Privacy Policy

Everplay Portfolio Games (as listed in Schedule 1)

Effective Date: 4 September 2026

Last Updated: 10 September 2026

1.                            Scope

This Privacy Policy explains how Everplay Games Ltd. (“Everplay,” “we,” “us,” or “our”) collects, uses, and discloses information when you use any of the Android games listed in Schedule 1 (each, a “Game,” and together, the “Games”). This Policy is a shared policy that covers each listed Game. It applies to a Game only where the entry for that Game in Schedule 1 identifies the exact Game title, the exact Google Play package name, the effective date of this Policy for that Game, and any title-specific privacy supplement that applies to that Game.

Adding a Game to Schedule 1 applies this Policy to that Game from the effective date shown for that Game. It does not change or describe processing that occurred before that date. If a Game differs in a material way from the practices described in this Policy, including its data practices, software development kits, identifiers, permissions, audience, or features, those differences will be described in a title-specific privacy supplement identified for that Game in Schedule 1, and that supplement controls for that Game to the extent of any inconsistency.

This Policy applies to all use of a Game, whether or not GooseUp or any other Everplay application is also installed on your device. Each Game collects and reports gameplay, advertising, attribution, analytics, diagnostics, security, and technical information as part of its ordinary operation, regardless of whether GooseUp is installed, in order to operate, measure, improve, and secure the Game. If you also install GooseUp, the additional processing described in the GooseUp section below will also apply.

Each Game covered by this Policy at initial launch is published and developed by Everplay Games Ltd., is rated 18+ / Mature, is not directed to children, and is not enrolled in Google Play Families. Each of these Games uses AppLovin for advertising mediation, Adjust for attribution and mobile measurement, Bureau for device security and fraud prevention, and BugSnag for crash reporting, diagnostics, stability, and release-health monitoring. None of these Games offers in-app purchases, paid virtual items, subscriptions, or other paid features, and none includes chance, wagering, gambling, or loot-box mechanics, user-generated content, public posting, chat, social features, or cross-promotion. Each of these Games uses the same qualifying-event, identifier, software development kit, and GooseUp installation framework described in this Policy, and no material title-level difference has been identified for these Games.

2.                            Categories of Information Collected

Category

Examples

Identifiers

Google Advertising ID (GAID), when available; Everplay’s internal user identifier; Android ID (ANDROID_ID) and other device or security identifiers, where used and permitted under applicable Google Play policies

Device and Technical Data

Device model, operating system version, application version, language, screen characteristics, network information, IP address, and approximate location inferred from IP address

Gameplay Data

Sessions, levels, milestones, gameplay events, and other in-game activity

Advertising Data

Ad impressions, clicks, completions, and rewarded-ad activity; advertising identifiers transmitted to advertising mediation and network partners

Attribution Data

Install source, campaign information, attribution data, and post-install event information provided to our attribution and measurement provider

Diagnostics and Stability Data

Crash reports, diagnostic logs, application stability, and release-health information

Fraud and Security Data

Fraud, security, device-integrity, and risk signals

Support and Request Data

Information you provide when you contact us for support or submit a privacy request

We also collect device-security and device-integrity signals through Bureau for security, fraud prevention, and related risk assessment. See the Service Providers and Disclosures section below.

We also collect crash reports and diagnostic information through BugSnag for stability, diagnostics, and release-health monitoring.

3.                            Sources of Information

We collect information directly from your device when you use a Game, and we receive information from our advertising mediation, attribution and measurement, analytics, diagnostics, and security service providers. We also collect information you provide when you contact us for support or submit a privacy request.

4.                            Purposes of Collection and Use

·       Provide, operate, maintain, and improve the Games

·       Measure gameplay activity and progress milestones

·       Deliver and measure advertising

·       Attribute installations and campaigns

·       Diagnose crashes and maintain application stability

·       Perform internal analytics and reporting, including through Snowflake, Bruin, and Domo

5.                            Detect and prevent fraud, abuse, manipulation, and security incidents

6.                            Support the optional GooseUp integration described below

7.                            Respond to support and privacy requests

8.                            Comply with legal obligations and protect legal rights

9.                            Create aggregated or de-identified information for lawful operational, security, and analytical purposes

10.                      European Privacy and Legal Bases

Everplay is established in Malta, and the GDPR applies to the processing described in this Policy. Everplay relies on the following legal bases for Game processing: performance of a contract, or steps at your request before entering into one, to provide, operate, maintain, and improve the Games and respond to support requests; our legitimate interests to operate and improve the Games, maintain security, prevent fraud and abuse, diagnose crashes, maintain stability, conduct internal analytics and reporting, and measure gameplay, advertising, and attribution; consent where required by law for advertising and attribution; and legal obligations, where necessary, to comply with law or protect legal rights.

We balance these legitimate interests against your rights and freedoms and do not rely on them where those interests are overridden.

11.                      Advertising and Attribution

Each Game displays advertising served through AppLovin, which acts as our advertising mediation platform and may pass ad requests to its network partners. Adjust provides attribution and mobile measurement services. A Game may display interstitial, banner, rewarded-video, or other advertisement formats. These providers may process Google Advertising ID (when available), identifiers they generate, IP and network information, device and application information, install and campaign information, and application or advertisement interaction data through their configured services. Everplay does not intentionally provide its internal user identifier or ANDROID_ID to AppLovin or Adjust for advertising or attribution purposes.

When you reset or delete your Advertising ID, we treat that as a clean break in advertising identity. We do not bridge old and new Advertising IDs using a persistent identifier.

12.                  Device Permissions

The Games use standard network and advertising permissions. On Android 13 and later, a Game may ask for your permission to send notifications. Notification permission is optional, and you can grant or withdraw it at any time in your Android settings. Granting notification permission does not allow us to read the content of notifications on your device.

 

The Games covered by this Policy at initial release do not request camera access, microphone access, device location permission, broad package-visibility access, or Usage Access permission. We do not collect precise device location. Where this Policy refers to location, it means approximate location inferred from an IP address.

13.                      Service Providers and Disclosures

We disclose information to the following categories of recipients. A recipient’s role depends on the processing it performs and applicable law. Where a recipient processes information on our behalf, we put in place a written agreement as required by applicable law:

·       Ad mediation and network partners (AppLovin and its demand-side partners)

·       Mobile measurement and attribution (Adjust)

·       Internal analytics infrastructure (Snowflake, Bruin, Domo)

·       Device security, fraud prevention, and related risk assessment (Bureau)

·       Crash reporting, diagnostics, stability, and release-health monitoring (BugSnag)

·       We may also disclose information to comply with legal obligations, enforce our terms, or protect rights and safety.

·       Bureau’s role for the Games is limited to device security, fraud prevention, and related risk assessment. Ordinary use of a Game does not involve identity verification, biometric collection, or facial liveness checks. Verification of that kind occurs only within the separate GooseUp Cashout process and is described in the GooseUp Privacy Policy.

14.                      International Transfers

Some recipients may process personal information outside the European Economic Area, the United Kingdom, or your jurisdiction. Where a transfer is subject to Chapter V of the GDPR or equivalent requirements, Everplay will make the transfer only where permitted by applicable law and where a lawful transfer basis and any required safeguards apply. Information about safeguards applicable to a particular transfer may be requested from us at hello@everplay.gs.

15.                      If You Also Install GooseUp

You do not need to install or use GooseUp to download, install, or play a Game. Each Game collects and reports the information described in this Policy as part of its ordinary operation, whether or not GooseUp is installed. GooseUp and its rewards program are available only to people age 18 and older. GooseUp must be separately installed on the same device as the Game before Coins can be credited. If GooseUp is installed on that device, Everplay may use qualifying Game events and related technical information to determine and credit GooseUp Coins. GooseUp does not need to be open or running in the foreground for this to occur. The GooseUp Privacy Policy (https://everplay.gs/PrivacyGooseUp.html) governs the GooseUp rewards profile, Coin crediting, Cashout, verification, and related GooseUp processing.

16.                      Retention

We retain information no longer than reasonably necessary for the purposes described in this Policy. In determining the applicable period, we consider operation of the Games, advertising and attribution needs, analytics and diagnostics, security and fraud risks, the optional GooseUp relationship, support and privacy requests, disputes and legal claims, legal holds and recordkeeping, and applicable legal obligations. Upon a valid deletion request, or as otherwise required by applicable law, we delete or de-identify personal information, subject to lawful retention exceptions and ordinary backup cycles. We may retain information for longer where required or permitted by law, including for legal holds, disputes, fraud or security investigations, legal claims, recordkeeping, or other legal obligations.

17.                      Security

We use technical and organizational measures designed to protect information against unauthorized access, loss, or alteration. No method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.

18.                      European Privacy Rights

You may request access to, correction or deletion of, restriction of processing of, or a portable copy of your personal information. You may object to processing based on our legitimate interests. To exercise these rights, contact us at hello@everplay.gs. We may verify your identity and will respond within the timeframe required by applicable law.

Where processing is based on your consent, you may withdraw consent at any time by contacting us at hello@everplay.gs; withdrawal does not affect the lawfulness of processing before withdrawal. You may object to direct marketing at any time by using the unsubscribe option in a marketing communication or by contacting us at that address. You may lodge a complaint with your local supervisory authority. If you are in Malta, you may lodge a complaint with the Office of the Information and Data Protection Commissioner (IDPC) at https://idpc.org.mt/.

19.                      U.S. Privacy Rights

As a matter of business policy, Everplay offers the following consumer privacy rights nationally, subject to applicable law and exceptions: access to personal information; correction of inaccurate personal information; deletion of personal information; a copy of personal information in a portable format where applicable; the ability to opt out of the sale or sharing of personal information and of targeted advertising; the ability to use an authorized agent where permitted by law; and the ability to appeal a decision on a privacy request. We do not sell personal information for monetary consideration. Depending on the facts and applicable law, disclosures of identifiers, device data, gameplay data, or ad interaction data to advertising partners may be “sharing” for cross-context behavioral advertising and may be a “sale” if the statutory definition is met.

To exercise your rights, including access, correction, or deletion of personal information, contact us at hello@everplay.gs, or use the in-Game deletion request feature under Settings > Privacy. To submit a statutory opt-out request to opt out of the sale or sharing of personal information or of targeted advertising, use the in-Game control at Settings > Privacy > Do Not Sell or Share My Personal Information, or contact us at the email address above. We may verify your identity and will respond within the timeframe required by applicable law. We will not discriminate against users who exercise their privacy rights.

Android advertising settings, including the ability to reset or delete your Advertising ID and to limit ad personalization, are device-level controls provided by Google. They may affect the advertising you receive, but they do not, by themselves, submit a statutory opt-out request to Everplay. To submit a statutory opt-out request, use the contact method described above.

 

20.                      California Privacy Disclosures

For California residents, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA), requires additional disclosures. The categories of personal information we may collect from or about you include:

·       Identifiers, including Google Advertising ID, Everplay’s internal user identifier, Android ID (ANDROID_ID), device identifiers, IP address, and similar technical identifiers.

·       Internet or other electronic network activity, including session duration, gameplay events, ad impressions, clicks, completions, and performance or crash data.

·       Geolocation data, limited to approximate location inferred from an IP address.

·       Inferences derived from device, gameplay, network, advertising, or security data, such as aggregate usage or fraud-prevention indicators.

We collect these categories from the Game, your device, and service providers that support advertising, attribution, analytics, diagnostics, and security. We use them to operate and improve the Game, serve and measure advertising, attribute installs and in-game events, maintain stability, and help detect fraud and security incidents.

We do not sell personal information for monetary consideration. Depending on the facts and applicable law, disclosures of identifiers, device data, gameplay data, or ad interaction data to advertising partners may be “sharing” for cross-context behavioral advertising and may be a “sale” if the statutory definition is met.

California residents may request the categories and specific pieces of personal information collected; the sources, business or commercial purposes, and categories of recipients; deletion, subject to exceptions; correction of inaccurate personal information; and to opt out of the sale or sharing of personal information for cross-context behavioral advertising. Where applicable, they may also request to limit the use or disclosure of sensitive personal information to purposes permitted by the CCPA/CPRA.

We will not discriminate against California residents for exercising their CCPA/CPRA rights. You may designate an authorized agent where permitted by law, and we may verify your identity before completing a request.

To submit a California privacy request, including a statutory request to opt out of the sale or sharing of personal information for cross-context behavioral advertising, contact us at hello@everplay.gs with the subject line “CCPA Rights Request.” You may also use any available in-game ad preferences or Android device advertising settings (Settings > Privacy > Do Not Sell or Share My Personal Information) to affect advertising or reset your Google Advertising ID. Those controls do not themselves submit a statutory opt-out request to Everplay. To submit a statutory opt-out, use the contact method above. We will acknowledge requests within 10 business days and respond within 45 calendar days, subject to a permitted extension.

California residents may also contact us regarding California Civil Code Section 1798.83 (“Shine the Light”). We do not disclose personal information to third parties for their direct marketing purposes.

21.                      Other U.S. State Privacy Rights

Residents of states with comprehensive privacy laws, including Virginia, Colorado, Connecticut, Texas, and other states with applicable laws, may have rights to access, delete, correct, or obtain a copy of their personal information; opt out of the sale of personal information and targeted advertising; and appeal a decision denying a privacy request. Everplay offers these rights nationally as described in the U.S. Privacy Rights section above, subject to applicable law and exceptions.

To exercise these rights or submit an appeal, contact us at hello@everplay.gs and identify your state of residence and the nature of your request. We may require information to verify your identity and may accept an authorized agent where permitted by law. We will not discriminate against you for exercising applicable privacy rights and will respond within the timeframe required by applicable law. Where required, we will explain how to contact the relevant state attorney general or privacy authority if an appeal is denied.

22.                      Children

The Games covered by this Policy are rated 18+ / Mature, are intended only for adults, are not directed to children, and are not enrolled in Google Play Families. If you are under 18, you may not use the Games.

We do not knowingly collect personal information through the Games from anyone under 18. If you are a parent or guardian and believe that we have received personal information from a person under 18, contact us at hello@everplay.gs. We will review the request and, where required by law, delete or de-identify the information, subject to lawful retention exceptions.

23.                      Changes to This Policy

We may update this Policy to reflect changes in the Games, our information practices, our service providers, legal requirements, or the choices available to you. The revised Policy will show a new effective or last-updated date. Where required by law, we will provide additional notice or obtain your consent before a material change takes effect.

24.                      Contact

Controller: Everplay Games Ltd.

Company No. C 116697

Ewropa Business Centre Level 3-701, Triq Dun Karm, Birkirkara, BKR 9034, Malta

Privacy Contact: hello@everplay.gs

Policy URL: https://everplay.gs/PrivacyPortfolioGames.html


 

Schedule 1: Covered Games

This Policy applies to each Game listed below. Each entry identifies the exact Game title, the exact Google Play package name, the publisher or developer, the effective date of this Policy for that Game, and any title-specific privacy supplement that applies to that Game. A Game is covered by this Policy only when its entry is complete.

 

Game Number

Game Title

Google Play Package Name

Publisher and Developer

Effective Date of this Policy

Title-Specific Privacy Supplement

 

1

 

Car Jam: Traffic Escape 3D

com.everplay.carjam

Everplay Games Ltd.

09/04/2026

None

2

Climb Rescue

com.everplay.climbrescue

Everplay Games Ltd.

09/04/2026

None

3

Mahjong Tile Match

com.everplay.mahjong

Everplay Games Ltd.

09/04/2026

None

4

Seat Escape 3D

com.everplay.seatescape

Everplay Games Ltd.

09/04/2026

None

5

Word Connect: Search Puzzle

com.everplay.wordconnect

Everplay Games Ltd.

09/04/2026

None

6

Helix Smash: Ball Drop

com.everplay.helixsmash

Everplay Games Ltd.

09/04/2026

None

7

Peak Climber 3D

com.everplay.peakclimber

Everplay Games Ltd.

09/04/2026

None

8

Color Match: Connect the Dots

com.everplay.colormatch

Everplay Games Ltd.

09/04/2026

None

9

Knife Master: Sharp Shot

com.everplay.knifemaster

Everplay Games Ltd.

09/04/2026

None

10

Traffic Jam: Color Match

com.everplay.trafficjam

Everplay Games Ltd.

09/04/2026

None

11

Nuts & Woods: Screw Master

com.everplay.nutsandwoods

Everplay Games Ltd.

09/10/2026

None

12

Water Sort!

com.everplay.watersort

Everplay Games Ltd.

09/10/2026

None

13

Rope Master: Untangle 3D

com.everplay.ropemaster

Everplay Games Ltd.

09/10/2026

None

14

Block Escape 3D: Slide Puzzle

com.everplay.blockescape

Everplay Games Ltd.

09/10/2026

None