Privacy Policy

Entities and Roles

• Pixel Illustrations Technology Co., Limited — publisher and data controller for the Services. Business Registration No.: 73990703-000-04-26-8. Registered Office: Unit 1021, Beverley Commercial Centre, 87-105 Chatham Road South, Tsim Sha Tsui, Kowloon, Hong Kong.
• Xiamen Pixel Party Network Technology Co., Ltd. (厦门像素派对网络科技有限公司) — developer and technical support provider. Unified Social Credit Code: 91350200MA8UQNAFXU. Registered Address: Room 508-5-1, No. 30 Guanri Road, Phase II, Software Park, Torch Hi-Tech Zone, Xiamen, Fujian, China.

1. Information We Collect

Our games are free to play and supported by advertising served through the TikTok platform. Information is collected automatically while you play, including:

• Device information: device model and manufacturer, operating system name and version, screen size, language and region settings, time zone, and network/connection type;
• Identifiers and technical data: IP address, country/region inferred from it, device and advertising identifiers made available through the TikTok platform (and, where the platform provides it, the Google Advertising ID or similar advertising identifier), and SDK versions;
• Usage data: session start and end time, gameplay events and progress, features and placements used, and interactions with in-game advertising (ad shown, clicked, completed or failed).

We do not ask you to provide, and do not collect, your name, postal address, phone number or email address. If you contact us by email, we receive your email address and the information you include, and use it only to respond to your request.

2. How We Use Information

• To operate, maintain and improve the Services;
• To provide in-game advertising through the TikTok platform and measure its performance;
• To perform analytics and understand how the Services are used;
• To detect, prevent and address fraud, abuse, security and technical issues;
• To comply with applicable legal obligations.

3. Legal Bases (EEA / UK)

Where the GDPR or UK GDPR applies, we process information on the following legal bases: consent, for advertising identifiers and personalized advertising (where required, consent is obtained through the TikTok platform's own consent and privacy settings); legitimate interests, for operating, analyzing and securing the Services and serving non-personalized (contextual) advertising; and legal obligations, where processing is required by law.

4. Sharing, Platform and Service Providers

Information is shared with the following recipients:

• TikTok (platform operator). When you play a TikTok Mini, the game runs inside TikTok, which hosts the runtime, serves the in-game advertising that funds the Services, and processes any in-game purchases. TikTok independently collects and processes information under its own privacy policy and terms. For users in the European Economic Area, the United Kingdom and Switzerland, the relevant TikTok entity is TikTok Technology Limited (Ireland); elsewhere it is TikTok Pte. Ltd. or TikTok Inc. as indicated in TikTok's policy: tiktok.com/legal/privacy-policy.
• GameAnalytics (analytics). We use GameAnalytics to understand gameplay and stability. Data is hosted on Amazon Web Services infrastructure in the United States: gameanalytics.com/privacy-policy.
• Professional advisers and authorities. We may disclose information to legal, accounting or other professional advisers, and where required by law, regulation or a binding request from a competent authority, or to protect our rights and property.

We do not integrate any advertising networks of our own into the TikTok Mini versions; advertising is provided solely by the TikTok platform. We may also disclose information in connection with a merger, reorganization or asset transfer.

5. International Data Transfers

The Services are operated using cloud infrastructure in the United States (including Amazon Web Services used by our analytics provider) and platform infrastructure operated by TikTok. Our affiliate and its authorized personnel in China may remotely access limited operational data under least-privilege access controls and confidentiality obligations, for development, maintenance and support. Where personal data is transferred outside the EEA, the UK or other regions requiring safeguards, transfers are covered by Standard Contractual Clauses, the UK International Data Transfer Agreement / Standard Contractual Clauses addendum, or other recognized safeguards, together with supplementary measures where appropriate.

6. Data Security

We use industry-standard measures, including TLS encryption for data in transit, encryption at rest applied by our cloud providers, access controls and least-privilege permissions. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

7. Data Retention

• Device identifiers, advertising identifiers and usage/event data: up to 24 months from collection, after which it is deleted or anonymized;
• Information from support requests: for up to 12 months after the request is closed;
• Aggregated or anonymized statistics that cannot identify you may be retained indefinitely;
• Data we are required to retain by law is kept for the period required by the applicable law.

8. Children

The Services are casual games that are not specifically designed for, or directed to, children under the age of 13 (or the minimum digital age of consent in your region, which ranges from 13 to 16 across the EEA and the UK). You must meet both the age rating displayed for the game in your region and the minimum age described here. We do not knowingly collect personal information from anyone below the applicable age. If we learn that we hold personal information of a user below that age, we will take steps to disable personalized advertising for that user and delete the information. If you are a parent or guardian and believe your child has provided us with information, contact us at the address below and we will delete it promptly.

9. Your Rights

Subject to applicable law, you may request access to, correction or deletion of your personal information, restriction of or objection to processing, data portability, and withdrawal of consent, and you may complain to a data protection authority.

• EEA / UK: rights under the GDPR / UK GDPR, including the right to lodge a complaint with your local supervisory authority (Article 77 GDPR);
• Brazil: rights under the LGPD, including confirmation, access, correction, anonymization, portability and deletion, and the right to complain to the ANPD;
• Türkiye: rights under the KVKK, including the right to apply to the Personal Data Protection Authority (KVK Kurumu);
• United States: California residents have rights under the CCPA/CPRA and will not be discriminated against for exercising them;
• Other regions: you may have equivalent rights under your local privacy laws.

To exercise a right, contact us at the email below. We will respond within the period required by applicable law.

10. Advertising Choices

You can reset your advertising identifier or limit ad tracking at any time in your device settings, which reduces personalized advertising across apps. You can also manage personalized advertising through the TikTok app's privacy and ads settings, and learn more from the following industry opt-out resources:

• Europe / UK: youronlinechoices.eu
• United States: optout.aboutads.info and optout.networkadvertising.org

Opting out does not block ads; ads may still be shown based on non-personalized factors such as your general region or the current game session.

11. Uninstalling

You may stop collection by our analytics provider by removing the Mini or stopping use of it within TikTok. Information collected by the TikTok platform is controlled by TikTok and managed through your TikTok account settings and TikTok's privacy controls.

12. Changes to This Policy

We may update this policy from time to time. The "Last updated" date identifies the current version. Material changes will be posted on this page and, where appropriate, notified in the Services or through the TikTok platform.

13. Contact Us