Privacy Policy

Effective: April 2026

I, Jochen Bregar, (collectively, "Winthir Studios" or "we", "us", "our") create and publish mobile games and applications. This Privacy Policy ("Policy") applies to all our games, websites and related services, collectively referred to here as our services. This Privacy Policy explains how we, and affiliated companies, collect, use, secure, and/or disclose end-users' ("you" or "your") personal information when you use our services.

1) Personal Data That We Collect

While using our services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to, your name ("Personal Information", "Personal data" or "data").

Personal information includes:

• Your name
• Email address or other contact details
• Any information you submit to our customer service team in the services or via email

Other than that, we may also collect certain data automatically such as:

• Communications in the services (e.g. messages with other players and in-game chats)
• Data and analytics about your use (e.g. play progress, levels, games played, session length, preferred settings, which in-game adverts you may have viewed)
• In-game preferences or game preferences, which friends you connect with
• IP address and device identifiers such as your Advertising ID, Device ID numbers, device type, and operating system
• General geographic location (e.g. country or city) based on your IP address and GPS location, with your consent

Some of these pieces of data may be collected using cookies and/or similar technologies (such as software development kits, or "SDKs").

2) How We Use Your Personal Data

When you install and use Winthir Studios mobile applications, we may collect and process some of your data for different legitimate purposes. Below are the reasons why Winthir Studios may collect data and the legal bases our company relies on in each case.

To provide and maintain our services, recognize you when you return to our games, and perform essential business operations:

• Legal basis: such data processing is strictly necessary for the service(s) requested.

To administer and protect our services (including troubleshooting, data analysis, testing, support, fraud prevention, reporting, and hosting of data):

• Legal basis: legitimate interests for running our business, provision of administration and services.

To cross-advertise our services and products and to send push notifications for changes to our services:

• Legal basis: legitimate interests in advertising our services and products and keeping users updated about new features.

To serve ads tailored to your preferences and interests, allowing us to continue offering free services and products:

• Legal basis: legitimate interests in running our business.

3) Website-Specific Data Processing

In addition to the above, the following applies specifically to the use of our website winthirstudios.com:

Server Log Files

Our hosting provider IONOS automatically collects and stores information in server log files which your browser transmits to us. These are: browser type and version, operating system used, referrer URL, hostname of the accessing computer, time of the server request, and IP address. This data is not merged with other data sources. The legal basis for the processing is Art. 6(1)(f) GDPR — legitimate interest in the technically error-free presentation and optimization of our website.

Newsletter (Buttondown)

If you sign up for our newsletter, we use the email service provider Buttondown (operated by Buttondown, LLC, USA) to send you emails. To do so, we transfer your email address to Buttondown. Your email is processed on the legal basis of your consent (Art. 6(1)(a) GDPR) and is stored until you unsubscribe. Every newsletter contains an unsubscribe link. Buttondown's privacy policy is available at https://buttondown.com/legal/privacy. Data may be transferred to the USA, where appropriate safeguards are in place under the EU-U.S. Data Privacy Framework.

Fonts

Our website uses self-hosted web fonts (Bricolage Grotesque and Outfit, both licensed under the SIL Open Font License). The font files are served from our own server. No font data is loaded from third-party providers, and no IP addresses are transmitted to external font services.

4) How We May Disclose Your Data

We will not rent or sell your personal data to third parties, but we may share your information from tools like cookies, log files, and device identifiers and location data with third-party organizations that provide automatic data processing technologies for the games. We do not control or influence these third parties' tracking technologies or how they may be used.

Ad Partners allow us to monetize ad inventory in our games and provide users with free products and services. These partners usually collect data via their own SDKs. Our advertising partners include:

• Unity Ads — https://unity3d.com/legal/privacy-policy

Analytics companies provide tools that help us understand how users interact with our services and improve them. These partners usually collect data via their own SDKs. Our analytics partners include:

• Google — https://policies.google.com/privacy

5) International Data Transfers

We are an international organization providing our games to users around the world. We and third-party organizations that provide automatic data processing technologies for the services or our third-party advertising partners may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world.

Please note that these countries and jurisdictions may not have the same data protection laws as your own. We take steps to ensure adequate safeguards are in place for the use and disclosure of information about you, including personal data, as described in this Privacy Policy.

6) Your Data Protection Rights

You may access, correct, update, or request deletion of your personal information. We will respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. You can exercise your data protection rights by contacting us using the information in the "Contact Us" section below.

Users' Rights in the European Countries

We are a data controller with respect to any personal information collected from individuals accessing or using our services. If you are located in the European Union, European Economic Area, United Kingdom, or Switzerland, you have the following data protection rights:

The Right of Access / The Right to Know

You may request a copy of your personal information in our files without undue delay and free of charge, unless we are permitted by law to charge a fee. You may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another "controller", where technically feasible.

The Right to Rectification

You may request to correct or update any of your personal information in our files.

The Right to Deletion

You have a right to have your personal information in our files deleted.

The Right to Restriction

You have the right to restrict our processing of your personal information.

The Right to Object

You may object to our processing at any time and as permitted by applicable law if we process your personal information on the legal bases of: consent; contract; or legitimate interests.

Automated Individual Decision-Making, Including Profiling

You have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, unless an exception applies under applicable law.

The Right to Lodge a Complaint

If you are located in the EU, EEA, UK, or Switzerland, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal data violates applicable data protection law.

Users' Rights in California

As a California resident, you may exercise the following rights in addition to the rights listed in the previous section regarding the personal information we collect about you, within the scope of the California Consumer Privacy Act of 2018 ("CCPA"):

The Right to Opt-Out of Personal Information Sales

You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future. If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.

The Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising any of the rights described above.

"Shine the Light"

California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California's "Shine the Light" law (Civ. Code § 1798.83).

To exercise your right to know and right to deletion, please submit a request by contacting us with the subject line "California Rights Request" in the "Contact Us" section.

7) Cookies and Push Notifications

Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer's hard drive. Like many services, we use cookies to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our services.

On the other hand, we may occasionally use push notifications through our services to send you game updates, high scores, and other service-related notifications. You may turn them off at the device level if you do not want to receive these types of communications.

8) Retention of Your Personal Data

We retain your personal data for as long as needed to provide you services, unless we are required by law to delete or asked to delete the information. If you no longer want us to use your information, you can request that we erase your personal information and close your account.

We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

9) Security

The security of your personal data is important to us. We take reasonable and appropriate measures to protect personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal data.

Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

10) Children

Our services are not intended for use by children under the age of sixteen (16). We will not knowingly collect personal information directly from children under the age of sixteen (16) without parental consent. To request the deletion of personal data, for any reason, please contact us.

11) Changes to This Privacy Policy

This Privacy Policy is effective except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page. We reserve the right to update or change our Privacy Policy at any time, and you should check this Privacy Policy periodically. Your continued use of the service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide by the modified Privacy Policy. In some changes to this Privacy Policy, we may notify you either through the email address you have provided us or by placing a prominent notice on our service.

12) Contact Us

If you have any questions about this Privacy Policy or further information related to its scope, please contact us at: info@winthirstudios.com