we can process your personal data that you submitted to us on such occasion, and in order to act on your request regarding the completed purchase. You can learn more about this in section 7. In-app purchases and sales of apps and games of this Privacy Policy.
We also collect and analyze data about users that are anonymized and aggregated according to certain criteria in order to develop our games and apps and monitor their performance, their optimization, improvement and elimination of errors and disturbances in their functioning.
You can find more details about the data we collect and for what purposes, as well as the basis for their collection and processing below:
| Data | Basis for data collection | Purpose for which we use data |
| Month and year of birth | We do not store or process this personal data additionally, except for the purpose of complying with legal obligations. | This data is necessary for us to fulfill our legal obligations regarding the processing of children’s data. We do not store or process data about the month and year of your birth additionally, this data only serve to verify your age. |
| Data related to the
use of the game (progress in the game, level
achieved,
time spent in game, in-game purchases) |
Processing of this
data is necessary in order to perform the
contract, that is in order to provide services.
____________________________ The processing of this data may also be based on legitimate interest. |
We process this data
so that we could enable you to use the game.
_____________________________________ We may process this data based on legitimate interest in order to improve safety and security when using our games and apps (detection and prevention of abuse, fraud, security risks, etc.). |
| IP address, country and region | The basis for
processing of this data is your consent.
The processing is necessary in order to comply with our legal obligations as a controller in the context of various duties related to the processing of personal data imposed by the legislation of different countries. ____________________________ The processing of this data may also be based on legitimate interest. |
We process this data
in order to identify country and region from
which you access our products and services (we
do not collect data about the precise location
of the device in real time).
______________________________________ We may process this data based on legitimate interest in order to improve safety and security when using our games and apps (detection and prevention of abuse, fraud, security risks, etc.). |
| General technical data about the device (operating system version, device model and brand, device language, processor data, memory capacity, screen size, software, mobile operator, internet provider, etc.) | The basis for the
processing of this data is performance of the
contract.
____________________________ The processing of this data may also be based on legitimate interest. |
We need this data in
order to enable you to use our games and apps,
that is so that we could optimize our games and
apps for your device model and operating system
version that you are using.
______________________________________ We may process this data based on legitimate interest in order to improve safety and security when using our games and apps (detection and prevention of abuse, fraud, security risks, etc.). |
| Advertising ID, device identifiers, display of marketing material and interaction with marketing material (Advertising ID, IDFA) | The basis for processing of this data is your consent. | This data is necessary to display advertisements that are relevant in accordance with your interests, age, gender, collected from our games or apps, as well as from other games, apps or websites. Please note that the processing of this data and the selection of displayed advertisements is carried out by third parties based on the data you have shared with them through our products or those of others (e.g. TikTok, Google or Instagram). |
| Data specified in requests sent to us by users (name and surname, address, country, e-mail address, etc.) | Data processing is necessary in order to comply with our legal obligations in connection with the request you submitted. | We process this data so that we can act upon your request. |
In addition to the purposes of data collection and processing set out in this Privacy Policy, we may occasionally collect data for other purposes, in which case we will notify you in advance of the intended purpose of processing, the data that would be collected and every other circumstances relevant to such collection and processing of your data, so that you could decide if you want to give consent for such data processing.
Access to your data have only employees of our company who have the right to process it considering the type of work they perform and only to the extent necessary to fulfill the purposes stated in the previous section of this Privacy Policy.
Transfer and recipients of your personal data
As part of our business operations and when carrying out our business activities, we may, in accordance with the law, transfer your personal data to certain categories of recipients, so your data may be made available to the following recipients:
The transfer to other countries or international organizations is carried out exclusively under the conditions specified by the regulations governing the transfer of personal data. Accordingly, data is transferred only to countries that are members of the Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data, that is, which have been determined to provide an adequate level of protection. In the case of transfers to countries that are not members of the mentioned Convention, the transfer of data is carried out on the basis of a contract concluded between us and third parties that contain standard contractual clauses, as well as with the implementation of all necessary technical, organizational and personnel measures for the protection of personal data, which provide the same level of protection of your personal data as domestic regulations as well as the integrity and confidentiality of personal data. Such measures include prevention of misuse, loss, damage, unauthorized modification, access or processing and other risks to which it may be exposed by human action, physical or natural environment.
We and our partners, i.e. third parties, use data collected about you in order to show you marketing materials and content about our products (apps or games), as well as third party content, based on your interests. We may do this by sending e-mails, newsletters, displaying advertisements within our apps and/or placing advertisements about our products on third-party websites, apps and games. If you do not agree to your data being used for the stated purposes, it is necessary to turn off this possibility (opt out) in the manner specified in this section of the Privacy Policy.
Data we process for marketing and advertising purposes
We process your data in order to inform you only about those contents that might be of interest to you. This may include data such as:
Marketing and advertisement partners
We may advertise our apps and games through media owned by other companies, and our apps and games may also include displaying ads about the products and services of other companies or entities based on your interests. We cooperate with third parties who are our marketing and advertising partners and who, through various tools, provide us with the necessary assistance for displaying such ads, and we may share with them the data we have collected about you in order to achieve the aforementioned purpose.
By consenting to this Privacy Policy, as well as by using or continuing to play our games, unless you opt out of interest-based advertising, you consent to our marketing and advertising partners collecting and using your data, for the purposes of advertising as set forth in this Privacy Policy as well as other purposes as described in their respective privacy policies. Please note that our Privacy Policy does not govern your relationship with our marketing and advertising partners, so it is necessary and recommended that you review and familiarize yourself with their privacy policies in order to get informed about the collection and processing of your data from their side. You can find a list of our marketing and advertising partners at the following link.
How to turn off interest based advertisement tools (opt out)
Please note that the settings in our apps and games are set so that the above-mentioned tools that we use for marketing and advertising purposes are turned on by default. However, as a socially responsible company, we take into account your wishes, interests and right to privacy, and therefore we have made it possible for you to opt out of such tools in the manner described below in this section.
We would like to point out that even if you decide to turn off displaying interest based ads, that is if you do not want your data to be collected and processed for the stated purpose, you will still be able to use our apps and games without interruption. However, please note that you will still see ads within apps and games, however these ads will not be displayed based on your inferred interest determined by collection and processing of your personal data.
You can find out further in the text how you can opt out of displaying interest-based ads and the collection and processing of your data for that purpose:
We use this opportunity to inform you of the rights you have regarding the collection and processing of your data by our company:
Right to access the data: You have the right to be informed about your data we process, as well as the right to request a copy of your personal data.
Right to withdraw the consent: You have the right to withdraw the consent. Such withdrawal does not affect the lawfulness of processing based on consent before its withdrawal. The withdrawal can be given in written form, including an e-mail, or you can deactivate your account.
Right to rectification: You have the right to rectification of your inaccurate personal data without undue delay as well as the right to request correction, addition, and update if the data is incomplete.
Right to erasure (“right to be forgotten”): You have the right to request the erasure of data (the right to be forgotten) where one of the following grounds applies: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed, in case of consent withdrawal (where there is no other legal ground for the processing), in case you objects to the processing and there are no overriding legitimate grounds for the processing, the personal data have been unlawfully processed, where your personal data have to be erased for compliance with a legal obligation, when the personal data have been collected based on consent of a data subject without the appropriate age to consent.
Right to restriction of processing: You have the right to request restriction of processing if you believe that the data is inaccurate, if the processing is unlawful and you oppose the erasure of the personal data and requests the restriction of their use instead, your data is no longer needed for the purposes of the processing, but you require such data for the establishment, exercise or defense of legal claims, when you have objected to the processing of your data based on legitimate interest.
Right to portability: You have the right to receive the personal data concerning you which you have provided to us, and the right to have such personal data transmitted directly to another controller where technically feasible.
Right to object: If the processing is based on legitimate interests, or is necessary for the purpose of performing tasks in the public interest or the execution of legal regulations, you have the right to submit an objection, after which we will suspend further processing of that data, unless there is an overriding legal basis for processing over your interests, rights or freedoms, or are necessary to submit or exercise a legal claim or defend against it.
In addition, where personal data are processed for direct marketing purposes you have the right to object at any time to processing of your personal data for marketing after which your personal data shall no longer be processed for such purposes.
Right to lodge a complaint: If you believe that your rights to the protection of personal data have been violated, you can lodge a complaint with a supervisory authority based on your residence, place of work or place of the alleged infringement.
Within our apps and games, there is an option to purchase within the app or game itself, and on the other hand, the apps and games themselves may be for sale in some markets.
In-app and game purchases
Although some of our apps are free, they include in-app purchases. Such purchases can only be made after you enter your app store password, and please note that you are responsible for keeping that password secure. Maintaining your authentication and security is subject to the specific terms of the app store and your mobile device’s operating system. You should keep in mind a 15-minute window for iOS and a 30-minute window for the Android operating system, which occurs after downloading the app, during which time it is possible to make an in-app purchase without entering a password for such a purchase.
Selling our apps and games
As we mentioned, our games or apps may be for sale in certain markets, and the purchase may be made through the following platforms:
Google Play
Our apps can be purchased on the Google Play Store platform or the platform itself may offer in-app purchases, and therefore all payments for these purchases are processed by Google Play in accordance with its company’s rules and regulations. To read the Terms of Use for this company’s games and software, click here. If you want to know more about their privacy policy, click here.
App Store
Our apps may be purchased on the App Store platform or the platform itself may offer in-app purchases, and therefore all payments for these purchases are processed by the App Store in accordance with its company’s rules and regulations. To read the Terms of Use for this company’s games and software, click here. If you want to know more about their privacy policy, click here.
Steam
Our apps may be purchased on the Steam platform or the platform itself may offer in-app purchases, and therefore all payments for these purchases are processed by Steam in accordance with its company’s rules and regulations. To read the Terms of Use for this company’s games and software, click here. If you want to know more about their privacy policy, click here.
Nintendo
Our apps can be purchased on the Nintendo platform, and therefore all payments for these purchases are processed by Nintendo in accordance with its company rules and regulations. To read the Terms of Use for this company’s games and software, click here. If you want to know more about their privacy policy, click here.
Amazon
Our apps may be purchased on the Amazon platform or the platform itself may offer in-app purchases, and therefore all payments for these purchases are processed by Amazon in accordance with its company rules and regulations. To read the Terms of Use for this company’s games and software, click here. If you want to know more about their privacy policy, click here.
Samsung
We sell our apps on the Samsung platform or offer in-app purchases. However, all payments are processed through the respective services provided by Samsung. To read more about Samsung’s privacy policy, click here. If you want to know more about the Samsung Terms of Service, you can read about it here.
Huawei
Our apps can be purchased on the Huawei AppGallery platform or the platform itself may offer in-app purchases, therefore all payments for these purchases are processed by Huawei in accordance with its company rules and regulations. To read the Terms of Use for this company’s games and software, click here. If you want to know more about their privacy policy, click here.
As a socially responsible company, we strive to make our apps and games a safe environment for children, and we always measure ourselves to the highest standards in terms of protecting children and their privacy. Thus, we do not knowingly collect data about children under the age of 13, except for the data necessary for the functioning of the app (which are listed in section 2. Personal data we collect), therefore we have introduced the verification of the age limit (age gate) as a prevention of the processing of personal data of children under that age. However, this limit may differ in relation to the country in which you live, so please refer to the table below which contains information on the prescribed age of consent in different countries. If a parent or guardian of a child under a certain age becomes aware that his/her child has provided us with data without their consent, he/she should contact us at dpo@trela.games, in order to determine all aspects of such processing and disable the same if necessary.
| Country | Age of consent | Country | Age of consent |
| Austria | 14 | Luxembourg | 16 |
| Bulgaria | 14 | Netherlands | 16 |
| Croatia | 16 | Philippines | 18 |
| Czech Republic | 15 | Qatar | 18 |
| France | 15 | Republic of Cyprus | 14 |
| Germany | 16 | Romania | 16 |
| Greece | 15 | Serbia | 15 |
| Hungary | 16 | Slovenia | 15 |
| India | 18 | South Africa | 18 |
| Ireland | 16 | South Korea | 14 |
| Italy | 16 | Switzerland | 16 |
| Japan | 15 | Turkey | 18 |
| Kingdom of Saudi Arabia | 18 | Ukraine | 18 |
| Lithuania | 16 | United Arab Emirates | 21 |
Some of our apps offer you the ability to chat with a virtual character. All our apps that offer such a feature will always ask you for permission to access your device’s microphone in advance. If you choose to give us permission, the virtual character will be able to repeat what you say to it. Please note that our apps do not have a sound recording feature, so what you say to the virtual character is not processed or stored on our servers, and it is used only by the app to play back what you said in real time. If you choose not to give us permission to access the microphone on your device, you will not be able to use the ability to talk to the virtual character while all other features of the games or apps will work without interruption.
We are taking care of your data privacy. Accordingly, we apply the highest possible level of protection of your data, including technical protection measures such as firewall, encryption, pseudonymization, passwords access restriction, data storage on servers in a local network without internet access to prevent the possibility of unauthorized access, which can be accessed only from a VPN with a certain IP address; physical protection measures such as storing data in special locked rooms with limited access; organizational and personnel measures such as limited access control, adequate training of employees, conclusion of a data confidentiality agreement, all in order to meet the requirements for data processing in accordance with the law, with the aim of ensuring the highest possible degree of protection of your data and minimizing the risk that may arise from the processing of your personal data.
As a responsible company, we do not use automated decision-making or automated profiling.
In addition to all cases specified in this Privacy Policy, we may process and share your data with third parties in the following cases:
This Privacy Policy is subject to change. Any changes to this Privacy Policy will be posted on our web page, so you can familiarize yourself with those changes. Please note that the web page will always display the latest version of the Privacy Policy, which you can access at any time via the following link. Please note that changes to the Privacy Policy will not reduce the level of protection of your data.
If you have any questions regarding the collection, processing and protection of your data while using our products and services, or if you have any questions about our work, please contact us by email at dpo@trela.games.
1. Residents of Brazil
In addition to the information contained in the previous sections of this Privacy Policy regarding the processing of your data, the following is additional information related to the processing of Brazilian resident data.
We process your data based on the principle of non-discrimination, therefore we do not process your personal data for unlawful or abusive discriminatory purposes.
In accordance with the regulations that define the age limit for giving consent, we have introduced age verification, therefore we do not knowingly and on purpose collect data about children under the age of 13, except for the data necessary for the functioning of our games and apps specified in section 2 of this Privacy Policy.
If a parent or guardian of a child under a certain age becomes aware that his/her child has provided us with data without their consent, he/she should contact us at dpo@trela.games, in order to determine all aspects of such processing and disable the same if necessary.
We will respond to your possible requests within the deadlines prescribed by the laws that apply to you.
2. Residents of the United States of America
In addition to the information contained in the previous sections of this Privacy Policy regarding the processing of your data, below is additional information related to the processing of data of children under the age of 13, residents of the United States of America to whom the Children’s online privacy protection rule (COPPA) applies.
In an effort to create a healthy and safe environment for children in our games and apps, we do not knowingly and on purpose collect data from children under the age of 13 in our games and apps, except for data necessary for the operation of our games and apps (which are set out in Section 2. Personal data we collect), nor do we use the data of children under this age to deliver personalized advertising materials to them. In order to prevent the collection and processing of data on children under the age of 13, we apply an age gate when logging into our games and apps, so we ask you to provide accurate information regarding your age.
With the aim of fair, transparent and non-deceptive data processing of the users of our games and apps, we have created this Privacy Policy, which is published on our website, which you can also access through the platform through which you download our games and apps, which contains all the information regarding the personal data we collect from our users, including children, how we use such data and whether, when and how we make it available to third parties.
We do not condition the use of our games and apps by providing additional personal data, especially of children, which are not reasonably necessary for the functioning of our products, on the contrary, a person who during age verification, provided information that he is younger than 13 years old, will be able to use our products, although in that case we do not collect his personal data except for the data that are necessary for the functioning of the game or app.
If a parent or guardian of a child under the age of 13 becomes aware that his/her child has provided us with data without their consent, he/she should contact us at dpo@trela.games to determine all aspects of such processing. In that case, the parent has the right to request access to the data provided by his/her child. Also, the parent of a child under the age of 13 has the right at any time to refuse to allow us to further use or collect data from his/her child, and to submit a request to delete data about the child that has been collected up to that time, in which case, we may disable a child from further use of our games or apps.
