Privacy Policy

Last updated: 6 October 2026

This Privacy Policy explains how Refold Games AB ("Refold", "we", "us" or "our") collects, uses and protects information when you play or otherwise interact with games published by Refold.

This Privacy Policy applies to Refold games distributed through websites, mobile applications and third-party game platforms, including games available on iOS and Android.

1. Who we are

Refold Games AB is a company registered in Sweden.

Refold Games AB
Västberga allé 7
126 30 Hägersten
Sweden

For questions about this Privacy Policy or our processing of personal data, contact:

privacy@refold.io

Refold Games AB is the data controller for personal data processed by us in connection with our games, except where another company acts as an independent controller for its own services.

2. Information we collect

Our games do not require you to create a user account.

Depending on the game, platform and your privacy choices, we may collect technical and usage information such as:

  • device type and device model;
  • operating system and version;
  • browser type and version;
  • game and application version;
  • country or approximate geographic location;
  • IP address;
  • device, installation, advertising or similar identifiers;
  • session duration and frequency of play;
  • gameplay activity, progress and in-game events;
  • game performance information;
  • crash reports, error messages and diagnostic information;
  • information relating to advertisements shown or interacted with; and
  • technical information required to provide cloud saves or leaderboards.

We do not intentionally collect information such as your name, postal address, email address or telephone number through our games.

Some of the information described above may not directly identify you by name but may nevertheless constitute personal data under applicable data protection law because it can be associated with a device, installation or individual. We therefore treat such information as pseudonymous data where appropriate rather than assuming that it is fully anonymous.

We may also create aggregated or anonymized statistics that can no longer reasonably be associated with an individual. Such information is not personal data and may be retained and used for purposes such as game development, statistics and business analysis.

3. How we use information

We use information collected through our games to:

  • operate and provide our games;
  • understand how our games are used;
  • analyze gameplay and player engagement;
  • improve game design, balancing, usability and performance;
  • identify and fix errors, crashes and technical problems;
  • provide cloud save functionality where available;
  • provide leaderboards where available;
  • prevent fraud, abuse and misuse;
  • display and measure advertising;
  • process and verify in-app purchases;
  • comply with legal obligations; and
  • protect our rights, users and services.

4. Analytics

We use third-party analytics services to understand how our games are used.

These services may process information such as device information, operating system, country or approximate location, game version, gameplay events, session information, identifiers and other technical information.

We use this information primarily to understand game usage, improve our games and identify features or areas that may need improvement.

Where applicable law requires consent before analytics technologies or identifiers may be used, analytics processing will be subject to the choices presented to you through the relevant consent mechanism.

5. Error and crash reporting

We use third-party services to identify crashes, errors and performance problems.

Information sent may include:

  • device and operating system information;
  • game or application version;
  • IP address;
  • technical identifiers;
  • crash information;
  • error messages;
  • stack traces; and
  • diagnostic and performance information surrounding an error.

We use this information to maintain the stability, security and performance of our games.

We configure our services with the aim of avoiding unnecessary personal information in crash and error reports.

6. Advertising

Some of our games are supported by advertising.

For mobile games, we may use third-party services to display and measure advertisements.

For web games, advertising and monetization may be provided through the platform on which the game is available.

Advertising providers may process information such as device identifiers, advertising identifiers, IP addresses, approximate location, information about advertisements displayed or interacted with and information about your device and use of the game.

Advertising may be personalized or non-personalized depending on the platform, your location, applicable law and your privacy choices.

Where required by law, we or the relevant platform will request consent before using information for personalized advertising, advertising measurement or related purposes.

You may be given controls to manage or withdraw your advertising consent. On mobile devices, additional advertising privacy controls may also be available through the operating system.

Third-party platforms and advertising providers may act as independent data controllers for some of their processing. Their processing is also governed by their own privacy policies and terms.

7. In-app purchases

Some games allow you to purchase digital items, features or other content.

Payments in our mobile games are processed by:

  • Apple through the Apple App Store; or
  • Google through Google Play.

Refold does not receive or store your full payment card information.

Apple or Google may provide us with transaction information, purchase receipts, product identifiers or similar information required to verify a purchase, restore purchases, prevent fraud or provide purchased content.

Payment information processed directly by Apple or Google is governed by their respective privacy policies and terms.

8. Cloud saves and leaderboards

Some games may provide cloud saving or leaderboard functionality.

Because our games do not require user accounts, these features may use an automatically generated game, installation or device identifier to associate information with a particular game installation or player.

Cloud save information may include game progress, settings, unlocked content and other gameplay information.

Leaderboard information may include scores, rankings, automatically generated player identifiers and, where a game allows the player to choose one, a display name.

Please do not include personal information in a leaderboard display name.

9. Legal bases for processing

Where the EU General Data Protection Regulation ("GDPR") applies, we process personal data using one or more of the following legal bases:

Consent
We rely on your consent where required, particularly for certain analytics, advertising, advertising identifiers, cookies or similar technologies.

You may withdraw your consent at any time through the privacy controls made available in the game, application, platform or device. Withdrawal does not affect processing that took place before consent was withdrawn.

Performance of a contract
We may process information when necessary to provide a game, feature or purchase that you have requested.

Legitimate interests
We may process limited information where necessary for our legitimate interests, including operating and improving our games, diagnosing technical problems, maintaining security, preventing fraud and understanding the general performance of our services, provided that those interests are not overridden by your rights and interests.

Legal obligations
We may process or retain information where necessary to comply with applicable laws, accounting requirements, court orders or other legal obligations.

10. Data retention

We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy.

Our general retention periods are:

  • analytics user-level and event-level data: up to 14 months;
  • crash, error and diagnostic data: normally up to 90 days;
  • cloud save and leaderboard data: normally up to 24 months following the player's last activity;
  • purchase and transaction information: for as long as necessary to verify and support purchases, prevent fraud and comply with applicable legal or accounting requirements; and
  • consent records and other compliance information: for as long as reasonably necessary to demonstrate compliance with applicable law.

Information may be deleted earlier when it is no longer required.

Aggregated or anonymized information that can no longer reasonably be linked to an individual may be retained for longer periods.

In some cases, technical limitations may make it impossible for us to associate information with a particular person, particularly because our games do not require user accounts.

11. International data transfers

Refold Games AB is based in Sweden, but some of the service providers used by our games operate globally.

As a result, personal data may be processed in countries outside Sweden and the European Economic Area ("EEA"), including the United States.

Where personal data is transferred outside the EEA, we and our service providers use appropriate safeguards as required by applicable data protection law. Depending on the recipient, these safeguards may include:

  • a European Commission adequacy decision;
  • participation in the EU-U.S. Data Privacy Framework, where applicable;
  • European Commission Standard Contractual Clauses; or
  • other legally recognized transfer mechanisms.

12. Third-party services and platforms

Our games may use or be distributed through third-party services.

These providers may process personal data on our behalf, as independent controllers, or both, depending on the service and circumstances.

When you access one of our games through a third-party website, application store or game platform, that platform may independently collect information about you according to its own privacy policy. Refold does not control all processing performed independently by those platforms.

We encourage you to review the privacy information provided by the platform through which you access the game.

13. Children

Our games are not directed at children under the age of 13.

We do not knowingly collect personal data from children under 13 in circumstances where parental consent would be required.

If you are a parent or guardian and believe that a child under 13 has provided personal data to us, please contact us at privacy@refold.io. We will investigate the matter and, where appropriate, take reasonable steps to delete the information.

Some distribution platforms may apply additional age-related requirements, restrictions or privacy protections.

14. Your rights

If the GDPR or similar data protection legislation applies to you, you may have the right to:

  • request access to personal data we hold about you;
  • request correction of inaccurate personal data;
  • request deletion of your personal data;
  • request restriction of certain processing;
  • object to processing based on legitimate interests;
  • withdraw consent where processing is based on consent;
  • receive certain personal data in a portable format; and
  • lodge a complaint with a data protection authority.

To exercise any of these rights, contact us at:

privacy@refold.io

Because our games generally do not use accounts and we may only hold pseudonymous technical identifiers, we may need information such as a game identifier, installation identifier or other technical information in order to locate data associated with you.

In some cases we may be unable to identify which data relates to you without additional information. We will not collect additional personal information solely for the purpose of identifying you unless reasonably necessary to process your request.

15. Complaints

If you are located in Sweden, you have the right to lodge a complaint concerning our processing of personal data with the Swedish Authority for Privacy Protection:

Integritetsskyddsmyndigheten (IMY)

You may also contact the competent data protection authority in the EU or EEA country where you live or work.

We encourage you to contact us first at privacy@refold.io so that we can try to resolve your concern.

16. Security

We use reasonable technical and organizational measures intended to protect information against unauthorized access, loss, misuse, alteration or disclosure.

However, no internet transmission, application or information-storage system can be guaranteed to be completely secure.

17. Changes to this Privacy Policy

We may update this Privacy Policy from time to time, for example when we:

  • release new games or features;
  • change service providers;
  • change how information is processed; or
  • need to comply with changes in applicable law.

When we make changes, we will update the "Last updated" date at the beginning of this Privacy Policy.

If changes materially affect how we process personal data, we will provide additional notice where required by applicable law.

18. Contact us

If you have questions about this Privacy Policy, our processing of personal data or your privacy rights, please contact:

Refold Games AB
Västberga allé 7
126 30 Hägersten
Sweden

Email: privacy@refold.io