Policies & Privacy

01

Privacy Policy

Karma Games Limited ("Karma Games", "we", "us", or "our") is committed to protecting your personal information. This Privacy Policy explains how we collect, use, and safeguard data when you use our mobile applications, including Puzzle Time and ThunderWords, and any other apps we publish (collectively, "our apps").

We are registered in England and Wales (Company No. 12425040). This policy is compliant with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Our apps are available on multiple platforms including the Apple App Store, Google Play Store, and Amazon Appstore. This policy applies regardless of which platform or device you use to access our apps.

Information we collect

Depending on how you use our apps, we may collect the following categories of information:

• Usage data — gameplay activity, puzzle completions, streaks, session length, and in-app interactions.
• Device information — device type, operating system version, unique device identifiers (such as advertising IDs), IP address, and language settings.
• Purchase data — records of in-app purchases or subscription status, processed by Apple or Google. We do not store payment card details. All payment processing is handled exclusively by the platform provider (Apple or Google) under their terms.
• Diagnostic data — crash reports and performance data to help us identify and fix issues.
• Analytics data — information about how you interact with our apps, collected via analytics tools including Google Analytics. This may include session data, feature usage, and aggregate behavioural patterns.
• Advertising data — if our apps serve personalised or interest-based advertising, we or our advertising partners may collect identifiers and usage data to serve relevant ads. See "Advertising and tracking" below.
• Communications — if you contact us by email or through support channels, we retain those communications to respond and resolve your query.
• Social features — if you connect a social network account (such as Facebook) to our apps, we may receive information from that social network as permitted by your privacy settings on that platform.

We do not require you to create an account to use our core apps. Where account features exist, we collect only the information necessary to provide them.

How we use your information

• To deliver and improve our games and features.
• To personalise your experience (e.g. saving progress, streaks).
• To diagnose technical problems and maintain app stability.
• To fulfil purchases and manage subscriptions.
• To serve advertisements, including interest-based or targeted advertising where permitted.
• To measure advertising effectiveness and understand our user base.
• To comply with legal obligations.

Legal basis for processing (UK GDPR)

• Contract performance — processing necessary to deliver the services you've requested.
• Legitimate interests — improving our products, preventing fraud, and ensuring security.
• Consent — where we ask for your permission before collecting optional data such as analytics or marketing communications.
• Legal obligation — where we are required to process data by law.

Advertising and tracking

Our apps may display advertisements served by third-party advertising networks. These partners may use cookies, web beacons (also known as tracking pixels or web bugs), device identifiers, and similar technologies to collect information about your interactions with ads and our apps, in order to serve you interest-based advertising.

Advertising partners we may work with include Google (including DoubleClick/Google Ad Manager). These partners operate under their own privacy policies.

We may also use Facebook Custom Audiences to serve relevant advertising to our users on Facebook and Instagram. This involves sharing hashed identifiers with Facebook under their Custom Audiences terms.

You can opt out of interest-based advertising at any time:

• iOS: Go to Settings → Privacy & Security → Tracking, and disable "Allow Apps to Request to Track". You can also reset your Advertising Identifier via Settings → Privacy & Security → Apple Advertising.
• Android: Go to Settings → Google → Ads, and enable "Opt out of Ads Personalisation".
• Amazon devices: Go to Settings → Apps & Games → Amazon Advertising.
• Industry opt-outs: Visit youronlinechoices.com (UK/EU) or optout.aboutads.info (US).

Opting out of interest-based advertising does not remove advertising from our apps — you will still see ads, but they will be less targeted.

Data sharing

We do not sell your personal data. We may share data with trusted third-party service providers who assist us in operating our apps, including:

• Apple Inc. and Google LLC — for app distribution and in-app purchase processing.
• Amazon — for app distribution via the Amazon Appstore.
• Analytics providers, including Google Analytics — to help us understand how our apps are used (data is aggregated and anonymised where possible).
• Advertising networks and partners — as described under "Advertising and tracking" above.
• Cloud infrastructure and hosting providers — for app hosting and data storage.
• Social networking platforms — where you have connected a social account to our apps, as permitted by your settings on that platform.

All third-party providers are required to protect your data in accordance with applicable law.

We may also disclose your information where required by law, court order, or to protect the rights, property, or safety of Karma Games, our users, or others.

Business transfers: If Karma Games is involved in a merger, acquisition, sale of assets, or similar transaction, your personal data may be transferred as part of that transaction. We will notify you via prominent notice on our website or in-app if your data becomes subject to a materially different privacy policy as a result.

Where we store your data

Your personal data is processed and stored within the European Economic Area (EEA) or the United Kingdom. Where data is transferred outside the EEA or UK — for example, to US-based service providers — we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the relevant authority.

Data retention

We retain personal data for as long as necessary to fulfil the purposes outlined in this policy, or as required by law. Where you delete the app or request erasure, we will delete or anonymise your data within 30 days unless a longer retention period is required.

Your rights

Under UK GDPR, you have the right to:

• Access the personal data we hold about you.
• Request correction of inaccurate data.
• Request erasure of your data ("right to be forgotten").
• Object to or restrict certain processing.
• Data portability — receive your data in a structured, machine-readable format.
• Withdraw consent at any time where processing is based on consent.

To exercise any of these rights, contact us at games@karma.co.uk. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.

California residents (CCPA)

If you are a California resident, the California Consumer Privacy Act (CCPA) grants you additional rights regarding your personal information:

• Right to know — you may request details about the categories and specific pieces of personal information we have collected about you, the sources, the purposes, and the third parties we share it with.
• Right to deletion — you may request that we delete personal information we have collected from you, subject to certain exceptions.
• Right to opt out of sale — we do not sell personal information as defined under the CCPA. However, the sharing of identifiers with advertising partners for interest-based advertising may constitute a "sale" under California law. You may opt out by using the device-level controls described under "Advertising and tracking" above.
• Right to non-discrimination — we will not discriminate against you for exercising your CCPA rights.

California residents may submit requests to games@karma.co.uk. We will respond within 45 days as required by law.

02

Cookie Policy

Our mobile apps do not use browser cookies. This Cookie Policy relates to our website and any web-based versions of our puzzle experiences.

What are cookies?

Cookies are small text files placed on your device when you visit a website. They help us understand how visitors use our site and improve your experience.

Cookies and similar technologies we use

In addition to cookies, our website and web-based experiences may use web beacons (also called tracking pixels or clear GIFs) — small image files embedded in pages or emails that help us understand user behaviour and measure campaign effectiveness. These work alongside cookies and may be placed by us or third-party partners.

• Essential cookies — required for the site to function correctly. These cannot be disabled.
• Analytics cookies — help us understand traffic patterns and page performance. We use Google Analytics for this purpose. Data is aggregated and anonymised where possible. Google Analytics sets cookies such as _ga and _gid.
• Advertising cookies — used to serve relevant advertising and measure ad performance. We may use DoubleClick (Google Ad Manager) cookies for this purpose.
• Preference cookies — remember your settings such as language or display preferences.

Managing cookies

You can control or delete cookies through your browser settings at any time. Disabling non-essential cookies will not affect your ability to use our core content. For more information, visit aboutcookies.org. To opt out of Google Analytics tracking specifically, you can use the Google Analytics Opt-out Browser Add-on.

03

Terms of Use

By downloading or using any Karma Games app, you agree to be bound by these Terms of Use. Please read them carefully before use.

Licence

Karma Games grants you a limited, non-exclusive, non-transferable, revocable licence to use our apps for personal, non-commercial purposes in accordance with these terms.

Prohibited conduct

You agree not to:

• Reverse engineer, decompile, or modify any part of our apps.
• Use our apps for any unlawful or fraudulent purpose.
• Attempt to gain unauthorised access to any systems or networks connected to our services.
• Scrape, copy, or redistribute our puzzle content without written permission.

In-app purchases & subscriptions

Some of our apps offer in-app purchases and/or subscriptions. All purchases are processed exclusively by the relevant platform provider — Apple (App Store), Google (Google Play), or Amazon (Amazon Appstore) — in accordance with their respective terms of service and payment policies. Karma Games does not process or store your payment card details.

Auto-renewing subscriptions renew automatically at the end of each billing period unless cancelled at least 24 hours before the renewal date. You can manage or cancel subscriptions through your platform account settings (Apple ID, Google Play account, or Amazon account). Refunds are governed by the platform provider's own refund policy; Karma Games cannot issue refunds directly for platform-processed purchases.

Pricing and available purchase options may vary by region and platform. All prices are displayed inclusive of applicable taxes where required by law.

Intellectual property

All content within our apps — including puzzle content, graphics, audio, and software — is the property of Karma Games Limited or its licensors and is protected by UK and international copyright law. Nothing in these terms grants you ownership of any content.

Disclaimer of warranties

Our apps are provided "as is" without warranty of any kind. We do not guarantee that they will be uninterrupted, error-free, or free of viruses. We reserve the right to modify, suspend, or discontinue any feature or app at any time.

Limitation of liability

To the maximum extent permitted by law, Karma Games shall not be liable for any indirect, incidental, or consequential damages arising from your use of our apps. Our total liability shall not exceed the amount paid by you for the relevant app or subscription in the preceding 12 months.

Governing law

These terms are governed by the laws of England and Wales. Any disputes shall be subject to the exclusive jurisdiction of the courts of England and Wales.

Changes to these terms

We may update these terms from time to time. Continued use of our apps after changes are posted constitutes acceptance of the revised terms. We will notify users of material changes via in-app notice or email where required.

04

Children's Privacy

Karma Games apps are designed for general audiences and are not directed at children under the age of 13. We do not knowingly collect personal information from children under 13.

Age-appropriate design

We are committed to complying with the UK Age Appropriate Design Code (Children's Code). Our apps avoid practices that could cause harm to younger users, including nudge techniques, data profiling, or features designed to extend engagement beyond what is appropriate.

Parental controls

We encourage parents and guardians to supervise their children's device usage. Most devices offer built-in parental controls that can restrict in-app purchases and limit app usage time.

If you believe a child has provided us with personal data

If you are a parent or guardian and believe your child has provided us with personal information without your consent, please contact us immediately at games@karma.co.uk. We will take prompt steps to delete that information from our systems.

05

Contact Us

If you have any questions about these policies, wish to exercise your data rights, or need to report a concern, please get in touch:

You can also contact the UK's data protection authority:
Information Commissioner's Office (ICO)
ico.org.uk  ·  0303 123 1113