PRIVACY POLICY
CHILDREN’S DATA AND GENERAL DATA PROTECTION
SWELL GAMES, TOO
SWELL GAMES, TOO ("Company", "we", "us") is committed to protecting the privacy of all users, including children, and ensuring compliance with applicable data protection laws such as COPPA, CCPA, and GDPR. This Privacy Policy explains how we collect, use, store, share, and protect Personal Data, including that of children under the age of 13 (or 16 in some jurisdictions).
1. Who Collects and Processes Your Personal Data?
SWELL GAMES, TOO is the data controller responsible for the processing of your Personal Data within our Apps and Games. In some cases, data may also be processed by our authorized service providers acting as data processors under contractual obligations.
2. How Do We Collect Your Personal Data?
We collect Personal Data in the following ways:
• Automatically through our Apps (device ID, operating system, usage data, IP address)
• When a user provides it voluntarily (for example, email for support requests or password recovery)
• From third-party platforms or SDKs integrated into our Apps (for example, analytics services)
We do not request or require users to provide more data than is necessary for the intended functionality of our services.
3. How Do We Handle Children’s Personal Data?
We comply with COPPA and GDPR-K requirements when collecting data from children. Specifically:
• We collect only minimal data necessary to operate and maintain our services (such as age information and basic device data)
• We do not collect children’s names, exact locations, or contact details without verified parental consent
• We do not use children’s Personal Data for behavioral advertising
• Parents or legal guardians have the right to access, review, delete, or refuse further collection of their child’s Personal Data
Requests regarding children’s data should be sent to: support@swell.kz
4. Which Personal Data Do We Process and How?
We may process the following categories of Personal Data:
• Device Data: device type, operating system, IP address, language, screen resolution
• Usage Data: gameplay behavior, session activity, crash reports
• Age Information: used solely to determine whether a user is a child
• Optional Contact Information: email address or phone number (only with verified consent)
This data is used exclusively to:
• Operate, secure, and improve our Apps and Games
• Provide customer support
• Monitor usage and fix technical issues
• Ensure compliance with applicable legal obligations
We do not engage in profiling or automated decision-making that affects user rights.
5. Data Retention Period
We retain Personal Data only for as long as it is necessary to:
• Fulfill the purposes for which the data was collected
• Comply with legal and regulatory requirements
• Resolve disputes and enforce our agreements
When Personal Data is no longer required, it is securely deleted or anonymized.
6. Automated Decision-Making or Profiling
We do not use automated decision-making or profiling that produces legal or similarly significant effects on users, including children.
7. Third Parties Who May Access Your Personal Data
We work with trusted third-party service providers strictly for the following purposes:
• Application analytics (for example, Unity Analytics, Firebase)
• Error tracking and performance monitoring (for example, GameAnalytics)
• Hosting and backend infrastructure
All such providers are contractually obligated to process Personal Data securely, only on our behalf, and in compliance with applicable data protection and child protection laws.
We do not share children’s Personal Data with advertisers and do not use it for profiling or monetization purposes.
8. Your Rights as a Data Subject
Under GDPR, COPPA, and other applicable laws, you have the following rights:
• Right of access — to know what Personal Data we process
• Right to rectification — to request correction of inaccurate or incomplete data
• Right to erasure — to request deletion of your or your child’s Personal Data
• Right to restriction — to limit how Personal Data is processed
• Right to object — to object to specific processing activities
• Right to withdraw consent at any time
To exercise these rights, please contact us at: support@swell.kz
9. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. Any updated version will be published within our Apps and/or on our official website. Continued use of our services after changes take effect constitutes acceptance of the revised Privacy Policy.
1. Who Collects and Processes Your Personal Data?
SWELL GAMES, TOO is the data controller responsible for the processing of your Personal Data within our Apps and Games. In some cases, data may also be processed by our authorized service providers acting as data processors under contractual obligations.
2. How Do We Collect Your Personal Data?
We collect Personal Data in the following ways:
• Automatically through our Apps (device ID, operating system, usage data, IP address)
• When a user provides it voluntarily (for example, email for support requests or password recovery)
• From third-party platforms or SDKs integrated into our Apps (for example, analytics services)
We do not request or require users to provide more data than is necessary for the intended functionality of our services.
3. How Do We Handle Children’s Personal Data?
We comply with COPPA and GDPR-K requirements when collecting data from children. Specifically:
• We collect only minimal data necessary to operate and maintain our services (such as age information and basic device data)
• We do not collect children’s names, exact locations, or contact details without verified parental consent
• We do not use children’s Personal Data for behavioral advertising
• Parents or legal guardians have the right to access, review, delete, or refuse further collection of their child’s Personal Data
Requests regarding children’s data should be sent to: support@swell.kz
4. Which Personal Data Do We Process and How?
We may process the following categories of Personal Data:
• Device Data: device type, operating system, IP address, language, screen resolution
• Usage Data: gameplay behavior, session activity, crash reports
• Age Information: used solely to determine whether a user is a child
• Optional Contact Information: email address or phone number (only with verified consent)
This data is used exclusively to:
• Operate, secure, and improve our Apps and Games
• Provide customer support
• Monitor usage and fix technical issues
• Ensure compliance with applicable legal obligations
We do not engage in profiling or automated decision-making that affects user rights.
5. Data Retention Period
We retain Personal Data only for as long as it is necessary to:
• Fulfill the purposes for which the data was collected
• Comply with legal and regulatory requirements
• Resolve disputes and enforce our agreements
When Personal Data is no longer required, it is securely deleted or anonymized.
6. Automated Decision-Making or Profiling
We do not use automated decision-making or profiling that produces legal or similarly significant effects on users, including children.
7. Third Parties Who May Access Your Personal Data
We work with trusted third-party service providers strictly for the following purposes:
• Application analytics (for example, Unity Analytics, Firebase)
• Error tracking and performance monitoring (for example, GameAnalytics)
• Hosting and backend infrastructure
All such providers are contractually obligated to process Personal Data securely, only on our behalf, and in compliance with applicable data protection and child protection laws.
We do not share children’s Personal Data with advertisers and do not use it for profiling or monetization purposes.
8. Your Rights as a Data Subject
Under GDPR, COPPA, and other applicable laws, you have the following rights:
• Right of access — to know what Personal Data we process
• Right to rectification — to request correction of inaccurate or incomplete data
• Right to erasure — to request deletion of your or your child’s Personal Data
• Right to restriction — to limit how Personal Data is processed
• Right to object — to object to specific processing activities
• Right to withdraw consent at any time
To exercise these rights, please contact us at: support@swell.kz
9. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. Any updated version will be published within our Apps and/or on our official website. Continued use of our services after changes take effect constitutes acceptance of the revised Privacy Policy.
