1. Introduction

Welcome to Cool Beans Games ("we," "us," or "our"). We develop and publish casual mobile games including puzzle games, word games, and other entertainment applications (collectively, "Games" or "Services"). We are committed to protecting your privacy and being transparent about how we collect, use, and share your information.

This Privacy Policy explains how we handle your personal data when you use our Games. It applies to all users worldwide and is designed to comply with the European Union General Data Protection Regulation (GDPR), the UK General Data Protection Regulation (UK GDPR), the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), the Children's Online Privacy Protection Act (COPPA), Brazil's Lei Geral de Proteção de Dados (LGPD), Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), Australia's Privacy Act 1988, South Africa's Protection of Personal Information Act (POPIA), and other applicable privacy laws.

By using our Games, you acknowledge that you have read and understood this Privacy Policy. If you do not agree, please do not use our Games.

2. Data Controller

Cool Beans Games is the data controller responsible for your personal data. If you have any questions or concerns about this Privacy Policy or our data practices, you can contact us at: support@coolbeans.games

3. Information We Collect

We collect the following categories of information:

3.1 Information Collected Automatically

• Device Information: Device type, model, operating system and version, screen resolution, language settings, and time zone.
  

• Advertising Identifiers (GAID): We collect the Google Advertising ID (GAID) from your Android device. Unlike standard ephemeral processing, this identifier is transmitted off-device and stored in our secure, external databases for internal attribution, user acquisition tracking, and performance analytics.
  

• Data Sharing and Retargeting: We share your GAID with third-party advertising networks and marketing partners. These partners use this identifier to serve personalized ads, enforce ad frequency limits, and run retargeting campaigns outside of our games.
  

• IP Address: Your Internet Protocol address, which is used to estimate your general geographic location (country or city level) and ensure regional privacy compliance.
  

• Usage Data: Information about how you interact with our Games, including session duration, levels completed, features used, in-app events, and gameplay statistics.
  

• Crash and Performance Data: Technical data about app crashes, errors, and performance metrics to help us improve our Games.
  
  

3.2 Information Collected by Third-Party SDKs

Third-Party SDKs
Our Games integrate third-party software development kits (SDKs) for advertising, analytics, and app functionality. These SDKs may collect data independently:

Google AdMob
We use Google AdMob to display advertisements (banner, interstitial, and rewarded video ads). AdMob may collect:

• Advertising ID

• Device information (model, OS version)

• IP address

• Ad interaction data
  

For more information, see Google's Privacy Policy: https://policies.google.com/privacy

Google Firebase Analytics
We use Firebase Analytics to understand app usage and improve our games. Firebase Analytics may collect:

• Usage data and app events

• Device information

• Session duration and feature usage

For more information, see Firebase Privacy: https://firebase.google.com/support/privacy

Firebase Crashlytics
We use Firebase Crashlytics to collect crash reports and diagnostic data to improve app stability. Crashlytics may collect:

• Crash logs and stack traces

• Device state at time of crash

• Device model and OS version

• App version information

For more information, see Google's Privacy Policy: https://policies.google.com/privacy

Firebase Cloud Messaging (FCM) We use Firebase Cloud Messaging to send push notifications to your device (re-engagement reminders). FCM may collect:

• Device token (anonymous identifier used to deliver notifications)

• Notification interaction data (whether notification was opened)

You can disable push notifications at any time through your device settings. For more information, see Firebase Privacy: https://firebase.google.com/support/privacy

GameAnalytics
We use GameAnalytics to collect gameplay statistics and performance metrics. GameAnalytics may collect:

• Device information (device model, OS version)

• IP address (for country-level location)

• Gameplay events and session data

• App performance metrics

For more information, see GameAnalytics Privacy Policy: https://gameanalytics.com/privacy

Unity Ads We use Unity Ads to display advertisements (interstitial and rewarded video ads). Unity Ads may collect:

• Advertising ID (GAID on Android)

• Device information (model, OS version, screen size)

• IP address

• Ad interaction data and engagement metrics

• Coarse location (country level)

For more information, see Unity's Privacy Policy: https://unity.com/legal/privacy-policy

Pangle (ByteDance) We use Pangle, operated by ByteDance, to display advertisements (interstitial and rewarded video ads). Pangle may collect:

• Advertising ID (GAID on Android)

• Device information (model, OS version, screen resolution)

• IP address

• Ad interaction data and engagement metrics

• Coarse location (country level)

For more information, see Pangle's Privacy Policy: https://www.pangleglobal.com/privacy/en

Google User Messaging Platform (UMP)

We use Google UMP to manage user consent for personalised advertising in compliance with GDPR and other privacy regulations. UMP collects:

• Consent choices and preferences

• Region/country information to determine applicable regulations
  

You can change your consent preferences at any time through the "Ad Preferences" option in the app's More menu.

We may add or change third-party service providers over time. We will update this Privacy Policy accordingly.

3.3 Information We Do NOT Collect

We do not collect your name, email address, phone number, physical address, payment information, photos, contacts, or any other directly identifying personal information. We do not require you to create an account to use our Games.

4. How We Use Your Information

We use the information we collect for the following purposes:

To Serve Advertisements: Our Games are free and supported by advertising. We use advertising identifiers and device information to display ads, including personalised ads where you have given consent.

To Improve Our Games: We use analytics data to understand how players use our Games, identify bugs, improve performance, and develop new features.

To Ensure Technical Functionality: We use device and crash data to maintain the stability and security of our Games.

To Comply with Legal Obligations: We may process data as necessary to comply with applicable laws, regulations, or legal proceedings.

5. Legal Basis for Processing (GDPR/UK GDPR)

If you are located in the European Economic Area (EEA), the United Kingdom, or a jurisdiction that requires a legal basis for processing personal data, we rely on the following legal bases:

• Consent: We rely on your explicit consent to collect your Google Advertising ID (GAID), store it in our external tracking databases, and share it with third-party partners for personalized advertising, attribution tracking, and retargeting campaigns [16933379]. You will be asked for your consent via our Google UMP banner upon launching the App. You can withdraw your consent at any time through the privacy preferences settings inside our Games.
  

• Legitimate Interest: For core analytics, game performance tracking, crash reporting, and serving contextual (non-personalised) advertisements. We have assessed that these activities are necessary for our business operations and do not override your fundamental rights and freedoms.
  

• Legal Obligation: Where we are required to process or retain data to comply with applicable local or international laws.
  
  

6. Advertising and Your Choices

Our Games display advertisements to support free access. You have the following choices regarding advertising:

Personalised Ads: If you consent, our advertising partners may use your advertising identifier and other data to show you ads that are more relevant to your interests. You can manage your consent at any time through the ad preferences or privacy settings within our Games.

Non-Personalised Ads: If you do not consent to personalised advertising, you will still see ads, but they will not be tailored to your interests.

Resetting Your Advertising ID: You can reset your advertising identifier or opt out of personalised advertising through your device settings (Android: Settings > Privacy > Ads).

7. Data Sharing and Disclosure

We do not sell your personal data. We share data only in the following circumstances:

Advertising Partners: We share advertising identifiers, device information, and IP addresses with our advertising partners (including Google AdMob, Unity Ads, and Pangle) to serve ads.

Analytics Providers: We share usage and device data with analytics providers (such as Firebase Analytics) to help us understand how our Games are used.

Legal Requirements: We may disclose data if required by law, regulation, legal process, or governmental request.

Business Transfers: If we are involved in a merger, acquisition, or sale of assets, your data may be transferred as part of that transaction.

8. International Data Transfers

Your data may be transferred to and processed in countries other than your country of residence, including the United States, where our third-party service providers operate. These countries may have different data protection laws than your jurisdiction.

For transfers of data from the EEA or UK, we rely on appropriate safeguards such as Standard Contractual Clauses (SCCs) approved by the European Commission, or other legally recognised transfer mechanisms. Our third-party partners maintain their own data transfer safeguards as described in their respective privacy policies.

9. Data Retention

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

Analytics data: Retained for up to 14 months, after which it is aggregated or deleted.

Advertising data: Managed by our advertising partners according to their own retention policies.

Crash data: Retained for up to 90 days for debugging purposes.

When data is no longer needed, we delete it or anonymise it so that it can no longer be associated with you.

10. Data Security

We implement reasonable technical and organisational measures to protect the data we collect from unauthorised access, loss, misuse, or alteration. However, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.

11. Children's Privacy

Our Games are not directed at children under the age of 13 (or under 16 in jurisdictions where GDPR applies). We do not knowingly collect personal information from children under these ages.

If we become aware that we have inadvertently collected personal data from a child under the applicable age threshold, we will take steps to delete that data as soon as possible.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us at support@coolbeans.games and we will promptly remove the data.

12. Your Rights

12.1 Rights Under GDPR / UK GDPR (EEA and UK Residents)

If you are in the EEA or UK, you have the following rights:

Right of Access: You can request a copy of the personal data we hold about you.

Right to Rectification: You can request that we correct inaccurate data.

Right to Erasure: You can request that we delete your personal data.

Right to Restrict Processing: You can request that we limit how we use your data.

Right to Data Portability: You can request your data in a structured, machine-readable format.

Right to Object: You can object to processing based on legitimate interests, including for direct marketing purposes.

Right to Withdraw Consent: Where processing is based on consent, you can withdraw it at any time without affecting the lawfulness of prior processing.

To exercise these rights, contact us at support@coolbeans games We will respond within 30 days. If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority.

12.2 Rights Under CCPA / CPRA (California Residents)

If you are a California resident, you have the following rights:

Right to Know: You can request information about the categories and specific pieces of personal data we have collected, the sources of that data, the purposes for collection, and the third parties with whom we share it.

Right to Delete: You can request that we delete personal data we have collected from you.

Right to Opt-Out of Sale or Sharing: We do not sell your personal data. However, certain data sharing for advertising purposes may constitute "sharing" under the CCPA. You can opt out of personalised advertising through the ad preferences in our Games.

Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

To exercise these rights, contact us at support@coolbeans.games We will verify your identity and respond within 45 days.

12.3 Rights Under LGPD (Brazil Residents)

If you are in Brazil, you have rights under the LGPD including: confirmation of processing, access to your data, correction, anonymisation or deletion of unnecessary data, data portability, information about third parties with whom data is shared, and the right to revoke consent. Contact us at support@coolbeans.games to exercise these rights.

12.4 Rights Under PIPEDA (Canada Residents)

If you are in Canada, you have the right to access your personal information, request corrections, and withdraw consent for the collection, use, or disclosure of your data. Contact us at support@coolbeans.games to exercise these rights.

12.5 Rights Under the Privacy Act 1988 (Australia Residents)

If you are in Australia, you have the right to access and correct your personal information. You can also make a complaint to the Office of the Australian Information Commissioner (OAIC) if you believe we have breached the Australian Privacy Principles. Contact us at support@coolbeans.games to exercise these rights.

12.6 Rights Under POPIA (South Africa Residents)

If you are in South Africa, you have the right to access, correct, and delete your personal information, and to object to the processing of your data. You may lodge a complaint with the Information Regulator. Contact us at support@coolbeans.games to exercise these rights.

13. Do Not Track Signals

Some browsers send "Do Not Track" (DNT) signals. There is currently no industry standard for how to respond to DNT signals. Our Games do not currently respond to DNT signals, but you can control personalised advertising through the consent and ad preference settings within our Games.

14. Data Erasure and Retention

Because we do not use user IDs or accounts, we cannot look up data by name or email. However, you retain the right to request the deletion of your data. If you wish to have your anonymous device data permanently purged from our external servers, please email us at suport@coolbeans.games and provide your device's Google Advertising ID (GAID). We will process and delete your database entry within 30 days.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will update the "Effective Date" at the top of this policy. We encourage you to review this Privacy Policy periodically.

If we make significant changes that affect your rights, we will make reasonable efforts to notify you, such as through an in-app notification.

16. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Cool Beans Games Email: support@coolbeans.games

For GDPR-related enquiries, you may also contact your local Data Protection Authority. For UK residents, this is the Information Commissioner's Office (ICO) at https://ico.org.uk.

For CCPA-related enquiries, California residents may also contact the California Attorney General's office.