Privacy Policy

1. Introduction and General Terms

At Lucky Faces Games Limited ("Happy Faces Games", "we", "us"), we respect your privacy.

This Privacy Policy explains how we collect, use, process, and disclose personal data when you interact with our games, software, websites, and related products and services, including mobile games, online features, social media pages, and other digital properties (collectively, the "Happy Faces Games Products").

If you have any questions regarding this Privacy Policy, please contact us at info@happyfaces.games.

For the purposes of applicable data protection laws, including the UK GDPR, EU GDPR, and other relevant legislation, Lucky Faces Games Limited acts as the data controller where we determine the purposes and means of processing your personal data.

Please read this Privacy Policy carefully. It explains:

• what personal data we collect about you;
• how and why we use that data;
• with whom we share your data; and
• your rights and choices in relation to your personal data.

Our products may include links to third-party services. We are not responsible for the privacy practices of those third parties and encourage you to review their privacy policies.

2. Personal Data We May Collect About You

Information You Provide When Using Our Games ("Basic Data")

When you play our games, we may collect:

• a unique pseudonymous user identifier (User ID);
• gameplay preferences and settings;
• game session times and duration;
• in-game interactions and activity;
• in-game purchases;
• gameplay progression and milestones;
• content you create, upload, or share within our games.

Information Used for Advertising Purposes ("Advertising Data")

Depending on your device permissions and settings, we and our advertising partners may collect:

• device make, model, and operating system;
• screen size, orientation, battery status, audio settings;
• mobile network operator;
• country, language, and time zone;
• IP address;
• browser type;
• advertising identifiers (such as Apple IDFA or Android Advertising ID);
• interactions with advertisements.

Analytics Information ("Analytics Data")

We may collect technical and usage data to understand how our products are used, including:

• device ID and User ID;
• operating system and version;
• device model and manufacturer;
• gameplay attempts, progress, results;
• session timestamps and duration;
• purchase transaction types;
• install source and first-launch data;
• ad impressions and clicks;
• crash reports and performance diagnostics.

Information from Third-Party Platforms ("Third-Party Login Information")

If you access our games through third-party services (such as Apple Game Center, Google Play Games, or social media platforms), we may receive limited profile and technical data from those services, subject to your privacy settings.

3. Why We Collect and Use Personal Data

To Provide and Operate Our Games

We process personal data to:

• enable gameplay functionality;
• save progress and user preferences;
• support multiplayer and social features;
• ensure technical stability and performance.

Legal basis: performance of a contract and/or legitimate interests.

To Improve Our Products

We use aggregated and pseudonymised analytics data to:

• improve gameplay experience;
• fix bugs and technical issues;
• develop new features;
• evaluate marketing effectiveness.

Legal basis: legitimate interests.

Monetisation and In-App Purchases

Where applicable, we process data related to purchases to operate and improve monetisation features.

Legal basis: contractual necessity and/or consent (where required).

Advertising and Marketing

We may process advertising data to:

• display contextual or interest-based advertisements;
• measure ad performance;
• limit ad frequency.

Legal basis: legitimate interests and/or consent (where required by law).

You may withdraw consent via your device or in-app settings.

Fraud Prevention and Legal Compliance

We may process personal data to:

• detect and prevent fraud or cheating;
• enforce our terms;
• comply with legal obligations;
• protect users and our business.

4. Data Sharing

We may share personal data with:

Service Providers

Including analytics providers, hosting providers, customer support, payment processors, fraud prevention and security partners — strictly for providing services to us.

Advertising and Analytics Partners

Who help deliver ads, analytics, and attribution services, subject to their own privacy policies.

Corporate Transactions

In connection with mergers, acquisitions, or asset sales.

Legal and Regulatory Authorities

Where required by law or to protect legal rights.

With Your Consent

Where you have explicitly agreed.

5. Tracking Technologies

We and our partners use technologies such as SDKs, cookies, APIs, and pixels to:

• remember preferences;
• understand usage patterns;
• deliver analytics and advertising;
• prevent fraud.

These technologies may collect data across time and devices. You can control tracking via device settings and applicable consent tools.

6. Automated Decision-Making

We may use automated systems to detect cheating or abusive behaviour. Where access is restricted based on automated decisions, users may request human review and challenge such decisions.

7. Your Rights

Depending on your location, you may have the right to:

• access your personal data;
• correct inaccurate data;
• request deletion or restriction;
• object to processing;
• withdraw consent;
• opt out of targeted advertising;
• lodge a complaint with a supervisory authority.

To exercise your rights, contact us at info@happyfaces.games. We may verify your identity before processing requests.

UK users may also contact the UK Information Commissioner's Office (ICO).

8. Data Retention

We retain personal data only as long as necessary for the purposes described in this Privacy Policy, unless a longer retention period is required by law.

9. Children

Our products are not intended for children under 13 years of age. We do not knowingly collect personal data from children under 13. If such data is identified, it will be deleted promptly.

10. Security

We implement appropriate technical and organisational measures to protect personal data, including encryption, access controls, and internal policies. However, no system is completely secure.

11. International Data Transfers

Your data may be transferred outside the UK/EEA. Where this occurs, we use appropriate safeguards such as Standard Contractual Clauses or other lawful transfer mechanisms.

12. Additional Information for California Residents

California residents have rights under the CCPA/CPRA, including access, deletion, and opt-out of sale or sharing for targeted advertising. We do not knowingly sell personal data of minors under 16.

Requests may be submitted to info@happyfaces.games.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via our games, website, or email.