MOUSETRAP GAMES PRIVACY POLICY

Last updated: 22.10.2025

Thank you for playing Mousetrap Games!

This Privacy Policy ("Policy") explains how Mousetrap Games sp. z o.o. with its registered office in Wrocław ("Mousetrap Games", "we", "us", "our") processes your personal data, who we share it with, and how long we store it. You will also learn about your rights and how you can exercise them.

This Policy applies to our mobile game applications (hereinafter referred to as "Games" or "Services").

Your use of the Games is also subject to our Terms of Service. Please read both documents carefully.

Before accessing or using the Game, you are required to accept the data processing terms described in this Policy. If you do not agree to the provisions of this Policy, please do not install, access, or use our Games.

I. WHO IS THE CONTROLLER OF YOUR DATA?

The controller of your personal data, i.e., the entity deciding on the purposes and means of processing, is:

Mousetrap Games Sp. z o.o.
ul. Stanisława Leszczyńskiego 4/29,
50-078 Wrocław, Poland

• KRS (National Court Register): 0000673373
• NIP (Tax ID No.): 8943102623
• REGON (Statistical No.): 367049230

II. HOW TO CONTACT US?

In all matters related to the processing of your personal data, you can contact us via e-mail: support@mousetrap.games or in writing at our registered address specified in section I.

III. DATA PROTECTION OFFICER (DPO)

We have appointed a Data Protection Officer (DPO) whom you can contact regarding all matters related to the processing of your personal data and exercising your rights.

Contact with the DPO is possible via e-mail: iodo@mousetrap.games (or, if you prefer, you can use the address support@mousetrap.games with the note "For the Data Protection Officer").

IV. WHAT DATA DO WE PROCESS AND FOR WHAT PURPOSE?

We process your data for the following purposes and on the following legal bases:

1. To perform a contract (provide the Services)

Legal basis: Art. 6(1)(b) of the GDPR (necessity to perform a contract)

The main purpose of processing your data is to fulfill the contract for the provision of Services (which you conclude by accepting the Terms of Service). We need this data to:

• Allow you to play and use Game features;
• Manage your in-Game account (if applicable);
• Verify and process in-Game payments;
• Provide you with technical support and respond to your inquiries;
• Communicate changes to the Services or legal documents.

For this purpose, we collect data you provide (e.g., nickname, e-mail address when contacting us) and data collected automatically (e.g., device ID, IP address, game progress data, purchase history).

2. To pursue our legitimate interests

Legal basis: Art. 6(1)(f) of the GDPR (our legitimate interest)

Our legitimate interest consists of:

• Improving the Games and player experience: We analyze how you use the Games to detect errors, improve stability, and develop new features.
• Ensuring security: We monitor the use of the Games to prevent fraud, abuse, and activities contrary to the Terms of Service.
• Conducting marketing activities: We may present you with our other Games or offers within the Games (direct marketing).
• Displaying advertisements: To offer our Games for free, we display third-party ads. For this, we and our partners may use data (like advertising IDs) to display personalized or contextual ads.
• Establishing, exercising, or defending legal claims: We may store data necessary to defend against or pursue claims.

3. To comply with legal obligations

Legal basis: Art. 6(1)(c) of the GDPR (legal obligation)

We process data to comply with our legal obligations, e-g., those arising from tax and accounting regulations (e.g., in connection with your purchases).

4. Based on your consent

Legal basis: Art. 6(1)(a) of the GDPR (consent)

In specific situations (e.g., when you first launch the Game), we may ask for your consent to process your data (e.g., your unique advertising identifier) to display personalized advertising from our partners. You can withdraw this consent at any time in your device settings or the Game settings.

V. PROFILING

To display ads that may interest you, and to analyze your in-Game behavior for improvement purposes, we may automatically process (profile) your data (e.g., advertising ID, game progress data, country, device type).

Profiling does not mean making decisions about you that have legal effects. It is only used to better tailor content (including ads) to your potential interests.

If the basis for profiling is our legitimate interest, you have the right to object to such processing at any time.

VI. HOW LONG DO WE STORE YOUR DATA?

We store your personal data for as long as it is necessary to provide you with the Services (i.e., for as long as you have an account or use the Game).

After this time, we may store data:

• For the duration of our legitimate interests (e.g., until the statute of limitations for any claims expires);
• For the period required by law (e.g., for tax and accounting purposes).

If you request the deletion of your data, we will delete or anonymize it, except for data that we must retain due to legal obligations or our legitimate interest.

VII. WHO DO WE SHARE YOUR DATA WITH?

We only share your data when it is necessary to provide the Services. We use trusted partners who process data on our behalf. These include:

• Analytics service providers: They help us understand how you use the Games (e.g., Flurry, GameAnalytics).
• Advertising partners (Ad Networks): They enable us to display ads in the Games. Our partners may collect data based on their own privacy policies (e.g., ironSource, AppLovin, Google AdMob, Unity Ads). We encourage you to read their privacy policies.
• Platform providers (App Stores): Entities like Apple (App Store) and Google (Google Play), which process your payments and provide us with data necessary for their verification.
• IT and hosting service providers: Entities on whose servers we store data.
• Legal, tax, and audit advisors: To the extent necessary to ensure legal compliance or pursue claims.

We may also share your data with public authorities (e.g., police, prosecutor's office) if required by law.

VIII. DATA TRANSFER OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)

Due to the global nature of our Services and cooperation with international partners (e.g., from the USA), your personal data may be transferred to countries outside the European Economic Area (EEA).

We always ensure that such transfers are based on appropriate legal safeguards. These are primarily:

• European Commission adequacy decisions (stating that a given country provides an adequate level of protection).
• Standard Contractual Clauses (SCCs) approved by the European Commission, concluded with our partners.

You have the right to receive a copy of the safeguards we use for data transfers outside the EEA. To do so, please contact our DPO.

IX. YOUR RIGHTS (UNDER GDPR)

In connection with our processing of your data, you have several rights:

1. Right of access (Art. 15 GDPR): You can request information about what personal data we process and receive a copy of it.
2. Right to rectification (Art. 16 GDPR): If your data is incorrect or incomplete, you have the right to request its correction.
3. Right to erasure ("right to be forgotten") (Art. 17 GDPR): You can request the deletion of your data, e.g., if you withdraw consent or the data is no longer necessary for the purposes for which it was collected.
4. Right to restriction of processing (Art. 18 GDPR): You can request that we restrict the processing of your data (e.g., if you contest its accuracy) – we will then only be able to store it.
5. Right to data portability (Art. 20 GDPR): If we process data based on a contract or consent, you have the right to receive it from us in a structured format and transmit it to another controller.
6. Right to object (Art. 21 GDPR):
   • If we process your data based on our legitimate interest (e.g., for analytics or direct marketing), you have the right to object at any time.
   • We must stop such processing unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.
7. Right to withdraw consent (Art. 7(3) GDPR): If we process data based on your consent (e.g., for personalized ads), you can withdraw it at any time. Withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal.
8. Right to lodge a complaint with a supervisory authority (Art. 77 GDPR): If you believe we are processing your data unlawfully, you have the right to lodge a complaint with the President of the Personal Data Protection Office (PUODO) (address: ul. Stawki 2, 00-193 Warsaw, Poland) or another supervisory authority in the EU.

To exercise these rights, please contact us or our DPO (contact details in sections II and III).

X. AGE LIMITS

Our Services are not intended for persons under the age of 16 (or under the age required to consent to data processing in your country).

We do not knowingly collect personal data from persons under this age. If you are a parent or guardian and you become aware that your child has provided us with data without your consent, please contact us. If we learn that we have collected data from such a person, we will delete it immediately.

XI. PUSH NOTIFICATIONS

We may send you "push" notifications through our Games to inform you about updates, game progress, or special offers. You can opt-out of receiving such notifications at any time by disabling them in your mobile device's settings.

XII. CHANGES TO THE PRIVACY POLICY

We reserve the right to make changes to this Privacy Policy, especially in the event of changes to our Games or changes in the law.

We will notify you of any significant changes in advance through an in-Game notification or by publishing a new version on our website. The "Last updated" date at the top of the document always indicates the current version. Your continued use of the Services after the changes take effect signifies your acceptance of them.