This Privacy Policy describes how BFA Ltd (“BFA”) and its third-party marketing and advertising partners (collectively, “Business Partners”) collect, use, process and share information related to you. This policy applies to all our games applications, whether downloaded from Google Play or App Store, on any mobile devices, or on any other platform where we may make our games applications available (“App”), and to all our marketing and advertising activities on all media and platforms and other services that we may provide to you from time to time. In this Privacy Policy we refer to our Games, Website, marketing and advertising activities and other services we offer collectively as our “Services“.

The App is a free to play game (with optional in-game-purchases), and in order to maintain a great game experience we process information from and about you in particular to improve the entire experience in the App and to support internal operations.

We update this Privacy Policy from time to time. We encourage you to review the Privacy Policy whenever you access the App to stay informed about how we process your personal data and how you can protect your privacy.

Collection of information

Regarding the General Data Protection Regulation (GDPR) right to request your data deletion please contact our mail:

When you access or use the App, we automatically collect general information about you, including: - Log Information - Device Information - Usage Information - Consumption information

If you log into the App using a third party site or platform suchas Facebook, Apple Game Center and Google Sign-In etc, we access information about you from that site or platform, such as your screen name, profile information and friend lists, in accordance with the authorization procedures determined by such third party site or platform provided that you have given the third party site in question such consent.

If you log into the App using a third party site or platform, you represent and warrant that (i) your access and use of such features in connection with the App will comply with the applicable terms and policies of such site or platform; and (ii) that you are over the minimum age limit that is prescribed for such third party site or platform by the legislation in the individual jurisdictions.

Use of information –purpose and legal basis

We use information about you for the following purposes in accordance with the legal bases for each type of personal data as described below:

Log-, device-, usage-, and consumption information -are being processed: a. to provide and deliver the products and services you request and send you related information as requested by you / as agreed with you; Our processing for the above purpose is necessary for compliance purposes, see Article 6(1)(c) of the GDPR. 1 b. to provide and maintain the App and the game experience; and c. to send you technical notices, updates, security alerts, and support and administrative messages; Our processing for the above purposes is necessary for the performance of a contract to which you are party in order to support the operation of the App, facilitate the delivery of requested products and services and enable maintenance and update of the App, see Article 6(1)(b) of the GDPR. provide news and information about the App that we think will be of interest to you; personalize and improve the App and provide tailored content and features; monitor and analyze trends, usage and activitiesin connection with the App; and provide children (as this term is construed under GDPR in EU, COPPA in the US and relevant applicable legislation in other jurisdictions) with reasonable contextual advertisements in the App. Our processing for the above purposes is justified by our legitimate interests in providing advertisements and content of interest to you and improving our services in accordance with Article 6(1)(f) of the GDPR (also known as "the balancing-of-interest rule"). provide non-child users that have given us consent to share their advertising IDs with our ad network partners (as further specified under Sharing of Information) for the purpose of serving them with personalized advertisement in the App (behavioral advertising). Our processing for the above purpose is justified by our legitimate interests in providing advertisements and content of interest to you in accordance with Article 6(1)(f) of the GDPR. The disclosure of your advertising ID to third parties for the purposes of behavioral advertising is based on your consent in accordance with Article 6(1)(a) of the GDPR (see more below under Sharing of Information).

Information from other sources -are being processed: j. to provide and deliver the products and services you request and send you related information; Our processing for the above purpose is necessary for the performance of a contract to which you are party in order to facilitate the delivery of requested products and services, see Section 6(1)(b) of the GDPR. link or combine information we get from others to help understand your needs and provide you with better service; and provide news and information about the App we think will be of interest to you; Our processing for the above purposes is justified by our legitimate interests in providing content of interest to you and improving our services in accordance with Article 6(1)(f) of the GDPR. We only process your information to the extent that is necessary to achieve the purposes for which the information has been collected.

Storage of information

BFA will store your personal data for as long as necessary in order to provide you with the App or otherwise fulfil the purposes as described above, unless further storage is required in order to establish, exercise or defend a legal claim or to comply with applicable law, including accounting rules. Your personal data are deleted or anonymized as soon as it no longer serves one of the above mentioned purposes

Sharing of information

We disclose information about you to the following categories of recipients based on the legal bases in Sections 6(1)(b), 6(1)(c) and 6(1)(f) of the GDPR (see a description of the legal bases above): •Social networks, see more under "Social Sharing features"; •Third parties if we are required to disclose your personal data by applicable law, rule, regulation, legal process or in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company; •The authorities if we believe your actions are inconsistent with the spirit or language of our policies or if the disclosure is necessary to protect the rights, property and safety of BFA or others; •Other players in order to provide certain in-app features, such as leaderboards, if you log into the App using a third-party service, such as Facebook or Apple Game Center; •Advertising network companies in order to serve contextual advertisements (the data include your IP-address, Device ID and advertising ID). Furthermore, if you have given your consent in accordance with Section 6(1)(a) of the GDPR, we share your advertising ID to advertising network companies for the purpose of them serving behavioral advertisements to you within the App.


When you access or use the Service, we may use industry-wide technologies which temporarily store certain information on your smartphone, your computer or other mobile device (“Local Storage”) and that allow us to enable automatic activation of certain features, and make your Service experience much more convenient and effortless. The Local Storage used by the Service is created per session and is removed as your session ends.

We also use certain monitoring and tracking technologies, including ones offered by third party service providers in order to collect and process Personal Data we specified above. These technologies are used in order to maintain, provide and improve our Services on an ongoing basis, in order to provide a better experience to our users and to provide our customers and potential customers with more relevant advertisements through our Services. For example, these technologies enable us to: (i) keep track of and apply our customer’s and potential customers’ Services and Website preferences and authenticated sessions, (ii) better secure our Services by detecting abnormal behaviors, (iii) identify technical issues and improve the overall performance of our Services, (iv) monitor and analyze our ads’ performance (v) create and monitor analytics relating to use of our Services, and (v) deliver to you targeted advertisements that are more tailored to you based on your browsing activities and inferred interests.

Cookies: A cookie is a small data file that is downloaded and stored on your computer or mobile device when you visit our Website. Learn more about cookies here: Pixel Tags: Pixel tags (also commonly known as web beacons) are transparent images, iFrames, or JavaScript placed on our Website or our advertisements and emails, that our third party service providers use to understand how the Website, such advertisements and emails are interacted with. To learn more about our use of Cookies and other tracking technology that we use please see our Cookie Policy.

Some of these tracking technologies are provided to us for implementation by our third party services providers referenced in Section ‎4 above. Some of these third party services providers may have direct contractual relationship with you (such as Google and Facebook). Additionally the services provided to us by such third party services providers may entail collection and processing of personal information by such third party services providers, in a scope which is broader than the scope of personal information we are eventually provided with by such third party services providers. This means that sometimes these third party services providers have more access to your personal information than we do. For example, our payment gateway service provider has access to your financial information under strict terms, while we do not receive such access at all in order to better protect your rights. To the extent you have direct contractual relationship with any of our third party services providers, any rights you may have with respect to your information, collected by such third party services providers, shall be governed by such contractual relationship. Otherwise the terms of this Privacy Policy shall fully apply.

In this context you should note that we may use Google and Facebook’s functionality of re-marketing through their tracking cookies and pixel-based retargeting services. This means that if you provided your consent to Google, Facebook or LinkedIn (the “Social Ad Platforms”) to be provided with personalized commercial offers, you may be served with ads (including advertisements of third parties) based on your access to the Services or Website, outside of the Services and Website and across the internet. In such event the Social Ad Platforms, will either place cookies on your web browser or retain similar data in their systems and use such cookies and data to serve you ads based on past visits to our Services and Website.

We use or may use the following advertising network companies: • Unity3d Ad network •Appodeal, Inc •Adcolony•Chartboost •Facebook Ads •Flurry •InMobi •Supersonic/IronSource •Tapjoy •Vungle •Mobvista The recipients' use of the disclosed information will not be covered by this Privacy Policy. If you have questions concerning the processing carried out by such third parties, you should review their privacy policy. In connection with our processing, we use data processors such as server hosting providers, technical service providers for supporting internal operations, user login services and analytics service providers.

Social sharing features The App offers social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take in the App with other media. You must be over the minimum age limit that is prescribed by the legislation in the individual jurisdictions to use any social sharing features integrated in the App. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. The App may containsocial features from the following providers: •Facebook •Apple Game Center•Google Play Games ServicesFor more information about the processing carried out by the respective third parties in connection with social sharing features, please visit the privacy policies of the entities that provide these features, which can be found here: •Facebook:•Apple Game Center:•Google Play Games Services:


You must be over a certain age to play our App and use our Services, depending on where you live. We do not knowingly collect or solicit Personal Data from or direct or target interest based advertising to anyone under the ages set out , or knowingly allow such persons to use our Services. If you believe that we might have any information from or about a child under the age set out below, please Contact Us.

If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the ages set out below, and that you have read and acknowledged this Privacy Policy.

The App is for a general audience. In order to comply with the legislation, you maybe presented to an age screen, when launching the App. When presented with this age screen, it is important that you state the correct age.

If you believe that we might have any information from or about a child under the relevant age set out above, please Contact Us. In the event that we learn that we have collected Personal Data from a child under the relevant age set out above, we will delete that information as quickly as possible.


BFA takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

Your rights

If you wish to use any of the rights described below, you may contact us at any time by emailing us at We process and answer your requests without undue delay and our response time can be up to three months in total as permitted by Article 12 of the GDPR.

Right to request access

You have the right to request access into the data that we are processing on you, see Article 15 of the GDPR, including information about: •the purposes of the processing •the categories of personal data concerned •the recipients or categories of recipient to whom the personal data have been or will be disclosed •the envisaged period for which the personal data will be stored Furthermore, you have the right to obtain a copy of the personal data undergoing processing. Please note that the access may be restricted due to intellectual property or trade secrets.

The right to object You have the right to object to our processing of your personal data on grounds relating to your particular situation when the data are processed based on the balancing-of-interest rule in Section 6(1)(f) of the GDPR, see Article 21 of the GDPR. In this case, we will cease the processing unless there are compelling legitimate grounds for the processing which override your interests, rights and freedoms or if the processing is necessary for the establishment, exercise or defense of legal claims. You have the right to object to our processing of your personal data for direct marketing purposes at any time. We will cease the processing of your personal data for this purpose after the objection. Please note that if you exercise this right, your user license to use the App will cease automatically.

Right torectification and erasure You have the right to have inaccurate personal data rectified, see Article 16 of the GDPR. Furthermore, you have the right to have your personal data erased where one of the following grounds applies, see Article 17 of the GDPR: •the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed, •if you have withdrawn your consent and there are no other legal grounds for the processing, •if you have objected to the processing and there are no overriding legitimate grounds for the processing, •the personal data have to be erased for compliance with a legal obligation in Union or Member State law, •the personal data have been unlawfully processed or •the personal data have been collected in relation to the offer of information society services. Please note that your right to erasure may be limited if the data are necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims.

The right to restriction You have the right to obtain restriction of processing in certain circumstances, see Article 18 of the GDPR. If you have the right to restriction, we will only process your data with your consent or for the establishment, exerciseor defense of a legal claim or to protect a person or important grounds of public interest

The right to withdraw consent If we have asked for your consent to our processing of your data, you have the right to withdraw your consent at any time, see Article 7 of the GDPR. If you withdraw your consent, we will cease processing of the data for which you have withdrawn consent, unless we have a legal obligation to keep some or parts of your data. Please note that if you withdraw your consent, your user license to use the App will cease automatically.The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal.

The right to data portability You have the right to receive the personal data you have provided us with which we process in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller if the processing is based on consent or contract performance, see Article 20 of the GDPR.

Push notifications We may send push notifications or alerts to your mobile device to provide game-related information, service updates, promotional communications and other related messages, if you have agreed to such notifications. You can deactivate these notifications by changing your notification settings on your device.


when you use our Services, we may process some of the following information about you:

Information provided by you when using the Games (collected automatically)
your mobile device’s unique device ID (Device ID) and device name;
your user preferences;
data and analytics about your use of our Services, such as: your overall progression to a particular level, your virtual currency or the completion of certain tasks during your gameplay, making a purchase or viewing a video ad.
Information that you provide voluntarily and data you provide to us when contacting us or reporting a problem with our Services:
your avatar/profile picture;
your username/nick;
your email address;
your name;
other details, necessary to process your inquiries.
Information collected and used for the purposes of serving advertisements:
the make, model and operating system of your device;
properties of your device, such as screen size and orientation, audio volume and battery;
the mobile network operator linked to your device;
the games played;
the country, time zone and locale settings on your device (i.e. country and preferred language);
network connection type and speed;
IP Address;
internet browser used to access the games;
the advertiser ID, which is an identifier unique to you if you use an Apple or Android device.
Information collected for the purposes of providing analytics:
your device ID;
your user ID (which is generated by us and allocated to you when you first play our games);
your device operating system & version;
your device make and model;
game play attempts, progression and results;
session game time start, end and duration;
purchase transaction types and spend you have made using virtual items in the games;
the country of your device;
the time, date and install source of your first download (e.g. from a clicked advertisement);
advertisements viewed and clicked;
identification of crashes and defects.
Information about you collected from our Trusted Partners:
When you access our Services via a third party social media provider such as Facebook, we may collect and store personal and non-personal information which is available on that third party social media provider, such as your Facebook name, your profile picture or its URL, your Facebook ID and other public data of your friends, provided that you have expressly agreed to the use of Facebook within our Services. We will also receive technical data in order to ensure our Services connect to the correct Facebook account.In the event that BFA will organize events or competitions for Users, we can also process your correspondence address, phone number, social media ID, your photo and bank account number.In order to fully use our Services, it is necessary to process the data listed above. If you do not agree to provide us with the above information, you will only be able to use our games and other Services to a limited extent.If you make payments under the Services, we will not collect or store any information about your payments. These issues are regulated under the operation of a given payment operator. BFA obtains only the information on making the relevant payment from the operator. We only collect information about transaction dates, currencies, values and products covered by the transaction, to guarantee you obtain the purchased products.

The primary purpose of processing your data is to provide you with our Services, which you use, that is, to perform the agreement between us and your consent to use our Services. The other grounds for processing are the requirements to fulfill the legal obligations imposed on us, fulfillment of the so-called “Legitimate interest” of BFA or for the reasons indicated in other parts of the Privacy Policy („COLLECTED DATA”; „ DATA PROCESSING PURPOSES”).As “Legitimate interest”, BFA treats the legitimate and rational purpose of data processing, in particular, protection of the security of processed data, marketing of BFA’s Services, but most importantly, to ensure that marketing activities addressed to you are appropriate, and to conduct analyzes that will help us to combat any illicit practices.If we invoke a Legitimate interest purpose, we first analyze and consider each potential impact of the processing on you and your rights. In other cases, data processing will always be preceded by your consent, which you can withdraw at any time. Withdrawal of consent does not affect the validity of the data processing prior to its withdrawal.In situations where the transfer of your data outside the European Economic Area occurs, we will execute it in accordance with the rules, which we described below (“Trusted Partners”).
Methods of data storage.
Your data will be available to us as long as it is necessary to meet the objectives set out in our Privacy Policy, in particular, for the time of providing you with the Services or providing you with technical assistance. In the case of processing based on your consent, in the event of its withdrawal we will delete the data without undue delay, no longer than 30 days from the receipt of your request.In exceptional cases, longer storage periods may result from applicable law, e.g. tax regulations or other legal requirements imposed on us, and obligations.At the time when we no longer need your personal data to provide you with the Services, we will remove them or they will be made anonymous.If you’re aware of any security vulnerabilities in our Services, please contact us contact us in particular by sending a message to
Your data may be used by us for the following purposes:

fulfillment of our contractual obligations, as part of the agreement you have concluded with us;
marketing, in particular to provide personalized and targeted marketing mails about the Services which you already use or which we think may interest you. This purpose is optional and we will first get your consent in the required cases;
delivery of the Services ordered by you;
communication with you as a User of our Services;
enable participation in interactive elements of the Services, if that is your will;
inform you about changes in our Services;
improvements to our Services;
organizing competitions by BFA, in particular for contact, mailing and tax purposes;
determining the conversion rate and other components of our services;
tax, legal and settlement;
billing, resulting from EU regulations regarding the protection of personal data;
targeting and personalization of marketing communication, offers and advertisements addressed to you.

In the case of personalization or targeting described above, we can profile your personal data. By doing so, we mean using the information we have collected to tailor the communication addressed to you and to your needs. However, we will not use profiling, which results in making automated decisions, which would affect your legal situation in any way, in particular, we do not submit automated offers by analyzing your behavior as part of the Services.

If you decide that you do not want to receive personalized offers, product recommendations or any advertising information, you can object at any time.

We may process certain aggregated data that is not personal data that relates to the behavior of users, in particular, sales data in individual regions and forward them to our Trusted Partners to provide and improve our Services.
The Services may include links from or to websites or services of third parties. Familiarize yourself with the privacy policies of the above-mentioned third parties.Some of the Services may be characterized by interaction with our Trusted Partners. Therefore, we may share some of your personal information with our Trusted Partner, which will be protected based on their privacy policies. Due to the optionality of such access, it will be preceded by your explicit consent, which you can always withdraw.
As part of creating and providing the Services, we use the help of our Trusted Partners, to whom we can share your data. We guarantee that we provide them with the minimum information necessary to enforce their cooperation. They may access your data and process it on our behalf as “Data Processors”, for the purposes and by the entities listed below:

our subsidiaries that help us in providing the Services;
SuperScale – privacy policy:
Trusted Partners who provide us with tools for internal management and data sharing;
Trusted Partners who help us in analyzing data by providing analytical tools;
Tenjin, Inc. – privacy policy:
AppsFlyer – privacy policy:
AdMob – privacy policy:
GameAnalytics – privacy policy:
Devtodev – privacy policy:
our legal, tax, audit and billing team;
social platforms for personalizing and targeting marketing.
Facebook Audience Network – privacy policy:
Pangle (TikTok Audience Network) – privacy policy:
Snapchat – privacy policy:
Trusted Partners helping us to manage advertising and services of Third Parties that may be of the most interest to you
Applovin – privacy policy:
Adcolony – privacy policy:
Fyber – privacy policy:
Inmobi – privacy policy:
ironSource – privacy policy:
Mintegral – privacy policy:
Tapjoy – privacy policy:
Vungle – privacy policy:
Unity Ads – privacy policy:
Chartboost – privacy policy:
Apple – privacy policy:
MoPub – privacy policy:
MoPub – partner list:
Moloco – privacy policy:

In cases provided by law, we may be required to disclose your data to the public authority, in particular to the police or the prosecutor’s office.

Your personal data may also be subject to processing, storage or transfer outside your country of residence and outside of the European Economic Area (EEA). Due to the fact that regulations concerning the protection of personal data in these countries may not guarantee the same level of protection as in your country or in the EEA, each time we will base our actions on standard EU clauses or Privacy Shield Framework, allowing you to transfer your data and provide the right level of protection.
PUSH NOTIFICATIONSIf you use our Services via mobile devices, after obtaining your prior consent, we can send you push notifications or local notifications to inform you about updates.
We would like to inform you that BFA is a regulated entity to which an obligation can be imposed to disclose your personal data, on the basis of a request by the authorized state authorities or in connection with other legal entities.In the case of transformation or merger of BFA with another entity, we will be able to transfer personal data to the third party involved in the process, which will protect personal data at least to the extent as under this Privacy Policy.
Remember that you have the right to object to the processing of your personal data at any time. To use this right, you can contact us in particular by sending a message to In addition, you have the right to:

access to your stored personal data;
request removal of your personal data from our database;
requesting rectification / correction of your data in justified cases;
requests to limit the processing of your data
transfer your data to another entity;
file a complaint with the appropriate data protection authority.

If you have any questions or doubts about how we process and protect your personal data or want to exercise your rights, do not hesitate to contact us and we will do our best to resolve any problems and provide you with help. You can direct messages to or to our Data Protection Officer at the address

This part of the document supplements the information contained in this Privacy Policy for the purpose of meeting legal requirements imposed by California Consumer Privacy Act (CCPA) and applies to all users who are consumers residing in the state of California, United States of America.Information in the scope below is in the relevant paragraphs of the Privacy Policy:

categories of personal information collected about you in the last 12 months
categories of sources from which the personal information was collected
purposes for collecting personal information
categories of third parties with whom we share personal information
categories of personal information we have disclosed within the last 12 months
categories of personal information we have sold within the last 12 months to our Trusted Partners helping us to manage advertising and services of Third Parties
We have disclosed and sold personal information to third parties within the last 12 months to our third-party advertising networks (see paragraph IX f). We do not sell the personal information of minors under 16 years of age without affirmative authorisation.
the date on which this Policy was last updated (at the top of this Privacy Policy)

You can designate an authorised agent to make a request under the CCPA on your behalf. The authorized agent must submit power of attorney that they have been authorized by you to act on your behalf and proof of their own identity.

You have the right to:

request access to your personal information
You have the right to request access to and receive the following information about personal information we maintain about you in the preceding 12 months.

The categories of personal information we collected about you.
The categories of sources from which the personal information is collected.
The business or commercial purpose for collecting personal information.
The categories of third parties to whom we sell or with whom we share your personal information.
The specific pieces of personal information we collected about you (i.e. data portability rights).
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: (i) sales, identifying the personal information categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
request deletion of your personal information
(we will delete the information we have collected about you, except for situations when that information is necessary for us to: maintain the functionality or security of our systems; comply with or exercise rights provided by the law).
opt-out of the sell of your personal information
(email us at or click “Do not sell My Personal Information” link.
CCPA gives you a right to direct a business that sells your personal information to stop selling your personal information and to refrain from doing so in the future. If you would prefer that your personal information is not shared with third parties (Advertising Trusted Partners), please, visit “Do Not sell My Personal Information”.

You also have the right not to be discriminated against for exercising any of the rights listed above.

If you have questions or concerns about your privacy or you want to exercise your rights, please contact us by email We may verify your request by asking for proof of identity such as your device ID and/or User ID.

We reserve the right to make changes to our Privacy Policy, if necessary, in particular for legal reasons or in connection with changes in the Services provided. In the event of such a circumstance, you will be informed and we will publish the current Policy text with the date of change on our website.The changes we make will be legally binding after 30 days of publication on the Internet. If you have any questions, please contact us.If you do not accept the changes introduced to the Privacy Policy, regardless of sending an e-mail to us, it will be incumbent upon us to ask you to immediately cease using our Services. We are asking for your understanding and please bear in mind that such resources are needed for the proper functioning of our Services, and that each User is subject to the same rules.

Contact and complaints BFA has the following contact information: BFA Ltd, Dzintaru prospekts 13/15 - 14, Jūrmala, LV-2015,