Privacy Policy
This Privacy Policy explains how LIGHTGAMES PTE. LTD., a company incorporated in Singapore that publishes games under the Light Gamers brand (“Light Gamers”, “we”, “us” or “our”), handles personal information when you play our mobile games, visit our website or contact us (together, the “Services”). LIGHTGAMES PTE. LTD. is the organisation responsible for your personal information (the “controller”).
Please read this policy together with our User Terms. By using the Services, you acknowledge the practices described here.
1. Information we collect
What we collect depends on which Services you use and the choices you make in your device and game settings. Our games are designed to be played without giving us your name or other contact details. We collect:
- Identifiers – an in-game player ID, device identifiers, advertising identifiers (such as Apple’s IDFA, where you allow tracking, or the Google Advertising ID) and your IP address.
- Device and technical data – device model, operating system and version, language, time zone, app version, network type, and crash and performance logs.
- Gameplay and usage data – levels played, progress, scores, session length, in-game actions and settings, and how you interact with ads shown in our games.
- Purchase history – which in-game items you bought, when, and the price and currency. Payments are processed by the app store (for example, the Apple App Store or Google Play); we do not receive your full payment card details.
- Approximate location – your country or region, inferred from your IP address. We do not collect precise (GPS) location.
- Communications – your email address and the content of any message you send us, for example when you ask for support.
2. How and why we use information
We use personal information for the purposes below. If you are in the European Economic Area (EEA), the United Kingdom or another place with similar laws, we rely on the legal grounds shown for each purpose.
- To provide the Services – deliver our games, save your progress, process and restore purchases, and answer support requests. Legal ground: performance of our contract with you.
- To improve and develop our games – analyse how our games are played, fix bugs, balance levels, test new features and create new games. Legal ground: our legitimate interests.
- To show and measure ads – show ads in our games (including optional rewarded ads), measure how ads perform, and, where permitted, personalise ads. Legal ground: your consent where the law requires it, otherwise our legitimate interests.
- To market our games – run and measure advertising campaigns for our games on other apps and websites, including working out which campaign led to an install. Legal ground: your consent where the law requires it, otherwise our legitimate interests.
- To keep the Services safe and fair – detect and prevent fraud, cheating, abuse and security incidents. Legal ground: our legitimate interests.
- To meet legal obligations – comply with applicable law, enforce our terms, and respond to lawful requests from authorities. Legal ground: legal obligation and our legitimate interests.
Where we rely on your consent, you can withdraw it at any time (see sections 5 and 6). Withdrawing consent does not affect processing that took place before you withdrew it.
3. Where we get information
- From you – when you contact us or make choices in our games, such as privacy or ad settings.
- Automatically – from your device when you use our games, through software development kits (SDKs) and similar technologies built into the games. Our website does not use advertising or analytics cookies.
- From platforms – such as Apple and Google, for example to confirm or restore a purchase.
- From partners – such as advertising, attribution and analytics providers, for example information about which ad campaign led you to install one of our games.
4. How we share information
We share personal information only as described below:
- Service providers that process information on our behalf and under our instructions, such as cloud hosting, analytics, crash reporting and customer support tools.
- Advertising and attribution partners (such as ad networks, ad mediation platforms and install-attribution providers) so that ads can be shown, measured and, where permitted, personalised. These partners may also use the information under their own privacy policies.
- Platforms such as Apple and Google, when needed to process purchases or provide platform features.
- Business transfers – if we are involved in a merger, acquisition, financing or sale of assets, information may be transferred as part of that transaction.
- Legal and safety – when we believe it is required by law, or necessary to protect the rights, property or safety of our players, us or others.
- With your consent – in any other case where you have asked us to, or agreed to it.
Notice for U.S. residents. Some U.S. state laws treat making identifiers, device data and usage data available to advertising partners for personalised advertising as a “sale” or “sharing” of personal information. You can opt out at any time, as described in sections 5 and 6.
5. Your choices: ads and tracking
- iPhone and iPad – we only access your device’s advertising identifier if you allow tracking. You can change this at any time in Settings › Privacy & Security › Tracking.
- Android – you can delete or reset your advertising ID, or opt out of ads personalisation, in your device’s Settings (usually under Privacy › Ads or Google › Ads).
- In-game settings – where a game offers privacy or consent settings, you can change your choices there.
- Stopping collection – you can stop all further collection by a game by uninstalling it.
If you opt out of personalised ads, you may still see ads, but they will be less relevant to you.
6. Your privacy rights
Depending on where you live, including under Singapore’s Personal Data Protection Act 2012, the EU and UK General Data Protection Regulation, and U.S. state privacy laws, you may have the right to:
- access the personal information we hold about you and get a copy of it;
- correct inaccurate or incomplete information;
- delete your information;
- receive your information in a portable format;
- object to or restrict certain processing;
- withdraw consent you have given;
- opt out of the “sale” or “sharing” of personal information and of targeted advertising;
- appeal our decision on your request; and
- complain to a data protection authority, such as Singapore’s Personal Data Protection Commission or your local authority in the EEA or UK.
To make a request, email [email protected] with “Privacy Request” in the subject line. If you can, include your in-game player ID so we can find your data. We may need to verify your identity before acting on a request, and we will respond within the time required by applicable law. You may use an authorised agent where the law allows it. We will not discriminate against you for exercising your rights.
7. Data retention
We keep personal information only for as long as it is needed for the purposes described in this policy. This includes providing the Services, meeting legal, accounting and reporting obligations, resolving disputes and enforcing our agreements. When information is no longer needed, we delete it or anonymise it.
8. Children’s privacy
Our Services are intended for a general audience and are not directed to children under 13, or a higher minimum age where local law requires (for example, 16 in some EEA countries). We do not knowingly collect personal information from children under that age without a parent’s or guardian’s consent where it is required. Where a game may appeal to younger players, we may use an age screen and limit data collection and advertising for those players. If you believe a child has given us personal information, please contact us and we will promptly delete it.
9. Data security
We use reasonable technical and organisational measures designed to protect personal information against loss, misuse, and unauthorised access, disclosure, alteration or destruction. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.
10. International transfers
We are based in Singapore, and our service providers and partners may process information in other countries, including the United States, whose data protection laws may differ from those where you live. When we transfer personal information across borders, we take steps required by applicable law to make sure it receives a comparable standard of protection. These steps include contractual safeguards such as standard contractual clauses.
11. Third-party services and links
Your use of our games is also subject to the terms and privacy policies of the platform you downloaded them from, such as the Apple App Store or Google Play. Our Services may contain ads or links to third-party websites and services. We are not responsible for the privacy practices of those third parties, and we encourage you to read their privacy policies.
12. Changes to this policy
We may update this Privacy Policy from time to time. We will post the updated version on this page and change the “Last updated” date above. If the changes are material, we will provide additional notice, for example in our games, and ask for your consent where the law requires it. Your continued use of the Services after an update means the updated policy applies.
13. Contact us
If you have any questions about this Privacy Policy or how we handle your personal information, or you want to contact our Data Protection Officer, please email [email protected].
LIGHTGAMES PTE. LTD.
Singapore