Privacy Policy

Last Updated: February 2025

Our privacy policy is designed to provide clarity regarding our privacy practices and principles in a way that is easy for our users to navigate, read, and understand. Ocean Feather Technology Inc. and its subsidiaries (collectively "Ocean Feather") are committed to handling your personal information with respect and care.

This privacy policy explains how Ocean Feather collects, uses, and discloses information from players of its games ("Ocean Feather Games"). Please read this policy carefully to understand how we handle your information. By downloading, accessing, or playing Ocean Feather Games, you consent to the collection of your information as described in this policy.

If you are a resident of California, additional privacy terms set forth in Appendix A apply to the processing of information collected during your play of the games.

If you are located in the European Economic Area (EEA) or the United Kingdom (UK), additional privacy terms set forth in Appendix B also apply to the processing of your personal information.

1. 1. Information We Collect

We collect information about you and your use of Ocean Feather Games. Some information may be necessary to provide you with access to Ocean Feather Games. Failure to provide such information may prevent us from offering you certain games, features, or services.

By downloading, accessing, and/or playing Ocean Feather Games, you consent to the collection of your information. Most of this data comes directly from you or your device, such as device information, your location, and game progress data. We use this data to offer you our games and services, including to optimize gameplay, prevent fraud, personalize in-game offers, verify purchases, and, in collaboration with third-party advertising partners, deliver targeted or contextual advertisements.

The information we collect falls into three categories:

(1) Information collected directly from you

(2) Information collected automatically

(3) Information collected from third parties

(1) (1) Information Collected Directly from You

When you download our game, we may collect your age as provided by you.

Information you provide in game reviews and surveys.

(2) (2) Information Collected Automatically

We use in-app analytics tools to collect unique user IDs, IP addresses, device IDs, operating system identifiers, identifiers we assign to your account, and other similar identifiers (collected from your device).

Information regarding your activities in Ocean Feather Games (for example, game progress or interactions with in-game ads), Internet, gaming, or other electronic network activity (such as information on your interactions with advertisements) (collected from your device). If you opt-in for Cloud Save in certain games, your gameplay data is stored in the cloud. For other games, depending on the platform, data may be stored locally on your device.

Your general geographic location (such as country, state, or city) determined by your IP address.

(3) (3) Information Collected from Third Parties

Ocean Feather collects user data through third-party advertising networks on Ocean Feather Games. This includes device IDs, unique advertising IDs associated with your device, and your approximate location. For more details, see the “Advertising” section below.

If you connect to Ocean Feather Games through a third-party platform, we may collect third-party account information and public details linked to that service (such as your name, profile photo, age range, gender, and your friends). Please note that when you share information on third-party platforms, such information may be collected separately by those platforms. The information we collect is governed by this privacy policy, while the information collected by the third-party platform is subject to its own privacy practices.

Please refer to the “Privacy for Children and Minors” section below for more details on how we collect information from children.

2. 2. How We Use Your Information

Ocean Feather uses your information for the following purposes:

To sell advertisements within Ocean Feather Games, as described in the “Advertising” section below.

To provide you with the products and services you request.

To allow you to log into Ocean Feather Games across multiple devices through Cloud Save.

To comply with local laws and provide available choices and controls to you.

To detect, investigate, and prevent activities that may violate our policies or be illegal.

In addition, Ocean Feather may use your information for the following purposes, as they align with our legitimate business interests:

To optimize or improve our products, services, and operations.

To enhance Ocean Feather Games and the user experience, increasing game functionality.

To monitor and analyze usage trends within Ocean Feather Games and measure service effectiveness.

For information on our use of children’s data, please see the “Privacy for Children and Minors” section below.

3. 3. How We Disclose Your Information

We may disclose your information outside of Ocean Feather under the following circumstances:

When you authorize us to share your information with another company, such as directing us to disclose your data to third-party platforms like social networks.

When we contract with or partner with third parties to provide services on our behalf, including the development and maintenance of Ocean Feather Games. These third parties provide services such as order processing, billing, sales, marketing, advertising, market research, data storage, analysis, and legal services.

In connection with the sale of Ocean Feather's business or part of it, we may share your information.

To enforce our Terms of Use or rules, ensure the safety and security of our users and third parties, protect the rights and property of both our users and third parties, address issues related to security or fraud, comply with legal processes, or when we believe disclosure is required by law.

As outlined in the “Advertising” section below.

If you consent, we may disclose your information publicly or to third parties, such as if you agree to provide a product or service review and allow your content to be attributed to you.

When we share information within the Ocean Feather corporate group, where such entities process your information in order to operate the Ocean Feather Games. All group companies will use your data only in accordance with this privacy policy.

Please note that once your information is disclosed to a third party, it will be governed by that party's privacy practices. However, when third-party companies provide services for us, such as customer support, we have agreements in place that govern their data practices, ensuring that they do not use your data for purposes other than those authorized by us or required by law.

You may request a notice detailing the categories of information we've disclosed to third parties and their names. To request such notice, please contact [email protected].

For further details about how we share information related to children, please refer to the “Privacy for Children and Minors” section below.

4. 4.Advertising

Ocean Feather relies on advertising to fund the development and distribution of the Ocean Feather Games, most of which are available to play at no cost to you. Accordingly, when you play the Ocean Feather Games you may see third-party advertising. This advertising is delivered to the Ocean Feather Games by advertising networks that sell advertising to interested third parties. Advertising networks collect a unique device ID or advertising ID that enables the delivery of advertisements that are relevant to you. Your advertising ID is consistent across all apps and thus allows for cross-app tracking and interest-based advertising. Advertising IDs are non-permanent, non-personal identifiers uniquely associated with your device. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognize your device when you use websites and applications. Advertising networks may use your device’s IP address to determine your approximate geographic location to enable them to deliver more relevant advertisements.

Some Ocean Feather Games reward you with in-game currency (such as coins or gems) for watching advertisements (“Rewarded Ad”). If you are a California resident, please review the Incentive Program section in Appendix A.

Please see the “Your Controls and Choices” section, below, for information on how to limit advertising tracking.

We do not sell data on children (players under the age of 13) and minors (players under the age of 16). Please see the “Privacy for Children and Minors” section below for more information on advertising to children.

5. 5.In-App Purchases

Ocean Feather Game does not offer any real money or gifts that can be exchanged for real currency.

6. 6.Your Controls and Choices

We provide you the ability to exercise certain controls and choices regarding our collection, use, and sharing of your information. In accordance with applicable law, you may be able to exercise certain rights with respect to the information we hold about you, including requesting access to that data or requesting that we amend or delete it. You may exercise your controls and choices, or request access to your information, by contacting [email protected]. See also Appendix A (for users in California) and Appendix B (for users in the European Union).

(1) Rights Regarding Your Information

Depending on your jurisdiction, you may have the right, in accordance with applicable privacy and data protection laws, to make requests related to your “personal information” or “personal data” (as such terms are defined under applicable law, and collectively referred to herein as “personal information”). Specifically, you may have the right to ask us to:

Tell you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we disclose personal information.

Provide you access to and/or a copy of certain personal information we hold about you.

Correct or update personal information we hold about you.

Delete certain personal information we have about you.

Provide you with information about the financial incentives that we offer to you, if any.

Restrict or object to certain uses of your information.

Opt you out of the processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable.

Please note that certain information may be exempt from such requests under applicable law. For example, we need to retain certain information in order to provide our services to you. We also need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address. If we are unable to verify you, we may be unable to respond to your requests.

You may also have the right to opt out of “sales” of your information and “sharing/processing of your information for targeted advertising” as described below. If you are a California resident, please see the Appendix A below for more information about our privacy practices and your rights.

As provided in applicable law, you also have the right to not be discriminated against for exercising your rights.

To exercise any of these rights, you can contact [email protected].

You may be able to designate an authorized agent to make requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.

Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. We will provide information about how to exercise that right in our response denying the request. You also have the right to lodge a complaint with a supervisory authority.

(2) Notice of Right to Opt Out of Sales of Personal Information and Processing/Sharing of Personal Information for Targeted Advertising Purposes

Depending on your jurisdiction, you may also have the right to opt out of “sales” of your information and “sharing/processing of your information for targeted advertising.”

As explained in the “How We Disclose Your Information” and “Advertising” sections above, we sometimes disclose information to unaffiliated third parties we collaborate with or that provide offers that we think may be of value to you. We also provide information to third-party advertising providers for targeted advertising purposes or use advertising analytics partners to assist us in analyzing the use of our services and our user/customer base. Under certain laws, the disclosure of your personal information to these third parties may be considered a “sale” of personal information or the processing/sharing of personal information for targeted advertising purposes.

If you would like to opt out of the disclosure of your personal information for these, please visit the following link, which is also available in the footer of our Site: “Do Not Sell My Personal Information.” Because opt out requests are tied to your device ID, please note that you will need to opt out on each device you use to access the Services.

Depending on your jurisdiction, you may be permitted to designate an authorized agent to submit such requests on your behalf. Please note that we do not knowingly sell the personal information of minors under 16 years of age.

7. 7.Privacy for Children and Minors

Ocean Feather applies special protections for its younger players’ data. For applications that are directed towards children and minors, Ocean Feather does not collect your information for profiling, targeted advertising, or geolocation tracking and we use the limited information we do collect to support our internal operations.

For applications that are directed at users age 16 and up, Ocean Feather has implemented age-screens to verify the age of players. When you download our game, we collect your age as indicated by you. We provide a separate experience for younger users through which we collect limited information and serve contextual advertising only. In that gaming experience, there will be no profiling, targeted advertising, or geolocation tracking, and we use the limited information we do collect to support our internal operations. A list of third party operators on the Ocean Feather Games can be found in Appendix C.

Ocean Feather collects data on children (players under the age of 13) and minors (players under the age of 16) only when necessary:

To deliver the game and access network features.

To serve contextual advertising, as noted above.

To provide you with the products and services you request.

Ocean Feather may use this data for the following purposes because these purposes are in Ocean Feather’s legitimate business interests:

To maintain and analyze game functioning.

To detect, investigate and prevent actions to ensure legal and regulatory compliance.

To protect the security and integrity of our users and Ocean Feather Games.

We work only with selected ad networks that respect the tag-for-child-directed (TFCD) parameter—aka the ‘COPPA flag’—on a per-app or per-request basis, so that interest-based advertising is switched off, and personal data collection is restricted. In addition, these ad networks are able to categorize and tag their ad creatives by age, so that the ads are appropriate content-wise.

If Ocean Feather discovers that we have inadvertently gathered personal information from a child under 13 years of age, we will take reasonable measures to promptly delete such personal information from our records.

If you are a parent or legal guardian of a child under the age of 13 (or a minor under 16) who uses the Ocean Feather Games, please contact us at [email protected], if you have any questions or comments. If you are a parent or guardian, you may review the information we have collected from your child or ask us to make no further use of, or delete, such information. We may need to verify your identity before implementing your request.

8. 8.Data Security and Integrity

The security, integrity, and confidentiality of your information are important to us. We have implemented technical, administrative, and physical security measures that are designed to protect your information from unauthorized access, disclosure, use and modification. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable.

We will retain your information for the length of time needed to fulfill the purposes outlined in this privacy policy unless a longer retention period is required, or for the establishment, exercise, or defense of legal claims, or for legitimate business purposes, or as provided by law.

9. 9.Data Retention

The length of time for which we retain your information depends on the purposes for which we collect it and use it. We may also retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. The criteria used to determine our retention periods include:

The length of time we have an ongoing relationship with you and provide services to you (for example, for as long as you have an account with us or keep using our services) and the length of time thereafter during which we may have a legitimate need to reference your information to address issues that may arise;

Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or,

Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations)

We will delete and/or aggregate your information after the retention period ends.

10. 10.Data Transfers, Storage and Processing Globally

Pursuant to our contract with you to provide you with the Ocean Feather Games, your information will be processed on servers that may not be located where you live, including on our servers hosted in the United States. Users outside the United States should be advised that through your continued use of the Ocean Feather Games, which are governed by U.S. law, this privacy policy, and our Terms of Use, you are transferring your information to the United States and (where applicable) you consent to that transfer. No matter where our servers are located, we take appropriate measures to safeguard your rights in accordance with this privacy policy.

11. 11.Changes to this Privacy Policy

From time to time, we may change this privacy policy to accommodate new technologies, industry practices, regulatory requirements, or for other purposes. If we make any material changes to this privacy policy, we will post the updated privacy policy here and notify our users. Please check this page frequently to see any updates or changes to this privacy policy.

12. 12.Comments and Questions

If you have a comment or question about this privacy policy, please contact [email protected]. The Ocean Feather Games may contain links to other sites or apps not owned or controlled by us and we are not responsible for the privacy practices of those sites or apps. We encourage you to be aware when you leave our Ocean Feather Games and to read the privacy policies of other sites or apps that we link to, which may collect your personal information.

13. 13.Contact Us

If you have questions about this privacy policy, please contact Ocean Feather at [email protected].

14. Appendix A – California Residents

Note: If you are an individual in the state of California, the following additional information applies to you:

CONTACT

Please contact [email protected] with any questions about this Appendix.

How We Collect and Use Your Personal Information

This section provides more detail on the types of personal information we collect from users and our purposes for doing so. This chart provides the information required by the The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020” CCPA” The below table describes what we currently collect and have collected from users over the past 12 months.

Category of Information Collected (only relevant if you are located in CA)

Personal Information

Use

Categories of other parties to whom we disclose the information for business and operational purposes

Identifiers

Name, email address, unique user ID, IP address, device IDs, hardware or operating system based identifiers, identifiers we assign to your account, other similar identifiers (collected from your device), and any information that you provide in communications with our support team.

We use this information to deliver relevant third-party advertisements to users so that we can make our games available at no cost to users, provide customer service to users, improve our services, and provide troubleshooting, such as addressing and remediating technical issues and bugs.

Affiliates and subsidiaries; Vendors and service providers; Ad networks and advertising partners; Entities for legal and security purposes; Entities for sales or transfer of business or assets; Others with your consent.

Internet or other electronic network activity information

Information on your activity in our games (for example, your game progress or your interactions with in-game ads), Internet, gaming or other electronic network activity information – such as information regarding an individual’s interaction with an advertisement (collected from your device)

We use this information to save your game progress and for Ocean Feather’s internal operations and internal analytics.

Affiliates and subsidiaries; Vendors and service providers; Ad networks and advertising partners; Entities for legal and security purposes; Entities for sales or transfer of business or assets; Others with your consent.

Geolocation data

Your coarse location (for example, country, state, or city), determined based on your IP address

Advertising networks may use your device’s IP address to determine your approximate geographic location to enable them to deliver more relevant advertisements.

Affiliates and subsidiaries; Vendors and service providers; Ad networks and advertising partners; Entities for legal and security purposes; Entities for sales or transfer of business or assets; Others with your consent.

Identifiers, characteristics of protected classifications under U.S. federal and California law, and Internet or other electronic network activity information

Third-party platform account information and information made public in connection with that service (including name, unique user ID, age range, and gender)Age (as provided during the age-screen at registration)


We use this information to allow users to access Cloud Save, which permits them to log into games on multiple devices, and to communicate with users on third-party platforms, including, but not limited to, Facebook, Twitter, Discord, Instagram, and YouTube.We also use this information to determine whether to provide you with the appropriate experience based on your age.

Affiliates and subsidiaries; Vendors and service providers; Ad networks and advertising partners; Entities for legal and security purposes; Entities for sales or transfer of business or assets; Others with your consent.

Identifiers and commercial information

Zip or postal code, information regarding your virtual items or currency in Ocean Feather Games, including amount of transaction and records of purchases you have made

We use this information to collect payment on in-app purchases and maintain a record of your transaction history.

Affiliates and subsidiaries; Vendors and service providers; Ad networks and advertising partners; Entities for legal and security purposes; Entities for sales or transfer of business or assets; Others with your consent.

Identifiers and Internet or other electronic network activity information

Email address

We use this information to contact users who have subscribed to updates about Ocean Feather Games. In limited circumstances, this may include the use of pixels. We also use this information to gauge the marketability of different game concepts and game art. We do not create advertising profiles of users that are children.

Affiliates and subsidiaries; Vendors and service providers; Ad networks and advertising partners; Entities for legal and security purposes; Entities for sales or transfer of business or assets; Others with your consent.

Inferences drawn from this information to create a profile about you

Your geolocation or preferences used to personalize our Games for you

We make these inferences based on the other categories of information in this chart.

Affiliates and subsidiaries; Vendors and service providers; Ad networks and advertising partners; Entities for legal and security purposes; Entities for sales or transfer of business or assets; Others with your consent.

We may additionally use this information for the following business purposes specified in the CCPA:

Auditing related to an interaction with you and concurrent transactions;

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;

Debugging to identify and repair errors in our services;

Short-term, transient uses;

Performing our services;

Internal research for technological development and demonstration; or

Activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance our services.

What Personal Information We Share

We primarily collect, use, and share de-identified and/or aggregated consumer information, which is not considered personal information under CCPA since it does not directly or indirectly reveal your identity. However, CCPA defines “sale” very broadly. It includes the sharing of CCPA Covered Information (by a covered business) in exchange for anything of value. According to this broad definition, in the year before the date this policy was issued, for some Ocean Feather Games we collected, and may have sold, only the following categories of information for non-children and non-minor users:

Unique and online identifiers – IP address, device IDs, or other similar identifiers (collected from your device);

Internet, gaming, or other electronic network activity information – such as browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement (collected from your device); and

Location information – for example, if you access our games on your mobile device our advertisers may derive information about location from your IP address.

We may share the information with recipients such as our service providers to achieve these business purposes. This means that we may disclose the categories of personal information listed above for a business purpose.

Your Choices Regarding “Sharing” and “Selling”:

You have the right to choose to opt out of our sale/sharing of your personal information for online analysis and advertising purposes. To opt out of the offline disclosure of your information to third parties for these purposes, please email us at [email protected].

Incentive Programs (California Residents Only)

The Services may offer opportunities to receive certain services or benefits such as discounts or free or extended services (such as bonus game time or additional credits), which may require the provision of personal information. Such opportunities could be considered a financial incentive under applicable law (each, an “Incentive Program”). When you participate in an Incentive Program, you agree to the terms of that Incentive Program, and may revoke your participation depending on the Incentive Program (e.g., by opting out of emails or terminating a service). To the extent we can determine the value of your information, we consider the value to you (and costs to us) of providing you with a discount, as compared to the value to us in an opportunity to gain a loyal, or even more loyal, customer; we seek to reasonably relate the benefits to you to the costs to us.

Sensitive Personal Information

The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA) if your sensitive personal information is used for certain purposes. In the limited circumstances that we process sensitive personal information as defined in the CCPA, we do not use or disclose it other than for disclosed and permitted business purposes for which there is not a right to limit under the CCPA.

Please see the “Your Controls And Choices” section of our Policy above for information about the additional rights you have with respect to your personal information under California law and how to exercise them.

Retention of Your Personal Information. Please see the “Data Retention” section above.

How to Exercise Your Rights If you are a California resident to whom the CCPA applies, you may exercise your rights, if any, to access or delete data by contacting us at [email protected].

15. Appendix B – EEA and UK Users

Note: If you are an individual in the European Economic Area (“EEA”) or the United Kingdom (“UK”), the following additional information applies to you:

CONTACT

For the purposes of EEA and UK data protection law, Ocean Feather, Inc. is the data controller. We are a company registered at 705 Tofino Cv, Round Rock, TX 78665 USA.

PURPOSES AND LEGAL BASIS OF PROCESSING

More information about the legal basis of processing in EEA law is set out in the table below:

Type of information

Purpose of processing

Legal basis for processing

Information you provide

Log-in details

To process, maintain and service your accounts.To communicate with you.

Contract

In-app purchase information

To fulfill orders.

Contract

Marketing information

To serve you with, or send you, marketing.

Consent

Other information

To communicate with you.

Legitimate Interests (to offer a successful product)

Information we receive from other sources

From other people

To fulfill orders.

Contract

From other sites

To provide you with a personalized online experience.

Legitimate Interests (to offer a successful product)

Information we collect automatically

Technical information

To improve and optimize our Games.

Legitimate Interests (to improve our Games)

We will use any of the above information to detect, investigate and prevent fraud, misuse of our services, and other illegal activities, and protect our and others’ rights and properties as well as to respond to court orders, lawsuits, subpoenas, and government requests.

RIGHTS

Users in the EEA and UK have rights in relation to their personal information. Some of these only apply in certain circumstances. We have described these situations below, as well as how you can exercise your rights. To exercise any of your rights, please email [email protected].

Access: to enquire about and access personal data held by Ocean Feather and details about how we use it and who we share it with;

Portability: in certain circumstances, you have the right to receive or ask us to provide your personal data to a third party in a structured, commonly used and machine-readable format;

Correction: to correct any personal data held about you that is inaccurate and have incomplete data completed;

Erasure: that we erase your personal data in certain circumstances;

Restriction of Processing to Storage Only: to require us to stop processing the personal data we hold about you other than for storage purposes in certain circumstances.

Objection: in certain circumstances, the right to restrict or object to our processing of your personal data. You also have the right to object to marketing based on profiling;

Withdrawing Consent: You can withdraw your consent at any time by entering your email address in this opt-out link; and

Complaints: if you wish to make a complaint about how we process your information, please email [email protected] and we will deal with your request as soon as possible. This is without prejudice to your right to launch a claim with your local data protection authority.

Announcements

We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend Game access for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these non-promotional, service-related announcements.

16. Appendix C – Third Party Operators on the Ocean Feather Games

Our Ocean Feather Games gather analytics information that provides insights from data to help us optimize our Games. Our Games may also serve contextual and personalized advertisements, depending on your age group and privacy preferences. As set out in the Children’s Privacy section of this policy, we provide a separate experience for younger users, including by limiting advertising to contextual ads. The chart below contains a list of common third-party service providers that may be present across our apps. It also provides links to their privacy policy and other privacy-related information, as well as opt-out options from personalized advertising when available.

Service provider name

Privacy-related disclosures

AdMob (Google)

https://support.google.com/admob/answer/6128543?hl=en#

AppLovin

https://www.applovin.com/privacy/

Google Privacy Policy

https://policies.google.com/privacy?hl=en

Adjust

https://www.adjust.com/terms/privacy-policy/

Facebook Audience Network and Facebook Analysis

https://www.facebook.com/about/privacy

Firebase (Google)

https://policies.google.com/privacy

Agora Privacy Policy

https://www.agora.io/en/privacy-policy/