BLU GAMES PTE. LTD.

Privacy Policy

Privacy Policy

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

This Privacy Policy explains how Blu Games Pte. Ltd. (UEN 202540034C, registered at 10 Anson Road, #26-06A International Plaza, Singapore 079903) ("Blu Games", "we", "us") collects, uses, shares and protects personal data when you play our mobile games, visit blu.games, or contact our support team.

Blu Games is the data controller for the personal data described in this Policy. Our games are published under the Funstop Games brand.

1. Scope

This Policy applies to all mobile games published by Blu Games on the Apple App Store and Google Play (including FinalFront and future titles), our websites, our playable and interactive advertisements, and our player support channels (together, the "Services").

Your use of the Services is also governed by our Terms of Service, which sit alongside this Policy.

It does not apply to third-party services you reach through our Services — including the App Store, Google Play, advertisers whose ads appear in our games, or any social platform you connect from. Those parties operate under their own privacy policies.

2. Data We Collect

We do not require you to create an account or provide your name to play. The data we collect falls into the following categories.

2.1 Device and technical data

Device identifiers: Identifier for Advertisers (IDFA) and Identifier for Vendors (IDFV) on iOS; Google Advertising ID (GAID) and App Set ID on Android; and internally generated pseudonymous installation IDs.

Device and environment: device model, operating system and version, language, country/region, time zone, screen resolution, network type, carrier, and available storage or memory where relevant to performance.

IP address, from which approximate (city or country level) location is derived. We do not collect GPS or precise location data.

2.2 Gameplay and usage data

Session data: install date, session starts and length, frequency of play, and retention events.

Progression data: levels reached, in-game currency and item balances, difficulty settings, wins and losses, and feature usage.

Interaction data: taps on menus and offers, tutorial completion, and A/B test group assignment.

2.3 Purchase data

Records of in-app purchases: product purchased, price, currency, store, transaction and receipt identifiers, purchase and renewal dates, refunds and cancellations.

We do not receive or store your full payment card number, bank details, or billing address. Payments are processed entirely by Apple or Google.

2.4 Advertising data

Ad impressions, clicks, rewarded-video completions, and estimated ad revenue attributed to your session.

Attribution data showing which advertising campaign, network, creative and channel led to your install.

On iOS, where you have not granted App Tracking Transparency permission, we rely on aggregated and privacy-preserving measurement (SKAdNetwork / AdAttributionKit) rather than device-level identifiers.

2.5 Diagnostic data

Crash reports, error logs, frame-rate and load-time metrics, and the technical state of the app at the point of failure.

2.6 Support data

If you contact us: your email address, the content of your message and any attachments, your player or device identifier, and our correspondence with you.

If you exercise a privacy right, the information we need to verify that the request relates to your data.

3. How We Use Data

Where we rely on consent, you can withdraw it at any time — see Section 8. Withdrawal does not affect processing carried out before withdrawal.

4. Advertising and Tracking

Our games are free to play and funded by a combination of in-app purchases and advertising. Advertising is delivered through mediation partners who work with a number of demand-side ad networks.

iOS: before any tracking for personalised advertising takes place, we present the Apple App Tracking Transparency prompt. If you decline, we do not access the IDFA and do not use device-level identifiers for advertising personalisation.

Android: you can reset or delete your advertising ID, or opt out of ad personalisation, in your device settings under Settings › Privacy › Ads.

EEA/UK: we present a consent management prompt compliant with the IAB Transparency & Consent Framework before setting non-essential identifiers. You can change your choices at any time from the in-game Settings › Privacy screen.

We do not use our games to build profiles about your health, finances, religion, politics, sexual orientation, or any other special category of personal data.

5. Who We Share Data With

We do not sell personal data for money. We share data only with the categories of recipient below, and only as needed for the purposes in Section 3.

5.1 Service providers and technology partners

An up-to-date list of active partners is maintained at blu.games/privacy and is available on request.

5.2 Corporate group

Blu Games is part of a group that includes Recreations Lab Pvt. Ltd. (India) and Blu Games FZ LLC (United Arab Emirates), and engages personnel and contractors in India, Singapore, the UAE, Türkiye and elsewhere. Group personnel may access data on a need-to-know basis for development, analytics, user acquisition and support, under written confidentiality and data protection terms.

5.3 Legal and corporate transactions

We may disclose data where required by law, court order, or a lawful request from a public authority, or to establish, exercise or defend legal claims.

If Blu Games is involved in a merger, acquisition, financing or sale of assets, data may be transferred as part of that transaction, subject to this Policy continuing to apply.

6. International Transfers

We operate globally, and personal data may be transferred to and processed in countries other than the one you live in — including Singapore, India, the United Arab Emirates, Türkiye, the United States and the European Union.

Where we transfer personal data out of the EEA, the UK or Switzerland to a country without an adequacy decision, we rely on the European Commission’s Standard Contractual Clauses (and the UK International Data Transfer Addendum where applicable), together with supplementary technical and organisational measures. Transfers out of Singapore are made in accordance with the transfer limitation obligation under the Personal Data Protection Act 2012.

7. Retention

After these periods we delete the data or irreversibly aggregate it so it can no longer be linked to you or your device.

8. Your Rights and Choices

Subject to your jurisdiction, you may have the right to:

Access the personal data we hold about you and receive a copy of it.

Correct data that is inaccurate or incomplete.

Delete your data, subject to legal retention requirements.

Restrict or object to certain processing, including profiling for advertising purposes.

Receive your data in a portable, machine-readable format.

Withdraw consent at any time where processing is based on consent.

Opt out of the sale or sharing of personal data, and of cross-context behavioural advertising, if you are a California resident. Some of our advertising activity may constitute "sharing" under the CCPA/CPRA; you can opt out through the in-game Settings › Privacy screen or by contacting us.

Lodge a complaint with your supervisory authority, or with Singapore’s Personal Data Protection Commission.

To exercise any of these rights, email privacy@blu.games from the address associated with your account, or use the in-game Settings › Privacy › Data Request option. We respond within 30 days and will tell you if we need longer. We will not discriminate against you for exercising a right, and we do not charge for a first request.

9. Children

Our games are not directed at children. They are rated for players aged 13 and over on Google Play and 12+ on the App Store, and we do not knowingly collect personal data from children under 13 (or under the applicable minimum age in your country, which is 16 in some EEA member states).

Where a store age signal or age screen indicates a user is under the applicable age, we disable personalised advertising, limit analytics to what is strictly necessary, and treat any advertising served as child-directed under the relevant platform policies.

If you believe a child has provided us with personal data, contact privacy@blu.games and we will delete it promptly.

10. Security

We apply technical and organisational measures appropriate to the risk, including encryption of data in transit (TLS) and at rest, role-based access control on the principle of least privilege, multi-factor authentication on production and analytics systems, logging and monitoring, vendor due diligence, and contractual confidentiality obligations on all personnel and contractors.

No system is completely secure. If a personal data breach is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority and, where required, affected players without undue delay.

11. Changes to this Policy

We may update this Policy to reflect changes in our Services, our partners, or applicable law. The version number and effective date at the top of this document will change accordingly. Where a change is material, we will give notice in-game or by another prominent means before it takes effect.

12. Contact

Blu Games Pte. Ltd.

10 Anson Road, #26-06A International Plaza, Singapore 079903

Privacy enquiries and data requests: privacy@blu.games

Player support: support@blu.games

Data Protection Officer (PDPA s.11(3)): dpo@blu.games

Legal and IP notices: legal@blu.games

Representatives

We have designated the following representatives under Article 27 of the EU GDPR and the UK GDPR. You may contact them on any matter relating to our processing of personal data, instead of or in addition to contacting us.

EU / EEA representative (Article 27, EU GDPR)

[Representative legal name]

[Street address, postcode, city, EU member state]

[representative email address]

UK representative (Article 27, UK GDPR)

[Representative legal name]

[Street address, postcode, city, United Kingdom]

[representative email address]

Contacting a representative does not affect your right to lodge a complaint with your local supervisory authority.

Purpose What we do Legal basis (EEA/UK)
Operate the game Run gameplay, save progress, restore purchases, sync across devices, deliver live-ops events. Performance of a contract
Support Answer your questions, investigate lost progress, resolve payment issues. Performance of a contract
Improve and balance Analyse aggregate play patterns, run A/B tests, fix bugs, tune difficulty and economy. Legitimate interests
Security and fraud Detect cheating, bot traffic, ad fraud, refund abuse and account takeover. Legitimate interests
Non-personalised ads Serve contextual advertising that does not rely on tracking. Legitimate interests
Personalised ads Serve advertising tailored to you and measure campaign performance using device identifiers. Consent
Marketing our games Measure install attribution, build audiences for user acquisition and retargeting. Consent
Legal compliance Meet tax, accounting, consumer-protection and platform obligations; respond to lawful requests. Legal obligation
Partner Role Data involved
Unity Technologies Game engine and runtime services Device and diagnostic data
Adjust GmbH Mobile measurement and attribution Device identifiers, install and event data
RevenueCat, Inc. In-app purchase and subscription management Purchase and receipt data, pseudonymous user ID
AppLovin (MAX) Ad mediation and demand Device identifiers, ad interaction data
Mediated ad networks Ad demand — including Google AdMob, Meta Audience Network, Liftoff, Mintegral and others Device identifiers, ad interaction data
Apple, Google App distribution, payments, push notifications, crash reporting Purchase, device and diagnostic data
Cloud and analytics hosting Storage, processing and business intelligence All categories, pseudonymised where possible
Support tooling Ticketing and correspondence Support data
Data type Retention period Reason
Gameplay and progression While the game is installed, then 24 months Progress restoration and reinstalls
Advertising and attribution 13 months from collection Campaign measurement cycle
Purchase records 7 years Tax, accounting and audit obligations
Diagnostic and crash logs 90 days Debugging window
Support correspondence 24 months from closure Dispute handling and quality review
Privacy request records 3 years Demonstrating compliance