Effective Date: June 30, 2025
At Fotoable (Betta Games), we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal information. By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use, and share your information as described in this Privacy Policy.
Remember that your use of Fotoable's Services (Betta Games) is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.
This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. "Personal Data" means any information that identifies or relates to a particular individual and also includes information referred to as "personally identifiable information" or "personal information" under applicable data privacy laws, rules, or regulations. This Privacy Policy does not cover the practices of companies we don't own or control or people we don't manage.
The following details the categories of Personal Data that we collect and have collected over the past twelve (12) months:
| Category of Personal Data | Personal Data Collected | Source of this Personal Data |
|---|---|---|
| Personal identifiers | Device identifiers, Advertising ID from Google or Apple, Internet Protocol address, Facebook username (if you login through your Facebook account) | You / Third Parties |
| Commercial information | In-app purchases, products or services purchased, purchasing or consuming histories and tendencies | You / Service Provider |
| Interaction information | Information on your interaction with our gaming application (If users log in via social networks or third parties mainly like Facebook) | You / Third Parties |
| Inferences drawn from other personal information | In-game behaviors | You / Service Provider |
We store information on servers located in the United States via Amazon Web Services or Google Cloud or Azure.
We collect Personal Data about you from the following categories of sources:
The Services use ad identifiers, which are non-permanent, non-personal identifiers such as the Android advertising ID (Advertising ID) or Apple's ID for advertising (the "SKAdNetwork ID") uniquely associated with your device. These technologies allow us and our advertising partners to recognize your device when you use the Services.
We may serve advertisements, and also allow third-party ad networks to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors ("Interest-Based Ads").
We comply with the Digital Advertising Alliance ("DAA") Self-Regulatory Principles for Online Behavioral Advertising. To make choices about Interest-Based Ads from participating third parties, including to opt-out of receiving behaviorally targeted advertisements from participating organizations, please visit the DAA's or NAI's consumer opt-out pages at http://www.networkadvertising.org/choices/ or www.aboutads.info/choices.
We process Personal Data to operate, improve, understand and personalize our Services. We use Personal Data for the following purposes:
| The third party sharing your personal data | Category of Personal data shared | Purpose of sharing | Period of retention |
|---|---|---|---|
| Appsflyer, Firebase, Facebook | A,D,F,K | Data Analytics | Limited period subject to the third party Policy |
| Facebook, Google Admob, Applovin, Unity, Ironsource, Pangle, Tapjoy, Chartboost | A | Monetization | Will be deleted upon requesting from users |
| GoogleUAC, Facebook, Tapjoy, Unity, AppleSearch | A | Advertising | Limited period subject to the Advertising partners policy |
| F | Gaming function like login, or share | Will be deleted upon requesting from users |
Your Personal Data may be provided to the third parties overseas only in the extent necessary for the following cases:
| Name of the third party overseas | Country | Purpose of Transfer | Personal Data Transferred | Period of retention |
|---|---|---|---|---|
| Appsflyer | U.S.A | Data Analytics | A, D, F,K | Limited period subject to Appsflyer Policy |
| Firebase | U.S.A | Data Analytics | A, D, F,K | Limited period subject to Firebase Policy |
| U.S.A | Data Analytics | A, D, F,K | Limited period subject to Facebook Policy | |
| U.S.A | Monetization | A | Will be deleted upon requesting from users | |
| U.S.A | Advertising | A | Limited period subject to Facebook Policy | |
| U.S.A | Gaming function like login, or share | F | Will be deleted upon requesting from users |
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate security measures. For example, the Services use industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of Personal Data you provide to us.
We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law.
We do not knowingly collect or solicit Personal Data about children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible.
If you are a California resident, you have the right to request certain information about our collection and use of your Personal Data over the past 12 months, including:
We destroy your Personal Data without delay when the Personal Data becomes unnecessary owing to the expiry of the retention period, attainment of the purpose of processing the Personal Data, unless the retention of such Personal Data is mandatory by other statutes.
The methods to destroy Personal Data and its destruction process are as follows:
To exercise your rights, you must send us a request that (1) provides sufficient information to allow us to verify your identity, and (2) describes your request in sufficient detail.
You may submit a request using the following methods:
We may share your Personal Data with our Monetization partners: Facebook, Google Admob, Applovin, Unity, Ironsource, Pangle, Tapjoy, Chartboost.
You have the right to opt-out of the sale of your Personal Data. We do not sell the Personal Data of minors under 16 years of age without affirmative authorization.
We respect your privacy and provide the option for users to delete their data:
We may need to change this Privacy Policy from time to time, but we will alert you to changes by placing a notice within the games (apps) by sending you a notification, and/or by some other means.
We designate a Privacy Officer who comprehensively takes charge of personal information processing: