App Privacy Policy

This App Privacy Policy explains how Maksim Paleyeu, trading as Relax Games ("we", "us") handles personal data in our game Twist & Merge: 3D Number Cube (the "Game") on iPhone and iPad (iOS and iPadOS), on Mac computers with Apple silicon (macOS), on Android (together, the "apps"), and in a web browser on web game portals (the "web version"). The web version works differently from the apps, and Section 14 describes it. It is information for you, not a contract: you do not agree to it by playing, and it does not replace any choice the Game asks you to make. Our website has its own Privacy Policy.

In short:

• Online play uses an anonymous account. We never ask for your name, email address or a password.
• The free apps show ads from our partners. Where the law requires it, ads are personalised and analytics is collected only with your consent, and you can change your choice in Settings → Privacy Settings.
• Offline mode sends nothing to our advertising partners and collects no analytics. The only thing that can leave your device is a crash report, sent to Unity the next time you are online.
• In the apps, you can delete your account and data in Settings → Delete My Data, or by email (how to delete).
• Some of our advertising partners process data in China or Russia (Section 7).
• The web version shows no ads, has no purchases for real money and does not use Unity Gaming Services. It sends us anonymous gameplay statistics through PostHog in the EU, with no identifier, no cookies and nothing stored on your device for them. It keeps your game in your browser (Section 14).

1. Who We Are

The controller responsible for your personal data in the Game is:

• Name: Maksim Paleyeu
• Trading as: Relax Games
• Legal form: self-employed sole trader (autónomo)
• Tax ID (NIF): Z2207759V
• Address: Calle San Ignacio de Loyola 27, 46008 Valencia (Valencia), Spain
• Email: hello@relaxgames.studio
• Website: relaxgames.studio

For any question about your data, write to hello@relaxgames.studio.

2. Online Play, Your Account and Offline Mode

Online play. When you play online, which is the default, the Game creates an anonymous account for you with Unity Gaming Services, our provider of online services. The account has a random Player ID and no name, email address or password. Your progress, wallet and items are saved to it.

Game Center and Google Play Games. If you are signed in to Apple Game Center (iPhone, iPad, Mac) or Google Play Games (Android), the Game links your account to it and receives your player ID and display name from Apple or Google. This lets you continue on another device.

Public leaderboards. Your scores and speed-run times appear on public leaderboards with your player name: your Game Center or Google Play Games display name (without spaces), or otherwise a random name generated automatically. Anyone who plays the Game can see them.

Offline mode. If you choose Play Offline, the Game does not connect to Unity's services or to our advertising partners: no account is used, and no analytics is collected or ads are shown. Your offline game is saved only on your device. If the Game crashes or freezes, the crash report waits on your device and is sent to Unity Diagnostics the next time the Game starts with an internet connection (Section 3.2).

3. What Data We Process

3.1 Data you give us

• Support emails. When you tap Support in the Game, your email app opens a message to hello@relaxgames.studio that already contains your Player ID (or, if you are not signed in to our online services, an identifier for your device), your device model and your operating system version. You see the message before you send it. We receive your email address, your message and anything else you add.
• Requests about your data, such as deletion requests, and the information you give us to find your account.

3.2 Data collected when you play online

3.3 Data that stays on your device

Your settings (sound, music, vibration, language), your offline game and the Game's local copy of your progress are stored on your device. Reminder notifications, if you allow them, are scheduled on your device; no data is sent for them.

4. Why We Use Your Data and Our Legal Bases

If you are in the European Economic Area (EEA), the UK or Switzerland, we rely on these legal bases under the GDPR:

4.1 Consent in the Game

In the EEA, the UK and Switzerland, and wherever else the law requires it, the Game shows a consent form (Google's User Messaging Platform) when you first start it. The Game starts analytics and ads only after it has checked whether your consent is needed and, if it is, collected your choice. If the consent form cannot load, for example because there is no connection, analytics and ads do not start until your choice has been collected.

You can change your choice at any time in Settings → Privacy Settings; the button appears where the law gives you this choice. Withdrawing consent does not affect processing that happened before. If you do not consent, you still see ads, but they are not personalised, and some partners may show limited ads or none.

On iPhone, iPad and Mac, the Game also asks for permission to track you across apps and websites (App Tracking Transparency). If you do not allow it, neither the Game nor its partners can access your advertising identifier (IDFA).

4.2 Profiling

Personalised ads involve profiling: our advertising partners use your advertising ID and data about your use of apps and websites to estimate your interests and choose ads for you. This happens only with your consent where the law requires it, and it has no legal or similarly significant effect on you. We do not make decisions about you based solely on automated processing that have such effects (GDPR Art. 22).

4.3 Do you have to give us data?

You do not have to consent to analytics or personalised ads, and refusing does not stop you playing. The online features (cloud saves, leaderboards and purchases) need the online account described in Section 2. If you do not want that, you can play in Offline mode.

5. Who Receives Your Data

We share data only with the partners listed in this section, and only for the purposes in this policy. Through the contracts and terms under which they work with us, we require each of them to protect your data to the same or an equal standard as this policy and the law.

• Service providers (processors) process data only on our instructions: Unity Technologies for Unity Gaming Services in the apps (Section 5.1), PostHog for the web version's anonymous statistics (Section 14.2), and our email hosting provider for support emails.
• Independent controllers decide for themselves how to use the data they receive, under their own privacy policies: our advertising partners (Section 5.2), including Unity for its advertising services, and Apple and Google as platform providers (Section 5.3).

5.1 Unity Gaming Services (our service provider)

Unity's privacy policy: unity.com/legal/game-player-and-app-user-privacy-policy. In the apps, the Unity engine the Game is built with may also send Unity basic statistics about your device's hardware and software (such as model, operating system and graphics capabilities), which Unity uses to improve its engine.

5.2 Advertising partners

The ad partners' software (SDKs) in the Game receives, directly from your device, your IP address, device and connection information, advertising and vendor identifiers (where available and permitted), your privacy choices, and data about the ads you see and interact with. With your consent, they may use this data to personalise ads and build profiles. "Apple devices" means iPhone, iPad and Mac, and "All" means the apps on Apple devices and Android. The web version contains none of these partners' software and shows no ads (Section 14).

5.3 Apple and Google

Privacy policies: Apple, Google.

5.4 Device features used for ads

• SKAdNetwork (Apple devices): Apple's system that lets ad networks measure installs and ad results without identifying you.
• Android Privacy Sandbox: on devices that support it, Google's ad software may use the Topics API (interest categories that your device works out itself) and the Attribution Reporting API (to measure ad results). You can turn these off in your device's ad privacy settings.
• Google Play Install Referrer (Android): some ad partners' SDKs read it to learn which ad or link led to the Game being installed. The Game also reads it for our own campaigns (Section 3.2).

5.5 Other recipients

• Our email hosting provider, which stores the support emails you send us.
• Courts and public authorities, when the law requires us to disclose data.
• A person or company that takes over the Game, if the business is transferred. We will tell you first.

We do not sell your personal data for money.

6. Advertising, Tracking and Your Choices

• Consent (where offered): Settings → Privacy Settings in the Game.
• iPhone, iPad and Mac: allow or deny tracking when the Game asks, or later in your device's Settings → Privacy & Security → Tracking.
• Android: delete or reset your advertising ID in your device's ad settings (for example Settings → Privacy → Ads, or Settings → Google → Ads, depending on the device), where you can also manage ad topics.
• US states with privacy laws: opt out of the "sale" or "sharing" of your personal information in Settings → Privacy Settings where it is offered, or by emailing us (Section 11.1).
• No Ads: removes the ads that appear on their own. Rewarded ads, which you choose to watch, stay available, so the ad partners' software remains in the Game.
• Offline mode: nothing is sent to our advertising partners and no analytics is collected; Unity receives only crash reports, the next time the Game is online.

7. International Data Transfers

Our partners may process your data outside the EEA:

For each transfer we rely on one of the safeguards in Chapter V of the GDPR: an adequacy decision of the European Commission where there is one (for example, for US companies certified under the EU–US Data Privacy Framework), and otherwise the safeguards offered in the partner's terms, such as the Commission's Standard Contractual Clauses (Art. 46(2)(c)). Transfers from the UK and Switzerland rely on the equivalent UK and Swiss mechanisms.

China and Russia have no adequacy decision, and their laws may allow public authorities to access data in ways that EU law would not. Contractual safeguards may not fully prevent this. If you do not want your data to reach these partners, you can refuse consent (they then receive less data) or play in Offline mode (they receive nothing).

The web version's statistics are stored by PostHog in the EU (Section 14.2). PostHog, Inc. is based in the United States; where its staff or its own service providers outside the EEA can access that data, PostHog's data processing agreement applies the Commission's Standard Contractual Clauses (Art. 46(2)(c)).

You can ask us which safeguard applies to a partner, and for a copy of it, at hello@relaxgames.studio.

8. How Long We Keep Data

9. Deleting Your Data

• In the Game: Settings → Delete My Data. This needs an internet connection and online play. Your account, your cloud saves and the Game's data on your device are deleted straight away, and the Game asks Unity to delete your analytics data. We complete the deletion of everything else linked to your Player ID (wallet and inventory, leaderboard entries, speed-run saves and analytics data) within one month.
• By email: write to hello@relaxgames.studio with your Player ID or leaderboard name. We delete your data within one month and confirm by email.
• Offline game: it is stored only on your device, so uninstalling the Game deletes it.
• Web version: it has no account, and we keep nothing from it that is linked to you. Clearing the website's data in your browser deletes your game there (Section 14.4).

Full instructions, and what we keep, are on Delete Your Account and Data. Data held by advertising partners, Apple and Google is deleted under their own policies.

10. Your Rights

Depending on where you live, you have the right to:

To use any of these rights, email hello@relaxgames.studio. It is free. We reply within one month of receiving your request. If a request is complex, or we receive many, we may extend this by up to two further months; if so, we will tell you within the first month and explain why. We may ask for information to confirm that the account is yours.

If you think we have not handled your data properly, you can complain to the Spanish data protection authority, the Agencia Española de Protección de Datos (AEPD), www.aepd.es. In the EEA you can also complain to the authority in the country where you live or work.

11. Additional Information for Some Regions

11.1 United States: state privacy laws

If you live in California, Colorado, Connecticut, Virginia, Utah, Oregon, Texas or another US state with a comprehensive consumer privacy law, this section applies to you as far as those laws apply to us.

What we collect. In the past 12 months we collected the data described in Section 3, which falls into these categories: identifiers (Player ID, advertising ID), internet or other electronic network activity (gameplay, session and ad interaction data), geolocation data (approximate, from your IP address) and commercial information (purchase history). We do not collect sensitive personal information.

"Sale" and "sharing". We do not sell personal information for money. Our advertising partners receive advertising identifiers and device and usage data to show interest-based ads, which may count as a "sale" or "sharing" (cross-context behavioural advertising) under these laws. We do not sell or share the personal information of consumers we know to be under 16.

Your rights. You can ask to know what personal information we collect, use and disclose; to delete or correct it; and to opt out of its sale or sharing, in Settings → Privacy Settings where offered, or by emailing hello@relaxgames.studio. You can use an authorised agent. We will not treat you differently for using these rights, and we do not offer any financial incentive for your data. We verify requests using the information we hold, such as your Player ID, and reply within the time the law allows.

11.2 Canada

We handle your personal information in line with the Personal Information Protection and Electronic Documents Act (PIPEDA). The purposes, retention periods and rights in this policy apply to you. If we do not resolve a concern, you can contact the Office of the Privacy Commissioner of Canada.

11.3 New Zealand

Under the Privacy Act 2020, you can ask to access and correct your personal information. If we do not resolve a concern, you can complain to the Office of the Privacy Commissioner.

11.4 Brazil

Under the Lei Geral de Proteção de Dados (LGPD), we rely on the same legal bases as in Section 4. You can use the rights in Section 10 by writing to hello@relaxgames.studio, and complain to the Autoridade Nacional de Proteção de Dados (ANPD).

11.5 Japan

Section 7 lists the countries your data may be transferred to and why. You can ask us for more information about those transfers and the measures our partners take.

12. Children

The Game is for a general audience and is not directed at children under 13. We do not knowingly collect personal data from children under 13; if we learn that we have, we delete it. In the EEA, a player under the age at which they can consent in their country (14 in Spain, and between 13 and 16 elsewhere) needs a parent or guardian to make or authorise the consent choices in the Game. If you are a parent or guardian and think your child has given us personal data, contact us at hello@relaxgames.studio and we will delete it.

13. Security

We protect your data with appropriate technical and organisational measures. Data sent between the Game and our online services is encrypted in transit (TLS). We do not run servers of our own: your data is stored by the service providers named in this policy.

14. Web Version

The web version of the Game runs in your web browser. It is published on web game portals, first on CrazyGames. The portal hosts the Game's files, including the skins and music the Game downloads while you play, and runs its own website and software under its own privacy policy. The other sections of this policy describe the apps; they apply to the web version only where this section refers to them.

14.1 What the web version does not have

The web version has no ads, no purchases for real money, no account and no Game Center or Google Play Games sign-in. It does not use Unity Gaming Services at all (Section 5.1): no Unity account or Player ID, no Unity Analytics, and no crash reports or engine statistics sent to Unity. None of our advertising partners' software (Section 5.2) is in it, so nothing is sent to them. Coins are earned by playing, and boosts and skins are bought only with coins.

14.2 Anonymous gameplay statistics

To see where players stop playing and what is too hard, the web version sends us anonymous gameplay statistics. They go to PostHog (PostHog Cloud EU), a product analytics service that processes them on our behalf and stores them in the European Union (Frankfurt, Germany). The first time you play in a browser, a short notice at the bottom of the screen tells you about them and links here.

Each statistic is an event from a fixed list. The Game checks every event against that list before it leaves your browser and drops anything else:

• the Game has loaded, and how long that took;
• tutorial steps shown, completed or skipped; your first turn and first merge; how many merges you have made, in steps (10, 25, 50 and so on);
• the highest tile you reach, and when the cube is full;
• boosts used or bought, skins bought with coins and their price in coins, and the screens you open (boost shop, skins, help, settings);
• in the speed run: a run started, paused or ended, the tiles reached and their times, and the button you choose on a result screen;
• the page was hidden or closed, or shown again, with the highest tile and the number of merges in that visit.

Each event also says how many seconds after the page started loading it happened, which web game it is (the full game, endless or speed run), the portal, the Game's version, the kind of device (phone, tablet or computer) and the browser family (such as Chrome or Safari). Your browser works out the last two from its user agent; the user agent itself is not sent.

What is not sent or kept:

• No identifier that lasts. The events of one visit are linked only by a random number the page makes when it loads. It is kept in memory only and is gone when you close or reload the page, so two visits cannot be linked to each other or to you.
• Nothing on your device. No cookies, and nothing in local storage, session storage or IndexedDB is written or read for the statistics. The Game does not read your saved game for them either.
• Nothing about who you are. No name, email address, account, advertising ID, CrazyGames account details or page address. PostHog is told not to create a person profile from the events.
• Your IP address is not stored. As with any request on the internet, PostHog's servers see your IP address when the events arrive. PostHog may use it to estimate an approximate location, such as the country, and then discards it: our PostHog project is set not to store IP addresses. We never receive it.

Legal basis: our legitimate interest in understanding how the Game is played and improving it (Art. 6(1)(f) GDPR), with minimal data that does not identify you. Nothing is stored on or read from your device for the statistics. Once recorded, they cannot be linked to you, so we cannot find, show or delete "your" events (Art. 11 GDPR). If you object to them, write to us; you can also stop them by blocking eu.i.posthog.com in your browser, and the Game plays the same.

Transfers and retention: PostHog stores the statistics in the EU; for access from outside the EEA, see Section 7. PostHog keeps them as long as our PostHog plan keeps events: one year on its free plan, up to seven years on a paid plan. We use them only in aggregate, for example how many players reach each tutorial step.

14.3 Data kept in your browser

The Game keeps the following in your browser's storage for the website where you play (local storage and IndexedDB). It is never sent to us.

All of this is needed for the game you asked to play, so it does not need your consent (Art. 22.2 of the Spanish LSSI-CE). None of it is used for the statistics.

CrazyGames. On CrazyGames, the Game also saves your wallet through CrazyGames' software. If you are signed in to a CrazyGames account, CrazyGames keeps this copy with your account, under CrazyGames' privacy policy. The Game also tells CrazyGames' software when loading and gameplay start and stop, and reads your language from it to choose the Game's language. We do not receive your CrazyGames account details. CrazyGames (Maxflow BV, Belgium) is responsible, as an independent controller, for its website, its software and your CrazyGames account, including the data its software collects and the cookies it uses; you manage those in CrazyGames' own privacy settings.

14.4 Deleting your data

• In your browser: clear the site data (cookies and site data) of the website where you play. This deletes your game, coins and settings in that browser. Clearing a portal's site data can also remove other data that the portal keeps in your browser.
• Saved with your CrazyGames account: this copy of your wallet is kept and deleted by CrazyGames under its own privacy policy. While you stay signed in, the Game may restore your wallet from it after you clear your browser.
• Statistics: we keep nothing that is linked to you, so there is nothing of yours to delete (Section 14.2).

14.5 Children and your rights

Section 12 applies to the web version as well. The web version asks for no consent and collects nothing that identifies a player, a child included. You have the rights described in Section 10; to use them, write to hello@relaxgames.studio.

15. Changes to This Policy

We will update this policy when the Game or the law changes, and change the date at the top of this page. We will tell you about significant changes in the Game before they take effect. If a change needs your consent, we will ask for it.

16. Contact Us

• Name: Maksim Paleyeu
• Trading as: Relax Games
• Legal form: self-employed sole trader (autónomo)
• Tax ID (NIF): Z2207759V
• Address: Calle San Ignacio de Loyola 27, 46008 Valencia (Valencia), Spain
• Email: hello@relaxgames.studio
• Website: relaxgames.studio

This policy applies to Twist & Merge: 3D Number Cube on iOS, iPadOS, macOS and Android, and to its web version on web game portals. It does not cover third-party websites or services linked from the Game, or the portals' own websites and services.