Last updated: 25 April 2025
This Privacy Policy explains how your personal data is collected and processed by Holeyo Studio ("Holeyo") when you use the our mobile applications (the "App").
The App is a free to play game (with optional in-game-purchases), and in order to maintain the high quality and a great game experience we process information from and about you in particular to improve the entire experience in the App and to support internal operations.
We update this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, depending on the specific changes, we will provide you with additional notice or require a renewed consent.
When you access or use the App, we automatically collect general information about you, including:
If you log into the App using a third party site or platform such as Facebook, Apple Game Center and Google Sign-In, we access information about you from that site or platform, such as your screen name, profile information and friend lists, in accordance with the authorization procedures determined by such third party site or platform provided that you have given the third party site in question such consent.
You can learn more about how such third-party sites or platforms process your personal data in the relevant privacy policy:
If you log into the App using a third party site or platform, you represent and warrant that (i) your access and use of such features in connection with the App will comply with the applicable terms and policies of such site or platform; and (ii) that you are over the minimum age limit that is prescribed for such third party site or platform by the legislation in the individual jurisdictions.
We use information about you for the following purposes in accordance with the legal bases for each type of personal data as described below:
We only process your information to the extent that is necessary to achieve the purposes for which the information has been collected.
Your Information is kept for as long as necessary in order to provide you with the Services or otherwise fulfill the purposes as described above unless further storage is required in order to establish, exercise or defend a legal claim or to comply with applicable law, including accounting rules.
We disclose information about you to the following categories of recipients based on the legal bases under Sections 6(1)(b), 6(1)(c) and 6(1)(f) of the GDPR (see a description of the legal bases above):
Furthermore, if you have given your consent in accordance with Section 6(1)(a) of the GDPR, we share your Device identifiers to advertising network companies for the purpose of them serving behavioral advertisements to you within the App. We use or may use the following advertising network companies:
The recipients' use of the disclosed information will not be covered by this Privacy Policy. If you have questions concerning the processing carried out by such third parties, you should review their privacy policy.
In connection with our processing, we use following data processors such as analytics service providers:
The App offers or can offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take in the App with other media. You must be over the minimum age limit that is prescribed by the legislation in the individual jurisdictions to use any social sharing features integrated in the App. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature.
Use of the App is limited to users aged 13 years and above, except in European Economic Area, where the App is limited to users aged 16 years and above. If you are accepting this Privacy Policy and using the App, you warrant you are 13 (or 16, depends what is applicable) or more years old.
If you have additional questions about Holeyo's privacy practices related to children under the applicable minimum age, please contact us at holeyo@126.com.
Holeyo takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.
We send push notifications or alerts to your mobile device to provide game-related information, service updates, promotional communications and other related messages, if you have agreed to such notifications. You can deactivate these notifications by changing your notification settings on your device.
Holeyo does not, and will not, provide your personal data in direct exchange for money. Therefore, in the literal sense, Holeyo does not sell your data. However, we have disclosed some categories of personal data we collect, explained under ”Sharing of information“, to the third parties for business purpose as explained under “Use of information – purpose and legal basis”.
To the extent this practice is interpreted to constitute a “sale” under the CCPA, please contact us at holeyo@126.com to exercise your right to withdraw your consent on sharing your personal data with third parties.
We process and answer your requests without undue delay and in any event within one month of our receipt of the request unless a longer period is required due to the complexity of the request. In this case, our response time can be up to three months in total as permitted by Article 12 of the GDPR.
You have the right to request access into the data that we are processing on you, see Article 15 of the GDPR, including information about:
Furthermore, you have the right to obtain a copy of the personal data undergoing processing. Please note that the access may be restricted due to intellectual property or trade secrets.
You have the right to object to our processing of your personal data on grounds relating to your particular situation when the data are processed based on the balancing-of- interest rule in Section 6(1)(f) of the GDPR, see Article 21 of the GDPR. In this case, we will cease the processing unless there are compelling legitimate grounds for the processing which override your interests, rights and freedoms or if the processing is necessary for the establishment, exercise or defense of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes at any time. We will cease the processing of your personal data for this purpose after the objection.
You have the right to have inaccurate personal data rectified, see Article 16 of the GDPR.
You have the right to obtain restriction of processing in certain circumstances, see Article 18 of the GDPR. If you have the right to restriction, we will only process your data with your consent or for the establishment, exercise or defense of a legal claim or to protect a person or important grounds of public interest.
If we have asked for your consent to our processing of your data, you have the right to withdraw your consent at any time, see Article 7 of the GDPR.
If you withdraw your consent, we will cease processing of the data for which you have withdrawn consent, unless we have a legal obligation to keep some or parts of your data.
The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal.
You have the right to receive the personal data you have provided us with which we process in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller if the processing is based on consent or contract performance, see Article 20 of the GDPR.
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal data that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
Under CCPA each California resident can request any business stops selling personal information to third parties.
You have a right to be informed about what categories of personal data we are collecting, including the purpose of the collection. You can freely find this information in our Privacy Policy. We update our Privacy Policy at least once every 12 months.
You can request us to disclose what personal data we have collected on you in the past 12 months.
We can assure you that our Privacy Policy is an relevant document where you can find information about what personal data we have collected about you over the past 12 months and intend to collect, sources of your personal data and how we use your personal data.
You also have a right to get a free copy of your personal information disclosed in a readily usable and readable format (right of access). You can make this request for free, twice per year.
When providing information under the right of access, we will provide you with the following information:
You can request us to delete the personal data we have collected on you in the past 12 months.
We fully recognize you right to deletion, however, we would like to note that in some cases we are obliged to keep your personal data for certain period of time. For instance, if we need to provide services to you, detect or resolve issues security or functionality-related issues, comply with the law, conduct research in the public interest, safeguard the right to free speech or carry out any actions for internal purposes that you might reasonably expect. If we do not have obligations to perform any of the above actions, we can delete your personal information at your request.
You may request Holeyo to erase without undue delay your personal data when it is no longer necessary for Holeyo to retain such data.
In order for your data to be erased you can contact Holeyo by holeyo@126.com with request.
California residents are protected against any discrimination that a business might subject them to based on the exercising of their CCPA rights.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
If you have any questions about this Privacy Policy, would you like to learn more about why, how, and what Personal Data we use, or to request deleting it, please contact us at holeyo@126.com.