Privacy Policy & Data Safety

1. Data Controller Information

This Privacy Policy explains how Prime1 Lab LTD (Công ty TNHH Prime1) ("Company", "we", "us", or "our"), incorporated in the Socialist Republic of Vietnam, collects, uses, stores, and protects data when you interact with our mobile titles published directly on Google Play under Prime1 Lab LTD and via authorized publishing partner Nguyen Duc Tuyen (Developer ID: 1727054190) on the Apple App Store.

We design our games according to privacy-by-design and data-minimization principles. We do not sell player personal information, and we strictly enforce user rights under Vietnam data protection laws and global international regulations.

2. Compliance with Vietnam Personal Data Protection Decree (Decree 13/2023/NĐ-CP - PDPD)

As an enterprise established under the laws of Vietnam, Prime1 Lab LTD strictly complies with Decree No. 13/2023/NĐ-CP on Personal Data Protection (PDPD):

• Article 9 (Rights of Data Subjects): Players possess the fundamental rights to be informed, give consent, access, delete, request restriction of processing, obtain personal data, object to processing, and seek compensation or legal protection in accordance with Vietnamese law.
• Article 11 (Consent): Processing of basic telemetry or advertising identifiers is based on free, explicit, informed consent obtained through in-game prompts or device permission mechanisms.
• Article 16 (Right to Erasure): Players or legal guardians have the right to request deletion of all collected personal data at any time via our automated console below or by emailing contact@prime1game.com.
• Article 20 (Cross-Border Transfer): Any technical transfer of diagnostic logs or gameplay records to international cloud infrastructure (e.g., Google Cloud, Firebase) is safeguarded with end-to-end TLS 1.3 encryption and rigorous assessment.

3. Legal Bases for Processing under GDPR (Article 6)

For users located in the European Economic Area (EEA), United Kingdom, and Switzerland, we process data strictly in accordance with Article 6(1) of the General Data Protection Regulation (GDPR):

• Article 6(1)(a) — Consent: Processing of device advertising identifiers (Google AAID, Apple IDFA) for personalized ad experiences, subject to your explicit opt-in consent or withdrawal via device settings.
• Article 6(1)(b) — Performance of a Contract: Necessary processing to deliver core gameplay mechanics, level progression, leaderboards, and process in-app purchase entitlements.
• Article 6(1)(c) — Legal Obligation: Maintaining accounting and financial records for in-app billing verification and statutory tax compliance.
• Article 6(1)(f) — Legitimate Interests: Monitoring frame pacing, crash telemetry, detecting fraud or unauthorized cheats, and ensuring network and server security.

4. Information We Collect & Mobile Identifiers

Depending on the game and your device settings, we process the following categories of technical data:

• Device Telemetry: Device model, operating system version, screen resolution, GPU family, memory heap status, and frame pacing diagnostics.
• Gameplay Progress: Level completions, high scores, unlockable achievements, and in-game currency balances stored locally or via official platform cloud saves (Google Play Games Services, Apple Game Center).
• Advertising Identifiers:
  • Android (Google Play AAID): Google Advertising ID, used exclusively for programmatic ad capping and analytics, adhering to Google Play Data Safety policies.
  • iOS (Apple IDFA / IDFV): Identifier for Advertisers (IDFA) is accessed strictly when permitted via the Apple App Tracking Transparency (ATT) prompt. Identifier for Vendor (IDFV) is used solely for non-tracking cross-game analytics within our developer ecosystem.
• Crash & Diagnostic Logs: Anonymized stack traces through Firebase Crashlytics or platform diagnostics to resolve engine bugs and memory leaks.

5. Apple App Tracking Transparency (ATT) & iOS Privacy Manifests

On iOS 14.5 and newer, our games fully comply with Apple's App Tracking Transparency framework. When you open our iOS games, you are presented with the native ATT modal. If you tap "Ask App not to Track", our code disables IDFA collection entirely, setting the tracking authorization status to ATTrackingManagerAuthorizationStatusDenied. Furthermore, all third-party SDKs integrated into our iOS games include certified Apple Privacy Manifests (PrivacyInfo.xcprivacy) declaring declared reasons for API usage.

6. Google Play Data Safety Compliance

Our Android titles comply with Google Play's Data Safety declaration requirements. We explicitly declare all data collected or shared, encrypt data in transit via TLS 1.3, provide mechanisms for account and data deletion, and do not access precise location, contacts, or camera/microphone hardware.

7. COPPA Compliance & Protection of Children

Protecting young players is foundational to our mobile game architecture. Our casual titles adhere strictly to the Children's Online Privacy Protection Act (COPPA), Vietnam child protection regulations under the Law on Children, and the UK Age Appropriate Design Code:

• We do not knowingly collect personal information from children under the age of 13 (or under 16 in certain EU jurisdictions).
• In games categorized as family or child-directed, interest-based behavioral tracking is disabled by default, and only contextual non-personalized ads are rendered.
• We do not request names, phone numbers, social media logins, or physical addresses from child players.
• If a parent or guardian discovers that a child has provided us with personal data without consent, please use our Data Deletion Console or email contact@prime1game.com for immediate purging.

8. California Consumer Privacy Act (CCPA / CPRA) Disclosures

Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CPRA), California residents are entitled to specific rights:

• Right to Know & Access: You may request the categories and specific pieces of personal information we have collected over the preceding 12 months.
• Right to Delete: You have the right to request deletion of your personal information collected by us, subject to statutory exceptions.
• Right to Opt-Out of Sale or Sharing: We do NOT sell your personal data for monetary consideration. To opt out of programmatic cross-context advertising sharing, reset your device advertising ID or submit an opt-out ticket below.
• Right to Non-Discrimination: We will never discriminate against you for exercising any of your CCPA/CPRA rights.

9. Data Retention Schedule

We retain data strictly for the duration necessary to fulfill the purposes outlined in this policy:

11. Third-Party Services & app-ads.txt

We integrate trusted third-party SDKs to deliver cloud services, analytics, and non-intrusive programmatic advertising. Our authorized ad inventory is documented at prime1game.com/app-ads.txt. Third-party partners include:

• Google AdMob & Firebase: Google Privacy Policy
• Apple StoreKit & Game Center: Apple Privacy Policy
• Unity Ads / AppLovin / Certified SSPs: As published in our app-ads.txt records.

12. Privacy Contact & Data Protection Desk

If you have questions, feedback, or wish to exercise your statutory privacy rights, contact our Data Protection Desk: