Privacy Policy

# Privacy Policy

We want it to be simple for you to protect your privacy. Here is a summary of how we process your information across our games.

What we collect depends on which game you are playing and the platform you are playing it on. Some of our games are online, account-based experiences that collect gameplay data; others — including several of our mobile titles, such as When Ski Lifts Go Wrong on iOS — collect little or no personal data at all.

For our online, account-based games (for example, Turbo Golf Racing):

- Some games cannot be played without an account. Where this is the case, the account you use will have been created using a third party such as Steam, Xbox, PlayStation, or Apple.

- Any account used to access these games creates and stores an account ID. This is used to find and join online games and to manage items you have unlocked or purchased.

- We track gameplay information to improve the stability and gameplay of the game.

- If you contact us, we may use that information to help fix any issues you have.

For our mobile and offline games (for example, When Ski Lifts Go Wrong on iOS):

- Many of these games can be played without an account and collect little or no personal data.

- Where a game is distributed through an app store (such as the Apple App Store), any account, purchase, or device information is handled by that platform under its own privacy policy, not by us.

Website:

- If you sign up to our newsletter, we will use the email address provided.

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## Privacy Policy

Effective date: 8th day of July, 2026

[www.hugecalf.com](https://www.hugecalf.com) (the "Site") and our games (each a "Game" and together the "Games") are owned and operated by Hugecalf Studios Limited, registered in England and Wales under company number 10475435. Hugecalf Studios Limited is the data controller and can be contacted at:

info@hugecalf.com

12 Nell Lane, Chorlton, Manchester

### Purpose

The purpose of this privacy policy (this "Privacy Policy") is to inform users of our Games and Site of the following:

1. The personal data we will collect;

2. Use of collected data;

3. Who has access to the data collected; and

4. The rights of Game and Site users.

This Privacy Policy applies in addition to the terms and conditions of our Games and Site. It applies to all of our Games across all platforms on which they are made available, including PC, console, and mobile. Because our Games differ, not every section of this Privacy Policy will apply to every Game — for example, some Games do not require an account and collect little or no personal data.

### GDPR

For users in the European Union, we adhere to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (the "GDPR"). For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection Act 2018.

### Consent

By using our Games and Site users agree that they consent to:

1. The conditions set out in this Privacy Policy.

When the legal basis for us processing your personal data is that you have provided your consent to that processing, you may withdraw your consent at any time. If you withdraw your consent, it will not make processing which we completed before you withdrew your consent unlawful.

You can withdraw your consent by emailing us on info@hugecalf.com

### Legal Basis for Processing

We collect and process personal data about users in the EU only when we have a legal basis for doing so under Article 6 of the GDPR.

We rely on the following legal bases to collect and process the personal data of users in the EU:

1. Users have provided their consent to the processing of their data for one or more specific purposes; and

2. Processing of user personal data is necessary for us or a third party to pursue a legitimate interest. Our legitimate interest is not overridden by the interests or fundamental rights and freedoms of users. Our legitimate interest(s) are: Improving the experience of the Game.

### Personal Data We Collect

We only collect data that helps us achieve the purpose set out in this Privacy Policy. We will not collect any additional data beyond the data listed below without notifying you first. The specific data collected varies by Game and platform, and some Games collect none of the data listed below.

Data Collected Automatically

When you play our Games or use our Site, we may automatically collect and store the following information (to the extent it applies to the Game you are using):

- Username

- Unique or online ID, including third party ID

- Gameplay information

- IP Address

For Games that do not require an account — including several of our mobile titles, such as When Ski Lifts Go Wrong on iOS — we may collect little or no personal data. Where such a Game is distributed through an app store, any account, device, or purchase information is collected and processed by the relevant app store provider under its own privacy policy.

### How We Use Personal Data

Data collected on our Games or Site will only be used for the purposes specified in this Privacy Policy. We will not use your data beyond what we disclose in this Privacy Policy.

The data we collect automatically is used for the following purposes:

1. To enable the user to play the Game;

2. To improve the Game;

3. To monitor appropriate behavior within the Game; and

4. To fulfil in-game purchases.

### Who We Share Personal Data With

Employees

We may disclose user data to any member of our organisation who reasonably needs access to user data to achieve the purposes set out in this Privacy Policy.

Third Parties

We may share user data with the following categories of third parties:

1. Third-party data analytics providers, who help us understand and improve the stability and gameplay of our Games; and

2. Our publishing partners, who help us distribute, operate, and support our Games.

The specific third parties involved depend on the Game you are using. Third parties will not be able to access user data beyond what is reasonably necessary to achieve the given purpose.

Other Disclosures

We will not sell or share your data with other third parties, except in the following cases:

1. If the law requires it;

2. If it is required for any legal proceeding;

3. To prove or protect our legal rights; and

4. To buyers or potential buyers of this company in the event that we seek to sell the company.

If you follow hyperlinks from our Games or Site to another site, please note that we are not responsible for and have no control over their privacy policies and practices.

### How Long We Store Personal Data

User data will be stored until the purpose the data was collected for has been achieved.

You will be notified if your data is kept for longer than this period.

### How We Protect And Store Your Personal Data

In order to protect your security, we use the strongest available encryption and store all of our data on servers in secure facilities. All data is only accessible to our employees. Our employees are bound by strict confidentiality agreements and a breach of this agreement would result in the employee's termination.

While we take all reasonable precautions to ensure that user data is secure and that users are protected, there always remains the risk of harm. The Internet as a whole can be insecure at times and therefore we are unable to guarantee the security of user data beyond what is reasonably practical.

### Your Rights as a User

Under the GDPR, you have the following rights:

1. Right to be informed;

2. Right of access;

3. Right to rectification;

4. Right to erasure;

5. Right to restrict processing;

6. Right to data portability; and

7. Right to object.

### Children

We do not knowingly collect or use personal data from children under 16 years of age. If we learn that we have collected personal data from a child under 16 years of age, the personal data will be deleted as soon as possible. If a child under 16 years of age has provided us with personal data their parent or guardian may contact our data protection officer.

### How to Access, Modify, Delete, or Challenge the Data Collected

If you would like to know if we have collected your personal data, how we have used your personal data, if we have disclosed your personal data and to whom we disclosed your personal data, if you would like your data to be deleted or modified in any way, or if you would like to exercise any of your other rights under the GDPR, please contact our data protection officer here:

Jonathan Hughes

info@hugecalf.com

### Do Not Track Notice

Do Not Track ("DNT") is a privacy preference that you can set in certain web browsers. We do not track the users of our Games or Site over time and across third party websites and therefore do not respond to browser-initiated DNT signals. We are not responsible for and cannot guarantee how any third parties who interact with our Games or Site and your data will respond to DNT signals.

### How to Opt-Out of Data Collection, Use or Disclosure

In addition to the method(s) described in the How to Access, Modify, Delete, or Challenge the Data Collected section, we provide the following specific opt-out methods for the forms of collection, use, or disclosure of your personal data specified below:

1. You can opt out of the use of personal data collection. You can opt-out by emailing us on info@hugecalf.com.

### Modifications

This Privacy Policy may be amended from time to time in order to maintain compliance with the law and to reflect any changes to our data collection process. When we amend this Privacy Policy we will update the "Effective Date" at the top of this Privacy Policy. We recommend that our users periodically review our Privacy Policy to ensure that they are notified of any updates. If necessary, we may notify users by email of changes to this Privacy Policy.

### Complaints

If you have any complaints about how we process your personal data, please contact us through the contact methods listed in the Contact Information section so that we can, where possible, resolve the issue. If you feel we have not addressed your concern in a satisfactory manner you may contact a supervisory authority. You also have the right to directly make a complaint to a supervisory authority. You can lodge a complaint with a supervisory authority by contacting the Information Commissioner's Office in the UK, or the Data Protection Commission in Ireland.

### Contact Information

If you have any questions, concerns or complaints, you can contact our data protection officer, Jonathan Hughes, at:

info@hugecalf.com