Legal
Privacy Policy
This privacy policy is applicable to the TO BE DISCLOSED app (hereinafter referred to as "Application") for mobile devices, which was developed by Neonhex Digital SRL (hereinafter referred to as "Service Provider") as a Free service. This service is provided "AS IS".
This Privacy Policy explains how the Service Provider may collect, use, store, share, and protect information when you use the Application, including gameplay, accounts, progression, chat, moderation, purchases, virtual currency, cosmetics, battle passes, support, analytics, security, and future live-service features.
What information does the Application obtain and how is it used?
The Application acquires the information you supply when you download, register, log in, contact support, participate in community features, make requests, submit reports, or otherwise use the Application. Registration with the Service Provider is not mandatory for every feature. However, some features may not be available unless you register or connect an account.
User-provided information may include usernames, display names, account identifiers, profile choices, support communications, moderation appeals, report descriptions, purchase support details, and other information you choose to provide. The Service Provider may use this information to operate the Application, provide support, send required notices, respond to requests, maintain safety, and provide marketing or promotional communications where permitted by law.
What information does the Application collect automatically?
In addition, the Application may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device's unique device ID or app instance identifiers, the IP address of your mobile device, your mobile operating system, app version, build number, device language, approximate region, connection information, crash reports, performance diagnostics, and information about the way you use the Application.
Gameplay, progression, and live-ops data
The Application may collect gameplay-related information, including match history, session activity, progression, scores, rankings, trophies, streaks, rewards, challenges, events, tutorial progress, battle pass progress, virtual currency balances such as gems, owned cosmetics, selected board cosmetics, inventory items, and feature usage. This information is used to provide gameplay, save progress, balance the game, operate events, prevent abuse, improve user experience, and provide live-ops features.
Chat, reports, and moderation data
If the Application includes chat, usernames, profiles, social, guild, friend, party, or other community features, the Service Provider may process user-generated content and related metadata. This may include chat messages, usernames, player identifiers, timestamps, reported content, report categories, moderation notes, warnings, mutes, suspensions, bans, appeals, and related safety records.
This information is used to operate community features, investigate reports, detect abuse, enforce rules, protect users, prevent fraud or harassment, and comply with legal obligations. Chat and moderation data may be reviewed by automated systems and/or authorized human reviewers.
Purchases, virtual currency, cosmetics, and battle passes
The Application may include purchases, subscriptions, premium currency such as gems, virtual items, board cosmetics, avatars, frames, boosters, battle passes, limited-time offers, and other digital entitlements. Purchases may be processed by third-party platforms or payment providers such as Google Play, Apple App Store, RevenueCat, or other authorized checkout providers.
The Service Provider may receive transaction-related information from those providers, such as purchase status, product identifiers, transaction identifiers, items purchased, currency, country, timestamps, refund status, chargeback status, fraud/risk signals, and entitlement status. The Service Provider does not collect or store full payment card numbers or full payment account details.
Advertising and ad measurement
The first release of the Application is not expected to include third-party advertising. This section is included for transparency in case advertising, rewarded ads, mediation, attribution, or ad-supported features are added in a later version.
If ads are added, the Application may process ad requests, impressions, clicks, rewarded-ad completion events, advertising identifiers, app instance identifiers, approximate region, consent status, tracking authorization status, fraud-prevention signals, attribution data, and related timestamps. Where required, the Application will request or respect applicable consent choices, including platform permissions such as Apple's App Tracking Transparency framework.
Does the Application collect precise real time location information of the device?
This Application does not gather precise real-time information about the location of your mobile device. The Application may process approximate region or country information based on IP address, platform settings, storefront region, or analytics services for security, localization, analytics, legal compliance, or store/payment operations.
Does the Application use Artificial Intelligence (AI) technologies?
The Application may use Artificial Intelligence (AI) technologies to enhance user experience, improve safety, and provide certain features. The AI components may process user data in the following ways:
- Personalized Content: AI may analyze your usage patterns to deliver content tailored to your preferences and behavior.
- Recommendations: AI may suggest features, services, offers, or content based on your interactions within the Application.
- Automated Functionalities: Certain app features may be powered by AI to automate tasks, improve efficiency, detect abuse, or support moderation.
- Data Protection: All AI processing is performed in accordance with this privacy policy and applicable laws, ensuring your data is handled securely and responsibly.
How does the Service Provider use information?
The Service Provider may use collected information to:
- operate, maintain, secure, and improve the Application;
- create accounts, save progress, provide matchmaking, progression, rewards, inventory, gems, cosmetics, battle passes, and live events;
- provide chat, social, community, and support functionality;
- review reports, moderate content, enforce rules, and protect users;
- process purchases, validate transactions, deliver virtual items, and handle purchase-related support;
- detect cheating, fraud, exploits, spam, abuse, account misuse, chargeback abuse, and other harmful activity;
- analyze gameplay, stability, performance, retention, crashes, and user experience;
- send service announcements, updates, support replies, legal notices, and permitted marketing communications;
- comply with legal, tax, platform, payment, and regulatory obligations.
Legal bases for processing (EEA / GDPR)
If you are located in the European Economic Area, United Kingdom, or another region with similar laws, the Service Provider processes personal data only where there is a valid legal basis, including:
- Performance of a contract: to provide and operate the Application and its core features.
- Legitimate interests: to secure the Application, prevent abuse, enforce rules, improve services, process purchases safely, protect players, and operate live-service features.
- Legal obligations: where processing is required by applicable law, lawful requests, tax duties, payment compliance, consumer protection, or regulatory obligations.
- Consent: where consent is required by law or platform rules, including for certain marketing, tracking, advertising, analytics, or device-storage activities.
Do third parties see and/or have access to information obtained by the Application?
Only aggregated, anonymized data is periodically transmitted to external services to aid the Service Provider in improving the Application and their service. The Service Provider may share your information with third parties in the ways that are described in this privacy statement.
Please note that the Application utilizes, or may later integrate, third-party services that have their own Privacy Policy about handling data. The exact list should match the SDKs and services included in the released build. These services may include:
- Google Play Services
- Apple App Store / Apple services
- Google Analytics for Firebase
- Firebase Crashlytics
- Facebook / Meta services
- RevenueCat
- AppLovin (not expected in the first release unless ads are enabled)
The Service Provider may disclose User Provided and Automatically Collected Information:
- as required by law, such as to comply with a subpoena, or similar legal process;
- when they believe in good faith that disclosure is necessary to protect their rights, protect your safety or the safety of others, investigate fraud, enforce rules, or respond to a government request;
- with trusted service providers who work on their behalf, do not have an independent use of the information disclosed to them, and have agreed to adhere to the rules set forth in this privacy statement;
- with platform providers, payment providers, analytics providers, infrastructure providers, moderation tools, and security partners where reasonably necessary to operate the Application.
International transfers
The Service Provider and its service providers may process information in countries other than your country of residence. Where required by applicable law, the Service Provider takes reasonable steps to ensure appropriate safeguards are in place for such transfers.
What are my opt-out rights?
You can halt all collection of information by the Application by uninstalling the Application. You may use the standard uninstall processes available as part of your mobile device or via the mobile application marketplace or network. Some platform-level tracking, analytics, notification, or advertising permissions may also be controlled through your device settings or platform privacy settings.
What is the data retention policy and how can you manage your information?
The Service Provider will retain User Provided data for as long as you use the Application and for a reasonable time thereafter. The Service Provider will retain Automatically Collected information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Application, maintain security, investigate abuse, respond to reports, process transactions, comply with legal obligations, resolve disputes, and enforce Terms and Conditions.
Different categories of data may be kept for different periods depending on the purpose, sensitivity, technical need, legal requirements, and payment, advertising, fraud-prevention, or moderation needs. When data is no longer required, it may be deleted, anonymized, or securely de-identified where appropriate. If you would like the Service Provider to delete User Provided Data that you have provided via the Application, please contact them at legal@neonhex.com and we will respond in a reasonable time. Please note that some or all of the User Provided Data may be required in order for the Application to function properly.
Your privacy rights
Depending on your location, you may have rights regarding your personal data, including the right to access personal data, request correction, request deletion, object to processing, request restriction of processing, request data portability, withdraw consent where processing is based on consent, and lodge a complaint with a competent data protection authority.
To exercise these rights, contact the Service Provider at legal@neonhex.com. The Service Provider may request reasonable information to verify your identity before fulfilling a request.
How does the Application address children's privacy?
The Service Provider does not use the Application to knowingly solicit data from or market to children under the age of 13.
The Application does not address anyone under the age of 13. The Service Provider does not knowingly collect personally identifiable information from children under 13 years of age. In the case the Service Provider discovers that a child under 13 has provided personal information, the Service Provider will immediately delete this from their servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact the Service Provider at legal@neonhex.com so that they will be able to take the necessary actions.
How is your information kept secure?
The Service Provider is concerned about safeguarding the confidentiality of your information. The Service Provider provides physical, electronic, and procedural safeguards to protect information we process and maintain. For example, access is limited to authorized employees, contractors, and service providers who need to know that information in order to operate, develop, secure, moderate, or improve the Application. Please be aware that, although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
How will you be informed of changes to this Privacy Policy?
This Privacy Policy may be updated from time to time for any reason, including changes to the Application, SDKs, platform requirements, purchases, advertising, AI features, chat systems, moderation systems, or legal requirements. The Service Provider will notify you of any changes to the Privacy Policy by updating this page with the new Privacy Policy. You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes.
How do you give your consent?
By using the Application, you are giving your consent to the Service Provider processing of your information as set forth in this Privacy Policy now and as amended by us. "Processing" means using cookies on a computer/hand held device or using or touching information in any way, including, but not limited to, collecting, storing, deleting, using, combining, and disclosing information. Where separate consent is required by law or platform rules, the Application may ask for that consent separately.
How can you contact us?
If you have any questions regarding privacy while using the Application, or have questions about the practices, please contact the Service Provider via email at legal@neonhex.com.