I. Privacy Statement
This Privacy Policy applies to the mobile application “Hot Games For Everyone” (the “App”) and to https://hag-landing.vercel.app (the “Website”, together with the App, the “Services”).
We respect the privacy of our users. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the Services. Please read this Privacy Policy carefully. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS OR USE THE APP.
We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you to any changes by updating the “Last updated” date of this Privacy Policy. You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, and to have accepted, the changes in any revised Privacy Policy by your continued use of the App after the revised Privacy Policy is posted.
This Privacy Policy does not apply to the third-party app store (e.g., the Apple App Store or Google Play Store) from which you download the App, which may separately collect and use data about you. We are not responsible for data collected by any such third party.
II. Age Restriction — Not Intended for Minors
The App contains mature and sexually suggestive content and is rated 17+ / 18+ on the applicable app store. The App is not intended for use by anyone under the age of 17 (or the age of majority in your jurisdiction, if higher). By using the App, you represent and confirm that you meet this minimum age requirement.
We do not knowingly collect personal information from minors. If we become aware that we have inadvertently collected personal information from a person under the required minimum age, we will take reasonable steps to delete that information as soon as possible. If you believe we may have collected information from a minor, please contact us using the details in Section XI below.
III. General
With regard to the Services, Bogdan Nikitin, registered at 90 Katerynynska St., Office 10, Odesa, Ukraine (“we,” “us,” or “our”), is the data controller for the purposes of the General Data Protection Regulation (“GDPR”).
This Privacy Policy provides information about how we collect and process personal data in connection with the Services. The company name used throughout this document must be consistent with the entity named in your App Store / Google Play developer account and in your Terms of Use.
IV. Access and Storage of Information
By using the App, access to information stored on your device, or storage of information on your device, may occur. This access or storage may involve further processing of personal data under the GDPR.
Where such access to, or storage of, information is strictly necessary for the technically error-free delivery of the Services, we rely on our legitimate interest in operating the App.
Where such processing serves other purposes (e.g., the needs-based design of our App), this will only be carried out with your consent under Art. 6(1)(a) GDPR. Consent can be withdrawn at any time with effect for the future.
V. Data That We Collect and Process
Account and registration information
Information you voluntarily submit to us that identifies you personally, such as your name, e-mail address, and (if applicable) other information about yourself. We use this information to verify your right to use your account, to administer the App's terms of use, and to contact you about technical, legal, or security notices relevant to your account.
Information collected automatically
When you use the App, some information is automatically collected, such as your device's operating system and version, device model, device identifier, general language and time-zone settings, and aggregated in-app usage data (e.g., how often you use the App, which features you interact with, and crash/performance data). This is collected via the third-party SDKs described in Section VI (Firebase, AdMob) to help us understand and improve the App's functionality.
We do not collect precise geolocation data. Any IP address collected is used solely for security, fraud-prevention, and basic diagnostic purposes, and only at the country/region level where required for those purposes.
In-App purchases and subscriptions
The App offers optional paid content (currently the Soft, Hot, and Hard levels) through the Apple App Store and/or Google Play in-app purchase systems, managed with the help of RevenueCat (see Section VI). All payment processing is handled entirely by Apple or Google — we do not receive or store your payment card details. We (via RevenueCat) receive limited transaction information (such as purchase confirmation, product identifier, and purchase date) from Apple or Google in order to unlock the relevant content in your account and to provide customer support.
User-generated content (custom questions and dares)
The App allows you to write and save your own custom questions and dares. This content is created entirely at your discretion and may reveal sensitive information about you, including details relating to your sex life or sexual orientation, which is treated as a special category of personal data under Art. 9 GDPR. We only process this content with your explicit consent, given by choosing to create and save it within the App. You may edit or delete your custom content, and your account data, at any time from within the App. We do not use custom content you create for advertising or marketing purposes, and we do not share it with third parties except service providers strictly necessary to operate the storage/sync feature (see Section VI).
Cookies and similar technologies (Website only)
If and to the extent you visit our Website, we and our service providers may use cookies or similar technologies to operate the Website, remember preferences, and understand aggregate usage. These technologies do not apply to your use of the App itself. Where the Website displays advertising, our advertising partners may use cookies to serve ads based on your browsing activity on the Website.
VI. How We Use and Share Information
Our legal basis for collecting and using personal information depends on the specific context: (a) your consent, (b) performance of a contract with you (e.g., to deliver the Services you requested), (c) our or a third party's legitimate interests (where not overridden by your rights), or (d) compliance with a legal obligation (Art. 6(1)(c) GDPR).
Where we rely on your consent, you may withdraw it at any time; this does not affect the lawfulness of processing carried out before withdrawal.
We do not operate our own servers to independently store your personal data. Instead, the App relies on the following third-party service providers, who process certain data on our behalf and, in some cases, independently as their own data controller. The legal basis for this sharing is Art. 6(1)(b) GDPR and, where applicable, Art. 28 GDPR (processor agreements). We do not permit these providers to use your information for their own marketing purposes beyond what is described below.
Google AdMob (advertising)
If the App displays ads, we use Google AdMob to serve and measure them. AdMob may collect your advertising identifier (IDFA/GAID), IP address, device information, and ad interaction data in order to serve ads and, where you have provided consent, personalized ads. You can opt out of personalized advertising through your device's ad- tracking settings. For details, see Google's Privacy & Terms (policies.google.com/privacy).
Firebase (analytics and crash reporting)
We use Google Firebase (including Firebase Analytics and/or Crashlytics) to collect aggregated, anonymized or pseudonymized usage data — such as app opens, feature interactions, session length, and crash/diagnostic logs — to help us understand app performance and fix technical issues. Firebase may process device identifiers and IP address as part of this service.
RevenueCat (subscription and purchase management)
We use RevenueCat to manage in-app purchases and subscriptions across the App Store and Google Play. RevenueCat receives purchase- and subscription-related data (such as product identifiers, purchase/renewal dates, and an anonymous app user ID) directly from Apple or Google in order to validate your purchase and keep your unlocked content in sync. RevenueCat does not receive your payment card details, which are handled entirely by Apple or Google.
Apple App Store Connect / Google Play Console
Apple and Google separately provide us with aggregated, store-level analytics (e.g., number of downloads, aggregate install/uninstall trends) through App Store Connect and Google Play Console. This data is aggregated by Apple/Google before it reaches us and is not linked to your individual identity by us.
We may disclose personal information where required by law, court order, or governmental request, or where we believe disclosure is necessary to investigate or prevent illegal activity, fraud, or a threat to any person's safety, or to enforce our Terms of Use.
If the App is acquired by, or merged with, a third party, or undergoes a sale or transfer of some or all of its assets, we may transfer the information we have collected as part of that transaction, subject to this Privacy Policy (or a policy at least as protective).
We do not sell your personal information, and we do not share your custom in-app content (Section V) with advertisers.
VII. Data Retention
We retain personal information only for as long as necessary for the purposes for which it was collected, unless a longer retention period is required by law (e.g., tax or accounting obligations). When there is no ongoing legitimate need to process your information, we delete or anonymize it, or, where immediate deletion is not possible (e.g., information held in backup archives), we securely isolate it from further processing until deletion is possible.
VIII. Your Privacy Rights (EEA/UK Users)
Subject to applicable law, you have the right to:
- Right to information — request details of the personal data we hold about you (Art. 15 GDPR).
- Right to rectification — request correction of inaccurate or incomplete data (Art. 16 GDPR).
- Right to erasure — request deletion of your personal data, subject to certain exceptions (Art. 17 GDPR).
- Right to restriction — request that we limit the processing of your data (Art. 18 GDPR).
- Right to withdraw consent — at any time, with effect for the future (Art. 7(3) GDPR).
- Right to data portability — receive your data in a structured, machine-readable format (Art. 20 GDPR).
- Right to object — object to processing based on legitimate interests, including direct marketing (Art. 21 GDPR).
- Right to lodge a complaint with your local data protection supervisory authority (Art. 77 GDPR).
We will respond to requests to access, change, or delete your information within thirty (30) days.
IX. California Privacy Rights (CCPA/CPRA)
If you are a California resident, you have the right to: know what personal information we collect, use, and disclose; request deletion of your personal information; opt out of the “sale” or “sharing” of personal information (we do not sell your personal information); and not be discriminated against for exercising these rights. To exercise these rights, contact us using the details in Section XI below.
X. Data Security
We take appropriate technical and organizational measures to protect personal data against loss, misuse, and unauthorized alteration, and only authorized personnel have access to personal data. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security of information transmitted to or from the App.
We use your personal information only as described in the version of this Privacy Policy in effect at the time such information was collected. Your continued use of the Services constitutes acceptance of this Privacy Policy and any future revisions.
XI. Contact Us
If you have questions about this Privacy Policy, or wish to exercise any of the rights described above, please contact us at: Artstudio.nikitin@gmail.com