Legal / privacy

Privacy Policy

Effective date: May 12, 2026 · Last updated: October 7, 2026

This Privacy Policy explains how Dumbakod Ltd (DUMBAKOD EOOD, "Dumbakod", "we", "us", or "our") handles information in connection with our websites, mobile apps and games published under Dumbakod on the App Store, Google Play and Steam, and any other product that links to this policy. It covers in particular:

1. Information We Collect Directly

Most Dumbakod apps do not require an account. We do not directly collect names, addresses, phone numbers, passwords, or government IDs through our general mobile apps unless a specific feature clearly asks you to provide information.

If you contact us by email, we receive your email address and any information you choose to include in the message. We use that information only to respond and handle support.

2. Accounts and Online Play

Белот Арена is an online multiplayer game and, unlike our other apps, it does require an account in order to play against other people. This section describes what that involves. If you only use our single-player apps, this section does not apply to you.

When you create an account we process the sign-in details you provide and a display name of your choosing. Your display name and in-game statistics are visible to other players you are matched with, so please do not use your full legal name or any other information you would rather keep private. We also process gameplay data needed to run matches, such as match history, scores, rankings, and connection information.

Белот Арена includes chat between players. Messages are transmitted through our servers and may be stored for a limited period so that we can respond to reports of abuse, cheating, or harassment. Do not share personal information, contact details, or payment information in chat. Other players can report messages to us, and reported messages may be reviewed by us to enforce our Terms of Service.

You can ask us to delete your Белот Арена account and its associated data at any time by emailing [email protected]. We may keep a minimal record where we are required to for security, abuse-prevention, or legal reasons.

The Викторина quizzes and Бележник offer optional online duels without an account. If you play online, the app creates a random key stored on your device and asks for a nickname. We store the nickname, that key, your duel results, your rating and your leaderboard position on our game server (hosted by Supabase). Your nickname, rating and results are visible to other players, so do not use your real name. You can ask us to delete this data by emailing us with your nickname. If you never play online, nothing about you is sent to our server.

3. App Data and Device Data

Our apps may store preferences, saved content, game progress, or app settings locally on your device. Some apps may use third-party services that automatically process technical data such as device identifiers, IP address, app version, crash information, diagnostics, approximate region, and interaction events.

Cinderdelve, our paid game for Steam (Windows and macOS), iPhone, iPad and Android, collects no personal data at all: no account, no analytics, no ads and no tracking. On phones and tablets it makes no network connections, and on Steam it only talks to the Steam client to record achievements. Its own Cinderdelve Privacy Policy gives the details.

4. Advertising and Analytics

Some free apps use Google AdMob to serve ads and help fund development. AdMob may process device identifiers such as the Android Advertising ID or Apple's IDFA, IP address, ad interactions, and usage signals. Google's practices are described in Google's Privacy Policy.

Some apps also show ads from Unity Ads (Unity Technologies) through AdMob mediation. Unity receives similar information to serve and measure ads — device identifiers where permitted, IP address and ad interactions — and follows the consent choice you made in the app. See Unity's Privacy Policy.

In the European Economic Area, the United Kingdom and Switzerland, apps with ads first show Google's consent form, and personalized ads are used only if you agree. You can change your choice at any time in the app (Settings → "Ads and privacy" / „Реклами и поверителност“).

On iOS, apps that use tracking request App Tracking Transparency permission before personalized advertising is enabled. If you decline, ads may still appear, but they should be non-personalized where supported.

Some apps (for example Тежестта на думите / Weight of the Words) use Google Firebase Analytics to understand how the app is used: levels played, hints used and screens viewed. It processes an app-instance identifier, these usage events, device model, operating system, app version and approximate region derived from the IP address. It does not collect the advertising identifier, and where consent is required, analytics storage stays off until you agree in the consent form. See Google's Privacy Policy.

We may use analytics, crash reporting, hosting, build, and diagnostic services to understand whether the apps work correctly. These services may process technical logs, device model, operating system version, app version, crash traces, and approximate usage events. We use this data to maintain the products, not to identify you personally.

5. Purchases and Store Platforms

In-app purchases, subscriptions, downloads, refunds, and store accounts are handled by Apple App Store, Google Play or, for our desktop games, Steam (operated by Valve). We do not receive your full payment card details. The relevant platform's own terms and privacy policy apply to store transactions.

6. How We Use Information

7. Sharing

We do not sell personal information. We may share limited data with service providers that help operate our apps, advertising (Google AdMob, Unity Ads), analytics (Google Firebase), hosting (including Supabase for online play), diagnostics, and app-store distribution. We may also disclose information when required by law or to protect our rights, users, or services.

8. Legal Bases for EEA and UK Users

Where GDPR or similar law applies, we process information only when we have a legal basis, including performance of a contract, legitimate interests in operating and improving our products, consent where required for tracking or personalized ads, and compliance with legal obligations.

9. Children

Our apps are intended for a general audience unless a store listing states otherwise. We do not knowingly collect personal information from children under 13. If you believe a child has provided personal information to us, contact us and we will take reasonable steps to delete it.

10. Your Choices and Rights

If consent is the legal basis for a processing activity, you may withdraw that consent at any time through app, device, or platform settings. This does not affect processing that already happened before withdrawal.

11. Data Retention

We keep support emails and operational records only as long as reasonably needed for support, business, security, or legal purposes. Locally stored app data remains on your device until you delete it or uninstall the app. Third-party providers retain data according to their own policies.

Белот Арена account data is kept while your account is active. If you ask us to delete your account, we remove it and its associated gameplay data, except for any minimal records we must keep for security, abuse-prevention, or legal reasons. Chat messages are retained only for a limited period for moderation purposes.

12. International Processing

Dumbakod Ltd is based in Bulgaria. Our service providers may process information in other countries. Where applicable, we rely on legally recognized safeguards for international processing.

13. Security

We use reasonable technical and organizational measures for the size and nature of our products. No online service can be guaranteed perfectly secure, and you use our apps and websites with that understanding.

14. Changes

We may update this Privacy Policy from time to time. The latest version will be posted on this page with a revised "Last updated" date.

15. Contact

Questions or privacy requests can be sent to [email protected].