PRIVACY POLICIES

Last update: October 28th, 2025

Welcome to the privacy policy of Hitopicus!

First of all, thank you for playing our games!

This document describes how and why Hitopicus collects and processes your personal data (the "Data") when you interact with our mobile games (the "Games") or our hitopicus.com website (the "Website"). Hereinafter, we refer to both the Games and the Website as the "Services".

We act as a data controller for the processing of personal data under applicable privacy laws, including the General Data Protection Regulation ("GDPR").

Please note that this policy only applies to information collected and/or processed received by Hitopicus through your use of the Services.

Please note you must be over a certain age to play our Games and use our Services, depending on where you live. If you are under the legal age in your country, please do not play our Games or use our Services.

If you have any questions, feel free to contact us at contact@hitopicus.com.

1. Who we are

Hitopicus and its affiliated companies ("Hitopicus", "we", "our", "us") develop and publish mobile games and operate related websites and services (collectively, the "Services").

Hitopicus is a French company incorporated under number 994 459 576 with the Trade and Commerce registries of Pontoise and having its main place of business located at 1 Route de Montmorency 95580 Andilly - FRANCE.

2. Our Games

2.1 Why do we collect or use your Data

When you install and play Hitopicus's Games, we can collect and process some of your Data based on your express consent or for different purposes.

In cases in which Hitopicus is a data "controller" (meaning, when Hitopicus is the main decision-maker, exercising overall control over the purposes and means of the processing of your Data), Hitopicus only uses your Data with a legal basis for doing so, such as:

A legitimate interest happens when we have a business or commercial reason to use your personal information and includes our own interests or the interests of third parties, and can cover commercial interests (e.g. sustain our free-to-play model), so long as this is not overridden by your own rights and interests.

In cases we are required under law or regulation to obtain your consent for the processing of your personal information, we will ask for your consent.

Here's why Hitopicus may collect your personal information and the legal basis we rely on in each case:

For all data processing activities that rely on users' consent, you can always change your preferences and withdraw your consent in the privacy settings of any of our applications.

Note that, if you opt-out, you will still be able to see ads in our applications and some of our partners may still serve ads to you.

2.2. Data we collect

When you use any of Hitopicus's applications on a mobile platform and, for the above specific purposes, we may collect and process (store, share with our partners, process for analytics purposes) the following Data strictly for the purposes identified above:

1. Data that you provide to Hitopicus directly

2. Data collected automatically by Hitopicus

2.3. How is your Data collected

Most of the personal information we process via our Games comes directly from you.

In addition, we may also collect personal information:

2.4. With whom may we share your Data

When you consent to the collection of Data for advertising and third party analytics purposes, we may share the data listed above with the following categories of recipients.

a) Advertising networks and Attribution

To provide users with free-to-play Games, we are working with third parties to (i) advertise our Games on different networks and other applications and (ii) monetize our Games via advertising revenue (we insert ads in our apps) and in-app purchases.

These third parties generally collect user and device-related Data via their own SDKs (Software Development Kit), notably for attribution purposes. For example, you may see our Games advertised in other apps. After clicking on one of these advertisements and installing our Game, you will become a user of our Services. In order to verify the installs, a device identifier may be shared with our attribution partner to 'match' the advertisement with your install: this is what we call the "mobile attribution".

The privacy policies of our partners may include additional terms and disclosures regarding their data collection and tracking technologies. We encourage you to check those privacy policies to learn more about practices and exercise your rights directly towards them:

b) Analytics partners

These partners provide us with tools and technologies that allow us to better understand how users interact with our Games and will help us improve it:

c) Storage / Servers

Hitopicus is relying on either AWS or GCP to store the Data we collect via our apps:

In addition to the other disclosures described in this Privacy Policy, we will also share your information:

d) Payment processors

We rely on different payment processors for our Games, depending on your device type (Google if it runs with Android, Apple AppStore Payments if it runs with iOS).

Please refer to their respective privacy policies and terms:

2.5. How long do we keep your Data

We keep the Data collected and processed for the purposes described in this policy only as long as necessary.

We will also retain and use your information for as long as is required in order to comply with our legal obligations.

2.6. Our policy regarding children

You must be over a certain age to play our Games and use our Services, depending on where you live. For the list of age restrictions by country, you can refer to this page published by the European Union Agency for Fundamental Rights.

We do not knowingly or willingly collect or solicit personal information from anyone under the applicable age, or knowingly allow such persons to use our Services.

If you are under the legal age in your country, please do not play our Games or use our Services.

In the event that we learn that we have collected personal information from children under the legal age, we will delete that information as quickly as possible. If you believe that we might have any information from or about children under the legal age please contact us at contact@hitopicus.com.

2.7. Data storage and International transfers

We store our Data on servers located in Europe via Amazon Web Services or Google Cloud Platform.

To deliver Services to you, it is sometimes necessary for us to share your Data outside of your country or region, e.g.:

We may therefore transfer information that we collect about you to our third-party partners across borders, including outside of the European Economic Area (the "EEA").

Please note that these countries outside of the EEA may not have the same data protection laws as your own jurisdiction. We take steps to ensure that there are adequate safeguards and mechanisms in place (including the use of EU Standard Contractual Clauses) to allow the transfer of your information outside of the EEA.

We also make sure any third parties we share information with have an adequate transfer mechanism in place, as well.

2.8. Security

We take appropriate security and technical measures to protect your information from unauthorised access, loss and misuse.

In addition, we request that our suppliers who process personal information on our behalf take a range of security measures designed to help protect your personal information and maintain an appropriate level of security.

3. Our Website

When you visit our hitopicus.com Website, here are the information that we may collect and process:

We, or our partners may use these information:

If you no longer wish to receive these emails, you may opt-out from receiving them at any time by emailing us at contact@hitopicus.com.

Cookies

Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are small text files stored on your browser that allow the collection of information related to your navigation on a website (e.g. interactive content or analytics).

Hitopicus uses Google Analytics to collect information related to the web traffic on our website. The following cookies have been set on our Website:

To opt-out from Google Analytics data collection: https://tools.google.com/dlpage/gaoptout

In accordance with our Data Protection Authority guidelines, cookies exempted of consent are valid for a maximum of 13 months, and cookies requiring consent are generally valid for 6 months.

In addition, the maximum data retention period of information collected via technical cookies is 25 months.

4. Your choices and rights

Under data protection law, you have certain rights in connection with your personal information and how we handle it. You can exercise these rights at any time by contacting us at contact@hitopicus.com:

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at contact@hitopicus.com.

If you're a user under CCPA or other US state laws

In order to comply with CCPA or other US state laws, this paragraph aims at disclosing the mandatory information.

Sharing and Selling of Personal Data

We may share your data with third-party service providers such as:

Under the CCPA, "selling" includes disclosing personal data for monetary or other valuable consideration. While we do not sell your personal data in the traditional sense, some of our ad partners may process data in a way that qualifies as a "sale" under the CCPA.

We share data with our partners for advertising and analytics, subject to appropriate safeguards. You have the right to opt-out of such selling and sharing.

5. Contact Information

You may exercise your rights in the Games or by contacting us at:

Email: contact@hitopicus.com

Postal Address:

HITOPICUS SAS
Legal Team
1 Route de Montmorency
95580 Andilly, France

As a data subject, you have the right to lodge a complaint with the CNIL, our French data supervisory authority: www.cnil.fr

California and Virginia residents may also opt-out of the sale/sharing of data via our in-game settings or use an authorized agent to make a request on their behalf.

We will respond within the timelines prescribed by applicable law. Identity verification may be required.

If you have any questions about this Privacy Policy, please contact us at contact@hitopicus.com.