Privacy Policy

Effective date:    01.08.2025

1. INTRODUCTION

This privacy policy of AceGame AS, a Norwegian company registered with the Register of Business Enterprises from Norway under organization number 934 783 565 (subsequently referred to as “AceGame”, “we,” “our,” or “us”) is based on data protection laws of Norway, European General Data Protection Regulation 2016/679 (GDPR), United Kingdom Data Privacy Act 2018 (UK DPA) California Consumers Privacy Act (CCPA) and Brazil’s Lei Geral de Proteção de Dados (LGPD). This privacy policy discloses what we collect and how we process your Personal Data when you are using our App. 

This privacy policy regulates privacy matters and Personal Data processing when it comes to: 

  1. using  https://acegame.app website and any sub-domain of the website (“Website”); 

  2. using AceGame app on iOS (Apple Inc) or Android (Google LLC) or any other mobile device platform where the App will be available in the future (“App”);

  3. processing data of our customers, partners, users, service providers or anyone else with whom we are doing business. 


2. DEFINITIONS

The terms listed below have the following meanings:

  1. Personal Data means information that relates to identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, etc.;

  2. Processing means any operation or set of operations which is performed on Personal Data, such as collection, recording, organization, structuring, storage, adaptation or destruction; 

  3. Data Subject (or you) is an identified or identifiable natural person who can be identified, directly or indirectly, based on particular Personal Data.

3. PERSONAL DATA PROCESSING

When you register to or use our App or when you visit our Website, AceGame will be the data controller and, where applicable, the data processor of your Personal Data. Personal Data may include the following types:

  • User Registration, Authentication and Account use (Identity Data and Contact Data): name; surname; email address (including for logins via accepted third-parties accounts, such as, but not limited to, social media accounts); phone number; username; birth date; age; gender; bio (optional); profile picture/avatar (optional); password (minimum 8 characters); invitation code (for invited users).

  • Technical and System-generated Data: log files; third party account identifier; user ID; password; IP address; browser version; pages you visited on our Website; cookie identifiers; device screen resolution; device type; device identifiers; device operating system; preferred language of display; login timestamps; date and time when pages or content were visited.

  • Communication Data: content; communications and other information you provide when you use the App or Website (including chats within the App); information that other visitors provide about you (including when you create or share messages or communicate with others); content; messages and emails you send us (including information about you); reviews and ratings; messages; files; images/photos; App notifications; App ads (analytics, interactions, measures).

  • Sports Preferences and Fitness Data: fitness experience and training level; sports interests; training and fitness goals; training preferences. 

  • Social Features and Content Sharing: user posts (text, images/photos, videos and audio files); comments; comments on other users’ posts; follower and following information; posts likes; calendar events; subscriptions to premium content.

  • Payment and Subscription Management: payment method details (e.g., card number, expiration date, cardholder name, card CVV, unique customer identifier, order ID, bank account details, PayPal account details; date/time/amount of transaction, location, zip code, recipient name/ID and location); subscription details (e.g., recurring payment, subscription type); payment history; withdrawal history.


We use different methods to collect data from and about you including through:

  • Direct interactions. You may provide us your Identity, Contact, Communication, Sensory information, Technical or Payment data by filling in forms on our Website or App, by corresponding through the Website or App features or in course of communication with us through email or by other means. 

  • Automated technologies or interactions. As you interact with our Website or App, we will automatically collect technical and system generated data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, website analytics tools and other similar technologies. Please see our Cookies Policy for further details. 

When you are visiting our Website or App, your Personal Data will be used in order to provide our services or respond to your request. If you decide to contact us by email or by phone, we will process your Personal Data in order to respond to your request. 

We act as a data controller with regards to Personal Data when (i) you are visiting our Website or App, (ii) you are registering an account with our App and use our App, (iii) when you are communicating with us through our Website or App chat, through our email or other contact means, or (iv) when we contact you based on our legitimate interest. 

We act as a data processor with regards to Personal Data when (i) we are processing your payment details related to your subscriptions you purchase within the App, and (ii) we are processing your payment details related to your any other purchases or payouts within the App. Please note that in these cases, the data controller (payment processor) has its own privacy policy which we recommend you to check. We are not responsible for the payment processor’s privacy policies and practices, as well as its compliance with applicable data protection laws.

We do not collect any other special categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, health, sex life, sexual orientation, political opinions, trade union membership, information about your biometric data). Nor do we collect any information about criminal convictions and offenses. We may use training level, fitness experience, and sports preferences — but not for medical/health evaluations. The recommended training is not based on actual/inferred physical condition of the users, we don’t use biometric, medical, or smart device data for tailoring the user’s recommended training and we do not take responsibility for using the App for the users with a medical history (e.g. injuries, chronic or acute diseases, etc).  We do not process Personal Data concerning health that reveals information about a user’s physical or mental health, and Personal Data is not used for the purpose of health care or health profiling. 

When Processing Personal Data, taking into account the nature, scope, context and purposes of the processing, is likely to result in a high risk to the rights and freedoms of the Data Subjects, we shall, prior to the Processing, carry out Data Protection Impact Assessments to determine the impact of the Processing operations on the protection of Personal Data.


4. USE OF PERSONAL DATA

We process your Personal Data for the following purposes: 

  • To provide our App and Website services, including to provide (i) personalized user experience to the users of our App and Website; (ii) personalized training recommendations to the users of our App; (iii) subscription billing and payments and managing paid content access for the users of our App; (iv) notifications and newsletters about account activity, new features, and security alerts for the users of our App; (v) an option to join the waiting list for our App release.   

  • To ensure the security, functioning, developing, monitoring and analytics of our App and Website. We process identity data, contact data, communication data and technical data in the context of our legitimate interest - to ensure safety and security, to investigate possible fraud or other violations. For example, we may use your log files for technical analysis as well as for statistical evaluation. We process Personal Data, including public feedback, to conduct research and for the further development of our App in the context of our legitimate interest.

  • To respond to your question and inquiries regarding our services. We process identity data, communication data, sensory information and contact data for this purpose.

  • To communicate with the general public, certain individuals or target groups (customers, service providers). For this purpose, we process technical data, contact data, communication data and identity data for this purpose.

  • Where it is necessary for our legitimate interests (or those of a third party) unless fundamental rights of users or other Data Subject(s) override those interests.

  • For legal purposes. We may use any type of Personal Data when Processing is required by the applicable law.


Lawful basis

We process your Personal Data under the following legal bases:

  • On the basis of performance of a contract - Art. 6 (1) (b) GDPR; Art 7 (V) LGPD - in order to provide you with the possibility of (i) account creation on our App; (ii) account management of our App; (iii) subscription management of our App, including subscription billing and payments and managing paid content access of our App; (iv) personalized training and fitness recommendations for you; (v) account password recovery and reset options; (vi) offering support and responding to your question and inquiries regarding our services.

  • On the basis of consent - Art. 6 (1) (a) GDPR; Art 7 (I) LGPD - to (i) personalize your user experience or display user profile information to other users; (ii) to provide social interaction between users and content sharing and engagement; (iii) provide you with our newsletters about our App’s new features and promotions or marketing materials related to our App and other services we provide, in compliance with the GDPR and the Norwegian Marketing Act; (iv) provide you with the option to join the waiting list for our App release. Please note that you may revoke your given consent at any time, for further details please check “Your Rights” section below.

  • On the basis of our legitimate interest - Art. 6 (1) (f) GDPR; Art 7 (IX) LGPD - when Processing is necessary for ensuring the security, functioning, monitoring, development and analytics of our App and Website.

  • On the basis of compliance with a legal obligation - Art. 6 (1) (c) GDPR; Art 7 (II) LGPD - when Processing is necessary for compliance with a legal obligation to which we or our service providers are subjects.



5. PROTECTION OF PERSONAL DATA

We process Personal Data in a way that assures an appropriate level of security, including protection against unauthorized Processing, destruction, accidental loss, or damage, while applying suitable organizational and technical measures under industry standards. We regularly test, assess and evaluate the effectiveness of our technical and organisational measures for ensuring the security of the Processing. 

Our physical security complies with industry standards. All data is encrypted in transit to align with best practices with Secure Socket Layer technology. Our App is using industry-standard data transport protocols. We never store Personal Data on devices like USB or CD. All data is stored in secured databases and processed in servers secured behind controlled access.

All our personnel and contractors are subject to confidentiality agreements. Only authorized personnel have granted minimum access on a need-to-have basis to Personal Data. 



6. SHARING OF PERSONAL DATA

Once you are creating an account and start interacting with our App’s services, some part of your Personal Data may become visible to other users of our App. When you decide to share any message, content or link publicly, it can be viewed by other users of our App (others will be able to find and see your publicly shared content, including your name and photo if you have provided one).

We will share your Personal Data with our service providers in order to provide and facilitate our App. To ensure compliance with data protection applicable legislation, we maintain active Data Processing Agreements with our service providers with Standard Contractual Clauses or ensure that any sharing is pursuant to another valid mechanism under the GDPR (such as, but not limited to, the EU-US Data Privacy Framework).

We retain the right to share your Personal Data as part of change in control, merge or sale, or in preparation for any of these events. Any third party which further buys us, or part of our business, will be entitled to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

Service providers 

Our service providers acting as processors based in the EEA or USA who provide us with IT and system administration services:

  • PayPal (Europe) S.à r.l. et Cie, S.C.A.

    • 22‑24 Boulevard Royal, L‑2449 Luxembourg, Luxembourg

    • Global online payments processor, facilitating electronic payments between users and businesses, supports money transfers, merchant services, P2P payments, and digital wallet functionality across a broad range of countries and currencies.

  • OpenAI Ireland Ltd

    • 1st Floor, The Liffey Trust Centre, 117‑126 Sheriff Street Upper, Dublin 1, D01 YC43, Ireland.

    • Provides AI models and APIs (such as ChatGPT and GPT‑5) for language generation, natural language understanding, and other AI-powered tasks.

  • Google Calendar API (part of Google Ireland Limited)

    • Gordon House, Barrow Street, Dublin 4, D04 E5W5, Ireland

    • API enabling apps to read, create, modify, and manage Google Calendar events and schedules programmatically.

  • Firebase (a Google product, under Google LLC)

    • Mountain View (Google Building 40, 1600 Amphitheatre Parkway), United States

    • A suite of cloud-based tools—real-time databases, authentication, notifications, hosting—for mobile and web app development.

  • Cloud Firestore (part of Google Cloud / Firebase)

    • Mountain View (Google Building 40, 1600 Amphitheatre Parkway), United States

    • A fully managed, scalable NoSQL document database with real-time syncing and high performance, for app data storage

  • SendGrid, Inc.

    • 1801 California Street, Suite 500, Denver, Colorado, United States

    • Cloud-based platform for sending transactional and marketing emails via APIs, SMTP, with analytics, deliverability tracking, and campaign tools.

  • RevenueCat, Inc.

    • 1032 E Brandon Blvd #3003, Brandon, Florida, United States

    • Subscription and in-app purchases management platform for mobile and digital apps - handling billing, receipt validation, analytics, and integrations with app stores.

  • Functional Software, Inc. (doing business as Sentry)

    • 45 Fremont Street, 8th Floor, San Francisco, CA 94105‑2250, United States

    • Provides developers with error tracking and performance monitoring tools that help diagnose, fix, and optimize application code across numerous languages and platforms.

  • PostHog, Inc.

    • While the core entity is U.S.-based, for customers requiring GDPR compliance PostHog provides PostHog Cloud EU, a managed hosting option where all data is hosted on infrastructure located in the EU—specifically AWS’s Frankfurt (eu-central-1) region. In this configuration, no data is transferred to the U.S.

    • Offers a product analytics and product development platform designed for developers and product teams.

Services providers that operate in EU/EEA are subject to the EU Data Act, thus ensuring we have all the required rights related to data portability.

7. TRANSFER OF PERSONAL DATA 

We are not and we will never sell your Personal Data to third parties.

The Personal Data you provide us with may be transferred to and processed on our servers, or servers of third-party providers. If such third party providers are located outside EEA, we ensure appropriate safeguards for such transfers, including entering into Data Privacy Agreements with Standard Contractual Clauses or ensure that the transfer is pursuant to another valid mechanism under the GDPR (such as, but not limited to, the EU-US Data Privacy Framework).

As far as the transmitting of Personal Data to a third party is not explicitly permitted by law, you consent that we may, if necessary, transmit Personal Data to law enforcement offices when relevant to defending against a governmental and public safety threat or the prosecution of a criminal act. Furthermore, you consent that we may, if necessary and related to legitimate law enforcement or criminal prosecution interests, transmit Personal Data to a third party. Transmission of data is not necessary and will not occur if a preliminary legal or law enforcement proceeding can be initialized or has already been initialized.

You retain, at all times, the possibility to object to the replacement of data controllers, data processors, subcontractors or sub-processors handling Personal Data to such changes or to terminate the contract with us.

8. RETENTION OF PERSONAL DATA 

We retain Personal Data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, including satisfying legal, contractual, and operational obligations. Retention periods vary based on the category of data and its use.

When you are creating your account with our App, we will store your Personal Data as long as your account will be active, or, if the case may be, further more for the reasons described in this policy. 

When you do not have an account with our App, we will store your Personal Data for the legal term required for applicable legislation compliance.

Identity and contact data Processed for the purpose of account management will be stored until account deletion occurs and might be stored for a period of 6 months after depending on the applicable legislation.

Certain Personal Data, such as payment records and invoices, are retained for a minimum of 5–7 years to comply with Norwegian accounting and tax regulations under the Norwegian Bookkeeping Act - Section 13.

Fitness and preference data Processed for the purpose of personalization will be stored until account deletion or consent revocation.

Technical and log data Processed for the purpose of analytics and security will be stored for 12 months from collection, for diagnostics and fraud detection.

Communication data Processed for the purpose of user support logs will be stored for 24 months from last interaction or until the statutory date for potential litigation is fulfilled according to the applicable legislation.

When you are making an inquiry with our App, or we process your Personal Data on the basis of our legitimate interest, we will process your Personal Data as long as it is required for the purpose of our legitimate interest, but not more than five years from such inquiry or occurrence of our legitimate interest. 

We may also retain and use Personal Data as necessary to comply with legal obligations (e.g., tax laws, anti-fraud, accounting), resolve disputes, and enforce agreements. 


9. YOUR RIGHTS 

According to the GDPR and the UK GDPR (as incorporated into UK law via the DPA 2018 and the European Union (Withdrawal) Act 2018), you have the following rights:

  • Right to rectification. You have the right to request to rectify, without undue delay, any incomplete, inaccurate or incorrect data pertaining to you.

  • Right to limitation of Processing. You can limit the use of Personal Data processed.

  • Right of opposition. You have the right to object, for reasons related to its particular situation, to the Processing based on our legitimate interest of your Personal Data, including regarding the creation of profiles. We will no longer process Personal Data, unless we demonstrate that we have legitimate and compelling reasons justifying the Processing and prevailing over the interests, rights and freedoms of the Data Subject or that the purpose is to establish, exercise or defend a right in court. When the Processing of Personal Data is for direct marketing purposes, you have the right to oppose the Processing of Personal Data for this purpose, including about the creation of profiles, insofar as it is related to that direct marketing. In this case, Personal Data is no longer processed for this purpose.

  • Right of access. You may request a copy of Personal Data collected during use of our Website or App. This data includes Personal Data processed, purposes of Processing, categories of Personal Data concerned, recipients of personal data, origin of the data (unless collected directly from you), the envisaged period for which Personal Data will be stored, the existence of other rights.

  • Objecting to or restricting the use of Personal Data. You can ask to stop using all or some portion of Personal Data or limit use thereof by requesting its erasure as described above or sending us a request.

  • Right to lodge a complaint with supervisory authority. You have the right to lodge a complaint with a competent data protection supervisory authority. Please note that we are regulated by the Norwegian Data Protection Authority: Datatilsynet, P.O. Box 458 Sentrum, NO-0105 Oslo, Norway. You can also contact them for advice and support at https://www.datatilsynet.no/en/about-us/contact-us/

  • Right to data portability. You can receive Personal Data we collected about you in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller. 

  • Right to be forgotten. You can request deletion of your Personal Data when following grounds applies: (i) the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw your consent and where there is no other legal ground for Processing; (iii) and there are no overriding legitimate grounds for Processing, or you object to Processing pursuant to Article 21(2) GDPR. You can remove your Personal Data by accessing your account settings and deleting your account. To delete your account, you need to follow these steps: Log in to your AceGame account via the App - Go to Profile - Click on Settings - Go to Manage Account - Click on Delete Account. You can also request removal of your Personal Data by sending us a request in this regard to the email address mentioned in the Contact section below. Please note that deleting your account means that you will permanently lose access to all of your data within your account as they will be permanently removed (including your posts, comments, chats, training programs, calendar events, etc). Please note that you can request the deletion of your Personal Data using the same procedure as stated above even if your request is not subject to GDPR and UK DPA 2018. Please be aware that, where imposed and/or permitted by the applicable law, we may not delete your Personal Data insofar as the Processing is necessary for: (i) for the exercise of the right to free expression and information; (ii) for compliance with a legal obligation which stipulates the Processing obligation under European Union law or domestic law applicable to us; (iii) for the establishment, exercise or defense of a right in court.

  • Right not to be subject to a decision based solely on automated Processing, including profiling. You also have the right to human intervention, to contest the decision, and to express your point of view every time you consider you were subject to a decision based solely on AI.

Exercise of rights granted according to the GDPR or the UK DPA 2018

To exercise any of the aforesaid rights you may contact us by email at the address mentioned in the Contact section below. Upon request, we will review it and will provide a response if we are a data controller, or, if we are the data processor, we will forward your request to the data controller. We may charge a reasonable fee if the request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

If we are data controllers, we shall review and pronounce on the request within 1 month as of its filing. This period may be extended by further two months, if necessary, for example, if your request is particularly complex or you have made several requests. We shall inform you as to any such extension within 1 month as of receipt of the request, stating the reasons for the delay. When you file a request by electronic means, the information is provided electronically, if possible, unless you have requested otherwise. Should your request be unclear we reserve our right to send you our additional questions.

Upon the filing of a request by an authorized person, the notarized power of attorney must be attached to the request. In case of death of the natural person, his / her rights are exercised by his / her heirs and the certificate of heirs shall be attached to the request. The heritage should be confirmed by a respective certificate, issued in the dead person’s jurisdiction.

Where data does not exist or their provision is forbidden by law, access of the requesting party to such data is refused.

Information for California and Nevada Residents


Under California Consumers Privacy Act (CCPA) and Nevada Privacy Law we have to inform consumers based in California and Nevada about our use, disclosure, Processing and collection of personal information. This section explains your rights as of California/Nevada consumer or resident pursuant to this act. Categories of Personal Data that we collect are described in the “Data Processing” section of this Privacy Policy. The purposes of Processing of Personal Data are described in the “Use of Personal Data” section of this Privacy Policy. 


We will never collect, sell, and/or disclose Personal Data to third parties or service providers for a business purpose.


CCPA prohibits any kind of discrimination acts against California consumers for executing their rights granted pursuant to CCPA and imposes requirements and restrictions on any kinds of financial incentives related to collection, Processing and use of California consumers Personal Data. We will not discriminate against you and will provide, and will not deny, a different level of quality of services and/or goods. Also, we will not charge or suggest that we will charge different prices or rates or impose penalties. However, we reserve the right to do so, when it is reasonably related to the value provided to the consumer by the consumer’s data. 


We honor rights granted to consumers pursuant to CCPA and Nevada Privacy Law, so we will accept verifiable requests of copy, deletion and right to know. California and Nevada consumers can execute your right twice per 12 months period. 


  • Deletion request. Right to request deletion of Personal Data we collected about you.

  • Copy request. Right to request a copy of Personal Data we collected about you.

  • Right to know. Description of Personal Data we collected about you within the last 12 months period as per the CCPA.


You can execute your rights by sending us an email at the address mentioned in the Contact section below. When you file a request by electronic means, the information is provided electronically, if possible, unless you have requested otherwise.


For California based consumers: we will provide you with a response within 45 days from the moment we received your request and verify your identity. 

For Nevada based consumers: we will provide you with a response within 90 days from the moment we received your request and verify your identity. 


Please take into account that we will satisfy your request only when we have verified your identity to a reasonable degree of certainty. You are entitled to authorize your agent to execute your rights. However, please note that we will verify your agent’s authorisation.


Information for Brazilian residents


Brazil’s Lei Geral de Proteção de Dados, the Brazilian General Data Protection Law, Federal Law no. 13,709/2018 (“LGPD”) became effective on August 16, 2020. The LGPD is a legal policy in Brazil, both online and offline, in the private and public sectors. As supervisory authority, the National Data Protection Authority (ANPD) has been created and charged with overseeing and enforcing the LGPD. LGPD requires that Brazilian Personal Data processed by an organization is appropriately and sufficiently managed and protected. 


We honor Brazilian residents’ rights and allow to execute the following rights granted by the article Art 18 of the LGPD: 

  • The right to confirmation of the existence of the Processing;

  • The right to access the data;

  • The right to correct incomplete, inaccurate or out-of-date data;

  • The right to anonymize, block, or delete unnecessary or excessive data or data that is not being processed in compliance with the LGPD;

  • The right to the portability of data to another service or product provider, by means of an express request

  • The right to delete Personal Data processed with the consent of the Data Subject;

  • The right to information about public and private entities with which the controller has shared data;

  • The right to information about the possibility of denying consent and the consequences of such denial; and

  • The right to revoke consent.


You can execute your rights by sending us an email at the address mentioned in the Contact section below. When you file a request by electronic means, the information is provided electronically, if possible, unless you have requested otherwise.

We will provide you with a response within:

  • Response to the right of access request will be provided within 15 days from the moment we received your request and verify your identity.

  • Other requests will be executed within reasonable time, but not more than 30 days from the moment we received your request and verified your identity. 

Please take into account that we will satisfy your request only when we have verified your identity to a reasonable degree of certainty. You are entitled to authorize your agent to execute your rights. However, please note that we will verify your agent’s authorisation.


10. USE OF ARTIFICIAL INTELLIGENCE

Our App uses artificial intelligence (AI) technologies to enhance user experience and provide personalized training and fitness insights. These AI systems analyze user-generated data (such as activity logs, training goals, and habits) to recommend workouts, track progress, and offer tailored suggestions. All AI-generated recommendations are assistive — not binding — and users always have control over their recommended plans and they can adjust or override recommendations at any time. Our App does not claim to diagnose, treat, or predict diseases. We ensure that the use of AI complies with the EU Artificial Intelligence Act and applicable data protection laws, including the GDPR.

Our AI system falls under the limited-risk or minimal-risk category, as defined by the EU AI Act, providing fitness and training recommendations without impacting safety or fundamental rights. 

Some features of our App may involve automated decision-making, such as determining fitness levels or generating recommendations based on your input and behavior. These decisions are made using AI models trained on anonymized data and are regularly reviewed for fairness, accuracy, and non-discrimination. You have the right to: (i) Obtain meaningful information about the logic involved; (ii) Understand the significance and potential consequences of such processing; (iii) Request human intervention; (iv) Express your point of view; and (v) Contest the decision. To exercise these rights, you may contact us by email at the address mentioned in the Contact section below. 

We continuously monitor the regulatory landscape surrounding AI technologies, including the EU AI Act. We will update our AI practices and this Privacy Policy to remain fully compliant with future obligations and to promote transparency and trust in our AI systems.


11. AGE LIMITATION

Our Website and App are generally not intended for users who are under 16 years old, except where applicable laws allow for a lower age of digital consent. We do not knowingly process any Personal Data from persons under 16 years of age, and any such data shall be immediately deleted upon detection, unless (i) Processing of Personal Data of persons under 16 years of age is explicitly allowed by the national Personal Data protection law applicable to such person’s Personal Data, or (ii) person under 16 years of age consented to Processing of its Personal Data or, where lawfully required, the consent was given by the tutor of the person under 16 years of age. If you are a parent or legal guardian and believe that your child has provided us with personal data without your consent, please contact us using the email address mentioned in the Contact section below. We will take steps to investigate and address the issue in accordance with applicable laws.

  • European Union (EU)

In accordance with the GDPR, we do not knowingly collect or process personal data from individuals under the age of 16, unless a Member State has set a lower age limit. (minimum age in some Member States may be as low as 13, provided that verifiable parental consent is obtained where required by law). Users under the age threshold must not use our services without the appropriate parental or guardian consent.

  • United Kingdom (UK)

Under the UK GDPR, the age of digital consent is 13. We do not knowingly collect personal data from individuals under this age without verifiable parental or guardian consent. If we become aware that we have collected personal data from a child under 13 without proper consent, we will delete that data promptly.

  • United States (USA)

In compliance with the Children’s Online Privacy Protection Act (COPPA), we do not knowingly collect or solicit personal data from children under the age of 13 without verifiable parental consent. If we discover that we have collected personal data from a child under 13 without such consent, we will promptly delete the data from our systems.


12. SPECIAL PROVISIONS

Third-parties content and links

Our App may contain embedded videos or links to other websites, services, and web addresses. This privacy policy applies only to our App, nor to embedded videos nor to those external websites, services and web addresses that we link to. Those websites, services, video hosting services and web addresses have their own privacy policies which we recommend you to check. We are not responsible for these external websites and services and their privacy policies and practices, as well as their compliance with applicable data protection laws. In addition, if you link to our App from an external site, we cannot be responsible for the privacy policies and practices of the owners and operators of that external website and recommend that you check the privacy policy of that external website.

Login through third-parties.

Facebook. The users who have a Facebook account can login or create an account with our App through their Facebook account, published by Meta Platforms Inc. (with register address at 1 Meta Way, Menlo Park, CA 94025, USA). 

Google. The users who have a Google account can login or create an account with our App through their Google account, published by Google Ireland Limited (with registered address at Gordon House, Barrow Street, Dublin 4, Dublin, D04 E5W5, Ireland).

Apple. The users who have an Apple account can login or create an account with our App through their Apple account, provided by Apple Inc. (with registered address at One Apple Park Way, Cupertino, CA 95014, USA).

Google Calendar integration

Our App allows you to add information to your Google calendar about your activity within the App. 


13. PRIVACY POLICY CHANGES

Please note that we may update this Privacy Policy from time to time, and, when significant changes are made in the future, we shall inform you about any such updates. If we make material changes to this Privacy Policy, we will notify you via email (if provided) and directly on our Website and App. Notification will occur in a reasonable amount of time before changes take effect.

A “material change” includes any update that involves: (i) a new category of data collected or new purpose for processing; (ii) a change in your rights or how you can exercise them; (iii) a new international data transfer arrangement; (iv) a new legal basis for processing (e.g. switching from consent to legitimate interest). Minor changes (e.g., clarifications, language improvements, or formatting edits) will not trigger user notification.

The use of data we collect, process, and save is subject to the version of this policy that is in effect at the time when the users provide such data. The date of the latest update will always be displayed at the top of this policy. By continuing to use the App and/or Website after any revised Privacy Policy becomes effective, you consent to be bound by the new Privacy Policy.


14. CONTACT

If you have any questions or requests regarding this policy, please send your request to privacy@acegame.app