SUBARA does not knowingly collect any personal information from children. We use a neutral age screen and local IP geolocation to determine if users are old enough to give consent in their country.

If you're under the legal age in your jurisdiction to provide explicit consent, we do not activate any tracking tools and we only collect pseudonymized usage metrics for internal operations. If you're old enough, we ask for your permission to enable cookies, analytics, or personalized ads.

If we ever learn that we collected personal data from a child by mistake, we will delete it right away. If you're a parent and think your child has shared personal data, please email us at support (at) subara.com.

To help improve our services, we collect technical and usage information using tools like Firebase and Unity Ads/ironSource SDKs. This is necessary to support our internal operations and helps us understand how players use our games.

We do not collect anything that can identify you personally unless you are above the legal age and provide explicit consent to do so. This data is shared only with trusted partners who respect this policy.

We never collect or share personal data from children under the legal age.

We use local IP geolocation only to check the user's country and apply the right privacy rules according to it. This happens on your device and the IP address is never stored or sent to our servers.

We do not track your physical location or use any GPS features.

Some parts of our content use third-party tools like Google Firebase or Unity Ads (ironSource). These tools may collect technical data, but only after asking for your permission if required by law.

We also link to websites and content outside of SUBARA. Always check the privacy policies of those websites before using them. SUBARA is not responsible for how other sites handle your data.

Effective Date: May 8, 2025

At SUBARA Ltd. ("we", "our", "SUBARA"), we are committed to protecting your privacy. This Privacy Policy explains how we collect, use, and safeguard personal information across our games and our website https://subara.com, in compliance with international privacy laws including the GDPR, COPPA, and others.

SUBARA Ltd. (based in Ireland) acts as the Data Controller for all personal data processed through our services.

This policy applies to:

- Our website: https://subara.com

- All mobile games developed and published by SUBARA Ltd.

This includes games directed at general audiences, with special attention to users under 13-16 years, according with privacy laws (COPPA 16 CFR Part 312).

We do not knowingly collect personal information from children under the legal digital age in their country (e.g., under 13 in the U.S., under 16 in parts of the EU).

To comply with different national laws, we use IP-based geolocation to determine the user's country and apply the corresponding minimum age threshold. This geolocation process is performed locally on the user’s device and no IP address or location data is sent or stored.

Before any data collection, users are shown a Neutral Age Screen that does not collect information or suggest answers.

If the user declares to be underage: we disable advertising identifiers (IDFA/AAID) but continue to collect pseudonymized analytics (App Instance ID only) for internal operations.

If the user declares to be of legal age: we may request explicit consent to enable tracking and personalized ads.

If we discover that we have collected personal information from a child without verifiable parental consent, we will delete it immediately.

If you believe your child has shared personal data with us, contact us at support (at) subara.com in order to delete any stored personal data and disable future data collection and storage.

We may collect the following data (with consent where applicable):

- Device identifiers (e.g., IDFA, GAID) -> with the finality to obtain usage metrics, performance analysis and personalize advertising

- Technical data: device type, OS, language, country, timezone -> with the finality to obtain usage metrics, performance analysis and personalize advertising

- In-game events, crashes, usage behavior -> with the finality to obtain usage metrics and performance analysis

We may store this data to support our internal operations:

- We will only store it for as long as strictly necessary, and never more than 14 months

- You have the right to ask us about deleting it at any moment by contacting us at support (at) subara.com

We use trusted third-party tools:

- Google Analytics for Firebase: https://firebase.google.com/support/privacy

- ironSource SDK (Unity Ads): https://unity.com/legal/ads-privacy

These services may collect technical or usage data for analytics and ad personalization, but only after obtaining user consent where legally required.

Other advertising networks may operate through mediation and comply with relevant frameworks (e.g., IAB TCF v2.2, COPPA Safe Harbor).

We process personal data on the basis of:

- Your consent (for tracking, ads, and analytics)

- Our legal obligations

- Our legitimate interests (only when user rights do not override them)

We do not sell your personal data. We may share data with:

- Service providers that operate on our behalf (e.g., analytics or ad networks)

- Authorities, if required by law

- Advertising partners, only with your consent

Some data may be processed outside your country. These transfers are protected using appropriate safeguards such as Standard Contractual Clauses or equivalent legal mechanisms.

Data retention is configured in Firebase Analytics for a maximum of 14 months per property. Once older than 14 months, individual records are purged; only anonymized, aggregate statistics are preserved indefinitely.

We retain personal data only as long as necessary for the purposes for which it was collected or as required by law. Once data is no longer needed, we securely delete or anonymize it.

We may use cookies and SDKs to enhance gameplay, measure usage, and show relevant ads. These are only enabled after obtaining your consent, when required by law. You can manage your preferences in-game or on our website.

We apply technical and organizational safeguards to protect your data from unauthorized access, loss, or misuse. This includes encryption, access control, and internal audits.

We may update this policy from time to time. If changes are material, we will notify you within our games or on our website and, where necessary, ask for renewed consent.

If you have any questions about this policy or how we handle personal data, contact us at support (at) subara.com.

Here are the cookies we use (only enabled with your explicit consent when necessary by law):

_ga - Google Analytics (Firebase SDK) - Distinguish unique users across sessions, to support internal operations.

_gid - Google Analytics (Firebase SDK) - Count the number of sessions per user, to support internal operations.

_gat - Google Analytics (Firebase SDK) - Throttle request rate to the server, to support internal operations.

_gac_<MEASUREMENT_ID> - Google Analytics (Firebase SDK) - Store campaign information (UTM, AdWords) for conversion measurement

IDFA / AAID - Unity Ads / ironSource SDK (mobile) - Persistent device identifier for personalized ads and measurement

These cookies will be deleted if the games are uninstalled from your device.

Legitimate interests: We process pseudonymized usage data (App Instance ID and event logs) on the basis of our legitimate interests in understanding, improving, and securing our Services. This processing is strictly limited to internal analytics—such as retention, cohort analysis, and performance monitoring—and does not involve profiling, marketing, or sharing with third parties for advertising purposes. We have carefully balanced our interests against your data protection rights and determined that our analytics needs do not override your privacy expectations.

Consent: For any processing that goes beyond internal analytics—such as setting cookies for personalized advertising or enabling third-party tracking—we will obtain your explicit consent in advance. You may grant, refuse, or withdraw consent at any time via our Consent Center or in your account settings. Withdrawal of consent will not affect the lawfulness of processing carried out prior to the withdrawal.