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Kalyna Digital OÜ Privacy Policy

Last Updated: March 20, 2023

Thank you for playing our games! This Privacy Policy describes the following:

  • The ways we collect personal data about you and why we do so
  • How we use your personal data, and
  • The choices you have about your personal data.

This Privacy Policy applies to Kalyna Digital’s games, stores, sites, and related services, which we collectively call the Service. We may periodically update this Privacy Policy by posting a new version on If we make any material changes, we will notify you as required under applicable law, including by posting a notice in the Service before the change becomes effective. Your continued use of the Service after the effective date will be subject to the new Privacy Policy.

We are Kalyna Digital OÜ agency, maker of Fish Sudoku, Alien Rescue, Volunteer Keeper, and many more. For details about how to contact us, see the “Contact” section below.

This Privacy Notice applies to personal information that we collect through our games, mobile applications, and other products (“Games“), websites we control, like at  (“Website“) (collectively “Services”).

All Kalyna Digital Services are governed by this Privacy Policy, and by using or accessing a Service, You consent to the processing, use, and disclosure of your data. Please do not install or use the Services if you disagree with this Privacy Policy.

Kalyna Digital reserves the right to modify this Privacy Policy. Your continued use of Services will signify your acceptance of the changes to this Privacy Policy.

Contact Information

If you have questions about data protection or any requests for resolving issues with your data, please contact us primarily through the support features within each Kalyna Digital game so we can reply more quickly. Alternatively, you may contact:

Name: Kalyna Digital OÜ

Address: Harju maakond, Tallinn, Lasnamäe linnaosa, Lõõtsa tn 5 // Sepapaja tn 4, 11415

Registration number: 16334482


The personal information we may collect about you through the Services falls into the following general categories:

1.1.Data you provide us directly

  • Contact information (such as name and email address or phone numbers)
  • Player name or tag and password
  • Profile information (such as profile photo)
  • Your messages and other content you submit when you use the Service (such as chat logs and player support tickets)

1.2 Information we collect automatically

When you use our Services, we may also collect certain information automatically from you and/or your device which may be considered personal information under applicable data protection laws, such as:

  • Data about your account and game progress, including, in most cases, an automatically created internal account ID
  • Your IP address and mobile device identifiers (such as your device or advertising ID)
  • Data about your device, such as device name and operating system, browser type and language, internet service provider, and mobile carrier
  • Data we collect with cookies and similar technologies (see more below)
  • Approximate location data (as derived from IP address)
  • Data about your use of the Service, such as gameplay data, purchases made, and your interactions with other players inside the Service

Advertising ID” means the Apple Identifier for Advertisers (“IDFA”) on Apple and Google Advertising Identity (“GAID”). These are unique identifiers for mobile devices that advertisers use for interest-based advertising. They are consistent across all apps and thus allow cross-app tracking. On Apple, you can opt out by choosing the “limit ad tracking” option in the privacy settings. On Google Android, you can opt-out by choosing the “Opt out of interest-based ads.” Advertising IDs are non-permanent, non-personal identifiers uniquely associated with your device. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognize your device when you use websites and applications.

“Device identifier/information” means device type, device model, device manufacturer, device operating system and language, or other technical data like screen size, processor, or a combination of these data, available from a device for a developer to check the device’s compatibility with a particular application.

Some of this information may be collected using cookies and/or similar technologies (such as ” software development kits or “SDKs”).

1.3 Information we obtain from third-party sources

(a) Information from social media platforms. You can connect to our Services via your social media account. The exact information we receive from you will depend on your social media privacy settings, but it will typically include your basic public profile information, such as:

  • your username
  • profile picture
  • age range
  • gender
  • your friends playing the same Game

Typical uses include updating game progress on multiple devices you may own so that you can continue your progress using multiple devices. In addition, we may show your Facebook friends in the Game and show your public Facebook profile name and picture in Game leaderboards and your Game profile.

(b) Third-party service providers. We may receive personal information about you from third-party sources. We may get your personal information, for example, when you installed our Game or when, before installation, you clicked on an advertisement for the Game (see “Third Parties” section below for further detail).

(c) Advertising partners. Occasionally, we may also receive personal information about you from other third-party sources. For example, if you click on an advertisement directing you to one of our Services (such as an ad for one of our Games in another publisher’s game), we will be provided with information about which ad network and advertising campaign the install originated from (See also “Advertising” below).

1.4 No special categories of information

We do not request or intend to collect any “special categories of information” such as any information on health, race, religion, political opinions or philosophical beliefs, sexual preferences, or orientation.


We use your personal information for the following purposes:

2.1 To provide and operate our Services:

  • To create user accounts/profiles to enable you to play our Games
  • To provide you with the correct versions of our games and/or applications (e.g., knowing which language to make our games available to you in)
  • To enable you to communicate with other users (including via chat rooms, forums, and/or private messages) and leaderboards local to you
  • To send you service-related communications, including confirmations, technical notices, updates, security alerts, and support/administrative messages

2.2 To improve our Services and keep them secure:

  • To respond to your customer support requests (e.g., if you write to us with a complaint)
  • To receive error messages about any issues you/your device encounters with our Services to enable us to fix bugs and interoperability issues
  • To detect and prevent illegal activities (e.g., hacking or cheating)
  • To track game installs (to measure the effectiveness of marketing campaigns).
  • To conduct optional user feedback surveys
  • To understand you, your preferences, and user traffic to enhance your experience and enjoyment using our Game
  • To conduct research

2.3 To personalize our Services:

  • To remember you next time you visit one of our Services
  • Communicate with you about promotions, rewards, upcoming events, and other news about the products and services we offer

2.4 For promotional activities (including marketing and advertising)

  • To provide you with in-game offers and rewards based on your in-game behaviors
  • To serve you with relevant, targeted advertisements (necessary to fund our Services)
  • To make you offers to purchase in-game items at a discount based on your in-game activity and purchase history.
  • To send you marketing communications and/or newsletters about rewards and promotions if you have subscribed to them

2.5 Other

  • To comply with our legal obligations
  • To exercise, establish or defend our legal rights, or to protect your vital interests or those of any other person
  • To prevent and/or detect fraud or fraudulent behavior


3.1 We use advertising to fund our Services and to make our games available for free. We show third-party advertising in our Games and also advertise our Services via third parties. We want to provide you with more detail about how we use the information for advertising in our properties and third-party properties.

When you view ads in Kalyna Digital properties(e.g., in our games)

3.2 To enable us to show in-game ads, we may send your advertising ID and IP address to advertisers (or ad networks) to enable them to find appropriate ads to serve you in our Games and on third-party properties. You can control and limit our use of your advertising ID in your device settings. Kalyna Digital does not control which specific ads are shown in our games (this is controlled by ad networks), but we do prohibit certain types of ads.

3.3. Advertising IDs are used by ad networks for several purposes (please refer to the Privacy Notices of our advertising partners listed herein as “Third Parties“), including, for example, to

(a) limit the number of times you see the same ad

(b) ensure they deal with humans with real devices, not automated “bots.”

(c) to serve you with advertisements likely to be relevant to you based on your advertising ID, your engagement with other brands and ads, which is recorded using your advertising ID, and to use your general geographic area.

(d) Other brands buy ad placements via an ad network or exchange to advertise their products in Kalyna Digital Games. The ad network or ad exchange is an intermediary between the other game companies and Kalyna Digital. For an ad network to charge the company purchasing the ad, clicks from the ad and potential installs of other developers’ apps are tracked. Views, clicks, and installs from ads are measured using the Advertising ID.

(e) Ad networks track which games you have used for marketing similar games.

Your IP address is typically used by advertisers to identify your general geographic location, for example, your country, state, and, sometimes, your city).

When you view Kalyna Digital ads on third-party services

3.4 Kalyna Digital also advertises its games on other apps by asking ad networks to place ads for audiences that will be interested in them (determined using Advertising IDs).

3.5 Ad networks use Advertising IDs for this and other purposes (please refer to the Privacy Notices of our advertising partners listed as “Third Parties”), including, for example, to

(a) Measure ad effectiveness (looking at total views, clicks, and installs generated by its advertising in other publishers’ games);

(b) Inform players that have not played for a while about new content in the Game. Kalyna Digital lists these users as Advertising IDs to an ad network. The ad network then shows these users ads about the new content.

(c) Not display ads for a game a player is already playing. Kalyna Digital may send an ad network a list of active players in the form of Advertising IDs. The ad network then excludes these players from seeing the ad.

(d) Market games to a group of potential players. Kalyna Digital provides Facebook with a list of Advertising IDs to match them with similar types of Facebook users to whom Kalyna Digital could then market its games. Kalyna Digital does not have information on how Facebook identifies or creates profiles of similar types of users.

3.6 You can opt out of interest-based advertising on mobile applications by changing the privacy settings of your device and selecting “limit ad tracking” (Apple iOS) or “opt out of interest-based ads” (Android).


The Services may use “cookies” and other technologies such as pixel tags, local shared objects, hardware-based device identifiers, flash cookies, operating system-based identifiers, clear GIFs, and web beacons.

Cookies: A “cookie” is a small file your browsers stores when told to do so by a website. Typically, websites place several different cookies on an end-user device. Some are “First-party” cookies,’ i.e., from the website itself, and others are “Third-party” cookies, meaning they belong to advertising and analytics entities or social networks. Cookies are personal information. However, Kalyna Digital’s cookies do not include any other personal information. They are typically used to identify your device quickly and to “remember” it during subsequent visits for functionality, preferences, and website performance. You can disable cookies on your device or set your device to alert you when cookies are being sent to your device; however, disabling cookies may affect your ability to use the Services.

Our legal basis for collecting and using the personal information described above will depend on the personal information and the specific context in which we collect it.

However, we will normally collect personal information from you only where (i) we need the personal information to perform a contract with you, (ii) the processing is in our legitimate interests and not superseded by your rights, or (iii) we have your consent to do so.

(a) Under our terms of service, “performance of the contract” as a legal basis for processing your information refers to when we make the Game and Services available to you, provide customer support, integrate Games with technology and distribution platforms such as Apple iOS and Google Android, and inform you of service-related changes and Game progress.

(b) We process your personal data based on our legitimate interests, for example, when we provide you the Game and Game events, serve interest-based advertisements to you (both in-game and on third-party properties), carry out marketing, keep our games secure, for engineering purposes, analyzing the users’ behavior across our Games, moderating chat discussion.

(c) We have a “legal obligation” to process your personal data when complying with a legal obligation, such as preventing a crime or fraud or maintaining tax records.

(d) If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

If you have questions about or require further information concerning the legal basis for collecting and using your personal information, please contact us using the contact information provided in the “Contact” section below.


We may share your personal information with the following types of recipients:

(a) With companies in our business group, third-party service providers, and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help enhance the security of our Services), or parties that otherwise process personal information for the purposes described in this Privacy Notice or communicated to you when we collect your personal information.

(b) With any competent law enforcement body, regulatory authority, government agency, the court of law, or another third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person

(c) With a potential or actual buyer (and its agents and advisers) in connection with any proposed or actual purchase, merger, or acquisition of any part of our business, provided that we inform the buyer it must use your personal information solely for the purposes disclosed in this Privacy Notice

(d) With any other person, with your consent for such disclosure.


Security Safeguards.

To help ensure a secure and safe player experience, we continuously develop and implement administrative, technical, and physical security measures to protect your data from unauthorized access or against loss, misuse, or alteration.

Data retention.

We retain your data for as long as your account is active or as needed to provide you with the Service. We may periodically de-identify unused game accounts, and we may regularly review and de-identify unnecessary data.
Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.


Your personal information may be transferred to and processed in countries other than the country you reside in. These countries may have data protection laws that differ from your country’s laws.

Specifically, our Game servers are currently located in the United States, and our business group members, third-party service providers, and partners operate worldwide. This means that when we collect your personal information, we may process it in any of these countries. However, we ensure appropriate safeguards are in place so that your personal information will remain protected in accordance with this Privacy Notice. This includes complying with the European Commission’s Standard Contractual Clauses for transfers of personal information among companies in our business group and third-party service providers and partners, which require all members of our business group to protect the personal information they process from the EEA in accordance with European Union data protection law. It also includes transferring personal information to third-party service providers and partners certified under the EU-US Privacy Shield.

The Standard Contractual Clauses can be provided on request. We have implemented similar appropriate safeguards with our third-party service providers and partners, and further details can be provided upon request.


We retain personal information we collect from you where we have an ongoing legitimate business need to do so. For example, to provide you with a Service you have requested or to comply with applicable legal, tax, or accounting requirements. For example, we periodically de-identify unused Game accounts and review and de-identify the unnecessary personal information.

When we have no ongoing legitimate business need to process your personal information, we will either delete or de-identify it, or, if this is not possible – for example, because your personal information has been stored on a backup server – then we will securely store your personal information and isolate it from any further processing until deletion is possible.


You have the following data protection rights:

(a) To access, correct, update, or request deletion of your personal information. You may do so in your account settings (via “Terms of Service and Privacy Notice“) or by contacting us using the information in the “Contact” section below.

(b) To object to the processing of your personal information (which is processed on the grounds of legitimate interests), ask us to restrict the processing of your personal information or request portability of your personal information. Again, you may opt out of personalized offers based on in-game behavior or by contacting us using the information in the  “Contact” section below.

(c) To opt out of marketing communications, we send you at any time. You can exercise this right by clicking on the “unsubscribe/opt-out” link in the marketing communications we send you or by contacting us using the information in the“Contact”  section below.

(d) If we are processing your personal information with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted before your withdrawal, nor will it affect the processing of your personal information conducted pursuant to lawful processing grounds other than consent. You may contact us using the details at the “Contact”  heading below.

(e) You have the right to file a complaint with a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

You can control and limit the type of personal information we collect and process about you in many ways. For example, you can disconnect your social media account(s) from our games or control your privacy settings to limit the information shared with us. You can also reset your mobile advertising identifier or limit ad tracking altogether using the settings on your phone. You can also limit or disable cookies (or similar technologies).

We will respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.


When we collect personal information, we do not know the age of our players. If a player has a Facebook account and has logged into a game, we obtain the age information from the player’s Facebook profile. If we discover we have inadvertently gathered personal information from a minor under 13 years of age, we will take reasonable measures to delete such personal information from our records promptly.


We may update this Privacy Notice from time to time in response to changing legal, technical, or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you in accordance with the significance of the changes we make.