SILLY MONKEYS · PRIVACY POLICY · GAMES FOUNDRY S.L.
Who We Are
This Privacy Policy explains how Games Foundry S.L. ("Company", "we", "our" or "us") collects, uses, shares and protects personal data when you use the mobile games we publish under the trade name Silly Monkeys, such as 2048, Duck Dash, Dunk Shot, Cannon Blast, Brick Breaker, Prism Pop, Ball Bounce, Solitaire, Word Trails, Block Stack and Pirate Hit (each, an "App"), and related services (the "Services").
Data controller: Games Foundry S.L., CIF B05791835, C/ Isabel Colbrand 10, 4th floor, Office 112, 28050 Madrid, Spain. Contact: support@sillymonkeys.app.
This Policy should be read together with our Terms and Conditions. It does not apply to information collected by third parties, including advertisers or ChillGames, through their own services.
Children
The Services are intended only for users aged 18 or over. We do not knowingly collect personal data from anyone under 18. If we learn that we have collected personal data from a person under 18, we will close the account and delete that data.
Personal Data We Collect
The Apps do not offer prizes, cash or rewards with real-world value, so we do not collect payment, bank, identity document or biometric data.
Information you provide:
- Account data: an account identifier created automatically when you open an App, username and, where you choose to provide them, email address or the data received when you sign in with Apple, Google or ChillGames.
- Communications: messages and attachments you send to customer support.
Information collected automatically:
- Device data: device model, operating system and version, language, app version, internal device ID, and advertising identifiers (IDFA on iOS, Google Advertising ID / App Set ID on Android).
- Network and location data: IP address and approximate location (country, state or region) derived from it. We do not collect precise GPS location.
- Gameplay data: Levels played and completed, Gems and other progress items collected, content unlocked, daily milestones, scores, progress and time spent.
- Security signals: device integrity checks and patterns of play used to detect cheating, bots or multiple accounts.
- Advertising data: ads viewed or clicked, and events reported by advertising and attribution partners.
Information from third parties: app stores (download and install data), advertising and attribution partners, and ChillGames (Games Growth S.L.U.) when you link your account or play the Apps through ChillGames (account identifier and advertising ID). We do not buy personal data from data brokers, and we do not receive personal data about you from other business partners.
How We Use Your Data and Legal Bases
| Purpose | Data used | Legal basis (GDPR) |
|---|---|---|
| Create and manage your account, save your progress and run the games | Account, device, gameplay | Performance of contract (Art. 6(1)(b)) |
| Allow ChillGames to credit rewards for your play, at your request | Account or advertising ID, gameplay, security signals | Performance of contract and legitimate interest in preventing fraud |
| Prevent cheating, bots and multiple accounts, and keep the Services secure | Device, network, gameplay, security signals | Legitimate interest (Art. 6(1)(f)) |
| Confirm you are not in a restricted territory | IP address, approximate location | Legal obligation and legitimate interest |
| Show ads that fund the Services (non-personalised) | Device, approximate location | Legitimate interest |
| Show personalised ads, run user-acquisition campaigns on third-party services and measure them | Advertising IDs, device, ad events | Consent (Art. 6(1)(a)); on iOS, only with App Tracking Transparency permission |
| Analytics and improving the games | Gameplay, device | Legitimate interest; consent where required |
| Customer support and complaints | Account, communications | Contract and legitimate interest |
| Comply with legal obligations and requests from authorities | Account, device | Legal obligation (Art. 6(1)(c)) |
| Service and account notifications | Account, email | Contract; promotional messages only with consent |
We use automated systems to detect cheating and fraud. Where an automated decision blocks your account, you may ask for human review, express your point of view and contest the decision by writing to support@sillymonkeys.app.
We do not use your personal data to train large language models.
Who We Share Your Data With
We do not sell your personal data for money. We share it only with:
- Games Growth S.L.U. (ChillGames): ChillGames is a separate rewards application operated by Games Growth S.L.U. (CIF B72941016), Calle Caléndula 95, Madrid, Spain, which allows its users to earn coins for playing the Apps. If you play the Apps through ChillGames, we share your account or advertising identifier and your gameplay data (Levels completed, progress items, time played and security signals) so that ChillGames can credit your rewards. We may also inform Games Growth S.L.U. of cheating or breaches of our Terms detected in the Apps. Games Growth S.L.U. processes this data as an independent controller under the ChillGames Privacy Policy.
- Service providers (processors): cloud hosting (Amazon Web Services), analytics, crash reporting, customer support and anti-cheat services, bound by contract to use the data only on our instructions.
- Advertising and attribution partners: such as AppLovin (advertising) and AppsFlyer (attribution). They receive advertising IDs, device data and ad events. Under some US state laws this may be a "sale" or "sharing" for targeted advertising; you can opt out (Section 8).
- Group companies, for internal administration and support.
- Authorities, courts and advisers, where required by law or to defend our rights.
- A buyer or successor, in the event of a merger, acquisition or sale of assets.
All our service providers have signed agreements requiring them to keep personal data confidential and use it only for the purposes for which we disclose it. We do not share your personal data with third parties for their own marketing. An up-to-date list of our main providers is available on request at support@sillymonkeys.app.
International Transfers
Some of our providers are located outside the European Economic Area, including in the United States. When we transfer personal data outside the EEA, we rely on an adequacy decision (including the EU-US Data Privacy Framework, where the provider is certified) or on the European Commission's Standard Contractual Clauses, with additional safeguards where necessary. You may request a copy of the relevant safeguards at support@sillymonkeys.app.
How Long We Keep Your Data
| Data | Retention period |
|---|---|
| Account and gameplay data | While your account is active; deleted or anonymised after closure |
| Security and blocking records | Up to 3 years after account closure, to prevent re-registration after a ban |
| Support communications | 2 years after the matter is closed |
| Advertising and analytics data | Per our partners' policies; IDs reset by you are no longer linked |
At the end of each period, data is deleted, destroyed or anonymised. We may keep it longer where needed for legal claims.
Your Rights and Choices
Everyone. You can at any time:
- Delete your account from the App settings or by writing to support@sillymonkeys.app.
- Reset or limit your advertising ID in your device settings, and refuse or withdraw App Tracking Transparency permission on iOS.
- Stop receiving our promotional messages by adjusting your notification preferences in the App settings, turning off push notifications on your device, or using the unsubscribe link in our emails.
- Withdraw any consent you have given, without affecting processing carried out before withdrawal.
Users in the EU, UK and Switzerland. You have the right to access, rectify and erase your data, to restrict or object to processing (including profiling based on legitimate interest), to data portability, and not to be subject to decisions based solely on automated processing without human review. You can manage advertising consent at any time through "Your Privacy Choices" in the App settings. You also have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD, www.aepd.es) or the authority in your country.
US residents. Depending on your state (including California, Colorado, Connecticut, Virginia, Texas, Oregon and others), you may have the right to:
- Know and access the personal data we hold about you, and receive it in a portable format.
- Correct inaccurate personal data.
- Delete your personal data, subject to legal exceptions.
- Opt out of the "sale" or "sharing" of personal data, targeted advertising and profiling, through "Your Privacy Choices" in the App settings or at https://sillymonkeys.app, or by email. Third-party ad networks may also offer their own opt-out tools, such as the Network Advertising Initiative (NAI) opt-out page.
- Not be discriminated against for exercising these rights.
- Appeal our decision on your request by emailing support@sillymonkeys.app with the subject "Appeal of Consumer Rights Decision".
The exact scope of these rights varies by state, and your state's privacy law may not apply to us at this time; there are also exceptions where we may not be required to fulfil a request. We honour Global Privacy Control (GPC) signals where required by law. California residents may also request information under California's "Shine the Light" law (Civil Code § 1798.83) by emailing support@sillymonkeys.app with the subject "California Privacy Rights", or by writing to our postal address in Section 11.
How to make a request. Email support@sillymonkeys.app or use the in-app option. We may ask for information to verify your identity; please do not send identity documents unless we ask for them. We will respond within one month (GDPR) or 45 days (US state laws), extendable where the law allows. An authorised agent may submit a request on your behalf with proof of authorisation.
Security
We use reasonable technical and organisational measures to protect personal data, including encryption in transit and access controls. No system is completely secure, so we cannot guarantee absolute security. You are responsible for keeping your device and account access secure.
Changes to This Policy
We may update this Policy from time to time. We will post the updated version in the Apps and at https://sillymonkeys.app, update the "Last Updated" date and, where changes are material, notify you in advance through the Apps or by email. Where the law requires your consent to a change, we will ask for it.
Contact
Games Foundry S.L. (Silly Monkeys) – C/ Isabel Colbrand 10, 4th floor, Office 112, 28050 Madrid, Spain – support@sillymonkeys.app