Privacy Policy
Who we are. This Privacy Policy explains how Dror Cohen, doing business as Tinker Labs (“we”, “us”) collects, uses, and shares information when you use our mobile games and related services (the “App” or “Services”).
Contact. Email: privacy@tinker-labs.com
EU/UK representative (GDPR Article 27). If you are located in the EU/UK, you may also contact our appointed representative. See Section 16.
1) Quick summary
- We use information to operate the game, keep it secure, measure performance, and (depending on your choices and region) show and measure ads.
- You can manage optional data processing inside the app:
Settings → Ads & Privacy. - Some partners (like advertising providers) may process data under their own privacy policies.
- You can request access/deletion and other rights by emailing us.
2) What we collect
A) Information you provide
- Support and feedback. If you contact us or send in-game feedback, we receive what you submit (for example: message text, and optionally an email address if you choose to include one). Anything you type may contain personal data if you choose to include it.
B) Information collected automatically (device/app)
- Identifiers. Device and app identifiers (for example: IP address; app instance identifiers; device model; OS version; language; time zone; approximate region). On iOS, use of the advertising identifier (IDFA) depends on your App Tracking Transparency choice.
- Gameplay and usage. Events about how the App is used (for example: screens viewed, actions taken, session length, and feature usage).
- Crash and diagnostics. Crash reports, performance metrics, and diagnostic logs.
- Approximate location. We may infer an approximate location (for example, city/region) from IP address or signals used by ad/analytics providers. We do not ask you to provide precise GPS coordinates for gameplay.
- Purchases. If you buy something, we receive confirmation/receipt data from the app store platform to validate the purchase and deliver items. Payment details are handled by the app store (for example, Apple or Google).
C) Account and login
We support sign-in via platform services (for example, Google Play Games or Game Center) and may also use an anonymous account identifier tied to your device for gameplay continuity.
D) Session replay
We may collect interaction data to understand usability issues (for example: taps, navigation timing, and screen flow).
This may include replay-style data of your session. Please avoid entering sensitive information into free-text fields.
You can opt out by shutting down Smartlook in Settings → Ads & Privacy.
3) How we use information
- Provide and operate the App. Save progress, enable account features, deliver purchases, and provide requested support.
- Security and fraud prevention. Detect abuse, prevent invalid traffic, and protect our Services.
- Analytics and improvement. Understand performance, fix bugs, and improve gameplay and UX.
- Advertising and marketing measurement. Show ads, measure campaign effectiveness, and attribute installs/purchases. Depending on your region and choices, ads may be personalized or non-personalized.
4) Our legal bases (EEA/UK)
If you are in the EEA/UK, we rely on different legal bases depending on the purpose:
- Contract (to provide the App and requested features).
- Consent (for optional processing where required, such as certain analytics, session replay, and personalized advertising).
- Legitimate interests (for example, basic service operations, security, fraud prevention, and measuring performance, where permitted).
- Legal obligations (for example, compliance and recordkeeping where required).
5) Automated processing and profiling (where applicable)
When personalized advertising is enabled (based on your region and choices), advertising partners may use automated processing
(sometimes called profiling) to show ads that may be more relevant and to measure ad performance.
You can reduce or disable personalized advertising through Settings → Ads & Privacy and (on iOS) via App Tracking Transparency settings.
6) When we share information
We share information with service providers and partners to run the App. Examples include:
- Advertising: Google AdMob, Meta (Facebook) and related partners.
- Analytics and infrastructure: Google Analytics 4 / Firebase.
- Game backend: Microsoft PlayFab.
- Session replay: Smartlook.
- Crash reporting: Unity crash reporting tools.
- Consent management UI: the in-app consent dialog shown via
Settings → Ads & Privacy.
Important: Some partners (especially advertising providers) may process certain data as independent controllers
for their own purposes described in their privacy policies, such as delivering and measuring ads, maintaining and improving their services,
and preventing fraud. Your choices in Settings → Ads & Privacy affect what is enabled in the App.
7) Your choices: Settings → Ads & Privacy
- You can open
Settings → Ads & Privacyat any time to accept or reject optional categories and adjust your choices. - Effect of opt-out. If you reject optional categories, we will disable or limit the related SDKs and disclosures where possible. Some processing may still occur for core service operations (for example: providing the Services, security and fraud prevention, debugging, and non-personalized advertising where permitted).
- On iOS, you can also control tracking permission via the system prompt and device settings (App Tracking Transparency).
- You can reset or limit the advertising identifier in your device settings (availability depends on OS).
8) California notice (CCPA/CPRA)
If you are a California resident, you may have rights to know/access, delete, correct, and opt out of certain disclosures of personal information. This section describes choices we provide. Whether specific CCPA/CPRA obligations apply depends on the facts and legal definitions.
- We do not sell personal information for money.
-
Do Not Sell or Share: if personal information is “shared” for cross-context behavioral advertising (for example, when personalized advertising is enabled),
you can opt out by using
Settings → Ads & Privacy(rejecting personalized advertising and marketing-related categories where available). Opting out limits disclosures for cross-context behavioral advertising, but some disclosures may still occur for core operations (such as providing the Services, security and fraud prevention, debugging, measurement, and non-personalized advertising where permitted). - Website: our website is informational only and does not use analytics or advertising tracking technologies (such as pixels) to collect personal information for advertising.
- Opt-out preference signals (GPC): if you access our website and your browser sends an opt-out preference signal such as the Global Privacy Control (GPC), we will process it as required by applicable law for that website context.
- How to submit requests: email privacy@tinker-labs.com. We operate exclusively online, so we provide email as a request method.
- Response timing (California): we typically confirm receipt of a request within 10 business days and aim to respond substantively within 45 days, subject to verification and legal exceptions. If we need more time, we may extend the response period as allowed by law.
9) Retention
- Account and gameplay data: kept while you use the App, plus a reasonable period for backup, fraud prevention, and support.
- Crash/diagnostics and analytics: typically retained up to 24 months (or less if configured), then deleted or aggregated/anonymized where possible.
- Support/feedback: typically retained up to 24 months after last contact, unless we need longer to resolve a dispute or comply with law.
10) International transfers
We are based in Israel and may use service providers that process data in other countries (including the United States and EU). Where required, we rely on appropriate safeguards for international transfers (for example, standard contractual clauses used by providers).
How to get details: you can request additional information about applicable safeguards by emailing privacy@tinker-labs.com.
11) Is providing data required?
Some information is necessary to provide the Services (for example, network information like IP address and certain identifiers needed for app
functionality, security, and saving progress). If you restrict required data (for example by disabling network access or deleting required identifiers),
parts of the App may not function properly. For optional processing (like certain analytics, session replay, and personalized ads), you can control this
via Settings → Ads & Privacy.
12) Security
We use reasonable administrative, technical, and organizational measures designed to protect information. No method of transmission or storage is fully secure.
13) Your rights
- You may have rights to access, delete, correct, object, restrict processing, and data portability, depending on where you live.
- If processing is based on consent, you can withdraw consent at any time via
Settings → Ads & Privacy. - To exercise rights, contact privacy@tinker-labs.com.
- EEA/UK complaint right: if you are in the EEA/UK, you also have the right to lodge a complaint with your local data protection supervisory authority.
- EU/UK representative: see Section 16.
How to make a data protection complaint
If you are unhappy with how we have handled your personal data, please contact us first so we can try to put it right. Email privacy@tinker-labs.com with "Data protection complaint" in the subject line, and tell us what happened.
How we handle complaints. We will acknowledge your complaint within 30 days of receiving it, make reasonable enquiries to investigate it, and tell you the outcome without undue delay.
Escalating to a regulator. If you are in the UK and remain unsatisfied after contacting us, you can complain to the Information Commissioner's Office (ICO) at ico.org.uk/make-a-complaint or by calling 0303 123 1113. If you are in the EEA, you can also lodge a complaint with your local data protection supervisory authority.
14) Children
Our Services are not directed to children under 13. If you believe a child provided personal information to us, contact us and we will take appropriate steps.
15) Changes to this policy
We may update this policy from time to time. We will update the “Last updated” date above and, if changes are material, we may provide additional notice in the App or on our website.
16) EU/EEA & UK GDPR Representatives (Article 27)
If you are located in the EU or UK and have questions or concerns regarding your personal data, you may contact our appointed GDPR representative:
EU Representative:
Euverify Ltd (Ireland)
Unit 3D North Point House
North Point Business Park
New Mallow Road
Cork
T23 AT2P
Ireland
Email: gdpr@euverify.com
UK Representative:
Euverify Ltd (UK)
3rd Floor
86-90 Paul Street
London
EC2A 4NE
United Kingdom
Email: gdpr@euverify.com
To submit a Data Subject Access Request (DSAR), data deletion request, or any other GDPR-related inquiry, please use our secure portal. This link allows you to verify our appointed representative and submit GDPR requests directly. Requests submitted through this portal are logged and tracked to ensure timely response and compliance.
Tinker Labs (Dror Cohen) • Based in Israel • privacy@tinker-labs.com