Privacy policy

1. Introduction

1.1. We take your privacy seriously and are committed to protecting your personal data. This Privacy Policy explains what personal data we collect when you use our games and apps, why we use it, who we share it with, and the rights you have over it.

1.2. By using our games, apps, or website, you acknowledge that your personal data will be handled as described in this Policy.

2. Who we are

2.1. The data controller is BELABS SOFTWARE SRL, a company registered in Romania with the Trade Registry under no. J2023000769339, CUI 48046258, with its registered office at 38 Oborului Street, Bogdănești Village, Suceava County, postal code 727035, Romania. For any privacy question, you can contact us at hello@belabs.ro.

3. Scope of this Policy

3.1. This Policy applies to our games and applications (the "Apps"), our website at belabs.ro, and related services. Our Apps are intended only for users aged 18 and over (see the "Children" section below).

4. The personal data we collect

4.1. Account data.

Our games require an account, and you cannot play without one. You do not create a separate username or password with us. Instead, you sign in using the account for the platform you are playing on: on Google Play you sign in with Google, on Apple platforms you sign in with Apple, and on Steam you sign in with Steam. When you sign in, we receive an identifier for your account with that provider and the limited profile information the provider shares with us, which may include a display name and, depending on the provider and your settings, an email address.

4.2. Device and technical data.

We collect device and connection information such as device identifiers, your advertising identifier (Apple IDFA / Google Advertising ID), IP address, device model, operating system and version, language and region settings, network information, and the App version.

4.3. Gameplay and usage data.

We collect information about how you use the Apps, such as game progress, levels, scores, session length, in-game actions and events, settings and preferences.

4.4. Purchase data.

When you make an in-app purchase, we receive a record of the transaction (such as the product, date, and a transaction identifier). Payments are processed by the platform you use (such as the Apple App Store, Google Play, or Steam); we do not receive or store your full payment card details.

4.5. Advertising data.

Our Apps may show ads. Our advertising partners process your advertising identifier and information about the ads shown to you and your interactions with them.

4.6. Diagnostics and crash data.

We collect crash reports, performance data, and error logs to keep the Apps stable and to fix problems.

4.7. Communications.

If you contact us for support or otherwise, we process your messages and the contact details you provide.

4.8. Website and recruitment.

If you use the contact form on our website, we collect the name, email address, and any information you submit. If you apply for a job, we process the information contained in your application and CV.

5. How we collect your data

5.1. We collect your personal data in the following ways:

Directly from you: when you create an account, make a purchase, contact us, or fill in a form.
Automatically: through tools and software development kits (SDKs) in our Apps that collect device, usage, advertising, and crash data.
From third parties: such as app stores and platforms (Apple, Google), the sign-in provider you choose, and our advertising partners.

6. Why we use your data and our legal bases

6.1. We use your personal data for the purposes below, relying on the legal bases set out in Article 6 of the GDPR:

To provide the Apps and your account and to operate their core features: performance of our contract with you (Art. 6(1)(b)).
To process in-app purchases and keep the required records: performance of a contract and compliance with our legal obligations (Art. 6(1)(b) and (c)).
To keep the Apps secure, prevent fraud and abuse, and diagnose and fix crashes and bugs: our legitimate interests in providing a safe and functioning service (Art. 6(1)(f)).
To measure and improve the Apps through analytics: your consent where required, otherwise our legitimate interests (Art. 6(1)(a) or (f)).
To show advertising, including personalized advertising: your consent (Art. 6(1)(a)), which you can withdraw at any time.
To send you marketing communications, where you have asked to receive them: your consent (Art. 6(1)(a)); you can unsubscribe at any time using the link in each message or by contacting us at hello@belabs.ro.
To comply with legal obligations and respond to lawful requests from authorities: compliance with a legal obligation (Art. 6(1)(c)).

7. Advertising and your choices

7.1. Our Apps may display ads served by third-party advertising networks (for example, Google AdMob, Unity Ads, or AppLovin). For personalized advertising we ask for your consent, and you can change or withdraw that consent at any time through the App settings or your device settings. You can also reset or limit your advertising identifier at any time in your device settings (on iOS, through the tracking and privacy settings; on Android, by resetting or deleting the advertising ID). If you opt out of personalized ads, you may still see non-personalized ads.

8.1. We do not sell your personal data. We share it only in the following situations:

Service providers and processors who help us operate the Apps (such as hosting, analytics providers like Google Firebase / Google Analytics, and crash-reporting tools), acting on our instructions.
Advertising partners (such as Google AdMob, Unity Ads, or AppLovin) that serve ads within the Apps.
App stores and platforms (such as Apple, Google, and Valve/Steam) that distribute the Apps and process payments.
The sign-in provider for the platform you use to log in (Google on Google Play, Apple on Apple platforms, or Steam on Steam).
Authorities, professional advisers, or a buyer where required by law, to protect our rights, or in connection with a merger, acquisition, or reorganization.

9. International data transfers

9.1. Some of the recipients above are located outside the European Economic Area (EEA), including in the United States. When we transfer your personal data outside the EEA, we rely on an adequacy decision of the European Commission (such as the EU-US Data Privacy Framework for certified providers) or on appropriate safeguards, such as the European Commission's Standard Contractual Clauses. You can ask us for more information using the contact details below.

10. How long we keep your data

10.1. We keep your personal data only for as long as necessary for the purposes described in this Policy:

Account data: for as long as your account is active, and for a limited period after you delete it (including in backups), unless we are required to keep it longer.
Purchase and transaction records: for the period required by applicable tax and accounting law.
Analytics, advertising, and diagnostics data: for the retention periods configured with our providers, after which it is deleted or aggregated.
Support and website messages: for as long as needed to handle your request and for a reasonable period afterwards.

10.2. When your data is no longer needed, we delete or anonymize it.

11. Security of your data

11.1. We implement reasonable technical and organizational measures to protect your personal data against loss, misuse, and unauthorized access or disclosure. However, no method of transmission or storage is completely secure, so we cannot guarantee absolute security. If you believe your account or your interaction with us is no longer secure, please notify us immediately at hello@belabs.ro.

12. Your rights

12.1. Under the GDPR, you have the right to access your personal data, to have it corrected or deleted, to restrict or object to its processing, and to receive it in a portable format. Where our processing is based on your consent, you can withdraw that consent at any time, without affecting the lawfulness of processing carried out before the withdrawal.

12.2. To exercise any of these rights, contact us at hello@belabs.ro. We will respond within the time limits set by law.

12.3. You also have the right to lodge a complaint with a data protection supervisory authority. In Romania, this is the National Supervisory Authority for Personal Data Processing (ANSPDCP), B-dul G-ral Gheorghe Magheru nr. 28-30, Sector 1, Bucharest, email anspdcp@dataprotection.ro, website www.dataprotection.ro. If you live in another EU/EEA country, you may contact your local supervisory authority instead.

13. Children

13.1. Our Apps are intended only for users aged 18 and over. We do not knowingly collect personal data from anyone under 18. If we become aware that we have collected personal data from a person under 18, we will delete it as soon as possible. If you believe a minor has provided us with personal data, please contact us at hello@belabs.ro.

14. Changes to this Policy

14.1. We may update this Policy from time to time. When we do, we will update the last-updated date shown on this page, and for significant changes we will provide a more prominent notice. Please review this Policy periodically. Where required by law, we will ask for your consent to any material changes; otherwise, your continued use of the Apps after the changes take effect means you accept the updated Policy.

15. Contact

15.1. For any question about this Policy or about how we handle your personal data, contact BELABS SOFTWARE SRL at hello@belabs.ro, or by post at 38 Oborului Street, Bogdănești Village, Suceava County, postal code 727035, Romania.

16. Applicable law

16.1. We process your personal data in accordance with:

Regulation (EU) 2016/679 (General Data Protection Regulation, GDPR);
Law no. 190/2018 on measures to implement the GDPR;
Law no. 506/2004 on the processing of personal data and the protection of privacy in the electronic communications sector;
and any other applicable data protection laws.