Privacy Policy for Black Room Games
Last Updated: December 10, 2025
Introduction
Welcome to the Services provided by Black Room Games ("Black Room Games," "we," "our," or "us"). We are committed to protecting your privacy. This Privacy Policy describes our practices for collecting, using, and sharing your personal information when you use our mobile game(s) and associated services (collectively, the "Services").
By using our Services, you agree to the data practices described in this Privacy Policy. If you do not agree, please do not use the Services.
1. The Data We Collect
We collect data necessary to provide, analyze, and secure our Services. This information generally falls into the following categories:
| Category | Specific Data Points Collected | Purpose of Collection |
|---|---|---|
| A. Device & Technical Data | Device make and model, Operating System and version, screen size, battery status, network type, anonymized device identifiers (for advertising/analytics). | Service optimization, fraud prevention, security, and compliance. |
| B. Network & Location Data | IP address, country, region, time zone, and language settings. | Localizing content, legal compliance, and security. |
| C. User Interaction Data | Onboarding flow completion, in-app purchases (IAPs), objective completions, session stats, app usage, crashes, and performance metrics. | Improving gameplay, bug fixing, and analysing user engagement/retention. |
| D. Advertising & Attribution Data | Ad impressions, clicks, conversions, campaign performance, and information inferred from your interaction with advertisements (e.g., browsing/purchasing tendencies). | Delivering personalized ads, measuring campaign effectiveness, and generating revenue. |
| E. Third-Party Analytics Data | Data collected by our integrated partners (e.g., AppLovin) for analytics and advertising purposes, which may include inferred behaviour and aggregated data. | Detailed performance analysis. |
Crucially, we do not intentionally collect sensitive network data, system files, or information that could be used to exploit security vulnerabilities, which is prohibited under the Device and Network Abuse policy.
2. How We Use Your Data
We use the collected information for the following legitimate business purposes:
To Provide and Maintain the Services: To deliver the core game experience and ensure the proper functioning of the app.
For Analytics and Improvement: To analyze game performance, track engagement, retention, and monetization, and inform updates and new features.
For Security and Legal Compliance: To ensure security, detect and prevent fraud, adhere to all applicable laws and regulations, and address compliance violations by monitoring data access.
3. Legal Basis for Processing (e.g., GDPR)
We rely on the following legal bases for processing your personal data, where required by law:
Consent: Where you have explicitly provided consent (e.g., for certain types of personalized advertising). You may withdraw this consent at any time.
Legitimate Interests: Necessary for our legitimate interests (e.g., security, fraud prevention, operating and improving our business), provided your rights do not override those interests.
Contractual Necessity: Necessary to perform a contract with you (e.g., providing the Services you request).
Legal Obligation: Necessary to comply with a mandatory legal obligation.
4. Sharing of Information
We do not sell your personal data. We only share it with third parties necessary to operate the Services or as required by law:
Analytics and Advertising Providers: Such as AppLovin, to assist us in analysing performance and serving advertisements. These partners must comply with all applicable data protection laws.
Cloud Hosting and Service Providers: To store data and perform business operations (e.g., cloud services).
Legal Authorities: When required by law, court order, or governmental request (e.g., to comply with the Device and Network Abuse policy or other regulatory requirements).
With Your Consent: Where you explicitly agree to the sharing.
5. International Data Transfers
Your data may be transferred to and processed in countries outside your country of residence, including those with different data protection laws. We implement appropriate safeguards (such as Standard Contractual Clauses (SCCs)) to ensure your personal data remains protected in accordance with this Privacy Policy.
6. Data Retention
We retain your personal data only for as long as necessary to fulfil the purposes outlined in this policy, or as required by law (e.g., tax, accounting, or compliance requirements). Once data is no longer necessary, we will securely delete or anonymize it.
7. Your Rights and Choices
Depending on your jurisdiction (e.g., EU, California), you may have the following rights regarding your personal data:
Access, Correction, and Deletion: The right to request access to, correction of, or deletion of your personal data.
Objection and Restriction: The right to object to or request the restriction of processing your personal data.
Withdraw Consent: The right to withdraw any previously given consent at any time.
Data Portability: The right to request a copy of your personal data in a portable format.
To exercise these rights, please contact us via email: info@blackroomgames.ge. We commit to responding to your request within 15 business days.
8. Third-Party Links and Services
Our Services may contain links to or integrations with third-party websites or services (like advertising networks). We are not responsible for the privacy practices or content of these external parties. We strongly recommend reviewing the privacy policies of any third-party before providing them with your data.
9. Children's Privacy
Our Services are not intended for children under the age of 13 (or 16 in certain jurisdictions). We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected data from a child, we will take immediate steps to delete it.
10. Do Not Track
We currently do not respond to "Do Not Track" (DNT) browser signals. We will update this policy if our practices change.
11. Changes to This Policy
We may update this Privacy Policy from time to time. We will post the revised policy with a new "Last Updated" date. We will notify you of material changes where required by law. We encourage you to review this policy periodically.
12. Contact Us
If you have any questions or concerns about this Privacy Policy or our data practices, please contact us:
Email: info@blackroomgames.ge
Post: Black Room Games LLC, Gorgasali Str. Turn 3,
Tbilisi, Georgia, 0114