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Privacy Policy

Last updated: January 15, 2026 · Effective immediately · Ra PmtWA · aycakalmaz5@gmail.com

Contents

  1. Scope of this policy
  2. Definitions
  3. Data controller & contact
  4. Information we collect
  5. How we use information
  6. Legal bases (EEA / UK)
  7. How we share information
  8. Advertising, ad networks & mediation
  9. Ad formats we display
  10. App Store & Google Play disclosures
  11. Regional disclosures
  12. Children's privacy & age gating
  13. Data retention
  14. International data transfers
  15. Security
  16. Your rights & choices
  17. Changes to this policy
  18. Contact us

1. Scope of this policy

This Privacy Policy applies to the Ra PmtWA website at rapmtwa.com and to all mobile applications published under the "Ra PmtWA" developer name on the Apple App Store, Google Play, and any other storefront we may distribute through (each, an "App", together the "Services"). It describes what information we collect, how we use it, with whom we share it, and the rights you have over your data.

For the avoidance of doubt, this policy covers our casual games, our daily utility apps, and our mobile management companion app. It also covers our website visitors, end users of our Apps, business partners, and job applicants who interact with us.

If you do not agree with this policy, please do not use the Services. By using the Services you confirm that you have read and understood this policy.

2. Definitions

  • "Personal data" means any information that identifies or can reasonably be used to identify a living person.
  • "Device data" means technical information about the device you use to access the Services, such as operating system, language, device model, screen size, advertising identifiers (IDFA, GAID), IP address, and crash logs.
  • "Usage data" means information about how you interact with our Services, such as features used, session length, in-app actions, and timestamps.
  • "Ad partners" means the third-party advertising and ad-mediation platforms listed in section 8.

3. Data controller & contact

Ra PmtWA ("we", "us", "our") is the data controller for the personal data collected through the Services.

  • Studio name: Ra PmtWA
  • Website: rapmtwa.com
  • Email: aycakalmaz5@gmail.com
  • Mail: Ra PmtWA, c/o the email above (we currently operate as a distributed studio and process mail electronically)

For any privacy question, request, or complaint, please contact us using the details above. We aim to respond within 30 days, and within statutory deadlines where applicable.

4. Information we collect

We collect information in three ways: (a) information you give us directly, (b) information collected automatically when you use the Services, and (c) information received from third parties such as app stores and ad partners.

4.1 Information you provide directly

  • Contact form on this website: your name, email address, optional company, and the message body. We use this only to reply to your inquiry.
  • Account information in our mobile management app: email, name, profile picture (if you sign in with a third-party identity provider such as Google or Apple), and the team / organization you create or join.
  • Support communications when you email us, including any attachments you choose to share.

4.2 Information collected automatically

  • Device data: device model, OS version, OS locale, app version, install timestamp, country (derived from IP or device locale), and free vs. paid status.
  • Usage data: features used, screens visited, button taps, session length, retention, and crash data.
  • Advertising identifiers: iOS Identifier for Advertisers (IDFA) only after you grant App Tracking Transparency (ATT) consent; Google Advertising ID (GAID) only after you grant consent in our in-app consent dialog.
  • Diagnostics: anonymized crash logs, ANRs, and performance metrics via Firebase Crashlytics and similar tools.
  • Cookies and similar on this website: a minimal set of functional cookies (no analytics, no advertising) used to remember your preferences. See section 11 for our cookie stance in the EEA/UK.

4.3 Information from third parties

  • App stores: aggregate download and crash data from Apple App Store Connect and Google Play Console.
  • Sign-in providers: limited profile information when you choose to sign in to the management app with Google, Apple, or another supported provider.
  • Ad partners: limited, ad-related information (see section 8) used to deliver and measure advertising.

5. How we use information

We use the information described above for the following purposes:

  1. To operate, maintain, and improve the Services, including crash triage, performance tuning, and feature development.
  2. To authenticate users of the management app and protect accounts.
  3. To display advertising in our free-to-play apps and to measure its performance.
  4. To respond to inquiries you send us through the contact form or by email.
  5. To detect, prevent, and address fraud, abuse, security incidents, and violations of our terms.
  6. To comply with legal obligations, including responding to lawful requests from authorities and meeting tax, accounting, and record-keeping requirements.
  7. To send service notifications about important changes, security incidents, and policy updates, where required or appropriate.

We do not use your data for automated decision-making that produces legal or similarly significant effects on you, except for limited fraud-prevention use cases described in section 11.

6. Legal bases for processing (EEA / UK)

If you are in the European Economic Area, the United Kingdom, or Switzerland, we rely on the following legal bases under the GDPR and UK GDPR:

  • Performance of a contract — to provide the Services you have requested, including the management app and website contact.
  • Legitimate interests — to operate, secure, and improve the Services, in a way that does not override your rights and freedoms.
  • Consent — for non-essential cookies, for personalized advertising, and for sharing data with ad partners. You can withdraw consent at any time.
  • Legal obligation — to comply with applicable law, court orders, and regulatory requests.

7. How we share information

We do not sell personal data. We share personal data only as described below:

  • Ad partners, only after you have granted applicable consent, to deliver and measure ads. See section 8 for the full list.
  • Service providers that process data on our behalf: cloud hosting (Google Cloud, Amazon Web Services, Cloudflare), error reporting (Firebase Crashlytics, Sentry), authentication (Google Sign-In, Apple Sign-In, Firebase Auth), analytics (Google Analytics for Firebase, only with consent where required), and customer support tools.
  • App stores, which receive limited data about app installs, crashes, and in-app purchases as part of normal app distribution.
  • Legal and safety: when we believe in good faith that disclosure is necessary to comply with a law, valid legal process, or government request, or to protect the safety, rights, or property of Ra PmtWA, our users, or others.
  • Business transfers: in connection with a merger, acquisition, financing, or sale of assets, with appropriate confidentiality protections.
  • With your consent: for any other purpose disclosed at the time of collection.

8. Advertising, ad networks & ad mediation platforms

Our free-to-play apps display advertising. We integrate the following primary ad networks and ad-mediation / bidding platforms. Each is a separate data controller for the data it receives. We encourage you to review their privacy policies.

8.1 Primary ad networks

  • Google AdMob / Google Ad Manager — policies.google.com/privacy
  • Meta Audience Network (Facebook) — facebook.com/privacy/policy
  • Unity Ads — unity.com/legal/privacy-policy
  • AppLovin — applovin.com/privacy
  • ironSource (Unity LevelPlay) — is.com/privacy-policy
  • Digital Turbine (AdColony / FYBER) — digitalturbine.com/privacy-policy
  • Liftoff / Vungle — liftoff.io/privacy-policy
  • Chartboost — chartboost.com/legal/privacy-policy
  • Tapjoy — tapjoy.com/legal/privacy-policy
  • Pinterest Ads — policy.pinterest.com/privacy-policy
  • Snap Audience Network (Snapchat) — snap.com/privacy/privacy-policy
  • X (Twitter) MoPub — mopub.com/legal/privacy
  • Yahoo / Verizon Media — legal.yahoo.com
  • Start.io — start.io/policy/privacy-policy
  • Adsterra — adsterra.com/privacy-policy

8.2 Ad mediation & bidding platforms

  • AppLovin MAX — applovin.com/privacy
  • Google AdMob Mediation — support.google.com/admob
  • Unity LevelPlay (ironSource) — is.com/privacy-policy
  • Moloco — moloco.com/privacy-policy
  • Digital Turbine FairBid — digitalturbine.com/privacy-policy
  • BidMachine (Smart) — bidmachine.io/privacy-policy
  • PubMatic — pubmatic.com/legal/privacy-policy
  • InMobi — inmobi.com/privacy-policy
  • Smaato — smaato.com/privacy
  • Pangle (ByteDance / TikTok) — pangle.io/privacy
  • Ogury — ogury.com/privacy-policy
  • Mintegral — mintegral.com/en/privacy
  • Amazon Publisher Services (APS) — aps.amazon.com/aps/privacy-policy

8.3 What ad partners typically receive

Depending on your consent and the ad format, ad partners may receive: advertising identifiers (IDFA / GAID), coarse location (country / region), device and OS information, app version, ad impression and click events, and a pseudonymous user token. We do not share your name, email, or contact list with ad partners.

We honor Apple's App Tracking Transparency (ATT) framework on iOS, Google's "privacy sandbox" initiatives, the Google Play Families Policy, and applicable regional consent rules. We never pass data to ad networks in a way that is intended to identify children (see section 12).

9. Ad formats we display

The following ad formats may appear in our free-to-play apps. The mix varies by app, country, and consent state.

  • Splash (app open) ads — displayed when the app is opened or brought to the foreground, with a dismiss option and frequency caps.
  • Rewarded video ads — users voluntarily watch a video in exchange for an in-app reward, with a clear "watch ad" button and a required disclosure.
  • Interstitial ads — full-screen ads shown at natural transition points (for example, between game levels) with frequency caps and never after a level-fail unless the user opts in.
  • Banner ads — small, persistent ads displayed in a designated area; we never place banners that interfere with active gameplay or input controls.
  • Native ads and native banners — ads that match the visual style of the surrounding content, clearly labeled "Ad" or "Sponsored".
  • Playables / rewarded interactive — short interactive previews offering a reward on completion.
  • Offerwall — optional, opt-in lists of ad tasks offering in-app rewards.

All ad formats honor the consent signals described in section 11 and the child-direction rules in section 12.

10. App Store & Google Play disclosures

10.1 Apple App Store

Apps distributed through the Apple App Store must comply with Apple's App Review Guidelines, the Apple Developer Program License Agreement, and applicable local laws. We:

  • Provide accurate App Privacy labels in App Store Connect, including the data we collect and the purposes for which we use it.
  • Comply with Apple's App Tracking Transparency (ATT) framework: the IDFA is only accessed after the user grants ATT permission.
  • Ship a PrivacyInfo.xcprivacy manifest with each app, declaring the Required Reason APIs we use.
  • Support Apple's SKAdNetwork for attribution without persistent identifiers where appropriate.
  • Honour Apple's Kids category rules where applicable: no behavioral advertising, no third-party analytics, and no links out of the app for users under 13.

10.2 Google Play

Apps distributed through Google Play must comply with the Developer Distribution Agreement, the Developer Content Policy, and the Families Policy for any app designed for children. We:

  • Maintain accurate Data Safety forms, including the data we collect, whether it is shared, and the security practices in place.
  • Comply with the Families Self-Certification requirements where applicable; we do not use ad SDKs designed for behavioral advertising in apps directed to children.
  • Use only declared advertising IDs and respect the user's "Opt out of Ads Personalization" setting.
  • Implement a Privacy Policy URL in the Play Console listing, which is this page (or its in-app equivalent).
  • Maintain a valid app-ads.txt file at the root of this domain, listing the ad systems authorized to sell ads on our behalf.

11. Regional disclosures

11.1 European Economic Area (EEA), United Kingdom, Switzerland

We comply with the EU General Data Protection Regulation (GDPR) and the UK GDPR. In particular:

  • For users in the EEA/UK, we use Google's User Messaging Platform (UMP) to surface an IAB TCF v2.2 compliant consent dialog before any non-essential cookies or ad SDKs run.
  • You can withdraw consent at any time from the app's "Privacy & Consent" settings.
  • You have the rights described in section 15, including the right to lodge a complaint with your local supervisory authority.
  • Where we transfer data outside the EEA/UK, we rely on the European Commission's Standard Contractual Clauses (SCCs) and equivalent UK SCCs, with supplementary technical and organizational measures.

11.2 United States — California (CCPA / CPRA)

For California residents, the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA/CPRA"), provides the following rights:

  • The right to know what personal data we have collected about you, the sources, the business purposes, and the categories of recipients.
  • The right to delete personal data we have collected, subject to legal exceptions.
  • The right to correct inaccurate personal data.
  • The right to opt out of sale or sharing: we do not sell or share personal data as those terms are defined under the CCPA/CPRA.
  • The right to limit use of sensitive personal information to that which is necessary to provide the Services.
  • The right to non-discrimination for exercising any of the above rights.

To exercise these rights, contact us at aycakalmaz5@gmail.com. We will respond within the statutory 45-day window (extendable by 45 days with notice). Authorized agents may submit requests on your behalf with appropriate verification.

11.3 United States — other state laws

We extend the same rights to residents of Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), Texas (TDPSA), Oregon (OCPA), and other U.S. jurisdictions with comparable privacy laws. "Sale" and "targeted advertising" opt-outs are honored via our consent dialog where applicable.

11.4 United Kingdom — Children & the Age Appropriate Design Code

We have regard to the UK Information Commissioner's Office Age Appropriate Design Code (AADC). Where our apps are likely to be accessed by children, we:

  • Set high-privacy defaults, including disabling behavioral advertising.
  • Avoid using nudge techniques or persuasive design that lead children to provide more data than necessary.
  • Use plain language and age-appropriate explanations in our consent dialogs.
  • Conduct a Data Protection Impact Assessment (DPIA) for any app likely to be accessed by children.

11.5 Canada (PIPEDA & Quebec Law 25)

We comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and Quebec's Act to modernize legislative provisions as regards the protection of personal information (Law 25). You may request access to and correction of your personal data, and you may withdraw consent at any time, subject to legal and contractual restrictions.

11.6 Australia (Privacy Act 1988 & Australian Privacy Principles)

We comply with the Australian Privacy Principles. If you are unsatisfied with our response to a privacy complaint, you may contact the Office of the Australian Information Commissioner (OAIC).

11.7 Brazil (LGPD)

We comply with the Lei Geral de Proteção de Dados (LGPD). You have the rights of confirmation, access, correction, anonymization, portability, deletion, and information about sharing. The Brazilian National Data Protection Authority (ANPD) is the supervisory authority for complaints.

11.8 South Korea (PIPA)

We comply with the Personal Information Protection Act. Cross-border transfers outside Korea occur only with appropriate consent or other valid legal basis. We do not process sensitive information without explicit consent.

11.9 Japan (APPI)

We comply with the Act on the Protection of Personal Information (APPI). We process personal information only within the scope of the stated purpose of use, and only share it with third parties in accordance with APPI.

11.10 India (DPDP Act, 2023)

We comply with the Digital Personal Data Protection Act, 2023. You may request access, correction, and erasure of your personal data, and withdraw consent at any time.

11.11 China (PIPL)

Where we process personal information of users in the People's Republic of China, we do so in accordance with the Personal Information Protection Law (PIPL), including requirements for separate consent, data localization where applicable, and cross-border transfer assessment.

11.12 Singapore (PDPA), Hong Kong (PDPO), New Zealand (Privacy Act 2020), South Africa (POPIA), Israel (Privacy Protection Law), Switzerland (nFADP)

We extend the same standards of transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity & confidentiality, and accountability to users in these jurisdictions. Where local law requires additional rights, those rights are honored.

12. Children's privacy & age gating

Protecting children's privacy is a non-negotiable part of how we build.

  • We do not knowingly direct any of our apps or advertising at children under 13 (or higher where required by local law, such as under 14 in Korea, under 16 in the Netherlands for "information society services", or under 18 in other contexts).
  • We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us so we can delete it.
  • For apps in the Apple "Kids" category or in the Google Play Designed for Families program, we do not use behavioral advertising, do not use third-party analytics SDKs that collect persistent identifiers, and do not include any links out of the app.
  • We honor the Google Play Families Policy, COPPA (Children's Online Privacy Protection Act), and the UK Age Appropriate Design Code.
  • Where required, we use neutral age screens and parent-gated flows (for example, a parent gate before any in-app purchase or any sharing of personal data).
  • We do not serve personalized advertising in apps that we know or believe to be accessed by children.

13. Data retention

We keep personal data only for as long as necessary for the purposes described in this policy, unless a longer retention period is required or permitted by law. Specifically:

  • Contact form submissions: up to 24 months, or until you ask us to delete them, whichever comes first.
  • Account data for the management app: for as long as your account is active; deleted within 30 days of account closure, except where retention is required for tax, accounting, or legal purposes.
  • Server logs, crash logs, and aggregated analytics: typically 30 to 180 days in identifiable form, after which they are anonymized or deleted.
  • Advertising identifiers: not stored by us in identifiable form; managed by the ad partners in accordance with their own retention policies.

14. International data transfers

Because we are a distributed studio and use global cloud providers, your data may be processed in countries other than your own. We rely on appropriate safeguards, including:

  • European Commission's Standard Contractual Clauses (SCCs, 2021/914) for transfers from the EEA.
  • The UK International Data Transfer Addendum to the EU SCCs for transfers from the UK.
  • For U.S. transfers, our service providers' participation in the EU-U.S. Data Privacy Framework and the UK Extension where applicable.
  • Additional technical measures (encryption in transit and at rest, role-based access) and organizational measures (vendor due diligence, access logging).

15. Security

We protect personal data with industry-standard safeguards, including encryption in transit (TLS 1.2+) and at rest, role-based access controls, least-privilege engineering practices, and periodic review of our service providers. No system is perfectly secure; if a breach affecting your personal data occurs, we will notify you and applicable regulators as required by law.

16. Your rights & choices

Subject to your jurisdiction, you have some or all of the following rights:

  • Access — request a copy of the personal data we hold about you.
  • Correction — ask us to correct inaccurate or incomplete data.
  • Deletion — ask us to delete your personal data, subject to legal exceptions.
  • Portability — receive your data in a structured, commonly used, machine-readable format.
  • Restriction — ask us to limit how we process your data in certain circumstances.
  • Objection — object to processing based on legitimate interests, including profiling.
  • Withdraw consent — withdraw any consent you have given, at any time, without affecting prior lawful processing.
  • Opt out of sale or sharing — though as noted, we do not sell personal data.
  • Opt out of targeted advertising — via the in-app "Privacy & Consent" dialog, the iOS Settings > Privacy > Tracking screen, or the Android "Opt out of Ads Personalization" setting.
  • Lodge a complaint — with your local data protection authority.

To exercise any of these rights, email aycakalmaz5@gmail.com with enough information for us to verify your identity. We may need to confirm your identity before responding.

17. Changes to this policy

We may update this policy from time to time. When we do, we will revise the "Last updated" date at the top of this page. For material changes, we will provide additional notice — for example, an in-app banner, an email to registered users, or a prominent notice on our website — at least 14 days before the change takes effect, unless a shorter period is required by law.

18. Contact us

If you have any questions, requests, or complaints about this policy or our handling of your data, please contact us:

  • By email: aycakalmaz5@gmail.com
  • By website: rapmtwa.com/contact
  • Subject line prefix: "Privacy" — helps us route your message quickly.

We aim to acknowledge privacy requests within 3 business days and to substantively respond within 30 days (45 days in California, extendable where permitted by law).

© 2026 Ra PmtWA. This policy is also accessible in-app via Settings > Privacy.

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