01Who We Are
inkdotstudiogame is an independent game developer and publisher of mobile and PC games, operating from Vietnam.
For the purposes of the EU/UK General Data Protection Regulation ("GDPR"), Vietnam's Law on Personal Data Protection No. 91/2025/QH15 ("PDPL") and other applicable laws, we are the controller of the personal data described in this Policy, except where we state otherwise.
Contact for privacy matters: inkdotstudiogame@gmail.com.
02Scope of This Policy
This Policy applies to all games, applications, websites, community channels, customer support and related services that we operate and that link to this Policy (together, the "Services"). It does not apply to third-party platforms, stores or services (such as the Apple App Store, Google Play, Steam, Facebook or Discord), which are governed by their own privacy policies.
Some games may include a short supplemental privacy notice describing features specific to that game. Where a supplemental notice applies, it should be read together with this Policy.
03Information We Collect
3.1 Information you provide to us
- Account information: username, nickname, email address, password (stored in hashed form), date of birth or age range, country, and profile avatar, if you create an account.
- Social login information: if you sign in with Apple, Google, Facebook or another provider, we receive the identifier and basic profile data that provider shares with us according to your settings.
- Communications: messages, bug reports, screenshots, survey responses and other content you send to customer support or our community channels.
- User content: player names, chat messages, custom levels or other content you create or share in our games.
- Contest and event entries: information you submit to participate in promotions, beta tests or giveaways.
3.2 Information collected automatically
- Device and technical data: device model, operating system and version, language, time zone, screen resolution, app version, network type, and IP address (from which we may infer approximate location at country/city level).
- Identifiers: game player ID, installation ID, and — only where permitted by you and by your device settings — advertising identifiers such as Apple IDFA or Google Advertising ID (GAID), and vendor identifiers (IDFV).
- Gameplay data: progress, levels, scores, achievements, in-game inventory and currency balances, session length and frequency, settings, and interactions with game features.
- Purchase data: items purchased, price, currency, transaction ID and date. We do not receive or store your full payment card details; payments are processed by the app store or payment provider.
- Diagnostic data: crash logs, performance data and error reports.
- Advertising data: ad impressions, clicks, rewarded-ad completions and related information collected by our advertising partners.
- Website data: cookies and similar technologies on our website (see Section 14).
3.3 Information from third parties
- App stores and platforms (e.g., Apple, Google, Steam) — purchase confirmations, refund notices and, where applicable, platform account identifiers.
- Advertising, attribution and analytics partners — information about how you discovered our games and how you interact with ads.
- Anti-fraud and security providers — signals that help us detect cheating, fraud or abuse.
3.4 Information we do not collect
We do not intentionally collect sensitive personal data (such as information about health, religion, political opinions, biometrics, sexual life or precise geolocation) through our games. Please do not share such information with us in chats or support messages.
04How We Use Your Information
We use personal data for the following purposes, relying on the legal bases indicated (for users in the EEA/UK, and similar bases under other laws):
| Purpose | Legal basis |
|---|---|
| Provide and operate the games: save progress, sync across devices, deliver purchased items, maintain leaderboards and multiplayer features | Performance of a contract |
| Create and manage your account; authenticate you | Performance of a contract |
| Process in-app purchases, restore purchases and handle refunds | Performance of a contract; legal obligation |
| Provide customer support and respond to requests | Performance of a contract; legitimate interests |
| Analyze usage, fix bugs, balance gameplay and improve the Services | Legitimate interests; consent where required by law |
| Show advertisements, including rewarded ads, to keep games free | Legitimate interests (contextual ads); consent (personalized ads) |
| Measure the effectiveness of our marketing campaigns (attribution) | Consent where required; legitimate interests |
| Send service messages and, with your permission, marketing and push notifications | Contract (service); consent (marketing) |
| Prevent cheating, fraud, abuse and security incidents; enforce our Terms | Legitimate interests; legal obligation |
| Comply with legal obligations, tax and accounting rules, and lawful requests from authorities | Legal obligation |
Under Vietnam's PDPL, where processing is based on consent, we will obtain your clear, voluntary and specific consent for each purpose, and you may withdraw it at any time. Withdrawal does not affect processing carried out before the withdrawal.
05Advertising & Analytics
Some of our games are free to play and supported by advertising. Our advertising partners may use identifiers and technical data to show ads, limit how often you see an ad, prevent ad fraud and measure performance.
- Personalized ads: we only show ads tailored to your interests where you have consented (e.g., via our consent dialog in the EEA/UK and other opt-in jurisdictions, or Apple's App Tracking Transparency prompt on iOS). If you do not consent, you may still see non-personalized (contextual) ads.
- Opting out: you can change your choice at any time in the game's Settings → Privacy menu, reset or limit your advertising ID in your device settings (iOS: Settings → Privacy & Security → Tracking; Android: Settings → Google → Ads → Delete advertising ID), or disable tracking on your device.
- Remove ads: where offered, an "ad-free" purchase disables ad display but may not disable analytics required to operate the game.
06Third-Party Services We Use
Our games integrate third-party software development kits (SDKs) and services. Each provider processes data under its own privacy policy, linked below. The table lists both the services currently in use and the services that may be used in our games now or in the future; not every game uses every service. When we add a provider not listed here, we will update this Policy before the change takes effect.
| Provider | Purpose | Data involved | Status |
|---|---|---|---|
| Advertising & mediation | |||
| Google AdMob | Display ads, ad mediation, frequency capping, fraud prevention | Advertising ID (GAID/IDFA), IP address, device data, ad interactions | In use |
| Google User Messaging Platform (UMP) | Collect and store ad consent (GDPR/CCPA) | Consent choices, device data | In use |
| Unity Ads / Unity LevelPlay (ironSource) | Display ads, ad mediation | Advertising ID (GAID/IDFA), IP address, device data, ad interactions | May be used |
| AppLovin (MAX, AppLovin Exchange) | Display ads, ad mediation | Advertising ID (GAID/IDFA), IP address, device data, ad interactions | May be used |
| Meta Audience Network | Display ads | Advertising ID (GAID/IDFA), IP address, device data, ad interactions | May be used |
| Liftoff Monetize (Vungle) | Display ads | Advertising ID (GAID/IDFA), IP address, device data, ad interactions | May be used |
| Mintegral | Display ads | Advertising ID (GAID/IDFA), IP address, device data, ad interactions | May be used |
| Pangle | Display ads | Advertising ID (GAID/IDFA), IP address, device data, ad interactions | May be used |
| InMobi | Display ads | Advertising ID (GAID/IDFA), IP address, device data, ad interactions | May be used |
| Digital Turbine (DT Exchange) | Display ads | Advertising ID (GAID/IDFA), IP address, device data, ad interactions | May be used |
| Chartboost | Display ads | Advertising ID (GAID/IDFA), IP address, device data, ad interactions | May be used |
| Analytics, crash reporting & remote config | |||
| Google Firebase (Analytics, Crashlytics, Remote Config, Cloud Messaging) | Usage analytics, crash reports, A/B testing, push notifications | App instance ID, gameplay events, device data, crash logs, push token | May be used |
| Unity Analytics / Unity Gaming Services | Gameplay analytics, cloud save, diagnostics | Player ID, gameplay events, device data | May be used |
| GameAnalytics | Gameplay analytics | Device ID, gameplay events, device data | May be used |
| Attribution & marketing measurement | |||
| AppsFlyer | Install attribution, campaign measurement | Advertising ID, IP address, install source, device data | May be used |
| Adjust | Install attribution, campaign measurement | Advertising ID, IP address, install source, device data | May be used |
| Meta (Facebook) SDK | Campaign measurement, optional Facebook Login | Advertising ID, app events, Facebook user ID (if you log in) | May be used |
| Payments, sign-in & platform services | |||
| Google Play Billing & Google Play Games Services | In-app purchases, achievements, leaderboards, cloud save | Transaction records, Play Games player ID | May be used |
| Apple App Store, Game Center & Sign in with Apple | In-app purchases, achievements, leaderboards, sign-in | Transaction records, Game Center ID, Apple ID token | May be used |
| Steam (Valve) | PC distribution, purchases, achievements | Steam ID, transaction records | May be used |
We do not receive your full payment card details from any of these providers. Some advertising partners may act as independent controllers of the data they collect; please review their policies for details on how to exercise your rights with them directly.
07How We Share Your Information
We do not sell your personal data for money. We share personal data only as follows:
- Service providers (processors) who host our servers, provide analytics, customer support tools, anti-cheat, cloud storage and similar services, under contracts that restrict their use of the data.
- Advertising and attribution partners, as described in Sections 5 and 6, subject to your choices.
- Platforms and app stores, to process purchases and enable platform features.
- Other players: your username, avatar, scores, and content you share publicly (e.g., leaderboards, chats) are visible to other players.
- Corporate transactions: in connection with a merger, acquisition, financing or sale of assets, subject to confidentiality and to this Policy.
- Legal and safety: where required by law, court order or a competent authority, or to protect the rights, property or safety of inkdotstudiogame, our players or the public.
- With your consent or at your direction.
08International Data Transfers
We are based in Vietnam and our service providers may process data in other countries, including Singapore, the United States and the European Union. These countries may have data protection laws different from those of your country.
When we transfer personal data internationally, we take appropriate safeguards, such as the European Commission's Standard Contractual Clauses (and UK equivalents) for data from the EEA/UK, and, where required, we prepare and file cross-border data transfer impact assessments in accordance with Vietnam's PDPL and its implementing decree. You may contact us for more information about these safeguards.
09Data Retention
We keep personal data only for as long as necessary for the purposes described in this Policy:
- Account and game data: for as long as your account is active. If you delete your account, we delete or anonymize it within 30 days, except as below.
- Inactive accounts: may be deleted after 24 months of inactivity, with prior notice where we have your contact details.
- Purchase records: kept for the period required by tax and accounting laws (generally up to 10 years under Vietnamese accounting law).
- Support communications: up to 3 years after the ticket is closed.
- Analytics and diagnostic data: generally up to 14–26 months, depending on the provider's settings, then aggregated or deleted.
- Data needed to resolve disputes, enforce our Terms or comply with legal obligations may be kept longer for that purpose.
10Data Security
We implement appropriate technical and organizational measures to protect personal data, including encryption in transit (TLS), access controls based on the least-privilege principle, hashing of passwords, logging and monitoring, and confidentiality obligations for staff and contractors. No method of transmission or storage is 100% secure; however, we work to protect your data and will notify you and the relevant authorities of a personal data breach where required by law (including within the timeframes required under the GDPR and Vietnam's PDPL).
11Your Rights & Choices
Depending on where you live, you may have some or all of the following rights:
- Access — obtain a copy of the personal data we hold about you.
- Rectification — correct inaccurate or incomplete data.
- Deletion — ask us to delete your data.
- Restriction — ask us to limit processing in certain cases.
- Portability — receive your data in a structured, machine-readable format.
- Objection — object to processing based on legitimate interests, including direct marketing.
- Withdraw consent — at any time, without affecting prior lawful processing.
- Complain — lodge a complaint with a data protection authority.
11.1 Users in Vietnam
Under the PDPL, you have the right to be informed, to consent and withdraw consent, to access, correct, delete and restrict processing of your personal data, to request provision of your data, to object to processing, to file complaints, denunciations and lawsuits, to claim compensation for damage, and to self-protect, as provided by law. You may file complaints with the competent personal data protection authority under the Ministry of Public Security.
11.2 Users in the EEA, UK and Switzerland
You have the rights listed above under the GDPR/UK GDPR. You may lodge a complaint with the supervisory authority in your country of residence.
11.3 California and other U.S. state residents
If you are a California resident, the California Consumer Privacy Act as amended by the CPRA ("CCPA") gives you the right to know what personal information we collect, use and disclose; to delete it; to correct it; to opt out of the "sale" or "sharing" of personal information for cross-context behavioral advertising; to limit the use of sensitive personal information; and not to be discriminated against for exercising these rights.
- In the past 12 months we have collected the categories of personal information described in Section 3 (identifiers, commercial information, internet/network activity, approximate geolocation and inferences) for the purposes described in Section 4.
- We do not sell personal information for money. Our use of advertising partners for personalized ads may constitute "sharing" under the CCPA. You can opt out via the in-game Settings → Privacy → Do Not Sell or Share My Personal Information option, by disabling ad tracking on your device, or by enabling a Global Privacy Control (GPC) signal where supported.
- We do not knowingly sell or share personal information of consumers under 16.
Residents of other U.S. states with comprehensive privacy laws (such as Virginia, Colorado, Connecticut, Utah, Texas and Oregon) may have similar rights, including the right to appeal our decision on a request by replying to our response.
11.4 How to exercise your rights
Send your request to inkdotstudiogame@gmail.com or use the in-game Settings → Privacy menu where available. Please include your player ID (found in the game settings) so we can locate your data. We may need to verify your identity before responding. We will respond within the time limits required by applicable law (for example, one month under the GDPR, 45 days under the CCPA, and the timelines prescribed under Vietnamese law). You may use an authorized agent where permitted by law.
12Children's Privacy
Our games are intended for a general audience and are not directed to children under 13 (or the minimum age of digital consent in your country, which may be up to 16 in some EU member states).
- Where a game may attract younger players, we may use a neutral age screen. If a user indicates they are under the applicable age, we limit data collection to what is necessary to support the internal operations of the game, disable personalized advertising, behavioral profiling and social features, and serve only contextual, age-appropriate ads.
- We comply with the U.S. Children's Online Privacy Protection Act (COPPA), Google Play's Families Policy (where applicable) and Apple's guidelines for the Kids Category.
- Under Vietnamese law, the processing of children's personal data requires the consent of the child (where required by law based on age) and of the parent or legal guardian, and is carried out in the best interests of the child.
If you are a parent or guardian and believe your child has provided us with personal data without appropriate consent, please contact us at inkdotstudiogame@gmail.com and we will promptly delete it.
13Account & Data Deletion
You may request deletion of your account and associated data at any time:
- In-game: open Settings → Account → Delete Account (where available) and follow the instructions.
- By email (available even if you have already uninstalled the game): send a request with the subject "Delete my data" and your player ID to inkdotstudiogame@gmail.com.
Deletion is permanent: your progress, virtual items and virtual currency will be lost and cannot be restored. Uninstalling a game does not by itself delete data stored on our servers. Some data may be retained as described in Section 9.
14Cookies & Similar Technologies
Our website uses cookies and similar technologies:
- Strictly necessary cookies — required for the website to function (e.g., remembering your consent choices). These do not require consent.
- Analytics cookies — help us understand how visitors use the website. Used only with your consent where required.
- Marketing cookies — used to measure and personalize advertising. Used only with your consent.
You can manage your preferences through our cookie banner or your browser settings. Blocking some cookies may affect website functionality.
15Third-Party Links
The Services may contain links to third-party websites, social networks or services. We are not responsible for the privacy practices of those third parties, and we encourage you to read their privacy policies.
16Changes to This Policy
We may update this Policy from time to time to reflect changes in our Services, technology or the law. We will post the updated Policy here and update the "Last updated" date. If changes are material, we will notify you through the game, by email or by other appropriate means, and obtain your consent where required by law.
17Contact Us
If you have questions, requests or complaints regarding this Policy or our data practices, please contact:
inkdotstudiogame
Email: inkdotstudiogame@gmail.com