Privacy Policy
Lightwell Games, LTD. ("Service Provider," "Company," "we," "us," or "our") publishes and operates a portfolio of mobile applications. This Privacy Policy applies to all of them. We currently publish two categories of application:
- Games — casual mobile games, free to play, supported by advertising.
- Apps — utility applications that are subscription-based, contain no advertising, and process content you choose to provide (for example, a photo) in order to deliver the application's core feature.
Any Game or App published by us, now or in the future, is covered by this single policy unless we publish a separate policy specific to it. Where our data practices differ between Games and Apps, this document says so explicitly. Where a section does not draw that distinction, it applies to both equally.
Please read this Privacy Policy carefully. By downloading, installing, or using any of our Games or Apps, you agree to the collection and use of information as described here.
## 1. Scope and Definitions
Throughout this document, "Application" refers collectively to any Game or App we publish; "you" refers to the end user of an Application. Where a right or obligation applies only to one category, we say "Game" or "App" specifically rather than "Application."
This policy does not apply to third-party websites, services, or applications that may be linked from within an Application, or to information collected by third parties directly, except as described in §4.
## 2. Information We Collect
Across all Games and Apps, we may automatically collect:
- Your device's Internet Protocol (IP) address
- General device information: operating system, device model, and locale
- The screens or pages of the Application that you visit, and the time and date of, and time spent on, each visit
- Total time spent within the Application
- Standard crash reports and performance diagnostics
We do not collect precise geolocation data in either our Games or our Apps.
In our Games specifically, we may additionally collect:
- An advertising identifier (e.g. Apple's IDFA, where permitted by your device settings)
- In-game progress, activity, and achievement data
- Data necessary for the advertising and analytics SDKs listed in §4 to function
In our Apps specifically, we may additionally collect:
- An anonymous account identifier, generated automatically the first time you open the App. Creating or using this identifier does not require you to provide your name, email address, or a password.
- Content you voluntarily choose to upload for processing — for example, a photograph. That content is transmitted to the third-party AI provider described in §4 solely to generate the output you requested. It is not used to train any machine-learning model, ours or a third party's, and is not shared for any purpose beyond producing your result.
- Purchase and subscription event data: which product was purchased and when. We never receive or store your payment card number, bank details, or Apple ID credentials — those are handled entirely by Apple.
For a better experience while using an Application, we may ask you to voluntarily provide certain additional personally identifiable information, such as when you contact support. Any information you provide in that context is retained and used as described in this policy.
## 3. How We Use Information
We use the information described above to:
- Operate, maintain, secure, and improve our Games and Apps
- Diagnose and fix technical problems, using crash and performance data
- Process the purchases and subscriptions you make, and maintain accurate entitlement records
- Respond to support requests and communicate important notices about the Application
- For Games only: serve, measure, and improve the relevance of advertising
We may also use aggregated or de-identified data, from which you cannot reasonably be identified, for internal analytics, reporting, and product-improvement purposes across our portfolio.
## 4. Third-Party Services
We work with third-party service providers to operate our Games and Apps. Only the data reasonably necessary for each provider to perform its function is shared with it, and each provider is contractually or contextually bound to use that data only to provide services to us — not for its own independent purposes, except where its own privacy policy (linked below where applicable) says otherwise for data it collects directly, such as advertising identifiers.
Used in connection with our Games:
- Google Play Services
- AdMob (advertising)
- Google Analytics for Firebase
- Firebase Crashlytics
- Unity
- GameAnalytics
- AppLovin
- Adjust
Used in connection with our Apps:
- Google (Gemini API) — receives the content you upload (e.g. a photo), temporarily, in order to generate the output you requested. Governed by Google's own privacy terms for that API.
- fal.ai — receives the same content only when used as a fallback processing path, if the primary provider is unavailable.
- Cloudflare — provides the edge infrastructure through which some of our Apps route requests to the AI provider. Content passes through in memory only for the duration of the request and is not stored.
- Supabase — provides the database, file storage, authentication, and server infrastructure that our Apps run on.
- RevenueCat, Superwall and Apple — process subscription and in-app purchase events on our behalf, and are the systems of record for your entitlement status.
We may disclose information we hold about you:
- As required by law, such as in response to a subpoena, court order, or similar legal process;
- When we believe in good faith that disclosure is necessary to protect our rights, your safety or the safety of others, to investigate fraud, or to respond to a government request;
- To trusted service providers who work on our behalf, who do not have an independent right to use the information beyond providing services to us, and who have agreed to comply with the restrictions in this policy.
We do not sell your personal information, and we do not share it with third parties for their own independent marketing purposes.
## 5. Advertising
Our Games are ad-supported. They use the advertising and analytics networks listed in §4 to display advertising, measure its performance, and — subject to your device's permissions — personalize which ads you see.
Our Apps contain no advertising. They do not display ads, and we do not share data collected in connection with an App with any advertising network for advertising purposes.
## 6. Cookies and Similar Technologies
Our Games and Apps, and any companion websites we operate, may use cookies, mobile advertising identifiers, and similar technologies to remember preferences, measure usage, and — for Games — support advertising. You can control some of these through your device's privacy settings, including limiting ad tracking.
## 7. Data Retention and Deletion
Games: you can stop all further collection of information by uninstalling the Game. To request deletion of data associated with your account, email us at info@lightwellgames.com with the subject "Data Deletion Request," including your user ID or the account information used in the Game. We will process such requests within a reasonable time.
Apps: where an App stores your content on our systems, your uploaded content and generated results are retained for as long as your account remains active. In some Apps your uploaded content and generated results are kept only on your device and are not retained on our servers; where that is the case, deleting the item in the App — or deleting the App — removes it permanently. Where an App provides an in-app account-deletion option (typically found under Settings), using it permanently and immediately removes your account, your uploaded content, and your generated results from our systems — no email required. Where no such option is available, you may request deletion by email as described above, and we will process the request within a reasonable time and delete the applicable data.
We retain data only for as long as reasonably necessary for the purposes described in this policy, or as required by law.
## 8. International Data Transfers
We and our service providers may process and store information in countries other than your own, including the United States. Where required by applicable law, we take steps intended to ensure that such transfers are subject to appropriate safeguards.
## 9. Children's Privacy
Our Games and Apps are not directed at children under the age of 13, and we do not knowingly solicit or collect personal information from them. If we discover that a child under 13 has provided us with personal information, we will delete it from our systems as soon as reasonably practicable. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at info@lightwellgames.com so we can take appropriate action.
## 10. Security
We maintain physical, electronic, and procedural safeguards designed to protect the confidentiality, integrity, and availability of the information we process and store. No method of transmission or storage is completely secure, however, and we cannot guarantee absolute security.
## 11. Your Rights
Depending on where you live, you may have rights under applicable data protection law — such as the EU/UK General Data Protection Regulation or the California Consumer Privacy Act — including the right to access, correct, export, or delete your personal information, and, where applicable, to object to or restrict certain processing. We do not sell personal information.
For Apps with an in-app deletion option, you can exercise your deletion right directly and immediately within the App. For any other request, or if you are unsure which applies to you, contact us at info@lightwellgames.com and we will respond within a reasonable time. If you are in the EU or UK, you also have the right to lodge a complaint with your local data protection authority.
## 12. Changes to This Policy
We may update this Privacy Policy from time to time, for any reason, including to reflect new features, applications, or legal requirements. We will notify you of changes by updating this page and revising the effective date below. Continued use of any Game or App after a change is deemed acceptance of the revised policy. We encourage you to review this page periodically.
This Privacy Policy is effective as of 01.08.2026.
## 13. Your Consent
By downloading, installing, or using any of our Games or Apps, you consent to the collection, use, and disclosure of your information as described in this Privacy Policy, as it may be amended from time to time.
## 14. Contact Us
If you have any questions about this Privacy Policy or our data practices, please contact us:
Lightwell Games, LTD.
Email: info@lightwellgames.com
