Privacy Policy

Summary

FreshCode ("we", "us", "our") is a software and electrical engineering company based in Bloemfontein, ZA. We are responsible for the personal information processed by our apps and games, as described in this policy.

Our apps & games

The details below show exactly what each app or game collects and which third-party services it uses. Everything else in this policy applies to all of them.

Information we collect

Information stored on your device

Game progress, settings and preferences are usually saved locally on your device. We can't see this data, and it's removed when you uninstall the app.

Information you give us

If you contact us for support or feedback, we receive your email address and whatever you choose to include in your message. If an app offers accounts, we store the details you sign up with, such as your email address or a sign-in provider ID.

Information collected automatically

Depending on the app, we or our service providers may collect:

• Device information: device model, operating system version, language and app version.
• Identifiers: an advertising ID (Android Advertising ID or Apple IDFA, if you allow it) or an anonymous app instance ID.
• Usage data: features used, levels played, session length and similar in-app activity.
• Diagnostics: crash logs and performance data.
• Approximate location: inferred from your IP address (country or city level). We don't request precise GPS location unless an app clearly says so and you grant permission.
• Purchase information: a record of in-app purchases. Payments are handled entirely by Google Play or the App Store; we never receive your card details.

How we use your information

• To run the app, save your progress and deliver purchases.
• To fix crashes and bugs and improve performance.
• To understand how our apps are used, so we can improve them.
• To show ads in free apps, which help keep them free.
• To reply to your support requests.
• To prevent fraud and abuse, and to comply with the law.

Where the law requires a legal basis (for example under South Africa's POPIA or the EU/UK GDPR), we rely on: performing our agreement with you (providing the app), our legitimate interests (keeping the app secure and improving it), your consent (for personalised ads and certain analytics where required), and legal obligations. You can withdraw consent at any time.

Third-party services

Some apps include software from trusted partners for ads, analytics, crash reporting, sign-in or purchases. These partners collect information directly from your device under their own privacy policies. Each app's section above lists exactly which ones it uses, with links to their policies.

We may also share information:

• with hosting and service providers who process it on our behalf, under confidentiality obligations;
• if required by law, or to protect the rights, property or safety of our users or others;
• with a successor if FreshCode is involved in a merger or acquisition, in which case this policy continues to apply.

We do not sell your personal information, and we do not "share" it for cross-context behavioural advertising as defined by California law, except through ad partners you can opt out of as described below.

Advertising & your choices

Free apps may show ads. In apps marked "Made for kids", or "All ages" without an age screen, ads are always non-personalised and suitable for children, and your advertising ID isn't used for tracking. In apps with an age screen, this applies to players under 13, and the app's section above explains what applies at each age. In other apps, ad partners can use your advertising ID to show more relevant ads and to measure ad performance. The choices below apply wherever your advertising ID is used.

• Android: Settings → Google → Ads → Delete advertising ID (or Opt out of Ads Personalization on older versions).
• iOS: we only access your IDFA if you tap Allow on the App Tracking Transparency prompt. You can change this any time in Settings → Privacy & Security → Tracking.
• EEA, UK, Switzerland and US states with privacy laws: where required, we ask for your consent before personalised ads are shown (or let you opt out of them, where that's what the law requires), and you can change your choice from within the app. In Voltlings, go to Settings → Ad privacy.

If you opt out, you'll still see ads, but they'll be less personalised.

Children

Unless an app is marked "Made for kids" or "All ages" above, it is not directed at children under 13 (or the minimum age in your country), and we don't knowingly collect their personal information.

Apps marked "All ages" are designed for everyone, including children. Unless the app also has an age screen, we treat every player as if they could be a child: we don't collect personal information from them, we don't show personalised ads or use advertising IDs for tracking, and any third-party services they use are configured for child-directed use.

Some "All ages" apps, such as Voltlings, are marked "Age screen". Instead of treating every player as a child, they ask for your year of birth. It's stored only on your device and is used to choose suitable ads: players under 13 get the child-directed protections above, and the app's section lists the details for each age group.

Apps marked "Made for kids" are designed to comply with the Children's Online Privacy Protection Act (COPPA), Google Play's Families Policy and Apple's Kids Category rules: they show only non-personalised, child-appropriate ads (if any), and they don't collect personal information from children for tracking or behavioural advertising.

If you believe a child has given us personal information, contact us and we'll delete it.

Retention & security

We keep personal information only as long as we need it for the purposes above. Support emails are kept for up to 2 years. Account data is kept until you delete your account. Analytics and crash data are kept for the periods set by the services listed above, typically 14 to 26 months. Data stored only on your device is removed when you uninstall the app.

We use reasonable technical and organisational safeguards, such as encryption in transit and restricted access. No system is perfectly secure, though, and we'll notify you and the relevant authorities of a breach where the law requires it.

International transfers

We are based in South Africa, and some of our service providers process data in other countries, including the United States and the European Union. When information leaves your country, we rely on safeguards such as the service providers' standard contractual clauses to protect it.

Your rights

Depending on where you live (including under South Africa's POPIA, the EU/UK GDPR and US state laws such as the CCPA), you may have the right to:

• access the personal information we hold about you;
• correct inaccurate information;
• delete your information;
• object to or restrict certain processing, including direct marketing;
• receive your data in a portable format;
• withdraw consent at any time;
• opt out of the sale or sharing of personal information;
• not be discriminated against for exercising these rights.

To exercise any of these, contact us. We'll respond within 30 days and may need to verify your identity first. You also have the right to complain to a data protection authority. In South Africa, that's the Information Regulator ↗. In the EU or UK, it's your local supervisory authority.

Deleting your data

• Data on your device: uninstall the app, or clear its data in your device settings.
• Account data: if the app has accounts, use the in-app Delete account option where available, or email us from the address linked to your account.
• Anything else: email jdkokt@gmail.com with the subject "Data deletion request", and tell us the app name and any identifier you can find (such as your account email or the player ID shown in settings).

We'll confirm and delete your data within 30 days, except for anything we must keep by law (such as purchase records for tax purposes).

Changes to this policy

We may update this policy from time to time, for example when we release a new app or add a service. We'll change the "Last updated" date above, and for significant changes we'll notify you in the app or on this page before they take effect.

Contact us