Privacy Policy

Last Updated: June 19, 2025

This Privacy Policy describes how Vito immortalis d.o.o. ("we," "us," or "our") collects, uses, discloses, and manages your personal information when you use our Anagram Arena mobile game and related services ("Services"). This policy applies exclusively to Anagram Arena and is intended for users who are at least 13 years old and reside in any country worldwide, except for the following restricted territories: Democratic People's Republic of Korea (North Korea), Iran, Syria, Cuba, Somalia, South Sudan, Eritrea, Central African Republic, and Sudan ("Restricted Countries").

By accessing or using our Services, you confirm that you are at least 13 years old, do not reside in a Restricted Country, and agree to the collection and use of your information in accordance with this Privacy Policy. If you do not meet these requirements or do not agree to this policy, please do not use our Services.

1. Information We Collect

a) Information You Provide to Us

• Account Information: When you create an account or interact with our game, we may collect personal information such as your name, email address, and username. We do not store passwords; authentication is handled securely through third-party services.
• Communications: If you contact our support team, we may collect information such as your name, email address, the content of your communications, and any other details you provide.

b) Information We Automatically Collect

• Device Information: We may collect information about the device you use to access our Services, including the hardware model, operating system, unique device identifiers (such as IDFA or GAID), and mobile network information.
• Usage Data: We collect data about your interactions with our Services, including game progress, in-game activities, session duration, and crash logs.
• Location Data: We may collect your general location (e.g., country or region) based on your IP address to ensure compliance with geographic restrictions and applicable laws.

c) Information From Third Parties

We may use your information from third-party services, such as social media platforms (e.g., if you log in through a social media account) or payment processors when you make in-app purchases.

2. How We Use Your Information

We use the information we collect for the following purposes:

• To Provide and Improve Our Services: To operate, maintain, and enhance your gaming experience, fix bugs, and improve performance.
• To Personalize User Experience: To customize game content and features based on your in-game activities and preferences.
• To Process Payments: To complete transactions and provide customer support for in-app purchases.
• To Communicate With You: To send updates, service-related notifications, and, with your consent where required, marketing communications. You can opt out of marketing communications at any time.
• To Ensure Safety and Security: To monitor, investigate, and prevent fraudulent activities and enforce our Terms of Use.
• To Comply with Legal Obligations: To comply with applicable laws, regulations, and legal requests in the jurisdictions where our Services are available.

3. Sharing of Your Information

We do not share your personal information with third parties except in the following situations:

• Service Providers: We share data with third-party service providers who assist in delivering and supporting our Services, such as cloud hosting, analytics, and customer support, under strict data protection agreements.
• Business Transfers: In the event of a merger, acquisition, or sale of our company, we may transfer your personal information to relevant third parties.
• Legal Requirements: We may disclose your information to law enforcement or government authorities if required by law or in response to valid legal requests.
• With Your Consent: We may share your data with third parties when you provide explicit consent.

4. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. You may request deletion of your account or personal information by contacting us at contact@anagramarena.com.

5. International Data Transfers

Our company is based in Croatia, and your information may be processed and stored in Croatia or other countries where our service providers operate. These countries may have different data protection laws than your home country. We implement appropriate safeguards, such as Standard Contractual Clauses (SCCs) for transfers to the EEA or UK, to ensure your information is protected in accordance with applicable laws. By using our Services, you consent to the transfer of your data to countries outside your place of residence, where permitted by law.

6. Age Restrictions and Children's Privacy

Our Services are not directed to individuals under 13 years old. We do not knowingly collect personal information from children under 13. If we become aware that a user under 13 has provided personal information, we will promptly delete their account and associated data in compliance with applicable laws, such as the Children’s Online Privacy Protection Act (COPPA). If you believe we have collected data from a child under 13, please contact us at contact@anagramarena.com.

7. Security of Your Information

We use reasonable technical and organizational measures to protect your personal information from unauthorized access, use, or disclosure. However, no system is completely secure, and we cannot guarantee absolute security.

8. Your Rights and Choices

Depending on your location, you may have the following rights regarding your personal information:

• Access: Request access to the personal data we hold about you.
• Rectification: Request correction of inaccurate or incomplete data.
• Deletion: Request deletion of your personal data, subject to legal exceptions.
• Restriction: Request restriction of processing in certain circumstances (e.g., for EEA residents under GDPR).
• Data Portability: Request a copy of your data in a structured, machine-readable format.
• Objection: Object to processing based on legitimate interests or for direct marketing (e.g., for EEA residents under GDPR).
• Withdraw Consent: Withdraw consent where processing is based on your consent.
• Opt-Out of Marketing: Unsubscribe from marketing communications by following instructions in the communication.

To exercise these rights, contact us at contact@anagramarena.com. We may verify your identity before processing requests. If you are in the EEA or UK, you may also lodge a complaint with your local data protection authority.

9. Third-Party Services and Links

Our Services may include links to third-party websites or services. We are not responsible for their privacy practices and encourage you to review their privacy policies.

10. Residents of Restricted Countries

Our Services are not available in the Democratic People's Republic of Korea, Iran, Syria, Cuba, Somalia, South Sudan, Eritrea, Central African Republic, or Sudan. We use IP address checks and other methods to identify and block access from these countries. If we detect unauthorized access from a Restricted Country, we will immediately terminate the account and delete any associated personal data. If you believe we have inadvertently collected your data from a Restricted Country, please contact us at contact@anagramarena.com.

11. California Residents

Under the California Consumer Privacy Act (CCPA), California residents have the following rights:

• Right to Know: Request details about the personal data we collect, use, disclose, or share.
• Right to Delete: Request deletion of your personal data, subject to legal exceptions.
• Right to Opt-Out of Sale: We do not sell personal information.
• Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.

Contact us at contact@anagramarena.com to exercise these rights. We will verify your identity before processing requests.

12. European Economic Area (EEA) and United Kingdom (UK) Residents

If you reside in the EEA or UK, your personal data is processed in accordance with the General Data Protection Regulation (GDPR) or UK GDPR. Our legal basis for processing your data includes:

• Contract: To provide our Services as per our Terms of Use.
• Consent: For certain processing activities, such as marketing communications, where you have given explicit consent.
• Legitimate Interests: For activities like improving our Services, ensuring security, and preventing fraud, where our interests do not override your rights.
• Legal Obligation: To comply with applicable laws.

You may exercise your GDPR rights (listed in Section 8) by contacting us at contact@anagramarena.com. You may also lodge a complaint with your local data protection authority.

13. Changes to This Privacy Policy

We may update this Privacy Policy periodically. Changes will be posted here with an updated "Last Updated" date. We encourage you to review this policy regularly.

14. Contact Us

For questions or concerns about this Privacy Policy or our data practices, contact us at contact@anagramarena.com.