Lightheart Entertainment Oy Privacy Policy

Last updated: 20 October 2026

Lightheart Entertainment Oy ("Lightheart", "we", "us") makes mobile games. This policy explains what personal data we collect when you play our games and use related services (the "Service"), why we collect it, how long we keep it, who we share it with, and what rights you have.

The latest version of this policy is always available at https://www.lightheart.games/privacy-policy/. We will tell you about significant changes in the game and ask for your consent again where the law requires it.


What we collect and why

Account and gameplay data. We process your player ID, username, game progress and gameplay statistics, and if you sign in with Apple or Google, the account ID from that service. We use this to run the game, save your progress, match you with other players and show rankings. Legal basis: performance of our contract with you.

Chat. If you use chat, we process the messages you send. We use them to deliver chat and to moderate it, including acting on reports of abuse. Legal basis: performance of contract, and our legitimate interest in keeping the community safe.

Purchases. When you buy something through Apple or Google, we receive purchase information and receipts from them. In the certain regions, you can also buy through Stash, which processes your payment and order; we receive the order details from Stash and share your player ID with it so your purchase can be delivered. We never receive your payment card details. We use purchase information to deliver and verify purchases and to prevent fraud. Legal basis: performance of contract, our legitimate interest in preventing fraud, and accounting obligations.

Device and technical data. We process your device model, operating system, IP address, error reports, crash logs and performance data. We use this to make the game work on your device, fix problems and keep the Service secure. Legal basis: our legitimate interest in providing a working and secure game.

Analytics. We collect events describing how you play, such as levels completed and menus visited, and when they happen. We use this to understand how our games are played and to improve them, mostly looking at it in aggregate. Legal basis: our legitimate interest in providing a working and secure game.

Advertising. Ads keep our games free to play. We and our advertising partners process advertising IDs, IP address, approximate location derived from it, and how you interact with ads and the game. This is used to show and measure ads, prevent ad fraud, and see which of our marketing campaigns led you to install the game. With your consent, partners may also personalise ads based on your activity across apps. Legal basis: consent for personalised ads and install attribution; our legitimate interest for showing non-personalised ads, measuring them and preventing fraud.

Support and feedback. When you contact us through our support site or by email, or send feedback, we process your message, contact details and relevant game data to answer you and fix issues. Legal basis: our legitimate interest in helping players and improving our games.

We do not make decisions with legal or similarly significant effects on you based solely on automated processing. Automated tools may flag possible cheating, fraud or abusive chat, and you can ask us to review any action taken against your account.


Your privacy choices

When you first start a game, a consent pop-up asks for your choices on analytics and personalised advertising. Refusing does not limit core gameplay; you will still see ads, but they will not be personalised. You can change your choices at any time by emailing privacy@lightheart.games. On iOS, tracking across other companies' apps also requires your permission through Apple's App Tracking Transparency prompt. On Android, you can reset or delete your advertising ID in your device settings.


How long we keep data

We keep full event data, such as gameplay and analytics events, error reports and advertising events, for 90 days. After that, we keep processed events with application specific user identifiers for up to 2 years. Beyond that we only keep aggregated analytics data. Your account, game progress and statistics are kept for as long as your account exists, until you ask us to delete it. Support and feedback messages are kept for up to 2 years after your last contact. Purchase records are kept even after your account is deleted, for as long as we need them for accounting, tax, fraud prevention and legal claims. Deleted data may remain in secure backups for up to 90 days, and if a backup is restored, we delete it again.


Who we share data with

We share data only with partners that help us provide the Service, as described below. Some act as our processors and use data only on our instructions. Others are independent controllers responsible for their own processing under their own privacy policies.

Hosting: Amazon Web Services stores player accounts and game data (https://aws.amazon.com/privacy/), and Google Cloud Platform hosts our analytics (https://policies.google.com/privacy). Both act as our processors.

Support: Zendesk runs our support site and handles support requests as our processor (https://www.zendesk.com/company/agreements-and-terms/privacy-notice/).

App stores and sign-in: Apple (https://www.apple.com/legal/privacy/) and Google (https://policies.google.com/privacy) process purchases and, if you use them, account sign-in. Their own terms apply to these.

Direct purchases: In the United States, Stash sells and processes purchases made outside the app stores. Stash is responsible for your payment data under its own privacy policy (https://www.stash.gg/legal/privacy-policy), and processes the game data we share with it on our behalf.

Ads in our games: AppLovin (https://legal.applovin.com/privacy/), Unity (https://unity.com/legal/game-player-and-app-user-privacy-policy), Mintegral (https://www.mintegral.com/en/privacy), Digital Turbine / DT Exchange (https://www.digitalturbine.com/legal/privacy-policy), Meta (https://www.facebook.com/privacy/policy) and Google show and measure ads. These networks may involve further advertising partners, as explained in their own policies.

Marketing our games: Singular (https://www.singular.net/privacy-policy/) measures which ads lead to installs and purchases.

We may also disclose data where required by law, to protect the rights and safety of our players or ourselves, or as part of a merger or sale of our business.

Some partners process data outside the European Economic Area, including in the United States. For these transfers we rely on adequacy decisions, such as the EU-U.S. Data Privacy Framework, or on the European Commission's Standard Contractual Clauses. Contact us for details.


Security

We protect personal data with technical and organisational measures such as encryption and access restrictions. Our staff access personal data when needed to handle support requests and feedback, investigate technical problems, security issues, cheating or fraud, moderate chat, or test pre-release versions of our games, and then only the data needed for the task.


Your rights

Under the GDPR and UK GDPR, you can ask us for a copy of your data, and to correct, delete, restrict or transfer it. You can object to processing based on our legitimate interests, and to direct marketing at any time. Where we rely on consent, you can withdraw it at any time without affecting earlier processing.

To exercise your rights, including deleting your account, email privacy@lightheart.games. We reply within one month. For complex requests we may extend this by up to two months and will tell you why. We may need to verify your identity. If you have not signed in, your data may be linked only to your device, so we may ask for your player ID, which is shown in the game, to find it. Where a partner is an independent controller, you can also contact them directly. If you play again after a deletion, new data will be collected. We keep records of privacy requests for up to 2 years.

You can also complain to a data protection authority, such as the Finnish Data Protection Ombudsman (https://tietosuoja.fi/en/home) or the authority in your own country.


US privacy rights

This section applies to residents of California and other US states with consumer privacy laws.

In the past 12 months we have collected the data described above, which falls into these categories: identifiers (such as player ID, advertising ID and IP address), commercial information (purchases), internet and app activity (gameplay, chat, and ad interactions), approximate location, and inferences used for personalised ads. We collect it from you, your device and our partners, for the purposes described above. We do not use sensitive personal information for purposes that would give you a right to limit it.

We do not sell personal data for money. However, letting advertising partners collect identifiers, app activity and approximate location to personalise ads across apps may count as "selling", "sharing" or "targeted advertising" under these laws. You can opt out by emailing privacy@lightheart.games or by limiting ad tracking in your device settings. We do not knowingly sell or share the data of anyone under 16.

You have the right to know what personal data we collect, use and disclose, to access, correct and delete it, to opt out of its sale or sharing and of targeted advertising, and not to be treated differently for using these rights. To make a request, email privacy@lightheart.games. An authorised agent may make a request for you with your signed permission. If we decline your request, you can appeal by replying to our decision. If your appeal is declined, you can contact your state Attorney General.


Children

The Service is intended for players aged 16 and older and is not directed at children under 13. We do not knowingly collect personal data from anyone under 16. If we learn that we have, we will delete it. If you believe a child has given us personal data, please contact us.


Contact

Lightheart Entertainment Oy is the controller of the personal data described in this policy, except where a partner acts as an independent controller.

Lightheart Entertainment Oy
Business ID: 3004546-1
privacy@lightheart.games