Marketing Policy

Marketing Policy

Blu Games Pte. Ltd. · Internal · Effective 19 August 2026 · Version 1.0

This Policy sets the standards that govern all marketing and user acquisition activity carried out by or on behalf of Blu Games Pte. Ltd. and its group entities. It is binding on employees, contractors, agencies, freelancers and any partner who creates, buys, approves or publishes marketing on our behalf.

Owner: Head of Growth. Approver: CEO. Review cycle: every 6 months, or on any material platform policy change.

1. Scope

This Policy covers:

Paid user acquisition across all networks — including Meta, Google Ads, AppLovin, Unity Ads, Mintegral, Liftoff, TikTok and any network added later.

All creative assets: video, static, playable, HTML5, interactive end cards, and app store assets.

App Store Optimisation — titles, subtitles, keywords, screenshots, preview videos and store descriptions.

Influencer, creator and affiliate marketing.

Owned channels — social accounts, community servers, push notifications, email and in-game cross-promotion.

Public relations, press materials and investor-facing marketing claims.

2. Governing Principle

Every advertisement we run must be a truthful representation of the product a player will receive. If a player installing from an ad would feel misled by what they find, the ad does not go out — regardless of how it performs.

This is not only an ethical position. Misleading creative is the single largest source of app store removals, network account bans and regulatory action in mobile gaming, and the risk it creates is out of proportion to any short-term CPI gain.

3. Creative Standards

3.1 Required

Gameplay shown in an ad must exist in the shipped build, or must be clearly and legibly labelled as a dramatisation, cinematic or concept.

Metagame, puzzle or mini-game sequences used as hooks must be reachable in the live game. Where a hook appears later in progression, it must still be genuinely attainable.

All claims about ratings, download counts, rankings or awards must be current, sourced and evidenced in the creative brief.

Monetisation must not be concealed: ads must not imply the game is free of in-app purchases or advertising when it is not.

Creative must carry the correct age-appropriate rating signals for the network and territory it runs in.

3.2 Prohibited

Fake or simulated gameplay presented as real gameplay without a disclaimer.

Fake user interface elements — simulated system dialogs, false close buttons, fake cursors, decoy CTAs, or any element designed to induce an accidental click.

"Fail" creative deliberately engineered to provoke a click through frustration where the underlying mechanic does not exist in the game.

Gambling, casino, slot-machine or real-money-wagering framing for a game that contains no such mechanic, and any framing that implies a cash prize or payout.

Sexualised imagery, violence, shock content, or any depiction of minors in a sexual, romantic or unsafe context. This is an absolute prohibition with no exceptions and no test-and-learn allowance.

Content that demeans or stereotypes any group by race, ethnicity, religion, nationality, gender, sexual orientation, disability or age.

Third-party intellectual property — characters, logos, trademarks, film or TV footage, sports league content, or unlicensed music — in any creative asset.

Countdown timers, scarcity claims or "last chance" messaging that is not factually true.

Health, financial or cognitive-benefit claims ("improves your IQ", "train your brain") without substantiation.

3.3 Playables and interactive ads

Playables must be built to the MRAID specification for the destination network and tested on the network’s validator before launch.

The playable mechanic must correspond to a mechanic in the live game.

The end card must show the correct app icon, title and store destination, and the close control must be present, functional and reachable throughout.

File size, load time and battery impact must meet each network’s published limits.

4. Music, Assets and Intellectual Property

Every asset used in a creative must have a documented licence covering paid advertising use, in the territories and for the duration it will run.

Stock, AI-generated and outsourced assets must have their licence or provenance recorded in the asset library before use.

AI-generated creative must be reviewed by a human before publication and must not reproduce identifiable real people or protected works.

Competitor games may not be named, shown or referenced in our creative.

5. Targeting and Audience Restrictions

No campaign may be targeted at users under 13, or under the applicable minimum age in the territory. Age targeting must be set explicitly rather than left at network default.

Campaigns must not target audiences built on sensitive characteristics — health, finances, religion, politics, sexual orientation or ethnicity.

Retargeting and lookalike audiences may only be built from data collected with a valid legal basis, and must respect App Tracking Transparency and EEA consent signals.

Territory targeting must exclude any market where the title is not classified, rated or lawfully distributable.

6. Data and Privacy in Marketing

Marketing activity must comply with the Blu Games Privacy Policy. Where the two documents differ, the Privacy Policy prevails.

No personally identifiable information may appear in creative assets, campaign names, or shared reporting.

Audience uploads to ad networks require documented consent and hashing; raw email or phone lists must never leave our systems unhashed.

SKAdNetwork and AdAttributionKit conversion value schemas must not be configured in a way that attempts to re-identify individual users.

Any new SDK, pixel or tracker added for marketing purposes requires a privacy review and an update to the partner list in the Privacy Policy before it goes live.

Privacy reviews, partner-list updates and any question about whether an activity is permitted under the Privacy Policy are raised to privacy@blu.games before the activity begins, not after.

7. Influencer, Creator and Affiliate Marketing

Every paid or incentivised placement must carry a clear and conspicuous disclosure — #ad or #sponsored placed where a viewer will see it before engaging, not buried in a description.

Contracts must require disclosure and give Blu Games the right to require removal of non-compliant content.

Creators must not be scripted to make claims we could not make ourselves under Section 3.

We do not buy, incentivise or solicit fake reviews, fake ratings or fake install volume on any storefront. This includes review-gating that solicits positive reviews only.

Affiliate and rewarded-install traffic must be disclosed to the platform where platform policy requires it, and must be excluded from ROAS reporting used for investor or board purposes unless separately labelled.

8. Approval Workflow

No creative may go live without a recorded Review approval. Approvals, briefs and asset licences are retained for three years.

9. Spend Authorisation and Fraud Controls

Campaign spend must stay within the budget approved for the period. Any increase above the approved cap requires CEO sign-off in writing before the change is applied.

New networks must be onboarded on a capped test budget and reviewed for traffic quality before scale.

Attribution fraud filters must be enabled at the MMP, and suspicious traffic — click flooding, install hijacking, device farms, abnormal CTR-to-install ratios — must be investigated and claimed back from the network.

Performance data presented internally, to the board or to investors must be reconciled to source-of-truth systems and must state whether figures are gross or net, and which cohorts are excluded and why.

10. Platform Compliance

All activity must comply with the published policies of the platforms we distribute and advertise on, including the Apple App Store Review Guidelines and Apple Search Ads policies, Google Play Developer Programme Policies and Google Ads policies, Meta Advertising Standards, and the advertising policies of AppLovin, Unity, Mintegral, Liftoff and TikTok.

Where this Policy is stricter than a platform policy, this Policy applies. Where a platform policy is stricter, the platform policy applies. Where a territory imposes additional requirements — for example EU Digital Services Act trader obligations, loot-box disclosure rules, or national advertising codes — those requirements apply in that territory.

11. Breach and Escalation

Any team member who identifies a non-compliant asset must pause the campaign immediately. Pausing is always the correct first action and will never be treated as an error.

The incident is reported to the Head of Growth the same working day.

The Head of Growth records the cause, remediates the asset, and reports to the CEO within two working days.

Network account warnings, store rejections and takedown notices are escalated to the CEO immediately and logged.

Repeated or deliberate breaches by an agency or contractor are grounds for termination of the engagement. For employees, they are a disciplinary matter.

12. Acknowledgement

All personnel and partners engaged in marketing activity for Blu Games confirm that they have read this Policy and will comply with it. Agencies and contractors must have it incorporated by reference into their engagement terms.

Approved by: _______________________________ Date: _______________

Prashanth Vijay Udumula, Chief Executive Officer, Blu Games Pte. Ltd.