Privacy Policy

1. Who we are

• Controller: To be confirmed, To be confirmed. Contact: cs@galaxynuts.net
• Privacy officer: To be confirmed
• If you live in the Republic of Korea, the Korean version applies: privacy.html.

2. Information we collect

Agreeing to the Terms or reading this policy does not mean you have consented to processing that requires separate consent; we ask for that consent separately.

We collect this information automatically while you use the Service (sign-in, saves, purchases, statistics), from the platforms you use, and from e-mails you send us. We do not ask for your name, phone number or government ID, and we use your IP address only to determine your country without storing it.

3. How we use information

• App functionality
• Analytics
• Fraud prevention, security and compliance
• Advertising or marketing
• Account management

The legal bases for each feature are listed in the EEA section.

4. Who we share information with

We do not sell personal information for money. We share it only as described below or where required by law.

Advertising partners (they may also use the information for their own purposes under their policies — whether this is 'provision' or 'processing on our behalf': To be confirmed):

Service providers that process information on our behalf under contract:

• Google LLC (To be confirmed) — Play Games sign-in, achievements, leaderboards, saves (processed under its own privacy policy)
• Apple Inc. (To be confirmed) — Game Center sign-in, achievements, leaderboards, saves (processed under its own privacy policy)

5. Platforms and stores

The Service is offered on the platforms below. Each platform company processes payment and account information under its own privacy policy.

Google Play — Google LLC

• Payment: Google Play's billing system — payment and billing are handled by Google.
• Account: You may link a Google Play Games account (if enabled).
• Information and role: Google processes payment and store-account information under its own privacy policy (platform). We receive only the order number, receipt and product information.
• Platform services: Play Games achievements, leaderboards and saved games (if enabled)

App Store — Apple Inc.

• Payment: App Store in-app purchase — payment and billing are handled by Apple.
• Account: You may link Game Center or Sign in with Apple (if enabled).
• Information and role: Apple processes payment and Apple Account information under its own privacy policy (platform). If you use Game Center we may receive your nickname and Game Center identifiers.
• Platform services: Game Center achievements, leaderboards and saved games (if enabled)

Toss (Apps in Toss) — Viva Republica, Inc.

• Payment: In-app payment in the Toss mini-app — processed by Google Play on Android and by Apple on iOS, with Toss as intermediary.
• Account: You use the game with Toss sign-in (userKey — an identifier for this app only) or the Toss anonymous key. If you unlink in the Toss app, Toss deletes the consent records and we delete the link on our side.
• Information and role: Toss provides information to us at Toss sign-in (Toss's 'consent to provision to third parties') and processes payment intermediation, Toss ads and event logs under its own policy (platform). We use only the userKey and do not open names, phone numbers or other encrypted fields.
• Platform services: Toss leaderboard and Toss ads (if enabled)

6. International transfers

We are based in the Republic of Korea, so your information is processed in Korea. It is also transferred to the recipients below, over encrypted connections, whenever you use the Service. Safeguards for your region are described in the regional sections.

7. How long we keep information

Records that the law requires us to keep (for example, payment records under Korean e-commerce law) are stored separately for the required period (To be confirmed).

8. Your rights and choices

• You can ask us to access, correct or delete your personal information, or to stop processing it, by e-mailing cs@galaxynuts.net. Including your in-game user ID helps us find your data. We respond without undue delay and as required by the law of your country; see your regional section for additional rights.
• Your game progress is stored on your device (and on the platform's cloud save if you use it); deleting the app deletes the data on your device.
• Where we rely on your consent, you can withdraw it at any time; this does not affect earlier processing.

9. Advertising, consent and device identifiers

• Consent form before personalised ads in the EEA and the UK: To be confirmed
• You can review or change your choices at any time in the game under Settings ▸ Privacy settings, which also offers 'Do Not Sell or Share My Personal Information'.
• Device settings — Android: Settings ▸ Google ▸ Ads ▸ Delete advertising ID. iOS: Settings ▸ Privacy & Security ▸ Tracking ▸ off (on iOS the advertising identifier is used only if you allow it in the App Tracking Transparency prompt).
• Behavioural information such as ad interactions is collected by the advertising partners listed in section 4.

10. Children

The Service is intended for a general audience and is not directed to children under 13 (or the higher age set by the law of your country — for example 14 in Korea and up to 16 in some EEA countries). We do not knowingly collect personal information from children below that age without the consent required by law; if we learn that we have, we will delete it. Parents and guardians can contact cs@galaxynuts.net.

11. Security

• Administrative: staff access is minimised, each operator receives limited permissions, and all administrative actions are recorded in an audit log.
• Technical: all communication is encrypted with HTTPS, sign-in sessions are stored only as hashes, and each request is checked for a game signature and rate limits. Connection IP addresses are not stored.
• Physical: servers rely on the data-centre security of our cloud provider.

12. Changes and contact

This policy takes effect on 2026-10-19. We will announce changes in the Service and on this page before they take effect; previous versions are available on request. Contact: cs@galaxynuts.net.

Users in the Republic of Korea

• If you live in the Republic of Korea, the Korean version of this policy (privacy.html) applies. It is written under the Personal Information Protection Act and includes the items that act requires (destruction, outsourcing, international transfers, the Chief Privacy Officer and remedies).

Additional information for users in the European Economic Area (GDPR)

• Controller: To be confirmed, To be confirmed. Contact: cs@galaxynuts.net. EU representative under GDPR Art. 27: To be confirmed. Data protection officer (Art. 37): To be confirmed.
• Legal bases (GDPR Art. 6(1)) for each feature:

The choice of legal basis for each feature: To be confirmed

• Personalised ads and reading the advertising identifier on your device happen only with your consent (GDPR Art. 6(1)(a); ePrivacy Directive 2002/58/EC Art. 5(3)). In the game, open Settings ▸ Privacy settings to review or change your choices. To be confirmed Without consent you may still see non-personalised ads.
• You can withdraw consent at any time; this does not affect processing before the withdrawal (Art. 7(3)).
• Your rights: access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20), and objection (Art. 21) — including objection at any time to processing for direct marketing, which includes profiling. Contact cs@galaxynuts.net; Your game progress is stored on your device; deleting the app deletes it. We will respond without undue delay and free of charge, in principle within one month, which may be extended by two further months where necessary, in which case we will tell you within the first month (Art. 12(3)).
• You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement (Art. 77).
• International transfers: the Republic of Korea is covered by an adequacy decision (Commission Implementing Decision (EU) 2022/254). For recipients in the United States we rely on the EU-U.S. Data Privacy Framework where the recipient is certified (Decision (EU) 2023/1795) or on the Commission's standard contractual clauses (Art. 46(2)(c)). Per-recipient basis: To be confirmed. You may request a copy of the safeguards at cs@galaxynuts.net.
• Retention periods are listed in the Retention section above (Art. 13(2)(a)).
• Data needed to provide the game (account, saves, purchases) is required to use the Service; consent to personalised ads is optional (Art. 13(2)(e)). We do not make decisions based solely on automated processing that produce legal or similarly significant effects (Art. 22).
• Children: the age of digital consent is 16 unless your Member State sets a lower age, not below 13 (Art. 8(1)). The game is not directed at children; if you are below that age, please use it only with a parent's or guardian's consent. Member-State ages: To be confirmed.

Additional information for users in the United Kingdom (UK GDPR)

• The EEA section above applies to you under the UK GDPR and the Data Protection Act 2018, with these differences. UK representative under UK GDPR Art. 27: To be confirmed. Data protection officer: To be confirmed.
• Children: the age of digital consent in the UK is 13 (UK GDPR Art. 8(1)).
• Complaints: you may first complain to us at cs@galaxynuts.net; we will acknowledge your complaint within 30 days (Data Protection Act 2018, s.164A). You can also complain to the Information Commissioner's Office (ico.org.uk/make-a-complaint, 0303 123 1113).
• International transfers from the UK rely on UK adequacy regulations or the ICO's International Data Transfer Agreement / Addendum to the EU standard contractual clauses. Per-recipient basis: To be confirmed.

U.S. state privacy notice (including California) and children's privacy (COPPA)

• Categories of personal information collected in the last 12 months (Cal. Civ. Code §1798.140(v)): identifiers (user ID, device and advertising identifiers); commercial information (purchase history); internet or other electronic network activity (gameplay events, ad interactions); approximate geolocation (country derived from IP). Sources: you, your device and the platforms you use. Purposes and retention: see the sections above.
• Sale and sharing: we do not sell personal information for money. If personalised ads are enabled, our advertising partners may use advertising identifiers for cross-context behavioural advertising, which may be 'sharing' under the CCPA (§1798.140(ah)). We disclose information to service providers for the purposes in this policy.
• Do Not Sell or Share My Personal Information: In the game, open Settings ▸ Privacy settings to review or change your choices. To be confirmed You can also e-mail cs@galaxynuts.net. We will not ask you to create an account to opt out (§1798.135(c)). Opt-out preference signals: To be confirmed.
• We do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age.
• We do not use sensitive personal information for purposes that would require a 'Limit the Use of My Sensitive Personal Information' link.
• Your rights: to know and access, delete, correct, and opt out of sale or sharing, and not to be discriminated against for exercising them (§1798.125). Send requests to cs@galaxynuts.net; we verify your request using your in-game user ID and respond within 45 days (extendable once by 45 days, §1798.130). An authorised agent may make a request on your behalf.
• Residents of other U.S. states with consumer privacy laws (for example Virginia — opt-out of targeted advertising, sale and profiling) may make the same requests by e-mail.
• We update this notice at least once every 12 months (§1798.130(a)(5)).
• Children (COPPA): the game is intended for a general audience and is not directed to children under 13. We do not knowingly collect personal information from children under 13; if we learn that we have, we will delete it. Parents can contact cs@galaxynuts.net. COPPA assessment: To be confirmed.

Users in other countries

• If you live elsewhere, you may have rights under your local law to access, correct or delete your personal information or to object to its processing. Contact cs@galaxynuts.net and we will respond in accordance with applicable law. Your game progress is stored on your device; deleting the app deletes it.

Regions where the Service is not offered

The Service is not offered in: Mainland China, Russia.

Company Information

• Company: To be confirmed (GALAXYNUTS)
• Representative: To be confirmed
• Address: To be confirmed
• Business registration no.: 318-86-02126
• Mail-order business report no.: To be confirmed
• Contact: cs@galaxynuts.net