UNDERWATER GAMES

Privacy Policy

(A) Who we are

We are Underwater Games OÜ, an entertainment company delivering games for mobile devices.

  • Registered name: Underwater Games OÜ
  • Registry code: 17486604
  • Registered office: Harju maakond, Tallinn, Kesklinna linnaosa, Estonia

Underwater Games OÜ is the controller of your personal information and is responsible for your personal data.

All references in this policy to “Underwater Games”, “our”, “us” or “we” refer to Underwater Games OÜ. All references to “apps” are to our mobile applications available for download.

(B) Our values and what this policy is for

We value your privacy and aim to be transparent, fair, and accountable in how we collect and use your personal information.

This Privacy Policy explains:

  • what data we collect
  • how we use it
  • your rights

If you have feedback, contact us using the details in section 10.

(C) Who this policy applies to

This policy applies to:

  • users of our mobile apps
  • users contacting our support

(D) What this policy contains

This Privacy Policy covers:

  • Collection and use of your data
  • Legal basis
  • Data sharing
  • Retention
  • Your rights
  • Children
  • International transfers
  • Security
  • Updates
  • Complaints

(E) Your rights to object

You may:

  • request us to stop using your data for marketing
  • object to processing based on legitimate interests

See section 5 for details.

(F) Your confirmation

By using our apps, you confirm that you have read and understood this Privacy Policy.

1. Collection of your personal information and how we use it

1.1 What we collect

We may collect:

(a) From apps:

  • Advertising ID (IDFA / GAID)
  • General location data (non-precise)
  • Device information
  • Chat data (if applicable)
  • Social data (if connected, e.g. Facebook)

(b) From support:

  • Email address
  • Any information you send us

1.2 How we use your data

We use your data to:

  • provide and optimize advertising
  • personalize content (if consent given)
  • manage support requests

1.3 Additional uses

We may also use data to:

  • respond to legal requests
  • improve our apps
  • ensure security
  • comply with laws

2. Legal basis

We rely on:

  • Contract → to provide the app
  • Consent → for personalized ads
  • Legitimate interests → to operate and improve our business

3. Sharing your data

3.1 Advertising partners

We may share data with:

  • Google AdMob
  • AppLovin
  • Meta (Facebook)
  • Unity Ads
  • Vungle

These partners may collect:

  • device data
  • usage data
  • advertising interaction data

3.2 Other partners

We may share data with:

  • cloud providers (e.g. AWS)
  • analytics tools (e.g. Firebase)
  • app stores (Google Play, Apple App Store)

3.3 Business transfers & legal obligations

We may disclose data if:

  • required by law
  • part of a business sale
  • necessary to protect rights

3.4 No selling of personal data

We do not sell your personal data.

4. Data retention

We keep your data only as long as necessary for:

  • providing services
  • legal compliance

5. Your rights

Under GDPR, you have the right to:

  • access your data
  • correct your data
  • delete your data
  • restrict processing
  • object to processing
  • data portability

We respond within 1 month.

6. Children

Our services are not directed at children under 16.
We do not knowingly collect data from children.

7. International transfers

Your data may be processed outside the EEA (e.g. USA).
We use safeguards such as:

  • Standard Contractual Clauses

8. Security

We protect your data using:

  • encryption
  • restricted access
  • industry-standard security practices

However, no system is 100% secure.

9. Changes

We may update this policy.
Updates will be available in our apps.

10. Contact & complaints

Contact:
📧 support@underwatergames.com

You may also contact the Estonian Data Protection Inspectorate:
Andmekaitse Inspektsioon

You also have the right to file a complaint under GDPR.