Privacy Policy

DATE: Jan 12, 2026

This Privacy Policy details how Wu Huaan (hereinafter referred to as "we" or "us") gathers and processes your personal data during your use of our mobile application, Twisted Screw Bear, on the iOS platform. Our collection and processing of relevant information are conducted exclusively to deliver high-quality gaming products and to ensure an optimized user experience.

1. How We Collect Your Personal Data

We acquire, employ, and process your personal data through diverse methods, pledging to safeguard the security of your data under all circumstances. Below are the specific categories of data we collect and our processing methods.

1.1 Categories of Personal Data

Upon your access to or use of Twisted Screw Bear, we may gather the following general information pertaining to you:

• Log Data: IP address, timestamps of access, and type of device used.
• Device Details: Manufacturer, model, operating system (iOS version), time zone settings, and language preferences.
• Device Identifiers: Online identification codes associated with the device used to access the game, specifically including IDFA (Advertising Identifier), Google Ads ID, Google Device ID, Game Center ID, and Google Play account ID.
• Usage Metrics: Game progression, scores achieved, achievement data, and logs of interactions with other players.
• Commercial Data: Transaction records, history of usage, personalized settings, and records regarding the acquisition of in-game virtual items.

1.2 Other Data Sources

Should you choose to log in to the game via third-party services, such as Apple Game Center, we will retrieve relevant information about you from said platform (including your display name and profile details). This is done in strict accordance with the platform's authorization procedures, provided you have consented to the necessary permissions.

You may review how these third-party platforms handle your data by consulting their respective privacy policies:

• Apple Game Center: https://www.apple.com/legal/internet-services/itunes/gamecenter/

By logging into the game through a third-party platform, you represent and warrant that:

1. Your access and utilization of game-related features adhere to the current terms and policies of that third-party service.
2. You meet the minimum age requirements mandated by the third-party platform under the laws of the applicable jurisdiction.

2. How We Use the Collected Information

We utilize your information for the objectives listed below. The usage of each data category aligns with a corresponding legal basis:

• Service Provision & Support: To process orders and requests, address inquiries, and maintain communication; to deliver game services, optimize and personalize your experience; and to transmit game-related alerts, technical updates, security notifications, and support messages.
  • Legal Basis: Article 6(1)(b) of the General Data Protection Regulation (GDPR). This processing is essential for the performance of the contract to which you are a party, supporting game operations, and ensuring the maintenance of the game.
• Marketing & Improvement: To send news regarding Wu Huaan or third-party promotions that may interest you based on your preferences; to refine your gaming experience and save settings; and to analyze operational data to develop new products and improve our software, content, and support.
  • Legal Basis: Article 6(1)(f) of the GDPR. We conduct this processing based on our legitimate interest in delivering relevant content and enhancing service quality.
• Personalized Advertising: To serve tailored advertisements and promotional materials to users who have consented to sharing their advertising identifiers with our network partners.
  • Legal Basis: Article 6(1)(f) of the GDPR. This is based on our legitimate interest in providing advertisements that match your interests.

3. Data Retention Period

We retain your information only for the duration required to provide game services, satisfy legal obligations, or to exercise, defend, or establish legal rights. We may keep specific personal information in our archives for a reasonable timeframe to resolve disputes, enforce policies, manage services, or comply with technical and legal mandates regarding security and integrity.

Usage Data is also retained for internal analytical purposes. Typically, this data is kept for a shorter duration, unless it is utilized to strengthen security, improve functionality, or if legal statutes obligate us to extend the retention period.

4. How Information Is Shared

Respecting your legal rights and in compliance with Articles 6(1)(b), 6(1)(c), and 6(1)(f) of the GDPR, we may disclose or facilitate the sharing of your collected information with various third parties as follows:

• Third-Party Partners: For collaborative service delivery, legal/security reasons, or regarding a business transfer/sale, subject to your permission.
• Competent Authorities: If we determine your actions violate our policies, or if disclosure is vital to protect the rights, property, or safety of Wu Huaan or others.
• Other Users: Specifically when you engage in public game communities, events, or appear on leaderboards.

4.1 Sharing with Ad Network Partners

Subject to your consent under Article 6(1) of the GDPR, we share device identifiers with advertising network companies to facilitate personalized ads. The networks we currently engage or may engage include:

• Applovin Corporation: https://www.applovin.com/privacy/
• AdColony: https://yandex.com/legal/international_ads_privacy_policy
• Amazon Publisher Services: https://www.amazon.com/privacyprefs
• Facebook, Inc.: https://www.facebook.com/about/privacy/
• Google LLC: https://policies.google.com/privacy
• Google Admob: https://support.google.com/admob/
• Unity Technologies: https://unity3d.com/legal/privacy-policy
• IronSource: http://www.ironsrc.com/wp-content/uploads/2019/03/ironSource-Privacy-Policy.pdf
• Vungle, Inc.: https://vungle.com/privacy/
• Fyber: https://www.fyber.com/privacy-policy/
• InMobi: https://www.inmobi.com/privacy-policy/

Please note that the use of disclosed information by these recipients is not governed by this Privacy Policy. We encourage you to review their individual privacy policies for questions regarding their data practices.

4.2 Cooperation with Data Processors

We collaborate with the following data processors for operations, including server hosting, technical support, login authentication, and analytics:

• Firebase (Google LLC): https://firebase.google.com/support/privacy
• Adjust: https://www.adjust.com/terms/privacy-policy/

5. Protection of Children's Information

Twisted Screw Bear is not intended for use by individuals under the age of 13. We do not intentionally harvest personally identifiable information from children under 13. Should we become aware that we have collected such data, we will promptly purge it from our servers. If you are a guardian or parent and discover that your child has provided us with personal information, please contact us so we may take appropriate action.

6. Information Security Measures

We value the trust you place in us and employ commercially acceptable standards to safeguard your personal information. However, please acknowledge that no method of internet transmission or electronic storage is entirely secure; thus, we cannot guarantee absolute data security.

7. Push Notification Services

If you have opted in to receive push notifications, we will transmit game updates, promotional content, and service messages to your iOS device. You retain the option to disable these notifications via your device settings.

8. Your Rights

8.1 Rights of Residents in the European Economic Area (EEA)

We are committed to processing and responding to your requests promptly, typically within one month. If a request is complex, we may extend this by up to two additional months (per Article 12 of the GDPR), in which case we will notify you of the delay and the reasons for it.

(1) Right to Request Access

Under Article 15 of the GDPR, you are entitled to access the data we process about you, including:

• The purpose of processing;
• Categories of personal data;
• Recipients (or categories thereof) to whom data is disclosed;
• The anticipated storage period.
  You also have the right to a copy of the data undergoing processing, subject to limitations regarding intellectual property or trade secrets.

(2) Right to Object

Under Article 21 of the GDPR, regarding data processed based on "legitimate interest" (Article 6(1)(f)), you may object based on your specific situation. We will cease processing unless we demonstrate compelling legitimate grounds that override your interests, or if processing is needed for legal claims.

You may object to direct marketing at any time, and we will immediately stop processing your data for that purpose.

(3) Right to Rectification

Under Article 16 of the GDPR, you may request the correction of any inaccurate personal data.

(4) Right to Restrict Processing

Under Article 18 of the GDPR, you may request a restriction on processing in specific scenarios. If granted, we will only process data with your consent, for legal claims, to protect others, or for public interest reasons.

(5) Right to Withdraw Consent

Under Article 7 of the GDPR, you may withdraw consent at any time where processing relies on it.

• Withdrawal stops future processing of the relevant data (unless retention is legally required).
• Withdrawal does not affect the lawfulness of processing that occurred prior to the withdrawal.

(6) Right to Data Portability

Under Article 20 of the GDPR, where processing is based on consent or contract, you may request your data in a structured, machine-readable format and have the right to transmit it to another controller.

8.2 Rights of Residents of California

(1) Request Response Period

We strive to respond to verifiable consumer requests within 45 days. If an extension (up to 90 days total) is required, we will notify you in writing regarding the reason and duration.

(2) Scope of Disclosed Information

Disclosures cover the 12-month period preceding the request receipt. If we cannot fulfill a request, we will explain why. For portability requests, we will provide data in a readily usable format to facilitate transmission.

(3) Right to Opt-Out

Under the CCPA, California residents have the right to direct businesses to stop selling their personal information to third parties.

(4) Right to Know

You are entitled to know the categories of collected data and the purposes for collection, as outlined in this Policy. We update this Policy at least annually.

(5) Right to Request Disclosure

You may request disclosure of personal data collected over the past 12 months.

• This Policy details categories, sources, and usage for data collected in the past 12 months.
• You may request a free copy of your personal information (Right of Access) up to twice per year.
• We will provide: categories of data collected, sources, purposes, third-party recipients, and specific pieces of information.

(6) Right to Request Deletion

You may request the deletion of personal data collected in the past 12 months.

• We honor deletion requests unless legal exceptions apply (e.g., providing services, security detection, legal compliance, public interest research, free speech, or internal operations aligned with expectations). Absent these exceptions, we will delete your information.

9. Data Deletion Request

If retaining your personal data is no longer necessary, you may request its immediate deletion. To initiate this, please send a request to: [email protected].

10. Contact Us

For any inquiries regarding this Privacy Policy, please reach out to us via:

Contact Email: [email protected]