LEGAL FRAMEWORK

Privacy & Data Governance

At IDUBEDA, I value your privacy and want to be accountable and fair to you as well as transparent with you in the way that I collect and use your personal information. I also want you to know your rights in relation to your information which you can find here.

In line with these values, this privacy policy tells you what to expect when I collect and use personal information about you. I have tried to make it easy for you to navigate so you can find the information that is most relevant to you and my relationship with you.

I am always looking to improve the information I provide to my customers and partners, so if you have any feedback on this privacy policy, please let me know using my contact details.

Effective Date

This policy is effective as of 01 July 2026.

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1. Who I Am

Who I am: I am Moises Friginal Santos-Olmo, an independent software developer creating games and apps under the trademark IDUBEDA from Spain. I am the controller of your personal information, and am responsible for its security.

All references in this policy to "IDUBEDA", "I", "me", or "my" refer to Moises Friginal Santos-Olmo. All references in this policy to "games" or "apps" are to my software programs that are available to download on mobile devices from official stores.

Who this policy applies to:

  • Users of my games and apps
  • Customer support contacts
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2. Collection of Your Personal Information

What personal information I collect about you:

From App Usage (with consent)

  • Identifier for Advertising (IDFA)
  • General location / IP address
  • Device information and technical data
  • Latency and session stability

From User Input

  • Email address (when contacting support)
  • Messages and correspondence history
  • Account credentials (if applicable)
  • Configuration preferences

How I use your personal information:

  • To manage advertising and provide relevant marketing
  • To record your advertising and marketing preferences
  • To receive and respond to customer support enquiries
  • For internal reporting and business administration
  • To comply with legal obligations
  • To establish, exercise or defend legal rights
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4. How & Why I Share Your Data

Third Party Advertising

I use third-party advertising technology companies to serve relevant advertising. These companies collect data to build a profile of your preferences. With your consent, they use data including:

  • Device information, IP address, unique device ID
  • Geo-location details
  • User ID assigned to you
  • Interaction with advertising
Third Party Advertising Partners:
• Admob, Inc. • AppLovin Limited • Facebook, Inc. • Unity Ads • Vungle, Inc. • InMobi Pte Ltd. • Mintegral International • Ogury Ltd. • Bytedance Pte. Ltd. • Smaato, Inc. • Chartboost, Inc. • ironSource Ltd.

Other Third Parties

  • Unity Web Services: Data storage and infrastructure
  • Google (Firebase): Analytics, bug reporting, and app improvement
  • OS Providers (Google, Amazon, Apple): In-app purchase verification

I never sell your personal information. I may disclose data for legal compliance, to protect rights, or if my business is sold or acquired.

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5. How Long I Store Your Data

I keep your personal information for no longer than necessary for the purposes for which it is processed. The retention period depends on the purpose and/or as required to comply with applicable laws and to establish, exercise or defend legal rights.

Retention Periods:

  • User account data: Retained for as long as you maintain an account
  • Support tickets: Retained for 2 years after resolution
  • Game analytics: Anonymized after 12 months
  • Advertising data: Retained as per partner policies
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6. Your Rights

You have certain rights in relation to your personal information. To exercise any of them, please contact me via email at privacy@idubeda.com.

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Access

Request a copy of your personal information I hold.

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Rectification

Correct inaccurate or out-of-date information.

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Erasure

Request deletion of your information ("right to be forgotten").

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Restrict Processing

Limit how I use your information in certain circumstances.

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Data Portability

Receive your data in a structured, machine-readable format.

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Object

Object to processing based on legitimate interests.

I will respond within one month of your request. I may need to verify your identity before responding. Some information may be exempt from certain requests due to legal obligations.

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7. Children

You must be aged 16 or over to purchase products or services from me. My apps and services are not directed at children younger than this and I do not knowingly collect any personal information from children younger than this.

If you are aged below 16 and I learn that I have inadvertently obtained personal information from you, I will delete that information as soon as possible.

Please contact me at privacy@idubeda.com if you are aware that I may have inadvertently collected personal information from a child below the age of 16.

In compliance with COPPA (Children's Online Privacy Protection Act) and GDPR-K, I implement age-gating mechanisms where required.

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8. International Data Transfers

As an independent developer based in Spain, your information may be processed in countries outside your own. This includes the United States of America where some of my service providers are located.

When I provide any personal information about you to any non-EEA members of my group or suppliers, I take appropriate measures to ensure the recipient protects your personal information adequately. These measures include:

  • European Commission approved standard contractual arrangements
  • Ensuring US-based entities have signed up to the EU-US Privacy Shield or equivalent
  • Transfer Impact Assessments where required
  • Compliance with GDPR Chapter V requirements

Further details on these measures are available on request by contacting me via the email address below.

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9. Security

Data security is handled with the same precision as low-level systems code. I employ multi-layered encryption at rest and in transit using industry-standard practices.

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verified_user ENCRYPTION LEVEL: AES-256 GCM

I take reasonable precautions to safeguard the confidentiality of your personal information, including encryption, firewalls and password protection systems. I review security procedures periodically to consider appropriate new technology and updated methods.

The main risk of processing your personal information is if it is lost, stolen or misused. I am committed to protecting your personal information from loss, theft and misuse. However, transmission over the internet is not completely secure.

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10. Changes to This Privacy Policy

I may update my privacy policy from time to time. Any changes I make to my privacy policy in the future will be made available to you via the privacy policy, accessible in my app or on this page.

Please check back frequently to see any updates or changes. The effective date will always be displayed at the top of this policy.

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11. Further Questions & Complaints

If you have any queries or complaints about my collection, use or storage of your personal information, or if you wish to exercise any of your rights, please contact me:

mail privacy@idubeda.com

In accordance with Article 77 of the General Data Protection Regulation, you may also make a complaint to the Information Commissioner's Office, or the data protection regulator in the country where you usually live or work, or where an alleged infringement has taken place.

The practices described in this privacy policy statement are current as of 01 July 2026.