Privacy Policy

Last Updated: March 11, 2026

This Privacy Policy explains how Hongtao Liu (referred to herein as "we," "us," or "our") collects, utilizes, and protects your personal information when you access and play our iOS mobile game, Fold Back. We are committed to processing your data responsibly, with the primary goal of providing you with an outstanding gaming experience while respecting your privacy.

1. Information We Collect

We may acquire your personal data through various channels when you interact with our services. We pledge to maintain the security of your information at all times. The types of data we gather and our collection methods are detailed below:

1.1 Categories of Personal Data

When you download, access, or play Fold Back, we may automatically collect the following information:

• Log Information: Details such as your IP address, the dates and times of your access, and the nature of the device used.
• Device Data: Information about your device's hardware model, manufacturer, operating system version (iOS), timezone, and chosen language.
• Unique Identifiers: Digital identifiers linked to your device or game instance, which may include your IDFA (Identifier for Advertisers), Google Ads ID, Game Center ID, Google Device ID, and Google Play account ID.
• Gameplay Metrics: Data regarding your in-game progress, high scores, achievements unlocked, and interactions with other users within the game.
• Transaction Records: History of your in-app purchases, configuration settings, and data related to the ownership of virtual goods or currency.

1.2 Third-Party Data Sources

If you choose to authenticate or link your account using a third-party platform, such as Apple Game Center, we will receive specific profile information (like your public nickname and profile data) from that service. This process is governed by the privacy settings and authorization terms you have agreed to with that third party.

To fully understand how these external platforms manage your privacy, we strongly recommend reviewing their respective policies:

• Apple Game Center: https://www.apple.com/legal/internet-services/itunes/gamecenter/

By utilizing a third-party login method, you confirm that:

1. Your use of the platform complies with their current terms of service and privacy policies.
2. You satisfy the minimum age restrictions set forth by the third-party provider in your local jurisdiction.

2. Purpose of Data Utilization

We leverage the data we collect for the following operational and commercial purposes, ensuring that each action is supported by an appropriate legal foundation:

1. Service Delivery & Account Maintenance: To process your transactions, respond to your support tickets, provide core gaming functionalities, and customize your experience. This also includes sending essential updates, technical notices, and security alerts.
   • Legal Basis: GDPR Article 6(1)(b). Processing is necessary for the performance of our contract with you, ensuring Fold Back operates smoothly and delivers the services you request.
2. Service Optimization & Marketing: To send promotional communications regarding Hongtao Liu's products (based on your preferences), analyze user trends, troubleshoot bugs, and develop new features to enhance overall software quality.
   • Legal Basis: GDPR Article 6(1)(f). This is conducted under our legitimate interest in improving our application, growing our business, and providing relevant content.
3. Personalized Advertising: To display tailored ads and promotional content within the game for users who have consented to share device identifiers with our trusted ad partners.
   • Legal Basis: GDPR Article 6(1)(f). This processing relies on our legitimate interest in delivering advertising that is pertinent to your interests.

3. Data Retention Policy

We will retain your personal data only for as long as it is necessary to fulfill the purposes outlined in this policy, deliver our gaming services, comply with applicable legal obligations, or resolve ongoing disputes. To enforce our terms, maintain service security, or satisfy regulatory requirements, certain data archives may be kept for a reasonable extended period.

Additionally, anonymized usage data is retained temporarily for internal analytics, unless we are legally bound to preserve it longer or it is necessary for enhancing security measures.

4. How We Share Your Information

In alignment with your privacy rights and under the stipulations of GDPR Articles 6(1)(b), 6(1)(c), and 6(1)(f), we may share your data with specific external entities under the following circumstances:

1. Authorized Third Parties: For essential functions such as hosting, customer support, or in the event of a business transition (like a merger or asset sale), provided you have given consent where required.
2. Legal Compliance: If we believe your actions breach our terms of service, or if disclosure is strictly necessary to protect the rights, property, or safety of Hongtao Liu, our users, or the general public.
3. Other Players: When you participate in competitive features like leaderboards or public forums, certain profile details and game statistics will be visible to others.

4.1 Advertising Partners

If you consent (per GDPR Article 6(1)), we may share your device identifiers with advertising networks to serve personalized ads. Our current or potential ad network partners include:

• Applovin Corporation: https://www.applovin.com/privacy/
• AdColony: https://yandex.com/legal/international_ads_privacy_policy
• Amazon Publisher Services: https://www.amazon.com/privacyprefs
• Facebook, Inc.: https://www.facebook.com/about/privacy/
• Google LLC: https://policies.google.com/privacy
• Google Admob: https://support.google.com/admob/
• Unity Technologies: https://unity3d.com/legal/privacy-policy
• IronSource: http://www.ironsrc.com/wp-content/uploads/2019/03/ironSource-Privacy-Policy.pdf
• Vungle, Inc.: https://vungle.com/privacy/
• Fyber: https://www.fyber.com/privacy-policy/
• InMobi: https://www.inmobi.com/privacy-policy/

Please be aware that once data is shared, its handling is governed by the specific privacy policies of these third-party companies.

4.2 Third-Party Data Processors

To ensure the smooth operation of Fold Back, we collaborate with service providers for server hosting, analytics, and authentication support. These include:

• Firebase (Google LLC): https://firebase.google.com/support/privacy
• Adjust: https://www.adjust.com/terms/privacy-policy/

5. Children's Privacy

Fold Back is not directed at children under the age of 13, and we do not knowingly request or collect personal information from users in this age group. If we discover that we have inadvertently collected data from a child under 13, we will take immediate steps to delete it from our systems. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately.

6. Security Measures

We deeply value the trust you place in us and employ standard, commercially reasonable security measures to protect your personal information from unauthorized access or disclosure. However, please be advised that no method of electronic storage or transmission over the internet can be guaranteed as completely secure.

7. Push Notifications

With your explicit permission, we may send push notifications to your device to inform you about game updates, special events, or administrative messages. You can manage or disable these notifications at any time through your iOS device settings.

8. Your Privacy Rights

8.1 Rights for European Economic Area (EEA) Residents

We strive to process all data requests promptly, usually within one month. For highly complex requests, this timeframe may be extended by up to two additional months (as permitted by GDPR Article 12), and we will inform you of any such delays.

(1) Right of Access: Under GDPR Article 15, you may request details about your data, including processing purposes, data categories, recipients, and retention periods. You can also request a copy of your data.

(2) Right to Object: Under GDPR Article 21, you can object to data processing based on legitimate interests. We will cease processing unless we have compelling grounds that override your rights. You may unconditionally object to direct marketing at any time.

(3) Right to Rectification: Under GDPR Article 16, you can request that we correct any inaccurate or incomplete personal data we hold about you.

(4) Right to Restriction: Under GDPR Article 18, you may ask us to suspend the processing of your data under specific circumstances.

(5) Right to Withdraw Consent: Under GDPR Article 7, you can withdraw your previously granted consent at any time, without affecting the lawfulness of processing that occurred prior to your withdrawal.

(6) Right to Data Portability: Under GDPR Article 20, you have the right to receive your data in a structured, commonly used format and request its transfer to another service provider.

8.2 Rights for California Residents (CCPA)

(1) Response Time: We aim to fulfill verifiable consumer requests within 45 days. If we require more time (up to 90 days), we will notify you in writing.

(2) Disclosure Scope: Data disclosures will cover the 12-month period prior to your request. If we provide data for portability, it will be in a readily usable format.

(3) Right to Opt-Out: California residents have the right to direct us not to sell their personal information to third parties.

(4) Right to Know: You have the right to know what personal information we collect and how it is used, which is thoroughly detailed in this Policy.

(5) Request Disclosures: You can request a free disclosure of your collected personal data up to twice within a 12-month period, including data sources, purposes, and third-party sharing details.

(6) Right to Deletion: You can request the deletion of your personal data collected over the past 12 months. We will comply unless an exception applies (e.g., to complete a transaction, detect fraud, or comply with legal obligations).

9. Requesting Data Deletion

If you determine that you no longer wish for us to retain your personal information, you have the right to request its deletion. To submit a verifiable data deletion request, please email us directly at: linyan82768@outlook.com.

10. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please do not hesitate to reach out to us:

Email Address: linyan82768@outlook.com