This Privacy Policy explains how Romantic Circle: Spin & Kiss (the “App”), developed and operated by FUNAPP LTD, collects, uses, shares, and protects your information.
By using the App, you agree to the practices described in this Policy.
1. Information We Collect
1.1. Information You Provide
We may collect information that you voluntarily provide when you:
- install and use the App;
- create an account or profile;
- participate in game features (spins, matches, gifts, etc.);
- contact us for support.
This may include:
- Account & profile information: nickname, avatar, age, gender, location (country or region), and any other details you choose to add to your profile.
- User Content: messages, chat, text, emojis, photos or media (if such features exist), virtual gifts you send or receive, and other content you create or share in the App.
- Support data: information and attachments you send when contacting our support team (including email address and description of the issue).
We strongly discourage users from sharing sensitive personal information (such as full name, address, financial data, or ID documents) in their profiles or chats.
1.2. Automatically Collected Information
When you use the App, we may automatically collect:
- Device information: device model, operating system version, language, time zone, device settings.
- Identifiers: app-specific identifiers (for example, IDFV on iOS) and other identifiers provided by the platform. If we use advertising technologies, we may also process the advertising identifier (such as IDFA), in compliance with platform rules and your consent choices.
- Usage data: your interactions with the App, such as screens viewed, buttons clicked, time spent in different sections, features used, and in-app events (for example, spins, matches, gifts sent/received).
- Log and diagnostic data: crash reports, performance logs, and error messages to help us maintain stability and security.
- Purchase and subscription data: information about in-app purchases and subscriptions (type of product, transaction date, subscription status). Payment details (such as card numbers) are processed by Apple or other platform providers and are not stored by us.
1.3. Analytics & Third-Party Services
We may use trusted third-party service providers (for example, analytics, crash reporting, cloud storage, remote configuration, or message delivery) to help us:
- understand how the App is used;
- improve functionality, balance, and performance;
- maintain stability and security;
- manage notifications and feature experiments.
These providers may process anonymized, pseudonymized, or aggregated technical data on our behalf. They are not allowed to use your data for their own independent marketing purposes.
1.4. No Unnecessary Sensitive Data
The App does not require or intentionally collect:
- medical records or health data (in the sense of clinical records);
- biometric identifiers;
- your precise GPS location (beyond coarse info like country/region if you choose to provide it);
- access to your contacts or address book;
- access to your personal photo library outside of what you explicitly choose to upload in the App.
If you choose to share photos or sensitive information in User Content, you do so at your own risk. We may remove such content if it violates our Terms.
2. How We Use Your Information
We use your information to:
- Operate and provide the App and its core functionality (including spins, matches, gifts, virtual currency, and social features).
- Create and manage your account and profile.
- Show your profile and User Content to other users according to the App’s features (for example, when you appear on a board, in a match, or in chat).
- Personalize your experience, for example:
- suggesting relevant matches or boards,
- displaying your progress, statistics, or leaderboards,
- adjusting offers, promotions, or in-app events.
- Process purchases and subscriptions, verify transactions with Apple or other platform providers, and manage access to premium features.
- Provide customer support and respond to your requests.
- Monitor and enforce safety, security, and compliance, including detecting fraud, abuse, or violations of our Terms (such as illegal or harmful content).
- Improve the App, including testing new features, performance optimization, and analytics.
We do not sell your personal data.
3. Legal Bases for Processing (EEA/UK Users)
If you are in the European Economic Area, the United Kingdom, or a similar jurisdiction, we process your personal data on the following legal bases:
- Performance of a contract: to provide the App and fulfill our agreement with you (for example, creating your account, enabling spins, matches, and in-app purchases).
- Legitimate interests: to improve the App, maintain security, prevent fraud, support users, and run analytics, provided that these interests are not overridden by your rights.
- Consent: for certain optional features, such as personalized advertising or marketing communications, when applicable. You can withdraw your consent at any time through your device settings or by contacting us.
- Legal obligations: to comply with applicable laws, regulations, and requests from authorities.
4. How We Share Information
We may share your information only in these limited cases:
4.1. Service Providers
With third-party service providers that help us operate the App, such as:
- cloud hosting and database services;
- analytics and crash reporting;
- customer support tools;
- notification and remote configuration services.
These providers are contractually required to protect your information and use it only according to our instructions.
4.2. Other Users
Certain information (like your nickname, avatar, age, basic profile, and User Content) may be visible to other users as part of the App’s social and gaming features (for example, boards, matches, chat, gifts, leaderboards).
You control what you choose to share in your profile and messages, subject to our Terms.
4.3. Legal Requirements & Protection
We may disclose your information if we believe in good faith that it is reasonably necessary to:
- comply with any applicable law, regulation, legal process, or governmental request;
- enforce our Terms and protect the safety, rights, or property of FUNAPP LTD, our users, or the public;
- detect, prevent, or address fraud, security issues, or technical problems;
- report child sexual abuse material or other serious violations to the appropriate authorities.
4.4. Business Transfers
In connection with a merger, acquisition, restructuring, or sale of all or part of our assets, your information may be transferred to the acquiring entity, subject to the same or equivalent privacy protections.
We do not sell or rent your information to advertisers.
5. Data Storage, Security & Retention
5.1. Storage locations. Data may be stored on secure servers in the European Union or other regions where our service providers operate.
5.2. Security measures. We use reasonable technical and organizational measures to protect your information against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.
5.3. Retention. We retain personal data for as long as necessary to:
- provide the App and its features;
- comply with legal obligations;
- resolve disputes and enforce our agreements.
If you delete your account or request deletion, we will delete or anonymize your personal data, unless we are required or permitted by law to keep certain information (for example, transaction records or security logs).
6. Your Rights & Choices
Depending on your jurisdiction, you may have the right to:
- access the personal data we hold about you;
- request correction of inaccurate or incomplete data;
- request deletion of your data, subject to legal exceptions;
- restrict or object to certain processing, including profiling based on legitimate interests;
- request a copy of your data in a portable format where technically feasible;
- withdraw consent where processing is based on consent (such as some forms of personalized advertising).
To exercise these rights, please contact us at support_kiss@funappgame.com.
We may ask you to verify your identity before responding.
You can also:
- manage notifications and permissions through your device settings;
- manage advertising preferences (including disabling IDFA) via your device’s privacy settings.
7. Children’s Privacy
7.1. The App is not intended for children under 18.
We do not knowingly collect personal information from children under 18.
7.2. If we become aware that a user is under 18, we may:
- delete or restrict their account;
- remove related data as appropriate.
7.3. If you believe that a child has provided us with personal data through the App, please contact us at support_kiss@funappgame.com, and we will take appropriate steps to remove the data.
8. International Data Transfers
8.1. Your information may be processed and stored in countries other than your country of residence, including within the European Union and other regions where our service providers are located.
8.2. Where required by law, we take appropriate measures to ensure that cross-border transfers of personal data provide an adequate level of protection, for example, by using standard contractual clauses or equivalent safeguards.
9. Changes to This Privacy Policy
9.1. We may update this Privacy Policy from time to time. When we do, we will revise the “Last updated” date at the top of this page.
9.2. Substantial changes will be highlighted where possible within the App or on our website.
Continued use of the App after any changes means you accept the updated Policy. If you do not agree, you should stop using the App and uninstall it.
10. Biometric Data or Face Data collection
NO BIOMETRIC / FACE DATA is collected.
The App does not collect or process biometric data or face data of any kind.
Any photos a user uploads or captures are treated as standard user content and are used solely for displaying the user’s profile.
The App does not perform facial recognition, face analysis, or measurement of facial characteristics.
We do not collect, store, analyze, or process any biometric identifiers or face data. User photos are optional and are used only as profile images.
11. Contact Us
If you have any questions or concerns about this Privacy Policy or our data practices, please contact us:
FUNAPP LTD
Building 152, No. 9
Naxxar Road
San Gwann SGN 9030
Malta
Email: support_kiss@funappgame.com