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Policy

Effective date: May 8, 2025

SUBARA is a brand used by multiple entities within the SUBARA group for the development and publishing of video games.

By using this website or any of our content, you agree to this privacy policy.

SUBARA may modify or update this Privacy Policy at any time as we add new features or laws change. We recommend reviewing this page frequently.

Privacy Policy

We protect your privacy

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, we do not activate any tracking tools or collect any personal data. 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.

Non-personal information

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

We do not collect anything that can identify you personally without your permission. This data is for internal use and shared only with trusted partners who respect this policy.

We never collect or share personal data from children under the legal age without verified parental consent.

Geolocation and tracking

We use local IP geolocation only to check the user's country and apply the right privacy rules. 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.

Third-party services

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.

Full Privacy Policy – Introduction

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, which may include children.

Children's Privacy

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: no personal data is collected, and tracking technologies are disabled.

If the user declares to be of legal age: we may request explicit consent to enable cookies, analytics, 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.

Data We Collect & Tools We Use

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

- Device identifiers (e.g., IDFA, GAID)

- Technical data: device type, OS, language, country, timezone

- In-game events, crashes, usage behavior

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).

Legal Basis & Data Sharing

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

International Transfers & Retention

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

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.

Cookies, Security & Updates

We 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 (enabled with consent):

_ga - Google Analytics (Firebase SDK) - Distinguish unique users across sessions

_gid - Google Analytics (Firebase SDK) - Count the number of sessions per user

_gat - Google Analytics (Firebase SDK) - Throttle request rate to the server

_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

For Kids and Parents

We care about your safety!

We never collect your name or personal info. If you're not old enough, we only display contextual (non personalized) ads.

If you have questions, ask your parents to email us at support (at) subara.com.

Legal Notice

The following entities are part of the SUBARA group:

SUBARA Global SL — NIF: B13949748 — Registered in Spain

Calle Impresores 20, Boadilla del Monte, 28660, Madrid - Spain

SUBARA Limited — Registration no. 750857 — Registered in Ireland

Landscape House, Baldonnell Business Park

Dublin 22, Ireland

Contact: support (at) subara.com

SUBARA is a trademark used by the entities above for activities related to video game development and publishing.

Development services are carried out by SUBARA Global SL, while publishing and commercial operations are managed by SUBARA Ltd.

The website www.subara.com is maintained and administered by SUBARA Global SL (Spain) under instruction from SUBARA Ltd. (Ireland), the legal owner of the domain and associated services (e.g., email infrastructure).

Links to external stores or platforms may direct users to games published by SUBARA Ltd., which is solely responsible for their commercial exploitation.

Access to this website implies acceptance of its terms and conditions. The site is for informational use only and does not collect personal data unless expressly provided by the user.

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