This policy is a professional operating draft for a publisher of games and utility applications. It should be reviewed against each live product, SDK, ad network, payment provider, country launch plan, and age rating before publication.
1. Who we are
FLY FLY MU TECHNOLOGY LIMITED ("FLY FLY MU", "we", "us", or "our") publishes and operates digital products, including games, utility applications, websites, advertising campaigns, paid features, subscriptions, and related support services.
Controller contact: [email protected]. Business address: No. 2-309, 2/F Chungking Express, Nos. 36 Nathan Road, KL.
2. Scope
This Privacy Policy applies to our website, games, utility applications, advertising and user acquisition activities, ad monetization features, payment-related entitlement records, support communications, and other services that link to this policy.
Some products may include additional notices, consent screens, app store disclosures, or region-specific terms. If a product-specific notice conflicts with this policy, the product-specific notice controls for that product.
3. Personal data we may collect
| Category | Examples |
|---|---|
| Contact and business data | Name, company, job title, email address, support messages, partnership inquiries, and information you choose to provide. |
| Account and profile data | User ID, nickname, avatar, language, region, login method, app preferences, and support identifiers where an account feature is offered. |
| Device and technical data | IP address, device model, operating system, browser type, app version, device language, approximate location derived from IP, crash logs, diagnostics, and security logs. |
| Game and app usage data | Gameplay progress, levels, scores, virtual items, feature usage, session duration, events, settings, and interaction data. |
| Advertising and attribution data | Advertising identifiers such as IDFA or Android Advertising ID where available, campaign source, ad impressions, clicks, installs, conversions, ad placement, frequency, and monetization events. |
| Payment and entitlement data | Purchase status, subscription status, store receipt, transaction ID, product SKU, refund status, virtual currency balance, and premium feature entitlement. We do not collect full payment card numbers through our products. |
| Cookies and similar technologies | Cookie IDs, SDK identifiers, pixels, local storage, analytics tags, and consent preferences where used by our website or products. |
4. How we use personal data and GDPR lawful bases
| Purpose | Typical lawful basis under GDPR |
|---|---|
| Provide, maintain, localize, and improve games, utility apps, accounts, features, and customer support. | Performance of a contract; legitimate interests; consent where required. |
| Operate paid features, subscriptions, virtual items, purchase validation, refunds, fraud prevention, and entitlement management. | Performance of a contract; legal obligation; legitimate interests. |
| Measure product performance, fix bugs, understand usage, perform analytics, and improve user experience. | Legitimate interests; consent where required by law or platform policy. |
| Run user acquisition, attribution, campaign measurement, ad creative testing, and marketing performance analysis. | Consent where required; legitimate interests for limited non-intrusive measurement where permitted. |
| Show contextual ads, personalized ads, rewarded ads, interstitials, banners, and measure ad revenue. | Consent where required for personalized advertising, tracking, cookies, or device identifiers; legitimate interests for contextual ads and security where permitted. |
| Protect users, prevent cheating, detect fraud, enforce terms, maintain security, and comply with legal requests. | Legitimate interests; legal obligation; vital interests in exceptional safety situations. |
| Send service notices, respond to inquiries, and communicate about product or policy changes. | Performance of a contract; legitimate interests; legal obligation. |
5. Advertising, user acquisition, and ad monetization
Our games and apps may use advertising networks, mediation partners, attribution providers, analytics providers, and app stores to acquire users, measure campaign performance, show ads, prevent ad fraud, and calculate ad revenue.
Depending on your region, device settings, consent choices, and product configuration, ads may be contextual or personalized. Personalized advertising may involve advertising identifiers, app events, approximate location, device information, and inferred interests. Where required, we request consent before using cookies, SDKs, device identifiers, or similar technologies for personalized advertising or cross-app tracking.
You can usually limit ad tracking through your device settings, app consent choices, or platform privacy controls. If a product includes a consent management tool, you may use it to change your advertising and analytics choices.
6. Paid features, in-app purchases, and subscriptions
Paid features may include premium tools, subscriptions, virtual items, virtual currency, ad-free access, additional content, or other in-app purchases. Payments are generally processed by the relevant app store or payment provider. We may receive purchase confirmations, receipts, transaction IDs, subscription status, refund status, and entitlement information so that we can provide purchased content and customer support.
7. Cookies, SDKs, and similar technologies
We and our partners may use cookies, pixels, local storage, mobile SDKs, and similar technologies for essential operations, security, analytics, attribution, advertising, fraud prevention, and remembering privacy choices. In regions where consent is required, non-essential cookies or SDK-based tracking should be activated only after consent.
8. How we share data
We may share personal data with service providers and partners that help us operate our products, including hosting providers, customer support tools, analytics providers, crash reporting providers, app stores, payment processors, advertising networks, mediation partners, attribution providers, fraud prevention vendors, localization providers, professional advisers, and legal authorities where required.
We may also disclose data in connection with a merger, acquisition, financing, restructuring, or sale of business assets, subject to appropriate confidentiality and data protection safeguards.
9. International transfers
We may process and store data in countries or regions outside your place of residence. Where GDPR or similar laws apply, we rely on appropriate transfer mechanisms such as adequacy decisions, standard contractual clauses, transfer risk assessments, and contractual, technical, and organizational safeguards.
10. Retention
We keep personal data only for as long as reasonably necessary for the purposes described in this policy, including providing services, maintaining purchase records, resolving disputes, enforcing terms, preventing fraud, meeting tax and accounting obligations, and complying with law. Retention periods may vary by product, data category, legal requirement, and user request.
11. Your privacy rights
Depending on your location, you may have rights to access, correct, delete, restrict, object to processing, withdraw consent, receive a portable copy of your data, appeal certain decisions, or lodge a complaint with a supervisory authority.
For GDPR-covered users, you may object to processing based on legitimate interests and you have an absolute right to object to direct marketing. Where processing is based on consent, you may withdraw consent at any time without affecting processing that occurred before withdrawal.
To exercise rights, contact [email protected]. We may need to verify your identity and the product, account, device, or transaction involved before fulfilling a request.
12. Children and age-appropriate use
Our products are not intended for children under the minimum age required by applicable law unless a product is specifically designed and disclosed for that audience. We do not knowingly collect personal data from children without appropriate consent or other lawful authorization. If you believe a child has provided personal data to us, contact us so that we can review and take appropriate action.
13. Security
We use reasonable technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, alteration, and disclosure. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.
14. Changes to this policy
We may update this Privacy Policy from time to time. The updated version will be posted on this page with a new effective date. If changes are material, we may provide additional notice through our website, products, or other appropriate channels.
15. Contact us
For privacy questions, user rights requests, advertising choices, or product support, contact us at [email protected].