Privacy Policy

1. Introduction and Scope

This Privacy Policy explains how Avanta Innovations Corporation (“Avanta,” “we,” “us,” or “our”), through its Avanta Games division, collects, uses, and protects information in connection with our mobile games and the Avanta Games pages of our website (together, the “Games”).

Our Games are not all alike. Some are offline single-player titles that collect nothing about you. Others are connected, offering features such as accounts, saved progress across devices, online play, or ways to play alongside other people. Because of that range, this policy describes practices by capability: a section that begins “where a Game offers…” applies only to those Games that actually offer it. Each Game's store listing and its in-game privacy notice tell you which capabilities that particular Game has before you play it.

This policy applies only to the Games. It does not apply to Avanta Build, our construction platform, which is a separate product with its own Privacy Policy. Nothing in this policy grants us rights over data held in Avanta Build, and nothing in that policy applies to players of the Games.

We are based in the Philippines, and this policy is intended to comply with the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations. Because our Games are made for a general audience that includes children, it is also written to meet the standards of the United States Children's Online Privacy Protection Act (COPPA), the Google Play Families policy, the Apple Kids Category guidelines, and Article 8 of the EU General Data Protection Regulation.

2. Our Approach: Only What the Feature Needs

We treat data collection as a cost to be justified, not a default to be filled. A Game collects something only when a feature you are using cannot work without it, and it stops collecting when that feature is no longer in play.

In practice that produces a spectrum. At one end, an offline single-player Game holds your progress in local storage on your device, never contacts us, and gives us nothing to hold. At the other, a connected Game with an account and online play needs an identifier for your save data and enough session information to place you in a game with other people. Both are covered here; neither collects more than its own feature set requires.

Where a Game does connect, the reasons are limited to those described in this policy: delivering the Game's own features, showing advertising, validating an in-app purchase with the app store, and reporting crash diagnostics.

3. Information We Collect

a. Game data on your device (all Games)

Level progress, scores, settings, and unlocked items are written to local storage on the device. In an offline Game this is the whole story: the data stays on the device, is not transmitted to us, and is deleted when you uninstall the Game or clear its data.

b. Account information (where a Game offers accounts)

Where a Game offers an account, we collect what is needed to create and secure it — typically an email address or a third-party sign-in identifier, a display name you choose, and authentication data. We do not require your real name, your postal address, or your phone number. Accounts are optional wherever the Game can function without one.

c. Saved progress in the cloud (where a Game offers it)

Where a Game syncs progress across devices, we store that progress against your account identifier so it can be restored. This is game state — levels, items, settings — not a record of you personally.

d. Online play (where a Game offers it)

Where a Game supports online or multiplayer play, we process the information needed to run a session: your display name, an account or session identifier, IP address, connection quality data, match results, and gameplay events used for scoring, matchmaking, and anti-cheat. Some of this, such as a display name and a score, is visible to other players by design.

e. Player-to-player features (where a Game offers them)

Where a Game lets players communicate or share content, we process what is sent so it can be delivered, moderated, and — if reported — reviewed. Please do not share personal information through these features. Section 6 explains the additional protections that apply to children.

f. Purchase information

In-app purchases are processed entirely by Apple's App Store or Google Play under their own terms and privacy policies. We never receive or store card numbers or payment credentials. We receive a transaction receipt confirming a purchase so the Game can unlock the item, plus aggregated, anonymous sales reporting from the stores.

g. Advertising data

Advertisements are served by third-party providers. To display an ad and prevent fraud, those providers process limited technical signals such as device type, operating system version, screen size, language, coarse country-level location derived from IP address, and the IP address itself. Section 5 sets out the strict limits we place on this.

h. Crash and stability diagnostics

When a Game crashes we may receive an automated report containing the device model, operating system version, Game version, and a technical stack trace. These reports are used only to fix defects.

i. Support correspondence

If you email us, we receive whatever is in that email, including the sending address. We use it only to answer and keep it no longer than needed to resolve the matter.

4. Information We Do Not Collect

Regardless of what features a Game has, none of our Games collect:

• Precise or GPS-level location;
• Your contacts, calendar, photo library, or files on your device;
• Microphone audio or camera images, unless a Game offers a feature that plainly requires it and you grant the permission for that purpose;
• Advertising identifiers (Apple IDFA or Google Advertising ID);
• Payment card numbers, bank details, or billing addresses;
• Biometric data or government identifiers;
• Persistent identifiers used to track you across other companies' apps or websites.

We also do not require a real name to play any Game, and we do not sell personal information or share it for cross-context behavioural advertising.

5. Advertising and Children

Our Games are supported in part by advertising. Because they are made for an audience that includes children, the following restrictions apply to every ad in every Game, online or offline:

• Contextual ads only. Ads are selected by what the Game is and non-personal signals such as coarse country and device type — never by who the player is or what they have done in other apps.
• No personalised or behavioural advertising. We disable personalised advertising in our providers' configuration for all Games and all players, regardless of age or country.
• No advertising identifiers. Our Games do not collect the Apple IDFA or the Google Advertising ID and do not present the iOS App Tracking Transparency prompt, because we do not track players across other companies' apps or websites.
• Certified providers only. We use ad providers self-certified under the Google Play Families Ads programme that support child-directed treatment, and we enable those settings.
• Age-appropriate ad content. Ad content is restricted to a general-audience rating, excluding gambling, alcohol, tobacco, dating, and mature or violent categories.
• No deceptive placements. Ads are clearly distinguishable from gameplay, are not disguised as game elements, and are not placed where a player is likely to tap them by accident.

Our ad providers process the signals in section 3(g) as independent controllers for fraud prevention, frequency capping, and delivery measurement. We do not permit them to use data from our Games to build advertising profiles or to target ads elsewhere.

6. Children's Privacy and Parental Consent

Our Games are made to be safe for players of all ages, children included. How this section applies depends on what a Game does.

a. Games that collect nothing

Where a Game is offline and has no account, no online play, and no player-to-player features, we collect no personal information from anyone, children included, and no parental consent is required for it to operate.

b. Games that can collect personal information

Where a Game offers a feature that would collect personal information — an account, cloud saves, online play, or player-to-player features — and the player is a child under 13 (or under the applicable age of digital consent in your country, which is up to 16 in parts of the European Economic Area), we will:

• Apply a neutral age screen that does not encourage the player to falsify their age, before any such feature is offered;
• Obtain verifiable parental consent from a parent or guardian before collecting, using, or disclosing that child's personal information;
• Give the parent clear notice, before consent, of what will be collected, how it will be used, and whether it will be disclosed to anyone;
• Collect no more than is reasonably necessary for the child to take part, and never condition participation in an activity on disclosing more than that;
• Offer the child the Game's core single-player experience without the data-collecting feature where consent is not given, wherever the Game's design allows.

c. Extra protections in connected play

• We do not make a child's personal information publicly available, and we do not permit a child's display name to be their real name.
• Where a Game lets players communicate, communication available to children is designed for safety — for example through pre-set phrases or moderated messaging rather than open free-text chat — with reporting and blocking available.
• We do not use a child's information for advertising, profiling, or any purpose beyond delivering the feature and keeping it safe.
• We do not send push notifications or other prompts designed to draw a child back into a Game using their personal information.

d. Parental rights

A parent or guardian may at any time review the personal information we hold about their child, have it deleted, refuse any further collection, and withdraw a consent already given — which will stop the collection and delete what we hold, though it may also disable the feature that depended on it. We will not require a parent to create an account to make such a request. Contact us at admin@avanta.com.ph, and we may ask for information sufficient to confirm you are the child's parent or guardian.

If we learn that we have collected personal information from a child without the consent required above, we will delete it promptly.

A note on purchases. Because all billing runs through Apple and Google, the parental controls those platforms provide — Apple's Ask to Buy and Screen Time restrictions, and Google Play's purchase-approval settings — apply to our Games automatically. We encourage parents to enable them.

7. How Information Is Used

Information described in section 3 is used only to:

• Run the Game and save your progress;
• Create and secure an account, and restore your progress on a new device, where a Game offers those;
• Operate online play, matchmaking, scoring, and leaderboards, where a Game offers them;
• Deliver, moderate, and — where reported — review content players send each other;
• Deliver and unlock in-app purchases;
• Display advertising within the limits in section 5;
• Diagnose crashes, fix defects, and improve stability and balance;
• Detect and prevent cheating, fraud, abuse, and technical attacks;
• Respond to your support enquiries;
• Comply with legal obligations.

We do not use information from the Games for advertising profiles, for automated decisions with legal or similarly significant effects, or to train artificial intelligence models.

8. Legal Bases for Processing

Where the GDPR or a comparable law applies, we rely on: performance of a contract for delivering the Game, your account, and any purchase; legitimate interests for crash diagnostics, anti-cheat, fraud prevention, moderation, contextual advertising that funds a free game, and securing the Games; consent — including verifiable parental consent under section 6 — where required for storing or accessing information on your device or for collecting a child's personal information; and legal obligation where we must retain or disclose information by law.

9. How Information Is Shared

We do not sell personal information, and we do not share it for cross-context behavioural advertising. Information is disclosed only in these circumstances:

• Other players. In a Game with online or social features, the parts of your profile designed to be visible — such as a display name, avatar, or score — are shown to other players. Nothing else is.
• App stores. Apple and Google process downloads, purchases, and refunds under their own privacy policies.
• Advertising providers. As described in section 5.
• Service providers. Vendors who host our servers and website, deliver crash reporting, support moderation, or help us answer support email, under contractual confidentiality and security obligations.
• Legal and safety. Where we believe in good faith that disclosure is required to comply with the law, enforce our Terms of Service, or protect the rights and safety of players — particularly children — or the public.
• Business transfers. In connection with a merger, acquisition, financing, or sale of assets, subject to the protections in this policy.

10. Data Retention

On-device game data is retained until you delete it or uninstall the Game. Account and cloud-save data is retained while the account is active and deleted within 90 days of you closing it, subject to legal retention requirements. Online play and moderation records are retained for as long as needed for safety and anti-cheat purposes and then deleted. Crash diagnostics are retained for up to 24 months. Support correspondence is retained until the matter is resolved and then deleted. Purchase records are retained as required by tax and accounting law.

11. Security

Collecting little is itself a strong safeguard. For the information we do hold, we apply reasonable administrative, technical, and physical measures, including encryption in transit, hashed credentials, access controls, and monitoring. No system is perfectly secure, and we cannot guarantee absolute security.

12. Your Rights and Choices

Depending on where you live, you may have the right to access, correct, delete, or port personal data about you, to object to or restrict processing, and to withdraw consent. Your most direct controls are:

• Delete local game data by uninstalling the Game or clearing its storage in your device settings.
• Delete your account, where a Game has one, from within the Game's settings or by contacting us. This deletes the associated cloud saves.
• Manage purchases and refunds through your Apple or Google account.
• Parents may exercise the rights in section 6(d) on behalf of a child.
• Contact us at admin@avanta.com.ph to exercise any other right.

Philippine residents may lodge a complaint with the National Privacy Commission at privacy.gov.ph. Residents elsewhere may complain to their local supervisory authority.

13. International Data Transfers

We operate from the Philippines, and our servers and service providers may process information in other countries. Where information crosses borders, we take reasonable steps to ensure it remains protected consistently with this policy and applicable law.

14. Third-Party Services

Advertisements, store links, and third-party sign-in providers may lead to destinations we do not control and whose practices this policy does not cover. We encourage parents to review the privacy policies of any third-party app or site their child reaches from one of our Games.

15. Changes to This Policy

We may update this policy as our Games evolve. If we make a material change — in particular, if a Game begins collecting a category of information it did not collect before — we will update the “Last updated” date above and give notice in the Game or on this page before the change takes effect. Where a change would require new or additional parental consent under COPPA or comparable law, we will obtain that consent before the change applies to a child's information.

16. Contact Us

Questions about this policy, or a request from a parent or guardian, can go to our Data Protection Officer:

• Avanta Games, a division of Avanta Innovations Corporation
• Cebu, Philippines
• Email: admin@avanta.com.ph