1. Who We Are
99Imperial Games operates https://games.99imperial.com and publishes mobile games on various platforms. The company serves as data controller for personal information collected through games and website services.
- Email: privacy@99imperial.com
- Website: https://games.99imperial.com
- Data Protection Officer: dpo@99imperial.com
2. What Data We Collect
2.1 Data You Provide Directly
Users may supply account information (username, email, password), communications for support purposes, payment information processed through Google Play (card details not stored locally), and gameplay progress data.
2.2 Data Collected Automatically
We gather device advertising identifiers, device specifications, gameplay metrics, crash reports, approximate country-level IP data for fraud prevention, and Google Play Games Services information including hashed account identifiers and achievement data.
2.3 Data from Third Parties
Information comes from Google AdMob, Play Games Services, Firebase Analytics, and Firebase Remote Config.
3. How We Use Your Data
We use collected information for game operation, advertisement delivery through AdMob, leaderboard functionality, bug fixes, customer support, legal compliance, fraud prevention, and optional game update communications.
4. Third-Party Services and SDKs
The games integrate with Google AdMob, Play Games Services, Firebase Analytics, Firebase Crashlytics, Firebase Remote Config, and Google Play Billing — each maintaining separate privacy policies.
5. Advertising and the AD_ID Permission
Free games display advertisements from Google AdMob using the com.google.android.gms.permission.AD_ID permission for Android applications.
Advertising identifier purposes:
- Serving in-game advertisements
- Frequency capping for ad displays
- Measuring advertising performance
- Fraud detection
User controls:
- Android: Settings → Privacy → Ads
- iOS: Settings → Privacy & Security → Tracking
- General opt-out: google.com/settings/ads
Opting out reduces ad personalisation but doesn't eliminate advertisements entirely.
6. Children's Privacy
Bolt Puzzle is not directed toward users under 13 years old (or higher thresholds in specific jurisdictions including the EU/UK at 16 years). We do not knowingly collect personal data from children. Parents should contact privacy@99imperial.com for removal requests, with deletion within 72 hours.
Regional age thresholds:
- United States: under 13
- European Union / UK: under 16
- South Korea: under 14
- Brazil: under 12 (absolute protection); 12–18 requires parental consent
- China: under 14
- Other nations: under 13 or applicable local minimum
7. Your Rights by Region
Users can exercise regional privacy rights by contacting privacy@99imperial.com. Response timeframes follow applicable local law requirements (typically 30–45 days).
- EU / UK (GDPR / UK GDPR): Access, rectification, erasure, restriction, portability, objection, consent withdrawal, and supervisory authority complaint rights.
- California (CCPA / CPRA): Knowledge, deletion, sale/sharing opt-out, non-discrimination, and sensitive personal information use limitation.
- Other US states (VA, CO, CT, TX, OR, MT): Access, correction, deletion, portability, and targeted advertising opt-out.
- Canada (PIPEDA / Law 25): Access, correction, consent withdrawal; Quebec residents receive de-indexing and data transfer rights.
- Brazil (LGPD): Confirmation, access, correction, anonymisation, portability, deletion, and information sharing details.
- Australia (Privacy Act 1988): Access and correction rights; complaints to OAIC.
- India (DPDP Act 2023): Access, correction, erasure, nominee nomination, and grievance rights.
- Japan (APPI): Disclosure, correction, usage cessation, and deletion.
- South Korea (PIPA): Access, correction, deletion, and processing suspension.
- China (PIPL): Access, copying, correction, deletion, consent withdrawal, and explanations.
- Singapore (PDPA): Access and correction.
- New Zealand (Privacy Act 2020): Access, correction, and Privacy Commissioner complaint.
- South Africa (POPIA): Access, correction, deletion, objection, and Information Regulator complaints.
- Switzerland (revFADP): EU GDPR-equivalent protections.
- EEA members (Norway, Iceland, Liechtenstein): EU GDPR rights through membership.
8. International Data Transfers
Data may transfer across borders to countries with varying protection standards.
Safeguards employed:
- EU / UK: Standard Contractual Clauses and UK International Data Transfer Agreements
- Switzerland: FDPIC guideline compliance
- Brazil: LGPD-provided mechanisms and contractual clauses
- China: PIPL requirements including security assessments
- Global: third-party processors maintain their own transfer mechanisms
9. How Long We Keep Your Data
| Data type | Retention period |
|---|---|
| Account data | Until deletion plus 30-day recovery |
| Gameplay progress | Until account deletion or request |
| Crash reports | 90 days |
| Analytics data | 14 months (aggregated / anonymised) |
| Ad interaction data | Up to 18 months |
| Customer support | 3 years from last contact |
| Legal / compliance | 6–7 years typically |
| Advertising ID | Until reset or opt-out |
10. How We Protect Your Data
Security measures include TLS 1.2 encryption for data in transit, restricted personnel access, third-party processor certifications (ISO 27001, SOC 2), regular security assessments, and no local card information storage. Data breach notification follows GDPR / UK GDPR requirements (72-hour supervisory authority notification) with affected-individual notification.
11. Cookies and Similar Technologies
The website and games employ cookies and tracking technologies. Jurisdictions requiring consent (EU, UK, ePrivacy regions) receive consent requests for non-essential cookies before placement.
Cookie categories:
- Essential — functionality-required (no consent needed)
- Analytics — usage understanding (consent required in EU / UK)
- Advertising — ad serving (consent required in EU / UK and other regions)
Users manage preferences through the website's consent tool or browser settings.
12. Google Play Games Services
Games integrating with Google Play Games Services provide hashed Google account identifiers for player identification. Achievements, leaderboard scores, and cloud-save data store on Google's servers. Public leaderboard display names match Google Games profile names.
Users disconnect services through myaccount.google.com or delete Play Games data through the Google Play Games app. Disconnection doesn't affect device-local game progress.
13. Your Choices and Controls
In-game options:
- Reset or decline personalised advertisements via device settings
- Disconnect from Google Play Games through game settings
Account deletion:
Email privacy@99imperial.com with subject "Account Deletion Request" including username or registered email; completion within 30 days.
Data portability:
Request a data copy via privacy@99imperial.com; delivery within 30 days in structured, machine-readable format.
14. Country-Specific Supplements
Detailed regional supplements covering EU / UK lawful bases, California share/sell distinctions, Brazilian DPO contact (dpo@99imperial.com), Indian Data Fiduciary status, Chinese PIPL representative (china-privacy@99imperial.com), South Korean PIPA officer, Canadian/Quebec rights, and Australian APP compliance are available on request from privacy@99imperial.com.
15. Links to Third-Party Services
Games and websites contain third-party links. This policy doesn't cover those services; users should review third-party privacy policies independently.
16. Changes to This Privacy Policy
Material changes trigger policy date updates, in-game or push notifications where feasible, and fresh consent for EU / UK users where required. Continued use after revision constitutes acceptance per applicable law.
17. Contact Us and Complaints
- General privacy: privacy@99imperial.com
- Data Protection Officer: dpo@99imperial.com
- Account / data deletion: privacy@99imperial.com (subject: "Account Deletion Request")
- Data subject rights: privacy@99imperial.com (subject: "Data Subject Request")
- Response time: within 30 days, or shorter per local law