Privacy Policy

Last updated: 1 May 2025

PEBBLE MEDIA INC (“Company”, “we”, “us”, “our”), its subsidiaries and affiliates, is the author and publisher of the gaming applications and associated online platforms, including but not limited to the Websites and any other related domains, games, or online services created or operated from time to time. This Privacy Policy applies to all games and services provided by the Company. This Privacy Policy explains how your data, including personal information, is collected and processed by us when you use our mobile applications (the "App"). This Privacy Policy highlights our privacy practices regarding the data that we collect and store through the Website, the data that you provide us while interacting with us on our Website and the data while using or accessing the services provided by us. Personal Information means any information, data, details, records that relate to and can be used to identify, recognize, locate or contact a natural person or individual either directly or indirectly in combination with other information.

The App is a free-to-play game (with optional in-game purchases). To maintain the high quality and a great game experience, we process information from and about you to improve the entire experience in the App and support internal operations.

We update this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, depending on the specific changes, we will provide you with additional notice or require a renewed consent.

Collection of information

Information we collect automatically through the app

When you access or use the App, we automatically collect general information about you, including:

  • Log Information: We log information about your use of the App, including the type of device you use, the features you use, access times, your IP address, demographics, mobile’s operating system, your computers’ operating system, and browser type and information collected via cookie.
  • Device Information: We collect information about the device you use to access the App, including information about the device manufacturer, device model, device's OS, time zone of the device, and language of the device.
  • Device identifiers: We collect online identifiers of the device you use to access the App, including IDFA, Google Ads ID, Google Device ID, Game Center ID, and Google Play Account ID.
  • Usage Information: We collect information relating to your use of the App, including your game progress, scores, achievements, and interactions with other players.
  • Consumption Information: We collect information about your consumption habits relating to your use of the App, including which purchases you make with both virtual and real currencies and the reception of virtual goods in-game.
  • Personal Information: We collect personal information that you provide via our App, including information you provide through any associated forms e.g., name, address, email address, bank details, sex, demographic data, date of birth, PIN code, designation and company, contact number/mobile number, user IDs, passwords, photograph, signature image, income proof, credit score, credit information report, e-KYC documents, or any other data regarding your usage of the App.

Information we collect from other sources

If you log into the App using a third party site or platform such as Facebook, Apple Game Center and Google Sign-In, we access information about you from that site or platform, such as your screen name, profile information and friend lists, by the authorization procedures determined by such third party site or platform provided that you have given the third party site in question such consent.

You can learn more about how such third-party sites or platforms process your personal data in the relevant privacy policy:

If you log into the App using a third party site or platform, you represent and warrant that (i) your access and use of such features in connection with the App will comply with the applicable terms and policies of such site or platform; and (ii) that you are over the minimum age limit that is prescribed for such third party site or platform by the legislation in the individual jurisdictions.

Use of information – purpose and legal basis

We use information about you for the following purposes in accordance with the legal bases for each type of personal data as described below:

  • Log, device, usage and consumption information and device identifiers are being processed:
    • to provide and deliver the products and services you request and send you related information as requested by you / as agreed with you;
    • to provide and maintain the App and the game experience; and
    • to send you technical notices, updates, security alerts, support, and administrative messages;
    • to provide better usability and troubleshooting;
    • to understand which parts of the App are visited and how frequently;
    • to market products and services based on legitimate business interest under the applicable law;

      Our processing for the above purposes is necessary for the performance of a contract to which you are the party to support the operation of the App, facilitate the delivery of requested products and services and enable maintenance and update of the App, see Article 6(1)(b) of the GDPR.

    • to provide news and information about the App that we think will be of interest to you;
    • to personalize and improve the App and provide tailored content and features;
    • to monitor and analyze trends, usage, and activities in connection with the App;

      Our processing for the above purposes is justified by our legitimate interests in providing advertisements and content of interest to you and improving our services in accordance with Article 6(1)(f) of the GDPR (also known as "the balancing-of-interest rule").

    • to provide users who have given us consent to share their advertising IDs with our ad network partners (as further specified under “Sharing of Information”) for the purpose of serving them with personalized advertisements in the App (behavioral advertising).
    • to assist our partners and third parties to provide you services and process payments through the App.

      Our processing for the above purpose is justified by our legitimate interests in providing advertisements and content of interest to you in accordance with Article 6(1)(f) of the GDPR. The disclosure of your advertising ID to third parties for the purposes of behavioral advertising is based on your consent in accordance with Article 6(1)(a) of the GDPR (see more below under Sharing of Information).

  • Information from other sources is being processed:
    • to provide and deliver the products and services you request and send you related information;

      Our processing for the above purpose is necessary for the performance of a contract to which you are the party in order to facilitate the delivery of requested products and services, see Section 6(1)(b) of the GDPR.

    • to link or combine information we get from others to help understand your needs and provide you with better service; and
    • to provide news and information about the App we think will be of interest to you;

      Our processing for the above purposes is justified by our legitimate interests in providing content of interest to you and improving our services in accordance with Article 6(1)(f) of the GDPR (also known as "the balancing-of-interest rule").

We only process your information to the extent that is necessary to achieve the purposes for which the information has been collected.

Storage of information

PEBBLE MEDIA INC will store your personal data for as long as necessary in order to provide you with the App or otherwise fulfil the purposes as described above, unless further storage is required in order to establish, exercise or defend a legal claim or to comply with applicable law, including accounting rules.

Your personal data is deleted or anonymized as soon as it no longer serves one of the above-mentioned purposes, unless a longer retention period is required by law or for directly related legitimate business purposes. Such purposes may include without limitation i) any ongoing services availed through the App, ii) any investigations and inquires under law, or iii) any contractual arrangements between the parties. We may keep records of all communications, both voice telephone calls and non-voice digital chats and emails received from and made to users for the purpose of administration of services, research and development, training, business intelligence, business development, or for user administration. We may share such telephone records with third parties when required by law or when required to provide or facilitate the user with the App services.

Sharing of information

We disclose information about you to the following categories of recipients based on the legal bases under Sections 6(1)(b), 6(1)(c), and 6(1)(f) of the GDPR (see a description of the legal bases above):

  • Social networks, see more under "Social Sharing features";
  • Third parties if we are required to disclose your personal data by applicable law, rule, regulation, legal process or in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
  • The statutory, government, regulatory, administrative or other authorities, if we believe your actions are inconsistent with the spirit or language of our policies or if the disclosure is necessary to protect the rights, property and safety of PEBBLE MEDIA INC or others;
  • Other players in order to provide certain in-app features, such as leaderboards, if you log into the App using a third-party service;

Furthermore, if you have given your consent in accordance with Section 6(1)(a) of the GDPR, we share your Device identifiers to advertising network companies for the purpose of them serving behavioral advertisements to you within the App. We use or may use, without limitation, the following advertising network companies:

The recipients' use of the disclosed information will not be covered by this Privacy Policy. If you have questions concerning the processing carried out by such third parties, you should review their privacy policy.

In connection with our processing, we use or may use, without limitation, the following data processors such as server hosting providers, technical service providers for supporting internal operations, user login services and analytics service providers:

Social sharing features

The App offers or can offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take in the App with other media. You must be over the minimum age limit that is prescribed by the legislation in the individual jurisdictions to use any social sharing features integrated in the App. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature.

Children

Use of the App is limited to users aged 13 years and above, except in European Economic Area, where the App is limited to users aged 16 years and above. However, if the permissible age for using the App in the jurisdiction from which the App is being accessed is higher than the applicable minimum age stated above, then such age shall apply. If you are accepting this Privacy Policy and using the App, you warrant you are 13 (or above, depends what is applicable) or more years old. In case of access or use of the App by minors (as defined by the laws of the jurisdiction from which the App is being accessed), it shall be presumed that such access and use is subject to the supervision and control of the parents/legal guardians and that they have accepted this Privacy Policy. We shall at all times, reserve the right to refuse or restrict your access or use of the App in the event we learn of your incompetency to use the App.

If you have additional questions about PEBBLE MEDIA INC's privacy practices related to children under the applicable minimum age, please contact us at apps@pebblemedia.net.

Transfer to third countries

In connection with the processing, we will in certain circumstances transfer your personal data to recipients outside the EEU.

We only transfer personal data to entities in third countries that have provided appropriate safeguards to ensure that their level of data protection is in agreement with this Privacy Policy and applicable law.

Consequently, the transfers will only occur based on the following safeguards:

  • If the entity is certified to comply with the principles for data protection under the US EU Privacy Shield Framework ("Privacy Shield") (you can view the entities certified under Privacy Shield at https://www.privacyshield.gov/), or
  • If we have entered into standard data protection clauses adopted by the European Commission with the entity, which is deemed to offer sufficient safeguards with respect to the protection of the privacy and fundamental rights and freedoms of individuals.
  • Entering into standard contractual clauses (SCCs) approved by relevant data protection authorities;
  • Ensuring the recipient country is recognized as providing an adequate level of data protection by the relevant authority;
  • Implementing binding corporate rules (BCRs) where applicable;
  • Taking additional technical and organizational measures to secure data during and after transfer.

Data Disclosure and Transfer

We share your personal data within:

  • The Company;
  • Employees, affiliates and related parties;
  • Business partners;
  • Service providers and vendors;
  • Authorized third-party agents; or
  • Contractors

We may share your information, including personal information and sensitive personal information to our partners, service providers, vendors, sponsors, marketing partners, third parties, agents, employees, payment facilitators, banks or our group companies or affiliates or any other parties which whom the Company has tie-ups in relation to provide any services or ancillary services on a need-to-know basis for the purposes mentioned in this Privacy Policy and you hereby consent to the same. We will not sell or rent or otherwise disclose your information for commercial purposes to anyone in a way that is contrary to the commitments made and/or other than as set forth in this Privacy Policy.

The Company expects these third parties to manage and handle your information using the same level of care and with the confidentiality obligations as of the Company. There are also several products and services offered by certain third parties through the App. If you elect to avail these third-party services, you may be required to disclose to them or grant them access to your personal information. In such cases, their use of your information shall be governed in accordance with their terms and privacy policy. Company shall not be liable for any use or access of your information by third parties, providing services through the App. We recommend you read, understand and evaluate the privacy policies and procedures of these external services providers before deciding to use their services.

We may also share your information, without obtaining your prior written consent, with judicial authorities, administrative bodies or government agencies mandated under the law to obtain information for the purpose of verification of identity, or for prevention, detection, investigation including cyber incidents, prosecution, and punishment of offences, or where disclosure is necessary for compliance of a legal obligation. You agree and consent for the Company to disclose your information, if so required, by any order or decree of such authorities under applicable law.

In case of any restructuring or reorganization of the Company, Company may also share, and/or transfer your personal information to any successor-in-interest as a result of change in ownership and control due to reasons such as merger, reorganization, or consolidation of it with another entity on a basis that it is not the surviving entity. We limit the collection and use of your personal information. We may process and disclose the personal information in a non-personally identifiable manner. Such information does not identify you individually. To the extent reasonably possible, we would restrict access to your account information and any other personal identifiably information and use it only for the purposes set out in this Privacy Policy, in order to operate, develop or improve our services.

Use of Cookies

This explains what cookies are, the different types of cookies, how we use them and most importantly how to control your cookies. By continuing to use our App, you are agreeing to the use of cookies and similar technologies for the purposes described here.

Our App uses cookies to improve your online experience. “Cookies” are small pieces of information sent by an organization to your computer and stored on your hard drive to allow the App to recognize you when you visit. They collect statistical data about your browsing actions and patterns and do not identify you as an individual. This helps us improve our services and deliver a more personalized service.

We use both session cookies and persistent cookies. A session cookie is only stored on your device during a single visit to the App (“browser session”) and is deleted when you close your browser to end the session. We use session cookies to make it easier for you to navigate our services.

A persistent cookie remains on your hard drive for an extended period. We use persistent cookies to remember you, so you don’t have to log in every time you use our services. Persistent cookies also enable us to track and target the interests of our users to enhance the experience on our services.

Our services gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp. This information is used to administer and improve performance, diagnose server problems, and to help ensure the security of our services.

Our services may include social media features, such as the Facebook Like button and widgets, such as a “Share” button. These features may collect information such as your IP address, which page you are visiting on our services and may set a cookie to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing it.

We may allow other companies or entities to serve advertisements to you. These companies or entities include third party advertisement servers, advertisement agencies, and advertisement technology vendors. We may target some advertisements to you that fit a certain general profile. In the course of serving advertisements or optimizing the services to its users, we may allow authorised third parties to place or recognize a unique cookie on the user’s browser.

Security

PEBBLE MEDIA INC takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

Push notifications

We send push notifications or alerts to your mobile device to provide game-related information, service updates, promotional communications and other related messages, if you have agreed to such notifications. You can deactivate these notifications by changing your notification settings on your device.

Does PEBBLE MEDIA INC actually "sell" personal data?

PEBBLE MEDIA INC does not, and will not, provide your personal data in direct exchange for money. Therefore, in the literal sense, PEBBLE MEDIA INC does not sell your data. However, we have disclosed some categories of personal data we collect, explained under ”Sharing of information“, to the third parties for business purpose as explained under “Use of information – purpose and legal basis”.

To the extent this practice is interpreted to constitute a “sale” under the CCPA, please contact us at apps@pebblemedia.net to exercise your right to withdraw your consent on sharing your personal data with third parties.

YOUR RIGHTS

Rights of EEU residents

We process and answer your requests without undue delay unless a longer period is required due to the complexity of the request. In this case, our response time can be up to three months in total as permitted by Article 12 of the GDPR.

Right to request access

You have the right to request access into the data that we are processing on you, including information about:

  • the purposes of the processing;
  • the categories of personal data concerned;
  • the recipients or categories of recipient to whom the personal data have been or will be disclosed;
  • the envisaged period for which the personal data will be stored.

Furthermore, you have the right to obtain a copy of the personal data undergoing processing. Please note that the access may be restricted due to intellectual property or trade secrets.

Right to object

You have the right to object to our processing of your personal data on grounds relating to your particular situation when the data are processed based on the balancing-of-interest rule in Section 6(1)(f) of the GDPR, see Article 21 of the GDPR. In this case, we will cease the processing unless there are compelling legitimate grounds for the processing which override your interests, rights and freedoms or if the processing is necessary for the establishment, exercise or defense of legal claims.

You have the right to object to our processing of your personal data for direct marketing purposes at any time. We will cease the processing of your personal data for this purpose after the objection.

Right to rectification

You have the right to have inaccurate personal data rectified.

Right to restriction

You have the right to obtain restriction of processing in certain circumstances. If you have the right to restriction, we will only process your data with your consent or for the establishment, exercise or defense of a legal claim or to protect a person or important grounds of public interest.

Right to withdraw consent

If we have asked for your consent to our processing of your data, you have the right to withdraw your consent at any time.

If you withdraw your consent, we will cease processing of the data for which you have withdrawn consent, unless we have a legal obligation to keep some or parts of your data.

The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal.

Right to data portability

You have the right to receive the personal data you have provided us with which we process in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller if the processing is based on consent or contract performance.

Rights of California residents

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal data that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

Right to opt out

Under CCPA each California resident can request any business to stop sharing personal information to third parties.

Right to be informed

You have a right to be informed about what categories of personal data we are collecting, including the purpose of the collection. You can freely find this information in our Privacy Policy. We may update our Privacy Policy from time to time.

Right to disclosure

You can request us to disclose what personal data we have collected on you in the past 12 months.

We can assure you that our Privacy Policy is a relevant document where you can find information about what personal data we have collected about you over the past 12 months and intend to collect, sources of your personal data and how we use your personal data.

You also have a right to get a free copy of your personal information disclosed in a readily usable and readable format (right of access). You can make this request for free, twice per year.

When providing information under the right of access, we will provide you with the following information:

  • The categories of personal data we are collecting about you,
  • The categories of sources of the personal data,
  • The purpose for collecting your personal data,
  • The categories of any third parties with whom we share your personal data,
  • The specific pieces of personal data collected about you.

Right to deletion

You can request us to delete the personal data we have collected from you in the past 12 months.

We fully recognize your right to deletion, however, we would like to note that in some cases we are obliged to keep your personal data for certain period of time. For instance, if we need to provide services to you, detect or resolve issues security or functionality related issues, comply with the law, conduct research in the public interest, safeguard the right to free speech or carry out any actions for internal purposes that you might reasonably expect. If we do not have obligations to perform any of the above actions, we can delete your personal information at your request.

Data Deletion Request

You may request PEBBLE MEDIA INC to erase without undue delay your personal data when it is no longer necessary for PEBBLE MEDIA INC to retain such data, unless retention is required by applicable laws.

In order for your data to be erased you can contact PEBBLE MEDIA INC by apps@pebblemedia.net with the request.

Right to equal services and prices

California residents are protected against any discrimination that a business might subject them to based on the exercising of their CCPA rights.

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you the App,
  • Charge you different prices or rates for the App, including through granting discounts or other benefits, or imposing penalties,
  • Provide you a different level or quality of the App,
  • Suggest that you may receive a different price or rate for services or a different level or quality of the App.

How to exercise my rights

If you wish to use any of the rights described above, you may contact us at any time by emailing us at apps@pebblemedia.net.

Mandatory verification: We will need to verify your identity before processing your request. However, because you cannot create an account with the App, and you do not provide us with any information directly, we only collect information automatically, we may use limited verification methods. To verify your identity, we will generally require the matching data in our systems to the information we can process when you are making a request. In certain circumstances, we may decline the request, mainly where we are unable to verify your identity, for example, if you disable cookies, changed the device you used to access the App or you already requested us to delete your personal data.

Contact

PEBBLE MEDIA INC has the following contact information:

PEBBLE MEDIA INC
Address: A120, Lake Gardens, Kolkata - 700045, India (IN)
E-mail: apps@pebblemedia.net