Privacy Policy of Picture Mania: Color Puzzle

(Version dated October 22, 2026)

1. Why do we have this policy?

This Privacy Policy is a set of commitments that FELLAWAY LIMITED promises to follow when collecting, processing, and protecting your personal data. Your privacy is our highest priority, and we are committed to safeguarding your personal information in accordance with applicable laws and security best practices. This Policy explains:

What data we process;
With whom we may share your data;
The purposes of data processing;
How long we retain your data;
How we protect your data; and
How you can control your data.

We strive to comply with international data protection regulations, including the GDPR (European Union), LGPD (Brazil), and PIPA (Korea). Where local laws grant you specific rights, these are outlined in Section 8 (How Can You Control Your Data?) and Section 11 (California Privacy Rights), along with additional regional notices.

2. Who are we?

FELLAWAY LIMITED is a company incorporated in Cyprus and the provider of Picture Mania: Color Puzzle. This Privacy Policy explains how we collect, use, and protect personal data processed when you play the Game, use advertising and purchasing services, or contact support. Game progress is stored locally on your device; the Game does not currently operate its own game accounts or game server.

Picture Mania is intended for players aged 16 and older. If you are under 18, please obtain permission from your parent or legal guardian. For any questions or concerns, contact us at support.web@fellawaygame.com.

If, under applicable law (e.g., GDPR), we are required to appoint a Data Protection Officer (DPO) or a similar representative (e.g., “Encarregado” under LGPD), we will publish the relevant contact information in this Policy.

Data Controller

For the purposes of the GDPR and other applicable data protection laws, the Data Controller is:

FELLAWAY LIMITED
Georgiou Griva Digeni, 113, Astromeritis, 2722, Nicosia, Cyprus
Email: support.web@fellawaygame.com

3. What data do we collect and why?

Personal data includes identifiers and other information that may identify or be linked to you. The Game does not currently require registration and does not collect your name, email address (unless you contact support), telephone number, precise location, contacts, photos, microphone or camera data, or payment card details. Advertising, attribution, analytics and payment providers may collect the limited data described below through their integrations. Progress and non-restorable virtual items are stored on your device.

Data Processing Overview

Data Processing Purpose	Legal Basis	Data Categories	Retention Period	Additional Information
Local Game Progress	Contract	Levels, scores, coins, boosters, rewards and settings stored locally on your device	Until you clear app data or uninstall the Game (subject to any device backup)	The Game has no registration or own gameplay server. Local progress may be lost upon uninstalling or changing devices.
Advertising Delivery & Fraud Prevention	Legitimate Interests / Consent where required	Advertising ID (where available), IP address, device model, Android version, language, approximate country, ad impressions, clicks and diagnostic events	As needed by advertising partners for delivery, measurement, security and compliance, under their own retention policies	AppLovin MAX mediates ads from AppLovin, Unity Ads, Google AdMob and Meta Audience Network. Consent and regional restrictions apply.
In-Game Transactions	Contract / Legal Obligations	Item purchased, purchase/order identifier, amount, currency, purchase status and related transaction records	As necessary for order support, legal claims and statutory financial retention; platform records follow store rules	Google Play Billing handles payment details; FELLAWAY does not receive card numbers. Unity IAP is a local technical integration.
Privacy Choices & Advertising Consent	Consent / Legal Obligations	Your advertising and consent preferences, including consent signals collected by Google UMP	While relevant to the consent choices and applicable recordkeeping obligations	Google UMP presents choices and communicates them to participating advertising vendors. You can revisit privacy choices in Game settings.
Advertising, Attribution & Analytics	Consent / Legitimate Interests as permitted by law	Advertising identifiers, Firebase installation ID, IP address, device attributes, broad country, installation source, gameplay events, sessions, ad revenue, in-app purchase revenue and diagnostics	As necessary for the specified purposes, subject to your consent or objection and vendors’ applicable retention schedules	AppsFlyer tracks acquisition and monetization; Firebase / Google Analytics processes gameplay analytics and remote settings; ad networks measure ads.
Advertising Preferences & Ad Formats	Consent / Legitimate Interests as permitted by law	Advertising identifiers, ad engagement events, coarse location, device details, and relevant consent signals	For purposes described by each advertising provider and applicable consent and retention requirements	The Game may show banners, interstitial ads and optional rewarded videos. Ad personalization is used only where lawful and any required consent has been obtained.
Customer Support	Contract / Legitimate Interests	Email address and information you choose to include in a support request, potentially including screenshots or device details	For the duration of the support case and as needed for legal obligations or disputes	FELLAWAY directly receives personal information only when you email support.
Technical & Diagnostic Data	Legitimate Interests / Consent where required	Crash/error logs, device specifications, Firebase installation ID, gameplay usage statistics and diagnostics	For the periods reasonably necessary to troubleshoot and improve the Game or under vendor policies	Firebase / Google Analytics and applicable SDKs support operation, measurement and troubleshooting.

4. Advertising, analytics and privacy choices

The Game uses third-party advertising, attribution, analytics and consent tools. These are not Facebook account-login or social features. The services active at launch are identified in Annex 1 to this Privacy Policy.

How It Works

Advertising Formats:
The Game displays banner ads and interstitial ads, and may offer optional rewarded videos. Rewarded videos provide a specified in-game benefit after the required complete viewing; availability depends on the advertiser and network.
Ad Mediation and Networks:
AppLovin MAX determines which eligible network serves an ad. Available networks at launch include:
- AppLovin (including AppLovin MAX)
- Unity Ads and Google AdMob
- Meta Audience Network
Consent and Controls:
Where required by law, we ask for your consent before processing data for personalized advertising. Google User Messaging Platform (UMP) records and communicates your choices. You can modify available privacy settings in the Game.
- Your region and privacy choices determine applicable advertising processing.
- You may decline or withdraw optional personalized-advertising consent.
- Where available and lawful, contextual or non-personalized ads may still be shown.
Attribution and Analytics:
AppsFlyer processes installation attribution, in-game events, and monetization measurements. Firebase / Google Analytics processes installation IDs, game sessions, events and diagnostic information. We use available consent controls and respect applicable regional laws.
Future Integrations:
The partners listed as planned in Annex 1 are not active integrations and will be added only after the relevant deployment and required privacy disclosures or consents.

5. Legal bases for data processing

We process your personal data only when necessary for providing access to and improving the Game. Our legal bases for processing include:

Contract: For delivering local game functionality, virtual items and in-game transactions.
Legitimate Interests: For necessary fraud prevention, technical maintenance, diagnostics and service measurement, where permitted and not overridden by your rights.
Consent: For personalized advertising and other optional processing to the extent required by applicable law; consent is managed through Google UMP where supported.
Legal Obligations: To comply with applicable laws such as tax reporting and consumer protection regulations.

6. How do we share your data?

We do not sell your personal data for money. Certain advertising disclosures may constitute “sharing” or a “sale” under applicable privacy laws; the relevant opt-out rights are described in Section 11. However, to provide you with our services, we may share your data under the following circumstances:

Service Providers & Partners:
- Technical/Customer Support Providers: Companies that help us operate and maintain the Game.
- Cloud/Hosting Services: The Game does not currently operate its own game server. Third-party SDK providers process relevant data using their own infrastructure.
- Analytics & Advertising Partners: Ad mediation and networks, attribution providers and analytics providers identified in Annex 1, subject to applicable legal bases and privacy choices.
- Software Providers: Google Play services and technical integrations required for in-app purchases, app installation attribution and consent management.
See Annex 1 (Third-Party Partners) for a list of integrations active at launch and a separate list of planned integrations. Partners may act as independent controllers or processors depending on the processing activity. We update the Annex when deployed vendors change.
Affiliates & Business Transfers:
- Data may be accessed or processed by authorized persons and service providers supporting the Game, including shared advertising and analytics arrangements within Cubic Games Studio. FELLAWAY remains the named provider and controller for processing purposes under its responsibility. Transfers of business operations may involve disclosures permitted by applicable law.
Legal & Regulatory Requirements:
- We may disclose data to comply with legal obligations, respond to lawful requests, or protect the rights, property, or safety of our users or the public.
International Transfers:
- Personal data may be processed outside the EEA, UK or Switzerland, including in the United States and Israel. Where required, we rely on appropriate transfer arrangements, such as applicable adequacy decisions, Standard Contractual Clauses or other valid safeguards, according to the recipient and transfer.
For users in other regions, including Brazil and South Korea, we apply additional safeguards and notices to the extent required by local law. Certain planned advertising integrations may involve processing in Asia, but are not part of the launch configuration.

7. Data retention

We retain your personal data only as long as necessary to fulfill the purposes outlined in this Policy or as required by law. For example:

Local Game Data: Levels, scores, coins and most items are stored on the device, not in an account held by FELLAWAY. Clearing app data or uninstalling may permanently remove them. Google Play may retain information about a restorable No Ads purchase independently.
Usage & Analytics Data: Personal or pseudonymous data collected by SDK partners is held for the periods required for the purposes described and under their applicable retention schedules, subject to legal rights and restrictions. Fully anonymized data may be retained longer.
Support Data: Retained for the duration of the support case or as required by law.

Once the purpose for which data is processed has been fulfilled, personal data is securely deleted.

8. How can you control your data?

You have the following rights regarding your personal data:

Access: Request a copy of the data we hold about you.
Correction: Request correction of inaccurate or incomplete data.
Deletion (“Right to be Forgotten”): Request deletion of personal data processed by us or our partners where applicable; clearing device-stored game progress requires action on your own device.
Restriction & Objection: Request that we limit or cease processing your data.
Withdraw Consent: Revoke optional advertising consents through the Game privacy settings or contact us. Withdrawing consent does not affect previous lawful processing.

Additional rights for specific regions:

Data Portability (GDPR, some other jurisdictions): Receive your data in a structured, commonly used, and machine-readable format.
Right to Lodge a Complaint: You may file a complaint with a supervisory authority (for example, in the EU or Brazil) if you believe we have processed your data unlawfully.
Request for Suspension of Processing (Korea): Under PIPA, users may request temporary suspension of processing under certain conditions.

To exercise these rights, contact us by email at: support.web@fellawaygame.com. We may need sufficient information to identify the relevant device or SDK data, such as an advertising or installation identifier, without requesting unnecessary personal details.

We may request proportionate information to verify your identity. For GDPR requests, we respond without undue delay and within one month of receipt; a permitted extension of up to two further months will be explained within the first month. Other applicable statutory deadlines may differ.

You can update advertising privacy choices via the Game settings, where supported. To request access to, restriction of, or deletion of personal data handled by FELLAWAY or its partners, contact support.

Picture Mania currently does not have a user account or in-game Help account portal. You can request information, correction or deletion by writing to support.web@fellawaygame.com. For data collected by advertising and analytics vendors, we may need to coordinate with the relevant provider and verify the device identifier.

For exercising your rights, you can:

at any time withdraw your consent where processing is based on consent, without affecting the lawfulness of earlier processing;
access to your Data received by us. You are entitled to access the Data about you received by us which means you have the right to request the provision of information about Data storage, access to Data, as well as copies of the stored Data;
require limitation of Data processing for the time required to verify the reliability of the information provided;
update privacy settings and advertising choices in the Game, where offered;
object to relevant processing of your data, by contacting support.web@fellawaygame.com;
request deletion of personal information we or our partners process; local progress is removed from the device by clearing app data or uninstalling.

Withdrawal of consent and deletion of data:

PLEASE NOTE that the Game has no central player account. Uninstalling the Game or clearing local app storage can delete local progress, coins and consumables, which generally cannot be restored. The No Ads purchase may be restored through Google Play. Uninstalling does not automatically delete SDK-held personal data; for partner-data deletion requests, contact us as described above.

9. How do we protect your data?

We and our service providers take reasonable technical and organizational measures to protect personal data against unauthorized access, alteration and loss. The safeguards used depend on the nature of the data and the service provider, and include:

Data Security Measures: Appropriate security for data transmitted to and stored by integrated providers.
Access Controls: Access to personal data is limited to persons and providers who need it for relevant purposes.
No Game Account Passwords: The Game does not currently provide a player account system or associated password-based login.
Review and Maintenance: We review integrations and seek appropriate safeguards from service providers.

We provide access to the Game internationally and seek to comply with applicable local laws. The Game is provided under its Terms of Service, subject to mandatory consumer rights.

FELLAWAY LIMITED respects the confidentiality of your data and strives to ensure the highest level of protection. Despite the measures we are taking to protect your information, any measures that we apply will not have any effect if you neglect the data security.

The Game stores gameplay progress locally, while integrated vendors process limited data for ads, attribution, diagnostics and purchases. We employ proportionate protections and work with service providers on their safeguards. We cannot guarantee that electronic storage or transmission is free of all security risks.

we use reasonable technical and organizational measures, including safeguards provided by integrated SDK vendors;
we do not operate an account login or two-factor authentication system for the Game;
we improve the techniques and methods of collecting, storing and processing the Data;
access to data available to FELLAWAY is limited to personnel and providers with an appropriate business need;
all persons having access to the Data are briefed on working with data, their knowledge and skills are systematically being checked.

Protecting your device and controlling access to it are important to the security of locally stored gameplay progress. Please do not install unauthorized versions of the Game or grant third-party apps unnecessary access to your device.

WARNING! The following actions are prohibited by this Policy and the Terms of Service, and may also violate the confidentiality of your data:

sharing private payment information or device access with untrusted third parties;
the use of unauthorized third-party programs, the use of robot programs and (or) programs that change the game process, including assistance in the game process. In addition to the fact that the use of such programs is expressly prohibited by the Terms of Service, they may contain malicious software that could harm the security of your data;
the acquisition of in-game values from third parties. By acquiring in-game values bypassing the Terms of Service, you can become a victim of fraudsters.

FELLAWAY LIMITED appreciate the help of our users in identifying and addressing potential vulnerabilities, as we take the security of our systems and data extremely seriously. Please report any security vulnerabilities found in our systems or applications to us as soon as possible.

In your email, please include a detailed description of the vulnerability, including any relevant technical details that may help us understand the nature and severity of the issue. If possible, please also include steps to reproduce the vulnerability, so that we can more easily investigate and remediate the issue. We take all reports of security vulnerabilities seriously, and we will investigate each report promptly and thoroughly.

We may also contact you for additional information or clarification, so please be sure to include your contact information in your email. Thank you for helping us maintain the security of our systems and data. We greatly appreciate your contribution to our security efforts.

Keep your device and Google Play account secure. If you suspect a security issue relating to the Game, contact us at support.web@fellawaygame.com.

10. Children’s privacy

Picture Mania: Color Puzzle is intended for people aged 16 or older and is not designed for children under 16. Its bright visual style may nonetheless appeal to younger users. We do not intend to target children with advertising or knowingly process their data for behavioral advertising.

No Knowing Collection of Children’s Data

We do not knowingly collect personal data from children under 16 (or a higher minimum age where relevant) for the Game. Advertising and analytics SDKs may receive technical data when the Game is opened; our current launch build does not include an in-game age gate.

If we discover that we have inadvertently collected personal data from a child without proper consent, we will promptly delete or anonymize that data.

Age Restriction & Verification

Age Restriction & Verification: The Game is designated for users aged 16 and older, but it does not currently ask users to confirm their age inside the Game. Store content ratings do not independently verify a user’s age.

Parental/Guardian Consent: Players aged 16 or 17 should obtain any consent required to enter these Terms or use the Game under applicable law. The Game is not offered to children under 16 merely on the basis of parental permission. Consent to personal-data processing is separate.

Limited Data Collection

We do not request names, contact details, photos or precise location during gameplay. SDKs may still process advertising identifiers and other technical data; data handling for younger users requires appropriate safeguards under applicable laws and platform policies.

Parental Controls & Guidance

We encourage parents and guardians to review their children’s app use, purchase permissions and advertising choices. See our Parent’s Guide for details on the Game’s local progress, advertising and in-app purchases.

Parental Rights

Parents or legal guardians may request to review, delete, or prevent further collection of their child’s personal data. If you believe we have collected information from a child contrary to applicable law, contact us immediately, and we will take appropriate measures.

Contact for Children’s Data Concerns

If you suspect a child under 16 is using the Game or wish to make a privacy request on a child’s behalf, contact support.web@fellawaygame.com.

Email: support.web@fellawaygame.com

11. California privacy rights

Where applicable to our processing, California residents have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), including:

Right to Know: Request details about the personal data we have collected about you during the period covered by applicable law.
Right to Delete: Request deletion of your personal data (subject to legal exceptions).
Right to Opt-Out: You may opt out of disclosures that constitute a sale or sharing of personal information under applicable law, including cross-context behavioral advertising.
Right to Correct: Request corrections to any inaccurate information.
Right to Non-Discrimination: You will not be treated differently for exercising your privacy rights.

To exercise these rights, please contact: support.web@fellawaygame.com. You may also use the Game’s privacy controls for applicable advertising opt-outs.

12. Changes to this policy

We reserve the right to modify or update this Privacy Policy at any time. Should significant changes be made, we will notify you via the Game or other appropriate channels. Where a change requires new consent, we will obtain it before the relevant processing begins. Continued use of the Game is not, by itself, consent to such processing.

13. Contact us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, or if you wish to request previous versions of this Policy, please contact us at:

FELLAWAY LIMITED
Address: Georgiou Griva Digeni, 113, Astromeritis, 2722, Nicosia, Cyprus
Email: support.web@fellawaygame.com

FAITHFULLY YOURS,
FELLAWAY LIMITED

This Policy is written in English. In the event of any discrepancies between translations, the English version shall prevail.