top of page

Privacy Policy

Last updated: 22 August 2026

​

Tolfy Games ("Tolfy Games", "we", "us", or "our") develops and publishes mobile applications and games and related digital services (collectively, our "Apps").

​

This Privacy Policy explains how we collect, use, disclose, and protect information in connection with our Apps. It applies to all of our Apps. Where a particular App processes information that the general sections below do not fully describe, that App is covered by an additional section under "App-Specific Disclosures" at the end of this policy.

​

For the purposes of the EU General Data Protection Regulation (GDPR), the data controller is Tolfy Games, R. Duque de Palmela 25 1, 2715-311 Lisbon, Portugal. You can reach us at [email protected].

​

1. Information We Collect

Information You Provide Directly

Most of our Apps do not require you to create an account or to provide personal information such as your name, email address, telephone number, or postal address.

Some Apps allow you to create a **local profile** — for example a display name, a profile photo, or credentials used to lock the App — and to enter content such as notes, measurements, or personal records. This information is stored **only on your device**. It is not transmitted to us, we cannot access it, and we cannot recover it for you if you lose it. Please see the App-Specific Disclosures below for the App you are using.

Information Collected Automatically

Our Apps use third-party services such as Google AdMob, Meta Audience Network, Google Analytics for Firebase, Firebase Crashlytics, Firebase Cloud Messaging, and OneSignal. Through these services, the following information may be collected:

  • IP address and general location inferred from it (typically country or region);

  • advertising identifiers (such as the Google Advertising ID) and app instance identifiers;

  • device information (device model, operating system version, language, time zone, screen characteristics, network type);

  • application usage data (app launches, screens viewed, session length, in-app events);

  • advertising interactions (ad requests, impressions, clicks);

  • diagnostic and crash data (stack traces, device state at the time of a crash);

  • push notification tokens and delivery/open events, if you enable notifications.

We do not intentionally collect precise location data, your contacts, or microphone recordings.

Some Apps request **camera or photo library access** so that you can add photos to content you create inside the App. Any photos you add are stored locally on your device and are not uploaded to us.

Some Apps request **storage access** so that you can export your own data to a file on your device. Exported files are created only when you ask for them and are saved to storage you control.

​

2. How We Use Information

We use information to:

  • provide, operate, and maintain our Apps;

  • display advertisements and measure their performance;

  • understand how our Apps are used and improve their features and content;

  • deliver notifications and reminders you have enabled;

  • detect, prevent, and investigate fraud, abuse, and security incidents;

  • diagnose crashes and technical problems;

  • comply with legal obligations.

We do not sell personal information for money. However, the use of advertising and analytics identifiers may be considered a "sale" or "sharing" of personal information under certain U.S. state privacy laws. See "Your Choices and Rights" below for how to opt out.

​

3. Legal Bases for Processing (EEA / UK Users)
Where the GDPR or UK GDPR applies, we rely on the following legal bases:

  • Providing the App and its core features | Performance of a contract (Art. 6(1)(b))

  • Personalized advertising, non-essential analytics | Your consent (Art. 6(1)(a))

  • Security, fraud prevention, crash diagnostics | Our legitimate interests (Art. 6(1)(f))

  • Health or other special category data you enter into an App | Your explicit consent (Art. 9(2)(a))

  • Meeting legal and regulatory obligations | Legal obligation (Art. 6(1)(c))

You may withdraw your consent at any time. Withdrawing consent does not affect processing carried out before the withdrawal.
 

4. Advertising

Our Apps may display advertisements provided by Google AdMob and Meta Audience Network, including banner, interstitial, native, and app-open formats.

Depending on your location and your device settings, these ads may be personalized (based on advertising identifiers and inferred interests) or non-personalized (based only on general context, such as the content of the App and coarse location).

Where required by law — including in the European Economic Area and the United Kingdom — we present a consent message before personalized advertising or non-essential analytics are enabled, and you can change your choice later from within the App. You can also limit ad personalization at any time through your device settings (Android: Settings → Google → Ads → Delete advertising ID or Opt out of Ads Personalization).

​

5. Analytics and Crash Reporting

Google Analytics for Firebase collects app launches, in-app events, interactions, device information, and approximate location derived from IP address, so that we can understand usage patterns and improve our Apps.

Firebase Crashlytics collects crash reports, including stack traces, device model and OS version, App version, the state of the App at the time of a crash, and a randomly generated installation identifier. Crash reports help us fix defects and are not used for advertising.

​

6. Push Notifications

If you allow notifications, we use OneSignal (which delivers messages over Firebase Cloud Messaging) to send them. OneSignal processes a push subscription token together with device information such as model, operating system version, language, time zone, and IP address, and records whether a notification was delivered or opened.

You can turn notifications off at any time in your device settings, or from within the App where the App offers that option. Reminders and alarms that you schedule yourself are generated on your device and do not require any data to be sent to us.

​

7. Locally Stored Data and Device Backups

Unless a particular App explicitly states otherwise, Tolfy Games does not provide cloud-based account synchronization. Content you create inside an App is stored in local storage on your device.

Please note that if you have enabled Android Auto Backup or a comparable feature, your device may copy App data to your own Google account backup. This backup is created and controlled by your device and your Google account settings, not by Tolfy Games, and is subject to Google's privacy policy. You can disable it in Settings → Google → Backup.

​

8. Data Retention

  • Data stored locally on your device is kept until you delete it, clear the App's storage, or uninstall the App. We have no ability to delete it remotely.

  • Advertising, analytics, and diagnostic data is retained by our third-party providers in accordance with their own retention schedules — for example, Google Analytics for Firebase retains event-level data for a configurable period (by default between 2 and 14 months), and Firebase Crashlytics retains crash reports for approximately 90 days.

  • Correspondence you send us (for example a support or privacy request) is retained for as long as necessary to handle the request and to comply with legal obligations.

​

9. Data Deletion

Because App data is stored locally, you can delete all of it at any time:

  • Android: Settings → Apps → (the App) → Storage → Clear data; or uninstall the App.

To request deletion of any information held by us or by our third-party providers in connection with your use of our Apps, email info@tolfygames.com. Please tell us which App you are using and, where possible, your advertising identifier or app instance ID. We respond to requests within 30 days.

​

10. Your Choices and Rights

Depending on where you live, you may have the right to:

  • access the personal information we hold about you;

  • request correction of inaccurate information;

  • request deletion of your information;

  • object to or request restriction of certain processing;

  • receive your information in a portable format;

  • withdraw consent you have previously given;

  • opt out of the "sale" or "sharing" of personal information and of targeted advertising (California, Colorado, Connecticut, Virginia and other U.S. states with comparable laws).

To exercise any of these rights, contact [email protected]. We will not discriminate against you for exercising them.

If you are in the EEA or the UK and believe we have not handled your information properly, you may lodge a complaint with your local supervisory authority. In Portugal this is the Comissão Nacional de Proteção de Dados (CNPD), www.cnpd.pt.

​

11. International Data Transfers

We are based in Portugal. Some of our service providers — including Google LLC, Meta Platforms, Inc., and OneSignal, Inc. — are located in the United States or process data in other countries outside the EEA. Where personal information is transferred outside the EEA or the UK, the transfer is made on the basis of the European Commission's Standard Contractual Clauses (and the UK Addendum where applicable), together with any additional safeguards required by law.

​

12. Children's Privacy

Our Apps are intended for users aged 13 and older and are not specifically directed to children under 13. Certain Apps have a higher minimum age, which is stated in the App-Specific Disclosures below.

We do not knowingly collect personal information from children below the applicable age. If you believe a child has provided us with personal information, contact us at info@tolfygames.com and we will take appropriate steps to delete it.

​

13. Data Security

We take reasonable technical and organizational measures to protect information processed in connection with our Apps, including limiting the data we collect, relying on established providers, and keeping our SDKs up to date. Data you create inside an App remains on your device and is protected by your device's own security features — we strongly recommend that you use a screen lock and keep your device software up to date. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

​

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date at the top of this page. Material changes will be highlighted within the affected App where appropriate. Continued use of our Apps after an update constitutes acceptance of the revised policy.

​

15. Third-Party Services

Our Apps rely on the following third-party services. Each provider processes information under its own privacy policy:

We encourage you to review these policies. We are not responsible for the privacy practices of third parties.
 

16. Contact Us

Tolfy Games R. Duque de Palmela 25 1, 2715-311 Lisbon, Portugal Email: info@tolfygames.com

​

bottom of page