Privacy Policy

Last updated: 1 January 2025

This Privacy Policy explains how Opion Games LTD ("we", "us", or "our") collects, uses, and protects your personal information when you use our website at opiongames.com and our mobile games, including Word Lock ("the Games"). Please read it carefully.

We are committed to protecting your privacy and complying with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. Who we are

Opion Games LTD is a company registered in England and Wales. Our registered address is 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom.

For privacy enquiries, contact us at: contact@opiongames.com

2. Information we collect through our Games

When you play our games on iOS or Android, the following categories of data may be collected:

• Device identifiers — including the Advertising ID (Google Advertising ID on Android, IDFA on iOS, where you have granted permission), device model, operating system version, and language settings.
• Approximate location — derived from your IP address at a country or region level only. We do not collect precise GPS location.
• Gameplay data — including levels played, scores, session length, and in-game actions, used to improve game balance and player experience.
• Purchase history — if you make in-app purchases, transaction records are processed by Apple App Store or Google Play. We receive confirmation of purchases but do not process payment card details directly.
• Ad interaction data — if you interact with advertisements shown in our games, data relating to those interactions may be collected by our advertising partners (see section 4).

3. Information we collect through our website

Our website (opiongames.com) is a static site and does not use cookies, analytics scripts, or tracking pixels. We do not build profiles of website visitors.

If you submit a consulting enquiry through our contact form, we collect your name, email address, and the message you provide. This data is processed by Formspree (see section 4) and delivered to us by email. We retain this information only for as long as needed to respond to your enquiry.

4. Third-party services and data sharing

We use the following third-party services, each with their own privacy practices:

• Unity Technologies (Unity Ads) — provides advertising in our games. Unity may collect advertising identifiers and device information to serve and measure ads. For personalized advertising, this requires your consent where applicable. See Unity's privacy policy at unity.com/legal/privacy-policy.
• Unity Technologies (Unity IAP) — facilitates in-app purchases. Purchases are processed by Apple or Google depending on your device; Unity IAP is the technical intermediary. See Unity's privacy policy linked above.
• Apple App Store / Google Play — process payments for in-app purchases under their own terms and privacy policies.
• Formspree — processes contact form submissions on our website. See formspree.io/legal/privacy-policy.

We do not sell your personal data to any third party.

5. Legal basis for processing (UK GDPR)

We rely on the following legal bases for processing your personal data:

• Consent — for personalized advertising via Unity Ads, where we present a consent prompt before enabling ad personalization.
• Legitimate interests — for contextual advertising, gameplay analytics, and fraud prevention, where our legitimate business interests do not override your rights.
• Contract performance — for processing in-app purchases and providing the functionality you have paid for.
• Legitimate interests — for responding to consulting enquiries submitted through our contact form.

6. Children's privacy

Our games are rated for general audiences. We do not knowingly collect personal information from children under 13 (or under 16 in jurisdictions where that threshold applies). If you believe a child has provided us with personal data, please contact us at contact@opiongames.com and we will delete it promptly.

7. Data retention

We retain personal data only for as long as necessary for the purposes described in this policy:

• Gameplay and advertising data is retained in accordance with Unity's data retention policies.
• Contact form enquiries are retained until the enquiry is resolved and no longer needed for that purpose, and in any event no longer than 2 years.
• Purchase records may be retained as required to comply with accounting and tax obligations under UK law.

8. Your rights under UK GDPR

If you are in the United Kingdom or European Economic Area, you have the following rights regarding your personal data:

• Right of access — request a copy of the personal data we hold about you.
• Right to rectification — ask us to correct inaccurate or incomplete data.
• Right to erasure — request deletion of your personal data in certain circumstances.
• Right to restrict processing — ask us to pause processing of your data in certain circumstances.
• Right to data portability — receive your personal data in a commonly used, machine-readable format.
• Right to object — object to processing based on legitimate interests.
• Right to withdraw consent — where processing is based on consent, withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at contact@opiongames.com. We will respond within 30 days.

You also have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk.

9. Security

We take reasonable technical and organisational steps to protect your personal data against unauthorised access, loss, or disclosure. However, no method of transmission over the internet is completely secure, and we cannot guarantee absolute security.

10. International transfers

Some of our third-party service providers (including Unity Technologies and Formspree) may process data outside the United Kingdom or European Economic Area. Where this occurs, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses, in accordance with applicable data protection law.

11. Advertising and consent (iOS and Android)

On iOS, we present Apple's App Tracking Transparency (ATT) prompt before accessing your device's advertising identifier. If you decline, only contextual (non-personalised) ads will be shown.

On Android, we present a consent request under the Google Consent SDK framework before serving personalised ads to users in applicable regions. You can change your preferences at any time within the game settings.

12. Changes to this policy

We may update this Privacy Policy from time to time. The updated version will be posted at this URL with a revised "Last updated" date. For significant changes, we will notify users through an in-game notice where reasonably practicable.

13. Contact us

For any privacy-related questions or to exercise your rights, please contact:

Opion Games LTD
71–75 Shelton Street, Covent Garden, London, WC2H 9JQ
contact@opiongames.com