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Privacy Policy

Effective: 9 Oct, 2025

Blackout Lab S.L. ("Blackout," "we," "us," or "our") respects your privacy. This Privacy Policy explains how we collect, use, disclose, and protect personal information when you use our mobile applications and any other related services (collectively, the "Services").

By using any of our applications, we presume that you have agreed to this Policy. If you do not agree, please do not use the Services or cease immediately the usage of those.

1. Scope & Who We Are

This Policy applies to all Blackout mobile applications and related features we operate. It does not cover third-party sites or services we do not control.

Contact us:
Blackout Lab S.L. is a company registered in Spain, company number B67427971 and whose registered address is CALLE DIPUTACIO, 260 - P. 5, BARCELONA, Spain
Email: [email protected]

2. Summary: Notice at Collection

We collect the following personal information for the purposes and retention periods shown.

Identifiers
Examples: Device IDs, advertising IDs (IDFA/GAID), IP address, unique user ID
Purpose: App operation, analytics, advertising, fraud prevention
Retention: Active use + up to 2 years after inactivity

Device/Technical
Examples: Device type/model, OS version, browser type, country/region, language settings
Purpose: Functionality, service improvement, localization
Retention: Active use + up to 2 years after inactivity

Gameplay & Usage
Examples: Game progress, interactions, session duration, in-app actions, purchase history (not payment details)
Purpose: Service provision, personalization, analytics, app improvement
Retention: Active use + up to 2 years after inactivity

Contact Info
Examples: Email, name (only if you contact support)
Purpose: Support communications, responding to inquiries
Retention: As long as necessary for inquiry resolution

Demographic
Examples: Age range, year of birth, gender (optional, only for users who pass age gate)
Purpose: Service personalization, compliance with age restrictions
Retention: Active use + up to 2 years after inactivity

Advertising Data
Examples: Ad interactions, ad IDs, advertising preferences
Purpose: Ad delivery, measurement, personalization (with consent)
Retention: ~13 months (cookie/ad ID lifetime)

We do not knowingly collect data from children under 16. Our Services are for users who meet the minimum age requirements of the applicable to our Services local legislation.

Legal Basis for Processing (for EEA/UK/Swiss Users)
Where we process personal information, our legal bases under the GDPR/UK GDPR include:
Contract (Art. 6(1)(b)) – to provide our Services, including app functionality, game features, and in-app purchases.
Legitimate Interests (Art. 6(1)(f)) – to secure our Services, prevent fraud, improve app performance, conduct analytics, and deliver contextual advertising.
Consent (Art. 6(1)(a)) – where required for personalized/targeted advertising, optional features, cookies/SDKs for behavioral advertising, and marketing communications.
Legal Obligations (Art. 6(1)(c)) – to comply with applicable laws and regulatory requirements.

3. Sources of Personal Information

You (app usage, gameplay, optional profile information, support requests).
Your device (cookies, SDKs, advertising IDs, device signals, crash logs).
App store platforms (purchase confirmations, app version information).
Advertising/analytics partners (ad interaction data, cross-app behavioral signals; see §8).
Third-party services (social network connections if you choose to link accounts).

4. We use personal information in order to

  • Provide, operate, and improve the Services.
  • Authenticate users and secure accounts; prevent fraud and cheating.
  • Process in-app purchases and manage virtual currency.
  • Personalize gameplay experience and app content.
  • Deliver advertising (contextual and, with consent, personalized).
  • Measure ad performance and conduct analytics.
  • Communicate about updates, features, and support.
  • Respond to support inquiries and troubleshoot issues.
  • Comply with legal obligations and cooperate with lawful requests.

5. Disclosures of Personal Information

We disclose personal information to:
Service providers (hosting, analytics, customer support, fraud prevention, ad serving) under contracts limiting their use to our instructions.
Advertising/analytics partners (see §8 and your choices in §9).
App store platforms (for purchase verification and app distribution).
Corporate affiliates (within the 52 Entertainment group).
Law enforcement/regulators when legally required or to protect users/Blackout.
Corporate successors in case of merger, acquisition, or reorganization.

We do not sell personal information for money. Some jurisdictions treat certain ad/analytics disclosures as "sharing" for targeted advertising—see Your Choices (§9).

6. Third-Party Services & Advertising Partners

We integrate third-party SDKs and services to operate our apps and deliver advertising. These partners may collect data independently according to their own privacy policies:

  • Advertising & Monetization: AppLovin MAX, AdColony, Unity Ads, ironSource, Fyber, MoPub
  • Analytics & Attribution: Google Analytics / Firebase Analytics, Facebook Analytics, GameAnalytics, Amplitude, Tenjin, AppsFlyer
  • Social & Support: Facebook SDK, Google Play Services
  • Payment Processing: Google Play Billing / Apple In-App Purchase (we do not receive or store your payment card details)

These partners operate as independent controllers or processors. We recommend reviewing their privacy policies for details of their personal data practices.

7. Cookies, SDKs & Advertising

We use cookies, SDKs, and similar technologies for app functionality, preferences, analytics, and advertising. We also use identifiers with advertising/analytics partners to measure usage and (where enabled) deliver interest-based ads.

Mobile: You can reset/limit advertising IDs (IDFA/GAID) in your device settings.
In-App Settings: You can control personalized advertising consent through our in-app settings/consent management interface.

8. Your Privacy Choices & Rights

Depending on your location, you may have rights to access, delete, correct, portability, and opt out of targeted advertising ("sharing").

Submit requests via [email protected] with "Data Subject Request" in the subject line.
Include your name, email, and relevant identifiers (e.g., user ID) to help us verify your identity.
We will respond within the timeframe required by applicable law.
We do not discriminate against you for exercising your rights.

Opt-out of targeted advertising:
Use in-app consent settings; adjust Limit Ad Tracking (iOS) or Opt out of Ads Personalization (Android); enable a Global Privacy Control (GPC) signal in browser (where required).

Opt-out of geolocation: Disable location permissions in your device settings.

Opt-out of push notifications: Manage notification preferences in device settings.

We do not use or disclose sensitive personal information for purposes that require an opt-out right under applicable law.

Your GDPR/UK Privacy Rights:
If you are located in the EEA, UK, or Switzerland, you have additional rights, including access, rectification, erasure, restriction, portability, objection (including to marketing), not to be subject to automated decisions, and to withdraw consent at any time.

9. Data Retention

We retain personal information only for as long as necessary for the purposes described above:
- Active accounts: Data retained during active use.
- Inactive accounts: Deleted/anonymized after 2 years inactivity.
- Support inquiries: Retained as long as necessary.
- Legal obligations: As required by law.
- Aggregated/anonymized data: May be retained indefinitely.

10. Data Transfers

We process data primarily in the European Union and may transfer it to other countries, including the United States. For EEA/UK/Swiss users, we rely on Standard Contractual Clauses, EU-U.S. Data Privacy Framework certifications, and other safeguards.

Service Providers & Recipients
Cloud hosting (AWS, Google Cloud), advertising platforms (AppLovin, Unity, ironSource, etc.), analytics providers (Google Analytics, Firebase, AppsFlyer, GameAnalytics, Amplitude, Tenjin), customer support tools, payment processors (Google Play, Apple).

11. Security

We use administrative, technical, and organizational measures, including encryption in transit, access controls, monitoring, and regular security assessments. No system is perfect; please report any suspected unauthorized access to [email protected].

12. Children's Privacy

Our Services are not directed to children under 16. We do not knowingly collect personal information from children under 16. If we discover we have collected data from a child under 16, we will delete it promptly. If you believe we have information from a child under 16, please contact us at [email protected].

13. Changes to this Policy

We may update this Policy from time to time. If we make material changes, we will notify you via in-app notice or other appropriate means. The "Effective" date shows the latest version.

14. Contact Us & Your Rights

Questions or requests about this Policy or your data?

Blackout Lab S.L.
Data Protection Officer
c/o 52 Entertainment
Email: [email protected]

Supervisory Authority:
Depending on your location, you may have the legal right to lodge a complaint with your local data protection authority. If you are an EU citizen and are not sure which is the competent authority, you can check here.

This Privacy Policy is part of and incorporates by reference our Terms of Service.