App Privacy Policy
Last updated: July 2, 2026
1. Introduction
This Privacy Policy is provided by Maksim Paleyeu, trading as Relax Games ("we," "us," or "our"), the developer of the mobile game Twist & Merge (the "Game") available on iOS and Android.
This Policy explains what information we collect, how we use it, with whom we share it, and your rights regarding your data.
By downloading or playing the Game, you agree to the practices described in this Policy. If you do not agree, please do not use the Game.
2. Information We Collect
2.1 Information You Provide
- Account information: When you sign in via Google Play Games (Android) or Apple Game Center (iOS), we receive your player name, player ID, and account identifiers provided by those platforms.
- Purchases: When you make in-app purchases, the payment is processed by Apple App Store or Google Play. We receive confirmation of the transaction, including product ID, price, and currency — but never your full payment card details.
2.2 Information Collected Automatically
| Category | Examples |
|---|---|
| Device information | Device model, operating system version, language, time zone |
| Network information | IP address (used to derive approximate, city-level location — e.g. for regional consent requirements); we do not collect precise GPS location |
| Advertising identifiers | IDFA (iOS, with your ATT permission), Android Advertising ID |
| Gameplay data | Score, level progress, cube merges, boosts used, currency earned/spent |
| Session data | Session start/end times, session duration, tutorial progress |
| Ad interaction data | Ads shown, clicked, rewarded video views, ad failures |
| Purchase events | Product purchased, price, currency (no payment card data) |
| Settings | Sound, music, vibration preferences; language selection |
| Consent status | Your GDPR consent choice (EEA/UK/Switzerland); your US state opt-out/opt-in choice; your ATT authorization (iOS) |
2.3 Cloud-Saved Game Data
If you are signed in, your game board state is saved to Unity Cloud Save servers to allow you to continue playing across devices. This data is linked to your Unity player account.
3. How We Use Your Information
We use the information we collect to:
- Run and improve the Game — provide gameplay functionality, leaderboards, cloud save, and remote configuration for game balance.
- Show advertisements — serve banner, interstitial, and rewarded video ads through our ad partners (see Section 5). With your consent (where required), ads may be personalized.
- Process purchases — verify and fulfill in-app purchases; provide "No Ads" and other premium features.
- Analyze usage — understand how players interact with the Game to fix bugs and improve features.
- Maintain leaderboards — display your score on global leaderboards.
- Comply with legal obligations — honor your privacy rights and regulatory requirements.
4. Legal Basis for Processing (EEA / UK / Switzerland)
If you are located in the European Economic Area, United Kingdom, or Switzerland, we process your data under the following legal bases:
| Purpose | Legal Basis |
|---|---|
| Core gameplay, cloud save, leaderboards | Legitimate interest (providing the Game) |
| Personalized advertising, analytics SDKs | Consent (obtained via the Google UMP consent form at first launch) |
| In-app purchases | Contractual necessity |
| Legal compliance | Legal obligation |
You may withdraw your consent at any time (see Section 8).
4.1 Brazil (LGPD)
If you are located in Brazil, we process your data under the legal bases recognized by the Lei Geral de Proteção de Dados (LGPD): legitimate interest for core gameplay and cloud save, consent for personalized advertising and analytics, and contractual necessity for purchases — mirroring the table above. You may exercise the rights listed in Section 8 by contacting us at [email protected], and you may lodge a complaint with Brazil's data protection authority, the Autoridade Nacional de Proteção de Dados (ANPD).
4.2 Canada (PIPEDA)
If you are located in Canada, we process your data in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA). The purposes, retention periods, and rights described throughout this Policy apply equally to Canadian users; you may also contact the Office of the Privacy Commissioner of Canada with any concerns we have not resolved.
4.3 United States — State Privacy Laws (California CCPA/CPRA and Others)
If you are a resident of California, Colorado, Connecticut, Virginia, Utah, Oregon, Texas, or another U.S. state with a comprehensive consumer privacy law, this section supplements the rest of this Policy and describes your rights under those laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA).
Categories of personal information we collect. In the preceding 12 months, we have collected the categories of personal information described in Section 2 of this Policy, which map to the following CCPA categories: Identifiers (player ID, advertising ID), Internet or other electronic network activity (gameplay events, ad interaction data, session data), Geolocation data (approximate, derived from IP address), and Commercial information (purchase history). We do not collect Social Security numbers, financial account credentials, precise geolocation, or other sensitive categories beyond what is described here.
"Sale" and "sharing" of personal information. We do not sell personal information for money. However, some advertising identifiers and device/usage data are disclosed to our advertising and mediation partners (see Section 5) to serve interest-based ads, which qualifies as a "sale" or "sharing" under the CCPA/CPRA's broad definitions (including cross-context behavioral advertising). We do not sell or share the personal information of consumers we know to be under 16 years of age without affirmative authorization.
Your rights. Subject to certain exceptions, you have the right to:
- Know what personal information we collect, use, disclose, sell, and share, and the categories of third parties involved.
- Delete personal information we have collected from you (see Section 8 and the in-game "Delete My Data" option in Settings).
- Correct inaccurate personal information we hold about you.
- Opt out of the sale or sharing of your personal information, at any time and without creating an account, via the in-game consent management panel in Settings → Privacy Settings. This panel also honors opt-out preference signals sent via the IAB Global Privacy Platform (GPP), where supported by your device and ad SDKs.
- Limit the use of sensitive personal information — not applicable, as we do not collect sensitive personal information as defined by the CPRA.
- Non-discrimination — we will not deny you goods or services, charge different prices, or provide a different level of quality because you exercised any of these rights.
- Designate an authorized agent to make a request on your behalf, subject to identity verification.
We do not offer any financial incentive or price/service difference in exchange for the collection, sale, or sharing of personal information.
To exercise any of these rights, contact us at [email protected] or use the in-game controls referenced above. We will verify your request using the information reasonably available to us (such as your platform account or device identifiers) and respond within the timeframes required by applicable law.
5. Third-Party SDKs and Data Partners
The Game integrates third-party SDKs that may independently collect data. Each partner operates under its own privacy policy.
Advertising
| Partner | Purpose | Privacy Policy |
|---|---|---|
| IronSource / Unity LevelPlay | Ad mediation, ad serving | is.com/privacy-policy |
| Google Mobile Ads / AdMob | Ad mediation, GDPR consent (UMP) | policies.google.com/privacy |
| AppLovin | Ad network | applovin.com/privacy |
| Mintegral | Ad network | mintegral.com/en/privacy |
| MyTarget | Ad network | target.my.com/doc/pp/en |
| BidMachine | Programmatic ads | bidmachine.io/privacy-policy |
| Yandex Mobile Ads | Ad network | yandex.com/legal/confidential |
| Unity Ads | Ad network | unity.com/legal/…privacy-policy |
Analytics & Backend Services
| Partner | Purpose | Privacy Policy |
|---|---|---|
| Unity Gaming Services Analytics | Gameplay event analytics | unity.com/legal/…privacy-policy |
| Unity Authentication | Anonymous and linked account login | unity.com/legal/…privacy-policy |
| Unity Cloud Save | Cross-device game state sync | unity.com/legal/…privacy-policy |
| Unity Economy | In-game currency and inventory | unity.com/legal/…privacy-policy |
| Unity Leaderboards | Global score rankings | unity.com/legal/…privacy-policy |
| Unity Remote Config | Server-side game configuration | unity.com/legal/…privacy-policy |
Platform Authentication
| Partner | Purpose | Privacy Policy |
|---|---|---|
| Google Play Games (Android) | Player sign-in and identity | policies.google.com/privacy |
| Apple Game Center (iOS) | Player sign-in and identity | apple.com/legal/privacy |
6. Advertising and Tracking
Personalized Advertising
With your consent (EEA/UK/Switzerland) or upon ATT authorization (iOS 14+), our ad partners may use your advertising identifier (IDFA on iOS, GAID on Android) to serve ads tailored to your interests, measure ad performance, and build audience profiles.
App Tracking Transparency (iOS)
On iOS 14 and later, we request permission to track you across apps and websites via
Apple's App Tracking Transparency (ATT) prompt before accessing your IDFA. You can change
this permission at any time in:
Settings → Privacy & Security → Tracking → Twist & Merge
Opting Out of Personalized Ads
- iOS: Deny ATT permission, or go to Settings → Privacy & Security → Apple Advertising → Personalized Ads (off).
- Android: Go to Settings → Google → Ads → Delete advertising ID (Android 12+) or enable Opt out of Ads Personalization.
- EEA/UK/Switzerland: Use the in-game consent management panel (accessible in Settings) to withdraw consent at any time.
- California and other U.S. states: Use the same in-game consent management panel (Settings → Privacy Settings) to opt out of the sale/sharing of your personal information at any time — see Section 4.3.
7. Children's Privacy
The Game is not directed to children under the age of 13 (or 16 where required by local law, including in EEA member states). We do not knowingly collect personal information from children under these ages.
If you are a parent or guardian and believe we have inadvertently collected data from a child, please contact us at [email protected] and we will delete it promptly.
8. Your Rights
Depending on your location, you may have the following rights regarding your personal data:
| Right | Description |
|---|---|
| Access | Request a copy of the data we hold about you |
| Rectification | Request correction of inaccurate data |
| Erasure | Request deletion of your data ("right to be forgotten") — available directly in-game via Settings → Delete My Data, or by contacting us |
| Restriction | Request that we limit processing of your data |
| Portability | Receive your data in a machine-readable format |
| Objection | Object to processing based on legitimate interests |
| Withdraw Consent | Withdraw consent for personalized advertising at any time |
| Opt Out of Sale/Sharing | Opt out of the sale or sharing of your personal information (California/U.S. states — see Section 4.3) |
| Non-Discrimination | Not be denied service or charged a different price for exercising your rights |
| Complaint | Lodge a complaint with your local data protection authority |
To exercise any of these rights, contact us at: [email protected]. We will respond within 30 days (or as required by applicable law). EEA/UK residents may also contact the data protection authority in their country of residence.
9. Data Retention and Security
- Analytics and gameplay events are retained for up to 24 months, after which they are aggregated or deleted.
- Cloud save data is retained as long as your account is active. You may delete it at any time using the in-game Settings → Delete My Data option, or by contacting us.
- Purchase records are retained for up to 7 years for accounting and legal compliance purposes.
We implement industry-standard technical and organizational measures to protect your data. All data transmitted to and from our servers uses TLS encryption.
10. International Data Transfers
Your data may be transferred to and processed in countries outside your country of residence, primarily the United States (Unity Technologies, Google, Apple, AppLovin, Unity Ads), and also Ireland/EU (Google's European processing facilities), Singapore (Mintegral), and China (Tencent, Mintegral) where certain advertising partners operate. When transferring data from the EEA, we rely on appropriate safeguards, including Standard Contractual Clauses (SCCs) approved by the European Commission; for transfers from the UK, we rely on the UK International Data Transfer Agreement or the UK Addendum to the EU SCCs. If you are located in Japan, this constitutes disclosure of the destination countries and processing purposes as required under the Act on the Protection of Personal Information (APPI). If you are located in Saudi Arabia, the UAE, or elsewhere in the region, we rely on your consent and applicable regulatory approvals for any cross-border transfer required to operate the Game.
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of material changes by updating the "Last updated" date at the top of this page and, where required by law, by providing additional in-game notice. Your continued use of the Game after any changes constitutes your acceptance of the updated Policy.
12. Contact Us
Maksim Paleyeu, trading as Relax Games
Email: [email protected]
Website: relaxgames.studio
This Privacy Policy applies to the mobile game Twist & Merge on iOS and Android. It does not cover third-party websites or services linked from within the Game.