This Privacy Policy ("Policy") explains how Wonderful Studio ("Wonderful Studio", "we", "us", or "our")
processes personal information when you use our mobile games, websites, and related Services (collectively,
the "Services"). Wonderful Studio is operated by WONDERFUL TYCOON LIMITED, the controller who is responsible
for handling your personal data under this Policy.
Please read this Policy carefully before using our Services. You can review and adjust your privacy
preferences at any time through the settings menu in our games.
1.Information We Collect
We may collect personal information in two ways: information you provide directly, and information we collect
automatically.
1.1Information You Provide to Us
Profile Details: When you create an in-game profile, you may choose a nickname and an
avatar from our preset library.
Age Range: We may ask you to indicate your age range (0-35, 35-55, 55+). We only collect
your age range instead of a precise age or date of birth.
Daily Engagement Data: If you take part in daily check-ins, streak challenges, or task-based
reward programs, we keep a record of your participation status, completion timestamps, and rewards earned.
Leaderboard Data: If you join leaderboards or ranking features, we may collect your
nickname, avatar, scores, and ranking positions. Some of this information may be visible to other players.
Support Correspondence: When you contact us for assistance or feedback, join promotions,
surveys, contests, or other activities, or subscribe to our updates or notifications, we may collect your
nickname, email address, your communications with us, and any other details you provide. The exact information
collected depends on the service you are using.
1.2Information Collected AutomaticallyWhen you access the Services, we automatically collect certain technical and
behavioral information:
Identifiers: An internally generated user identifier, device-level identifiers (such as IDFV
or Android ID), advertising identifiers (such as IDFA or GAID), and partner-assigned identifiers (such as
Pangle ID or AppsFlyer ID). We also derive a coarse geographic location (country or region) from your IP
address; the raw IP itself is not retained.
Device and Technical Information: Device model, time zone, device country, system language,
CPU and hardware attributes, available storage, screen attributes, network type and status, operating system
information, and other technical data.
Usage Information: Session start and end times, features accessed, in-game progress,
achievement unlocks, leaderboard standings, total playtime, daily check-in and task completion records,
general interaction patterns, and data about your interaction with our Services.
Ad Interaction Information: Information about your interactions with ads displayed within the
Services, including whether you viewed, tapped, or watched a rewarded ad to completion.
1.3Sensitive Personal Information
We do not intentionally collect sensitive personal information (such as biometric data, health information).
If we find that such information has been collected inadvertently, we will erase it without undue delay.
2.How We Process Your Information
We process your personal information for the purposes set out below, relying on the corresponding legal bases
where applicable.
2.1Delivering and Maintaining the Service: We use Profile Details, Age Range, Daily Engagement
Data, Leaderboard Data, Identifiers, Device and Technical Information, and Usage Information to run our games,
push updates, resolve technical issues, manage game functions, and deliver age-appropriate content.
Legal basis: Performance of a contract; Consent.
2.2Enhancing User Experience: We analyze Identifiers, Device and Technical Information, and Usage
Information to understand player behavior, identify trends, optimize game mechanics, and improve the overall
stability and performance of the Services. Legal basis: Legitimate interests.
2.3Service Communications: We use Identifiers and Device and Technical Information to deliver
operational notices, including security alerts, maintenance announcements, and Policy updates.
Legal basis: Performance of a contract; Legitimate interests.
2.4Promotional Communications: With your permission, we may send push notifications about new
features, invitations, events, or offers that might interest you. Legal basis: Consent.
2.5User Support: We use Support Correspondence to address your inquiries and issues, process
complaints, and refine our support workflows. Legal basis: Performance of a contract; Legitimate
interests.
2.6Surveys and Activities: When you voluntarily participate in promotions, surveys, contests, or
similar activities, we process your Support Correspondence for administration and analysis.
Legal basis: Consent.
2.7Advertising: We process Identifiers, Device and Technical Information, and Ad Interaction
Information to display personalized or contextual advertising and to measure, optimize, and prevent fraud in our
advertising campaigns. Legal basis: Legitimate interests (contextual advertising and fraud prevention);
Consent (personalized advertising and ad measurement that depend on device identifiers).
2.8Service Integrity and Security: We rely on Identifiers and Usage Information to detect fraud,
deter abuse, verify accounts, and safeguard the Services. Legal basis: Legitimate interests.
2.9Regulatory Compliance: We process the necessary categories of information to meet our
obligations under tax laws, consumer protection laws, content regulations, and other applicable rules.
Legal basis: Legal obligation.
Where we rely on legitimate interests, we have carried out balancing assessments to confirm that our
processing does not unduly affect your fundamental rights. You may object to such processing at any time as
permitted by applicable law.
3.How We Share Your Personal Information
We share personal information only where there is a lawful reason to do so, including the situations described
below.
3.1Corporate Group: We may share information with companies within our corporate family for
purposes consistent with this Policy. Appropriate contractual and organizational safeguards are in place for any
such sharing.
3.2Service Providers: We engage trusted service providers to help us operate the Services. They
act on our instructions and are bound by data processing agreements:
3.3Advertising Partners: We work with third-party advertising partners that may act as
independent controllers or, in some scenarios, as joint controllers with us. They may receive Identifiers,
Device and Technical Information, and Advertising Interaction Information to deliver and measure ads.
Your choices for EEA, Switzerland, and UK: Personalized advertising requires your consent,
managed through the UMP SDK. You can change your preferences at any time in the in-game privacy settings.
Opting out does not remove ads, but the ads you see will no longer be tailored to you.
Your choices for the United States: Under CCPA/CPRA, our sharing of identifiers with
advertising partners may constitute a "sale" or "sharing" of personal information. You can opt out at any time
through the "Do Not Sell or Share My Data" option in your in-game settings.
3.4Other Disclosures: We may also disclose your information in the following circumstances:
Where we sell, transfer, or merge parts of our business or assets, the new owners will assume our rights and
obligations under this Policy;
Where required for purposes of national security, law enforcement, or other public interests.
4.International Transfer
Our data is stored in the eastern United States. Because we serve a global audience, your personal information may
be processed in jurisdictions outside your country of residence by our affiliates, service providers, or advertising
partners.
For each international transfer, we take appropriate legal safeguards, including Standard Contractual Clauses
(SCCs), adequacy decisions, or equivalent mechanisms, to ensure your information receives a level of protection
consistent with applicable law.
5.Data Security
We are committed to keeping your personal data safe. In line with applicable laws, we take reasonable and
appropriate administrative, technical, organizational, and physical security and risk management measures
designed to protect your personal data against accidental or unlawful destruction, damage, loss or alteration,
unauthorized or unlawful access, disclosure or misuse, and any other unlawful form of processing of the personal
information.
6.Data Retention
We retain your personal data only for as long as reasonably necessary to fulfill the purposes set out in this
Policy. Once it is no longer required for those purposes, we will either delete or anonymize it, unless
applicable laws require otherwise.
7.Your Privacy Rights
7.1
Depending on where you reside, you may exercise the following rights with respect to
your personal information:
Access Right: Request a copy of the information we hold about you.
Correction Right: Request to correct inaccurate or incomplete information.
Deletion Right: Request to delete your information, subject to legal retention obligations.
Restriction Right: Ask us to limit certain processing activities.
Objection Right: Object to processing based on our legitimate interests.
Consent Withdrawal: Withdraw consent at any time through the in-game privacy settings.
Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.
Data Portability Right (EEA, UK, Brazil): Receive your information in a structured,
machine-readable format, or request its transmission to another controller where technically feasible.
Complaint Right: Lodge a complaint with your local data protection authority.
7.2
To exercise any of these rights, please email us at privacy@wondtycoon.com. We may need to verify your identity before
processing the request, and we will respond within the timeframes required by applicable law.
8.Children's Privacy
Our Services are designed for users of various age groups. We do not knowingly collect personal information
from, or serve targeted advertising to, children as defined by applicable laws. If you believe that we may hold
information about a child, or have served targeted advertising to a child in breach of this Policy, please
contact us at privacy@wondtycoon.com.
9.Contact Us
For any privacy-related questions, rights requests, or feedback, please contact us at privacy@wondtycoon.com.
10.Updates to This Policy
We may revise this Policy from time to time. We will notify you of any material changes by posting a prominent
notice within the Services together with the updated Policy. By continuing to use the Services, you confirm
that you have read and understood the updated Policy.
11.Jurisdiction-Specific Terms
The following terms apply in addition to this Policy where required by the laws of the relevant jurisdiction.
11.1 EEA, Switzerland, and UK
Legal Basis: We process your personal information in accordance with one of the legal bases
set out under European data protection laws. See Section 2 for the
specific legal basis applicable to each processing purpose.
International Transfers: We rely on adequacy decisions where available and Standard
Contractual Clauses, supplemented by transfer impact assessments and additional technical or organizational
measures where warranted.
EEA Local Representative:
The DPO Centre Europe Limited
Alexandra House, 3 Ballsbridge Park, Dublin, D04 C7H2, Ireland.
Email: eurep@wondtycoon.com.
Supervisory Authorities: You may lodge a complaint with your local supervisory authority.
11.2 United States
Additional Rights: You may request details about the categories of personal information
collected, sold, disclosed, or shared; the purposes for which this personal information was collected, sold, or
shared; the categories of sources of personal information; and the categories of third parties with whom we
disclosed or shared this personal information.
Right to Opt Out of Sale/Sharing: See Section 3.3 for
instructions on opting out of the "sale" or "sharing" of your personal information as defined under applicable
state privacy laws.
Authorized Agents: You may designate an authorized agent to submit a request on your behalf.
We may require verification of the agent's authority and your identity.
Non-Discrimination: Exercising your privacy rights will not result in discriminatory treatment
regarding the price or quality of our Services.
Appeals: If you disagree with our response to a rights request, you may appeal by emailing privacy@wondtycoon.com. We will respond within the legally
prescribed timeframe.
11.3 Brazil
Legal Basis: We process personal information of Brazilian residents in accordance with the Lei
Geral de Proteção de Dados (LGPD). Applicable legal bases include contractual performance, legal obligations,
legitimate interests, and consent.
International Transfers: Where information is transferred outside Brazil, we ensure LGPD
compliance through recognized adequacy findings, contractual safeguards, or other lawful transfer mechanisms.
Additional LGPD Rights: Confirmation of whether we process your personal information;
anonymization or blocking of unnecessary, excessive, or unlawfully processed information; information about
entities with which your information has been shared; and notification regarding the possibility and
consequences of denying consent.
11.4 South Korea
Legal Basis: We process personal information in South Korea in accordance with the Personal
Information Protection Act (PIPA) based on consent, contractual necessity, and legal obligations where
applicable.
Outsourcing (Entrustment) of Processing: We outsource certain personal information processing
tasks to service providers as described in Section 3.2 and supervise
their compliance through entrustment agreements.
International Transfers: Your personal information may be transferred to and processed in
countries outside South Korea as described in Section 3. Refusing
overseas transfer may result in restrictions on all or part of our Services where such transfer is necessary
for global service delivery.
Additional Rights Under PIPA: You may seek remedies for damages arising from the processing of
your personal information.
Destruction of Personal Information: When personal information is no longer necessary for the
purpose for which it was collected, we will destroy such information without delay in a manner that renders it
unrecoverable unless retention is required by law.
11.5 Japan
International Transfers: Where personal information is transferred outside Japan, we comply
with the Act on the Protection of Personal Information (APPI) by relying on recognized adequacy, contractual
protections with recipients, or your consent as applicable.
Additional APPI Rights: You may request notification of the purpose of use of your retained
personal information and request suspension of use or cessation of third-party provision where information has
been handled in violation of the APPI.
Security Management Measures: We implement necessary and appropriate administrative,
technical, and organizational measures to prevent leakage, loss, or damage to personal information.