Privacy Policy

This Privacy Policy explains how Individual Entrepreneur Muratov Lenur Mustafayevich (hereinafter "Operator," "we," "us," or "our") collects, uses, shares, and protects the personal data of users (hereinafter "you" or "User") of the mobile game MELS and related services (hereinafter the "Services"). MELS is an ad-supported game that may show advertising and offer optional in-app purchases.

We act as the Data Controller and are responsible for processing your information in accordance with applicable data protection laws, including the EU/UK General Data Protection Regulation (GDPR), the Swiss Federal Act on Data Protection (FADP), the California Consumer Privacy Act as amended by the CPRA (CCPA/CPRA), and other United States state privacy laws.

What Data We Collect

• Data You Provide to Us:
  • Account & Registration Data: nickname, email address, and password.
  • Support Data: any information you submit when contacting our customer support.
• Data Collected Automatically:
  • Gameplay Data: progress, achievements, in-app purchases, and in-game activity.
  • Gameplay & Behavioral Telemetry: in-game events generated as you play, such as level starts and completions, combat actions and their outcomes (e.g., rounds, hits, critical hits, unit health changes, weapon used), in-game tap coordinates within the game screen, the in-game screens you view, and menu interactions (clicks and navigation). This telemetry is associated with a player/session identifier and is used to measure and improve the game.
  • Session & Device Identifiers: session identifiers, your PlayFab player identifier, device type and model, and operating system version.
  • Technical & Device Data: IP address, language, and crash/diagnostic reports.
  • Advertising Identifiers: Google Advertising ID (GAID/AAID) on Android, IDFA on iOS, and similar identifiers used by our advertising partners.
  • Location Data: We collect approximate location derived from your IP address (country/region/city level). In addition, our advertising and analytics partners Yandex Mobile Ads and Yandex AppMetrica may collect precise (GPS-level) location through the device, where permitted by your device permissions and your consent, for advertising and measurement purposes. Our other advertising and attribution partners (Google AdMob and AppsFlyer) may process your IP address and advertising identifiers for advertising, analytics, and attribution. You can disable location access at any time in your device settings.

For iOS Users (App Tracking Transparency): on iOS devices we request your permission to allow tracking via Apple's App Tracking Transparency (ATT) framework. You can withdraw this permission at any time in your device settings.

Why We Use Your Data (Purposes of Processing)

• To Provide and Operate the Services: create your account, save game progress, and ensure the game functions correctly.
• To Improve the Services (Analytics & Telemetry): we collect and analyze gameplay and menu telemetry to compute product metrics, fix bugs, balance gameplay, optimize performance, and develop new content. We process this data solely to operate and improve MELS — we do not sell it and do not use it to build profiles for third parties.
• For Support and Security: respond to your inquiries and protect the Services from fraud and abuse.
• For Advertising: display advertising within the Services through our partners. Where your valid consent is required (see "Advertising and Your Consent Choices" below), advertising identifiers and technical data may be used to show personalized ads; otherwise we and our partners serve non-personalized ads.

Legal Bases for Processing (EEA, UK & Switzerland)

If you are located in the European Economic Area, the United Kingdom, or Switzerland, we rely on the following legal bases under the GDPR/UK GDPR/FADP:

• Performance of a contract (Art. 6(1)(b)): to create and operate your account and save your game progress.
• Legitimate interests (Art. 6(1)(f)): to operate gameplay and menu analytics/telemetry for measuring and improving the game, to secure the Services against fraud, and to serve non-personalized ads — balanced against your rights and freedoms. You may object to processing based on legitimate interests.
• Consent (Art. 6(1)(a)): for personalized advertising and the use of advertising identifiers where required. You may withdraw consent at any time.
• Legal obligation (Art. 6(1)(c)): to comply with applicable laws and lawful requests.

Data Sharing and Third Parties

We do not sell your personal data for money. We share data only with the categories of service providers and partners listed below, strictly for the purposes described:

• Backend / Game Services: your core gameplay data is stored and processed by Microsoft Azure PlayFab. See the Microsoft Privacy Statement.
• Advertising & Analytics Partners: we share advertising identifiers and technical data with our advertising, attribution, and analytics partners to deliver and measure advertising and to attribute app installs:
  • Google (Google AdMob / Google Ads) — Google Privacy Policy and How Google uses information.
  • Unity Ads (Unity Technologies) — Unity Privacy Policy.
  • Yandex Advertising Network (Yandex Mobile Ads SDK), including Yandex AppMetrica — the Yandex Mobile Ads SDK is used to serve and measure advertising; Yandex AppMetrica is initialized together with the SDK for ad delivery and attribution. See the Yandex Ads Privacy Policy and the AppMetrica Terms.
  • AppsFlyer (attribution & marketing analytics) — we use the AppsFlyer SDK to measure app installs, marketing attribution, and in-app events. AppsFlyer may process advertising identifiers, IP address, and event data for these purposes. See the AppsFlyer Services Privacy Policy.
• Payment Processors: purchases are processed by the app stores (e.g., Google Play). We do not store your financial information. We store only non-financial purchase records (product ID, transaction ID, receipt) to validate purchases and deliver content.

We require our SDK and advertising partners to handle data from the Services in compliance with applicable law and Google Play's Developer Program Policies. The partners listed above act as independent controllers for their own advertising and measurement purposes; please review their policies for details on how they process data and the controls they offer.

Where Your Data Is Stored and Processed

To operate analytics and product metrics, gameplay and menu telemetry is sent from the game to our own analytics infrastructure. We act as the controller of this infrastructure and use the following providers strictly as our processors (they process the data only on our instructions, for our purposes, and do not receive it for their own advertising):

• Rented private servers (VDS): our application servers, hosted in the European Union (Frankfurt, Germany), receive telemetry events and store recent data in a database used to compute product metrics. This data is kept on these servers for analytics and product-improvement purposes only.
• Google Cloud Storage: raw telemetry events are archived in a cloud storage bucket located in the EU, where they are retained for a limited period.
• Google BigQuery: stored telemetry is processed and aggregated in BigQuery (EU region) to calculate metrics and analytics for the game.

Most telemetry is pseudonymous: it is linked to a player/device identifier rather than to your name. We treat it as personal data and protect it accordingly. We do not sell this data and do not share it with advertisers; it is used only to operate and improve MELS. Google Cloud Storage and BigQuery are used here as our hosting and analytics providers (processors) and are distinct from the advertising partners described above.

Advertising and Your Consent Choices

MELS shows advertising. Depending on your region and choices, ads may be personalized (tailored using advertising identifiers and inferred interests) or non-personalized (based only on contextual information and not on your past behavior).

EEA, UK & Switzerland. Before serving personalized ads, we present a consent message through a Google-certified Consent Management Platform (the Google User Messaging Platform / UMP SDK) that integrates with the IAB Transparency & Consent Framework (TCF), in line with Google's EU User Consent Policy. Through this message you can consent to or refuse the use of cookies/local storage and personal data (such as your advertising ID) for ads personalization. If you refuse or do not consent, you will continue to see non-personalized ads. You can review or change your consent choices at any time from within the game's settings (the "Privacy options" / consent control), which re-displays the consent message.

Availability by app version. The in-app consent functionality described above is available starting with MELS version 142 (planned release: June 2026). Users running version 141 or earlier do not receive personalized advertising and are served non-personalized ads only.

United States. For users in U.S. states with applicable privacy laws, we present a U.S. states privacy message that lets you exercise your opt-out choices regarding the sharing of your personal information for cross-context behavioral advertising (see "Privacy Rights for Users in the United States" below).

Device-level controls. Regardless of region, you can limit ad tracking and reset or delete your advertising identifier at any time: on Android via Settings → Google → Ads, and on iOS via Settings → Privacy & Security → Tracking and Apple Advertising.

Users below the age of consent. Where we identify that a user is below the applicable age of consent, we instruct our advertising partners not to serve personalized ads (e.g., by using the "tag for users under the age of consent" signal). Such users may still see non-personalized ads.

Privacy Rights for Users in the EEA, UK & Switzerland (GDPR)

If you are located in these regions, you have the following rights regarding your personal data:

• Access: request a copy of the personal data we hold about you.
• Rectification: correct inaccurate or incomplete data.
• Erasure ("Right to be Forgotten"): request deletion of your account and associated data using the "Delete Your Account" option in the Account Management page on our website.
• Restriction & Objection: restrict or object to certain processing, including processing based on legitimate interests.
• Data Portability: receive your data in a structured, machine-readable format.
• Withdraw Consent: withdraw consent for personalized advertising at any time, without affecting the lawfulness of processing before withdrawal.
• Lodge a Complaint: file a complaint with your local data protection supervisory authority.

Privacy Rights for Users in the United States (State Privacy Laws)

If you are a resident of California (CCPA/CPRA), Virginia, Colorado, Connecticut, Utah, or another U.S. state with a comprehensive privacy law, you may have the rights below. Over the past 12 months we may have collected the following categories of personal information: identifiers (e.g., account email, advertising ID, IP address), internet/network activity (gameplay and in-app activity), approximate geolocation (from IP) and precise geolocation, and commercial information (non-financial purchase history).

• Right to Know / Access: request the categories and specific pieces of personal information we have collected, used, and shared.
• Right to Delete: request deletion of your personal information.
• Right to Correct: request correction of inaccurate personal information.
• Right to Opt Out of "Sale" / "Sharing" / Targeted Advertising: we do not sell personal information for money. However, the use of advertising identifiers for personalized (cross-context behavioral) advertising may be considered a "sale" or "sharing" under some state laws. You may opt out at any time through the in-app U.S. states privacy message and via your device's ad settings.
• Right to Limit Use of Sensitive Personal Information: where applicable, you may limit the use of any sensitive personal information.
• Right to Non-Discrimination: we will not discriminate against you for exercising any of these rights.

"Do Not Sell or Share My Personal Information": you can exercise this choice through the in-app U.S. privacy options, by disabling/limiting ad personalization in your device settings, or by contacting us using the details below. Authorized agents may submit requests on your behalf where permitted by law.

How to Exercise Your Rights

To exercise any of the rights described above, use the "Delete Your Account" option in the Account Management page on our website or contact us using the details in the "Contact Information" section. We will verify your request and respond within the timeframes required by applicable law.

Children's Privacy

MELS is rated for ages 7+ and is not directed to young children. We do not knowingly collect personal data from children below the applicable age of consent (typically 13 to 16, depending on the region) without verifiable parental consent, and we do not serve personalized ads to such users. If you believe a child has provided us personal data, please contact us and we will delete it promptly.

Data Retention

We keep personal data only for as long as necessary for the purposes described in this Policy, or as required by law. Account and gameplay data are retained while your account is active; when you delete your account, associated data is removed in accordance with our data deletion process. Raw telemetry events archived in cloud storage are retained for a limited period (and then deleted), while aggregated or de-identified metrics derived from telemetry may be kept longer for long-term analytics. Advertising and diagnostic data are retained for limited periods consistent with our partners' policies.

International Data Transfers

Your data may be processed on servers located outside your country of residence (including those of Microsoft PlayFab, Google Cloud, our advertising partners, and our own analytics servers in the European Union). Where data is transferred out of the EEA, UK, or Switzerland, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses or adequacy decisions.

Policy Updates

We may update this Privacy Policy from time to time. We will notify you of any significant changes by posting the updated policy within the Services or by other means of direct communication. The "Last Updated" date above reflects the most recent revision.