Privacy Policy

Last updated: September 2025

PE Vadym Dobrohurskyi and its subsidiaries and affiliates (collectively, “Vaymo Games”, “we“, “our” or “us“) develops, publishes and operates social games for web and mobile environments, as well as web and mobile applications (each, an “App“). We also operate the website www.vaymogames.com, including its subdomains and related features (collectively, the “Site”). The App and the Site are referred to together in this Privacy Policy as the “Services”.

Vaymo Games respects your privacy and is committed to making our practices regarding your data more transparent and fair. This Privacy Policy describes how we collect, store, use, share and otherwise process your personal data collected through our digital or online properties or services that link to this Privacy Policy. Please note that this Privacy Policy does not apply to the processing of your personal data by certain service providers and partners of ours (such as some of our advertising partners).

We may provide additional disclosures or information about our collection and processing of your personal data. These notices may supplement this Privacy Policy or clarify our processing practices.

California Notice at Collection/State Law Privacy Rights: see the “California Notice at Collection/ State Law Privacy Rights” section below for important information about your rights under applicable US state consumer privacy laws.

Vaymo Games is a “data controller”. This means that we are responsible for deciding how we hold and use personal data about you.

1. Information We Collect

We collect and process personal data from you when you make use of our Services or otherwise communicate with us. We may combine personal data collected from the below categories for the purposes set forth in this Privacy Policy. Please note that you are not legally required to provide us with any personal data, but without it, we will not be able to provide you with the full range of our Services or with the best user experience when engaging with them.

Data received from you:

You may provide to us personal data through the Services or otherwise, which may include, without limitation:

Categories of personal data provided:	More detailed description of these categories of personal data:
Contact data	Name, email address, phone number.
Profile data	Username, age/ date of birth (where required under applicable law), profile picture, links to your profiles on social networks, and any other information that you add to your account profile.
Communications data	Based on our exchanges with you, including when you contact us through the Services, communicate with us via chat features, social media, or otherwise.
Billing/transaction data	Your credit/debit card information, bank account number or other payment method details are processed and stored on our behalf through our service providers or partners. We may still however receive personal data related to or needed for your purchase, such as your name, billing address, email address, the items purchased, the purchase price and currency, order numbers and transaction history.
Social Network Account contacts	Personal data about others you may provide to us when you choose to connect your Social Network Account to our games.
Feedback about our Services and promotion data	When you reply to surveys or fill forms or participate in our interviews. Please note that if you participate in our advertised events, contests or giveaways through the Services, we may ask you for your contact data to notify you if you win or not, to verify your identity, determine your eligibility, and/or to send you the relevant rewards. In some situations, we may need additional information as a part of the entry process. These contests are voluntary. You must read the rules and other relevant information for each contest that you enter.
User-generated content data	Such as comments, questions, messages, and other content or information that you generate, transmit, or otherwise make available on the Services or otherwise. This may include your progress in games when you post on our public forums or groups (e.g., on social media) or when you interact with other users through the in-game chat or within the games.
Marketing data	Your preferences for receiving our marketing communications and details about your engagement with them.
Other data	Not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Data received from third party sources:

We may combine personal data we receive from you with personal data we obtain from other sources, such as:

Public sources, such as social media platforms, and other publicly available sources.
Private sources, such as data providers and advertising partners. This data may include, without limitation, your location, time zone, age and other demographic or interests-based information received from or about you and shared with us with your consent or based on another legal basis.
Third-party services, such as social media services, that you use to access, or otherwise link to, our Services, such as Facebook, Google, Apple or a similar social network (“Social Network Account“). This data may include, without limitation, your username, profile picture, email address associated with your Social Network Account, location, time zone, a list of your Social Network Account’s friends using our Apps (along with their photos and their other public profile information) and other information associated with your account on that third-party service that is made available to us based on your account settings on that service. You should also read the social media services’ terms and conditions and privacy policies. If you are unclear about what information a third-party application is sharing with us, please visit that third-party application’s website in order to learn more about their privacy practices.

Data automatically collected:

When you visit, interact with or use our Services, including any email sent to you by us or via our Services, we, our service providers, and our partners may automatically collect or log information about you, your computer or mobile device, and your interaction over time with the Services, our communications and other online services. Some of the automatic collection described in this section is facilitated by the use of “cookies” and other tracking technologies.

Such information may include, without limitation, device data and online activity data such as connectivity, technical or aggregated usage data, IP address, in-game identifier, game statistics, game preferences, unique advertising ID (e.g. IDFA), data regarding a device type, operating system, browser or App version, mobile carrier, locale and language settings, your country/state and region, user activity on our Services, in-App activity (such as game play content/product interaction and advertising data) and; diagnostic data (i.e. crash data and game performance data). It may also include communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

Do not give us sensitive information:

We ask that you do not provide us with any sensitive types of personal data (e.g., health-related information, information related to racial or ethnic origin, political opinions, religion or other beliefs, criminal convictions information etc.) – whether through the Services or otherwise. For example, please do not input any of these types of sensitive information in any free-text ‘message’ fields via which you can communicate with us on the Services (e.g., using any ‘Contact Us’ functionality or similar).

2. How We Use Information and Legal Bases

We may use your personal data for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal data:

To facilitate, operate, optimize and provide our Services, including to proceed with your request to set up an account with us;
To authenticate the identity of our users, and allow them access to additional features or functionalities;
To establish and maintain your user profile on the Services;
To provide our users with customer care, assistance and technical support services;
To enable you to interact with other users in the game and create an in-game friends list, as well as sharing your in-game data with other users;
To enable you to identify other users in the game who are listed in your phone “contacts,” provided that you have authorized upload of your contacts for that purpose;
To further develop, customize and improve the Services and your user experience, based on common or personal preferences, experiences and difficulties, including (among others) by personalizing your profile and friends list; and
To communicate with you about the Services, including to contact our users with service-related messages (such as purchase confirmations, support, technical or administrative messages, or system maintenance notices).

Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal data for marketing and advertising purposes:

Game related advertisement. Our games include advertising for third party services and products, and we also use third party services and products to serve ads on our behalf. We and our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the “data automatically collected” section above) with the Services, including in-game progress and activity data, based on your preferences or other data available to us, to our advertising partners or to our service providers. We use your data, for example, to: (i) improve our Services and your user experience; (ii) improve our advertising practices and make the ads we deliver within our games more effective, and, more relevant and less repetitive; (iii) measure and analyze the effectiveness of, and the costs associated with, the ads you see in our Services and those that are placed on our behalf in our advertising partners’ online assets (such as their own websites or mobile applications). We may also share information about our users with advertising partners to facilitate interest-based advertising to those or similar users on other online platforms. Please note that if you reset your advertising ID or otherwise opt-out of interest-based advertising within the Apps, you may still see advertisements in the Apps, or on any other channels, but those ads will not be targeted based on the above-mentioned identifiers. For example, such ads may be instead based on context, such as your progress and actions in the games, or your language preferences.

While Vaymo Games’s data processing is subject to this Privacy Policy, our third-party advertising partners will process your personal data in accordance with their own privacy policies and practices. We encourage you to read such privacy policies at your earliest convenience. Please note that it is the advertising partners’ responsibility to protect any information they collect from you or otherwise hold about you, and we are not liable for the use and protection of such data by these partners.

Direct marketing. We may contact you with promotional and marketing messages and may personalize these messages based on your needs and interests, such messages may relate to new services, events and special opportunities bonuses, incentives, new features, VIP services, or any other information we think you will find valuable; and to facilitate, sponsor and offer certain events and promotions. You can stop receiving such marketing and promotional communications at any time. You can do this by contacting us at [email protected] or by following the “unsubscribe”, “stop” or “change email preferences” instructions in the marketing or promotional communications you receive.

Research and development. We may use your personal data for research and development purposes, including to analyze and improve the Services and our business and to develop new products and services. As part of these activities, we may create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data, which we or our service providers may use for our lawful business purposes, including to analyze to provide and improve our respective services and promote our business.

Compliance and protection. We may use your personal data:

To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
To comply with any applicable laws and regulations, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
To protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
To audit our internal processes for compliance with legal and contractual requirements or our internal policies;
To enforce the terms and conditions that govern the Services; and
To prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

Automated decision-making. We use technologies that may be considered automated decision-making or profiling. We will not make any automated decisions about you that produce legal or “similarly significant effects” (within the meaning of applicable data protection laws), unless such a decision is necessary for entering into, or the performance of, a contract with you, we have obtained your consent, or we are required by applicable law to use such technology. You will find information on your right to object to this processing of your data below under section 7 (“Data Subject Rights”).

Legal bases. Where required by applicable data protection laws, our legal basis for collecting and using your personal data will depend on the particular purpose for which your personal data is being processed, the country in which you reside and the specific context in which such personal data was collected.

However, we generally use the following:

Performance of a contract. We will use this basis for example for service delivery and operations, such as processing your personal data to make the Services available to you.
Consent. In limited cases (e.g., where you choose to sign up to receive direct marketing emails or where you accept certain types of cookies on our Sites), we will process your personal data based on your consent.
Legitimate interests. We will process your personal data based on our legitimate interests, for example, in maintaining and improving our Services and offerings, including improving our customer service and support operations, for research and development, including understanding how our Services are used, matching users to create in-game friends lists, for compliance and protection, including, business risk evaluation, fraud detection and protecting and securing our users, ourselves and our Services.
Compliance with a legal obligation. We may process your personal data where we need to do so to comply with our compliance and protection obligations, including a legal obligation, which is set out in applicable law, or if we receive an order from a court or regulatory body.

3. Data Retention

While data protection laws may vary between jurisdictions, Vaymo Games has taken reasonable steps to ensure that your personal data is treated in a secure manner, and in accordance with common industry practices, regardless of any lesser legal requirements that may apply in their jurisdiction.

We retain your personal data for only as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting purposes (e.g., as required by laws applicable to record and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use, or for fraud prevention purposes). To determine the appropriate retention period for personal data, we may consider factors such as the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Please note that except as required by applicable law, we will not be obligated to retain your personal data for any particular period, and are free to securely delete it for any reason and at any time, with or without notice to you.

In some circumstances, we may anonymize your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you and it is no longer considered personal data.

4. Who We Share Personal Data With

We may disclose your personal data to the following categories of recipients and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection:

to our subsidiaries and affiliated companies (companies owned or operated by us);
to other users of our games. Such users will be able to see your public profile information, user-generated content data (except for any private messages) such as your name and profile picture, certain in-game information, such as your game status, scores and awards, in-game actions and game-play recordings, your general location (at state or country level), and other information, where we have your consent;
to third party service providers who need to have access to information for the purpose of providing services on our behalf, and in accordance with our documented instructions. Such service providers may include, without limitation, providers of services in the following fields of service: data hosting, data analytics, marketing and email distribution, data and cyber security, fraud detection and prevention, payment processing, customer support (e.g. AI agent chat functionality providers), content moderation, testing, user engagement, monitoring, session recording and business, legal and financial compliance (e.g., to our accounting and auditing firms). In certain circumstances, service providers may process some of your personal data for their own purposes, or by determining the means required for the processing. For example, our payment processors process your personal data to provide us payment services, but they may also process such data for fraud detection purposes or for the purpose of carrying out your direct payment instructions. In those circumstances, we make sure that the purposes indicated by those service providers are compatible with our Services. Please note that different privacy policies may apply in such circumstances, and we recommend that you review those upon their provision by the service providers;
to our advertising partners, for the interest-based advertising purposes described above;
to partners, with whom we may sometimes share your personal data or enable partners to collect information directly via our Services. For example, social network platforms with which we integrate;
to any competent law enforcement body, regulatory, government agency, court or another third party that we believe in good faith to be necessary or appropriate if the information is required by law in order to prevent, investigate, or to establish or exercise our legal rights or to defend against legal claims;
to our professional advisors, such as lawyers, accountants, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us;
to an actual or potential buyer (and its agents and advisers) in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our stock and/or assets or other corporate change, including, during the course of any due diligence process, and provided that we inform the buyer it must use personal data only for the purposes disclosed in this Privacy Policy; and
to any third parties designated by you, i.e., we may share your personal data with third parties where you have instructed us or provided your permission to do so.

For the avoidance of doubt, Vaymo Games may share your personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data in our sole discretion and without the need for further approval.

5. Data Security

In order to protect your personal data, we use a number of technical and organizational measures, including encryption where deemed appropriate. However, please be aware that regardless of any technical and organizational measures used, we cannot and do not guarantee the absolute protection and security of any personal data processed by us or by any third parties on our behalf. If you discover any security or vulnerability issues related to the Services – please contact us by email at [email protected].

6. Your Choices

Notwithstanding the data protection laws applicable to your jurisdiction, you may (depending on the Services you use) have the below choices:

Access or update your information. If you have registered for an account with us through the Services, you may review and update certain account information by logging into the account.
Data Deletion and Closure of Accounts. You may at any time direct Vaymo Games to delete your account by contacting us at [email protected] and requesting account deletion. This will result in closure of your account and deletion of all of your playing history, social media log-in (if applicable), and other information associated with you in connection with the game. Deletion is irreversible. If you maintain accounts with multiple games, you should request closure of each. Upon receipt of your request, we will comply promptly, but please allow some time for processing.
Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
Cookies and other tracking technologies. Our Services may use cookies, SDKs, and similar tracking technologies to enhance functionality and analyze usage, including for analytics and performance purposes. You can control or disable cookies through your browser settings. Some SDKs used in our games (such as Unity Analytics and Appsflyer) may collect technical information using such technologies. For details about the data they collect and how to opt out, please refer to their respective privacy policies. Please note that disabling cookies or trackers may affect the performance of certain features of the Services.
Please note:
If you wish to manage the information we receive about you from a third-party application or platform where you use our Apps, such as Facebook, Apple or Google, please follow the third-party application’s instructions for updating your information and changing your privacy settings. If you wish to prevent the use of your personal data device’s advertising ID or other identifiers for interest-based advertising, you may change your device settings in your device operation system to reset such advertising ID or opt-out of such advertising (typically, this is available under the “Privacy” or “Ads” section in your device settings).
Google uses technologies such as cookies in order to track and analyze the use of our Site and/or an SDK to serve ads within our Apps. To learn more about how Google processes data, we recommend you review Google’s policies located at: https://policies.google.com/technologies/partner-sites. For additional information, please see Google Analytics’ opt-out web tool available at: https://tools.google.com/dlpage/gaoptout.

7. Data Subject Rights

Subject to the data protection laws applicable to your jurisdiction and the conditions of such laws, you may ask us to take the following actions in relation to your personal data that we hold:

Request access to your personal data. This enables you to access or receive a copy of the personal data we hold about you and to request information about our processing of your personal data.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal data. This enables you to ask us to delete, or remove personal data where there is no good reason for us continuing to process it.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party). You also have the right to object where we are processing your personal data for direct marketing purposes.
Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal data to another party in a format, which is generally readable or usable by automatic tools or devices and which can be used or disclosed by automatic means.
Right to Withdraw Consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.

If you wish to exercise your rights under applicable law with respect to a specific App, please contact us by emailing [email protected]. If your request is not limited to a specific App, you may still use the same email address to contact us.

EEA & UK Residents – Data Protection Rights
If you are located in the European Economic Area (EEA) or the United Kingdom (UK), you have the right to lodge a complaint with your local data protection authority.

For EEA residents: You can find contact details for your national authority here:
https://edpb.europa.eu/about-edpb/board/members_en
For UK residents:
Information Commissioner’s Office (ICO)
Water Lane, Wycliffe House, Wilmslow, Cheshire SK9 5AF, United Kingdom
Tel: +44 303 123 1113
https://ico.org.uk/make-a-complaint/

You may also contact us at [email protected] if you have any questions or requests regarding your personal data.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. To protect your privacy and security and process your request, we may request specific information and take reasonable steps to verify your identity before processing your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal data). If we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions. Normally, you will not have to pay a fee to exercise any of your applicable data protection rights. However, we may charge a reasonable fee if your request is unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

8. Data Transfers

Your personal data may be maintained, processed, accessed and stored by Vaymo Games and our service providers, advisers, partners (including advertising partners) or other recipients of data in countries other than the country in which you are resident, as necessary for the proper delivery of our Services, or as may be required by law. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

However, we have taken appropriate safeguards to ensure that your personal data will remain protected in accordance with this Privacy Policy.

Where we share your personal data with third parties who are based outside of the EEA/UK, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented:

Transfers to territories with an adequacy decision. We may transfer your personal data to countries or territories whose laws have been deemed to provide an adequate level of protection for personal data by the European Commission or the UK Government (as and where applicable).
Transfers to territories without an adequacy decision. We may transfer your personal data to countries or territories whose laws have not been deemed to provide such an adequate level of protection. However, in these cases:
we may use specific appropriate safeguards, which are designed to give personal data effectively the same protection it has in the EEA/UK – for example, standard contractual clauses approved by relevant authorities for this purpose; or
in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal data to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.

If you require further information about the specific mechanism used by us when transferring your personal data out of the EEA/UK, you may contact us at [email protected]. You may have the right to receive a copy of the appropriate safeguards under which your personal data is transferred by contacting us at [email protected].

9. Minors

The game “Turbo Tiles” is available to individuals who are sixteen (16) years of age and over. We reserve the right to request proof of age or parental consent at any stage. We may block users whom we suspect are under the applicable age. We do not knowingly collect personal data from minors and do not wish to do so. If we learn that a minor is using the Services, we may prohibit and block such use and will make all efforts to promptly delete any personal data stored with us with regard to such minor. If you believe that we might have any such data of a child, please contact us by email at [email protected].

10. Amendments and Controlling Version

This Privacy Policy was last changed on the date set forth at the top of this Privacy Policy. We may amend this Privacy Policy from time to time in response to changing legal, technical or business developments. The amended version of this Privacy Policy, which will be posted on our Services, will be effective as of the published effective date. In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business. The Privacy Policy has been drafted in the English language, which is the original and controlling version of this Privacy Policy. All translations of this Privacy Policy into other languages shall be solely for convenience and shall not control the meaning or application of this Privacy Policy. In the event of any discrepancy between the meanings of any translated versions of the Privacy Policy and the English-language version, the meaning of the English language version shall prevail.

11. Contact Us

For personal data processed under this Privacy Policy, the data controller is PE Vadym Dobrohurskyi. If a subsidiary or affiliate of Vaymo Games acts as the data controller in the future, we will provide a timely notification at the time your personal data is collected. If you have any questions about this Privacy Policy, your personal data, or wish to contact the Vaymo Games Privacy Team, please email us at [email protected].

12. California and U.S. State Privacy Rights

If you are a resident of California or another U.S. state with applicable privacy laws, you may have certain rights regarding your personal data, including the right to request access, correction, or deletion.

We do not sell or share personal data as defined by the California Consumer Privacy Act (CCPA).

To exercise your rights, please contact us at [email protected]. We may need to verify your identity before processing your request. You also have the right to file a complaint with your state’s privacy regulator.