Privacy Policy

Last Updated: November 8, 2025
Welcome to Hungry Studio!

Hungry Studio ("Hungry Studio","we","us" or "our") is dedicated to protecting your privacy. This Privacy Policy ("Policy") explains how we collect, use, and share your personal data(also known as personal information in certain jurisdictions) when you use our mobile game applications, websites, and other online products and services (collectively, the "Services"), or when you otherwise interact with us.The Services are operated by ARETIS LIMITED ("the Data Controller"), which is responsible for determining the means and purposes of processing your personal data.

Please review this Policy before using our Services. By using our Services, you acknowledge that you have read, understood and agreed to this Policy.
You can manage your privacy preferences at any time through the in-game settings interface.If you have any questions, please contact us using the details provided in Section 9 Contact Us.

This Policy will help you understand the following content:

  1. What Personal Data We Collect
  2. How We Use Your Personal Data
  3. How We Share Your Personal Data
  4. International Transfer of Data
  5. Data Security and Data Retention
  6. Your Legal Rights
  7. Children's Privacy
  8. Changes to this Policy
  9. Contact Us
  10. Jurisdiction Specific

1. What Personal Data We Collect

We will collect the Personal Data such as the following in lawful and fair manner: (a) personal data you provide directly to us; (b) personal data collected automatically when you use our Services; and (c) personal data we receive from third parties. We will only collect personal data that is adequate, relevant, and limited to what is necessary for the purposes for which it is processed.

1.1 Personal Data You Provide to Us

  • Customer Service Data: We collect data that you provide directly to us when you contact customer support, give feedback, participate in surveys or activities, or subscribe to our communications. This information may include your name, email address, delivery address, and any other details you provide. The specific data collected varies based on the service you are using.

1.2 Personal Data We Collect Automatically

When you use our Services, we automatically collect certain data, which includes:
  • Identifiers Data: a unique, randomly generated user ID, device ID (e.g. IDFV, Android ID), advertising ID (e.g. IDFA, GAID), third-party unique ID (e.g. Pangle ID, AppsFlyer ID), IP address, country and city information inferred from IP address;
  • Device & Technical Data: device model, device time zone, device country, system language, information of CPU, information of storage capacity, information of screen, information of network, information of operating system, and other technical data;
  • Gameplay Data: data about your interaction with our Services, for example, game access time, usage logs, progress, achievements, play time and other gameplay information;
  • Ad Interactive Data: data about your interaction with advertisements within our Services. For example, information that you have viewed or clicked an ad. We use this information for advertising measurement, optimization, and fraud prevention.

1.3 Personal Data We Received from Third Parties

We may also receive information about you from third parties, which includes the following:
  • Social Media Platforms.
    In certain scenarios, you may have the option to log in with your Google account. When you choose this method, we use Google's account verification service and receive necessary information (such as an encrypted login code and your login status) to enable account functionality. Please note that your use of any third-party login solution, along with the personal data you provide to them or that they collect, is governed by Google's terms of use, privacy policy, and other agreements. You can review Google's privacy policy at: https://policies.google.com/privacy.
    When you participate in activities hosted on third-party platforms, we may receive information(e.g. user ID, verification status) about your participation, based on your authorization, which shall be subject to the notification of the relevant activities.
  • App Marketplaces.
    When you make in-app purchases through the Apple App Store or Google Play, we receive information such as your device ID, transaction time, order details (encrypted), and payment status. Please note that all payment transactions for in-app purchases are processed through the respective app marketplace using your marketplace account. We do not collect or store any payment card details. This information is processed solely by the app marketplace.

1.4 About Sensitive Personal Data

Sensitive personal data refers to personal data that, once leaked or illegally used, will easily lead to infringement of human dignity or harm to the personal or property safety of a natural person. The scope of sensitive personal data may vary pursuant to different applicable data protection law. Our Services will not intentionally collect your sensitive personal data.

2. How We Use Your Personal Data

We use your personal data for the following purposes:
Purpose Examples of Processing Activities Personal Data Categories Legal Basis under GDPR
Service Provision & Maintenance To deliver games and ensure they function correctly on users' devices, provide updates, and fix bugs or crashes.
  • Identifiers Data
  • Device & Technical Data
  • Gameplay Data
 Contractual necessity (Art 6(1)(b) of the GDPR)
To facilitate users' in-game subscriptions through verification of subscription details.
  • Data provided by App Marketplaces
To enable account login, verification, and to enable the account functions you request.
  • Data provided by Google when you choose to log in with a Google account
To fulfill the terms of activities in which users participate (e.g., reward distribution)
  • Customer Service Data
  • Data provided by Social Media Platforms when you participate in activities hosted on third-party platforms
Game Performance and User Experience Enhancement To improve game stability, security, and performance by analyzing how users interact with our games and identifying areas for enhancement.
  • Identifiers Data
  • Device & Technical Data
  • Gameplay Data
 Legitimate interests (Art 6(1)(f) of the GDPR)
To understand user trends, preferences, and interactions with our games, informing data-driven decisions to refine and optimize our existing services and the gaming experience.
  • Identifiers Data
  • Device & Technical Data
  • Gameplay Data
Service Communications To deliver essential, non-promotional communications related to the services we provide to you. This includes critical security updates, bug fixes, and important updates to our Terms or Policies.
  • Identifiers Data
 Contractual necessity (Art 6(1)(b) of GDPR) or Legitimate interests (Art 6(1)(f) of GDPR)
Marketing and Promotional Communications To send you push notifications about new features, testing invitations, and other promotional content that we believe may be of interest to you. These communications are based on your consent.
  • Customer Service Data
 Consent (Art 6(1)(a) of the GDPR)
Customer Support and Inquiry Response To provide timely and accurate customer support, respond to inquiries, handle complaints, and improve services based on users' feedback.
  • Customer Service Data
 Legitimate interests (Art 6(1)(f) of the GDPR)
Survey and Activity Administration To administer voluntary surveys and other activities.
  • Customer Service Data
 Consent (Art 6(1)(a) of the GDPR)
Advertising and Marketing Communications To deliver, measure, and optimize the effectiveness of advertisements within our Services.
  • Identifiers Data
  • Device & Technical Data
  • Ad Interactive Data
 Consent (Art 6(1)(a) of the GDPR)
Security Assurance To enhance game safety, detect and prevent fraud, verify identities, and protect user accounts.
  • Identifiers Data
  • Gameplay Data
 Legitimate interests (Art 6(1)(f) of the GDPR)
Legal Compliance To comply with our legal obligations, such as retaining transaction records as required by tax and commercial law.
  • Identifiers Data
  • Data provided by App Marketplaces (e.g. purchase records)
 Fulfillment of legal obligation (Art 6(1)(c) of the GDPR)

3. How We Share Your Personal Data

We do not disclose your personal data to third parties without a valid legal basis. Such processing is justified on the basis of your consent, the necessity for the performance of a contract with you, compliance with a legal obligation, or the necessity for the purposes of our legitimate interests. We may share your personal data with the following categories of third parties:
  • Our affiliates. We may share your personal data with companies within our corporate family where necessary for the purposes set out in this Policy and we ensure they are contractually bound. For international data transfers, we ensure an adequate level of data protection by implementing appropriate legal mechanisms, such as the Standard Contractual Clauses.
  • Technical service providers. We engage the following third-party service providers (Data Processors) to perform functions on our behalf in delivering our Services. We enter into data processing agreements with these providers that contractually obligate them to protect your data and process it only according to our instructions:
  • Advertising partners. We may share your data with advertising partners to serve ads to you and measure the effectiveness of those ads. The data we share may include device identifiers (e.g., GAID, IDFA), IP address, device and technical data and information about your interaction with ads.
    Legal Basis and Your Control:
    • EEA/SWITZERLAND/UK: This sharing for personalized advertising is based exclusively on your consent, which we obtain and manage through a Consent Management Platform (CMP). We require our advertising partners to process personal data according to the consent status we transmit to them. You can change your preferences at any time in the privacy settings of our games. You may manage your consent related to advertisement through the in-game settings interface. Please note that you may still receive advertisements from us and third parties on our Services even if you withdraw your consent for tailored advertising; but these ads will not be tailored to you.
    • California: You have the right to opt-out of the "sale" or "sharing" of your personal data for cross-context behavioral advertising. You can exercise this right at any time by using the "Do Not Sell My Data" in our in-game settings. You may also contact us at privacy@hungrystudio.com.
    These advertising partners may process your data under their own privacy policies. A list of our main advertising partners is available in the Advertising Partners List.
In addition, we may disclose your personal data in the following cases:
  • Where we choose to sell, transfer or merge parts of our business or our assets, in such a case, the new owners will assume all our rights and obligations in this Policy;
  • Where it is necessary for the purposes of national security, law enforcement, or public interests.

4. International Transfer of Personal Data

Due to the global nature of our operations, your personal data may be transferred to, stored in, and processed by our affiliated companies, service providers and advertising partners in countries outside your country of residence. Our data storage servers are located in the eastern United States.
Where the transfer of your personal data to a recipient located in a foreign country constitutes an international or cross-border transfer under applicable law, we rely on approved legal transfer mechanisms and implement appropriate safeguards to protect your data.

5. Data Security and Data Retention

We are committed to keeping your personal data safe. We take reasonable and appropriate administrative, technical, organizational, and physical security and risk management measures in accordance with applicable laws to ensure that your personal data is adequately protected against accidental or unlawful destruction, damage, loss or alteration, unauthorized or unlawful access, disclosure or misuse, and all other unlawful forms of processing of your personal data in our possession.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes set out in this Policy. We will either delete or anonymize your personal data when it is no longer required to satisfy the purposes set out in this Policy unless otherwise specified by applicable laws.

6. Your Legal Rights

Your legal rights regarding your personal data vary depending on your jurisdiction, and may include the following:
  • Right to access your data. You have the right to access personal data we hold about you, how we use it, and who we share it with.
  • Right to correct your data. You have the right to correct any personal data held about you that is inaccurate.
  • Right to delete your data. You can delete or remove certain personal data that we have stored about you. However, please note that we may need to retain certain personal data where we have valid legal grounds under applicable data protection laws. If that is the case, we will inform you of such valid grounds.
  • Right to restrict data processing. You have a right to request us to stop processing the personal data we hold about you other than for storage purposes in certain circumstances (such as where you believe such data to be inaccurate, our processing is unlawful or that we no longer need to process such data for a particular purpose).
  • Withdrawal of consent. You may withdraw your consent at any time through the in-game privacy settings. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. Please note that even if you withdraw consent for tailored advertising, you may still receive non-personalized advertisements.
  • Right to portability (applicable to EEA, Swiss, and UK users). You have the right to receive a copy of certain personal data we process about you in a structured, electronic format. Additionally, you have the right to have us transmit such personal data directly to another controller, where technically feasible. However, please note that we may not be able to provide you with personal data if providing it would interfere with another's rights (e.g. where providing the personal data we hold about you would reveal data about another person or our trade secrets or intellectual property) or there are other limitations recognized under data protection laws.
  • Right to lodge complaints. You have the right to lodge complaints about the data processing activities carried out by us before the competent data protection authorities, where existing.
You can exercise your rights entitled by the privacy laws in your jurisdiction at any time by contacting privacy@hungrystudio.com. We may ask you to verify your identity and your jurisdiction before taking further action on your request. We will respond to your request within the time frames required by applicable law (e.g., typically 30 days under GDPR/UK GDPR and 45 days under CCPA/CPRA). If we decide not to respond to your request for the above rights, we will explain the reasons.

7. Children's Privacy

Our Services are designed and provided to users of various age groups. We do not knowingly collect personal data from, or serve targeted advertisements to, children as defined and required by applicable laws. If you believe that we may have personal data from or about a child, or have served targeted advertising to a child in violation of our policies, please contact us via email at privacy@hungrystudio.com.

8. Changes to this Policy

This Policy may be changed from time to time. If we change anything important about this Policy (e.g., the type of personal data we collect), we will provide a prominent link together with the updated policy for your reference on our Services. By continuing to use the Services, you acknowledge that you have read and understood the updated Policy.

9. Contact Us

If you have any questions, complaints, feedback, or other inquiries regarding personal data protection related to the use of our Services, including any requests to exercise your legal rights, please contact us through the following ways:

10. Jurisdiction Specific

EEA, SWITZERLAND AND THE UK ("EUROPE") SECTION

Legal basis
In each case where we process your personal data, we do so lawfully in accordance with one of the legal basis set out under Europe data protection laws. To learn more about our legal basis under GDPR, see Section 2 How We Use Your Personal Data.
International transfer
We transfer your personal data to third countries on the basis of the following safeguards:
  • Adequacy Decisions: We transfer data to countries that benefit from an adequacy decision by the European Commission or the UK government (as applicable). This includes transfers to countries that benefit from adequacy decisions, such as Argentina and Israel. It also includes transfers to the United States, but only when the recipient is a commercial organization certified under the EU-U.S. Data Privacy Framework (and listed on the official roster).
  • Standard Contractual Clauses (SCCs): For transfers to countries without an adequacy decision, we rely on the European Commission's and/or UK's approved Standard Contractual Clauses. Prior to such transfers, we conduct a Transfer Impact Assessment (TIA). Where the TIA indicates that the laws of the third country do not provide a level of data protection equivalent to that in the EEA/UK, we implement supplementary technical, contractual, and organizational measures to ensure your data is protected. These SCCs (including copies) can be accessed via https://commission.europa.eu/publications/standard-contractual-clauses-international-transfers_en.
Local Representative
Our representative in the European Economic Area (EEA) is:
The DPO Centre Europe Limited
Alexandra House, 3 Ballsbridge Park, Dublin, D04C 7H2, Ireland
Email: eurep@hungrystudio.com

US STATES PRIVACY SECTION

Your Privacy Rights
In addition to the privacy rights described in Section 6 Your Legal Rights, you may have the following rights:
  • Exercising the right to know
    You have a right to request additional information about the categories of personal information collected, sold, disclosed, or shared; purposes for which this personal information was collected, sold, or shared; categories of sources of personal information; and categories of third parties with whom we disclosed or shared this personal information.
  • Exercising the right to Opt-Out of sale or sharing
    Under the CCPA/CPRA, "sale" and "sharing" of personal information are defined broadly. While we do not sell your data in the traditional sense for money, our disclosure of certain personal data (such as advertising identifiers) to third-party advertising partners for cross-context behavioral advertising may be considered a "sale" or "sharing" under these laws.
    You have the right to direct us to stop such "sales" or "sharing" of your personal information. You can exercise this right at any time by using the "Do Not Sell My Data" in our in-game settings. You may also contact us at privacy@hungrystudio.com.
Authorized Agents
You may designate an authorized agent to make a request on your behalf. For security, we require the authorized agent to provide proof that you have given them permission to act for you, and we may need to verify your identity directly.
Non-Discrimination
We will not deny, charge different prices for, or provide a different level of quality of services if you choose to exercise these rights, unless allowed under applicable law.
Appeals
If you wish to appeal any of our decisions regarding a rights request under US privacy laws, you may do so by contacting privacy@hungrystudio.com. We will respond to your appeal within the time period required by applicable law.