Effective Date: [July 06, 2026]
Tunergy Studio (referred to as "we," "us," or "our") operates the website at https://www.tunergystudio.com and publishes mobile applications under the Tunergy brand (collectively, the "Services"). This document explains our practices regarding the collection, use, and disclosure of personal information when you interact with our Services.
If you have any questions after reading this policy, you can reach us at <support@tunergystudio.com> or by mail at 63 MODY ROAD, TSIM SHA TSUI, HONG KONG.
YOUR RIGHTS AND CHOICES — AT A GLANCE
Depending on where you live, you may have certain rights regarding your personal information. This section gives you a quick overview; full details are provided in the sections that follow.
| Right | What it means | How to exercise it |
| Access | Request a copy of the personal information we hold about you. | Email us at <support@tunergystudio.com> |
| Correction | Ask us to fix inaccurate or incomplete information. | Email us at <support@tunergystudio.com> |
| Deletion | Request that we delete your personal information, subject to certain legal exceptions. | Email us at <support@tunergystudio.com> |
| Opt-out (California) | Opt out of the "sharing" of your personal information for cross-context behavioral advertising. | Adjust your device ad tracking settings (iOS: Settings > Privacy > Advertising > Limit Ad Tracking; Android: Settings > Google > Ads > Opt out of ad personalization) |
| Data Portability (EU/UK) | Receive a machine-readable copy of data you have provided to us. | Email us at <support@tunergystudio.com> |
| Withdraw Consent | Withdraw any consent you have previously given. | Email us at <support@tunergystudio.com> |
We will respond to all requests within the timeframes required by applicable law (typically 30 days).
1. WHAT WE COLLECT
We collect information in two ways: (1) information you give us, and (2) information we collect automatically when you use our Services.
A. Information You Provide to Us
We do not require you to create an account or register to use our Services. However, you may choose to provide information to us when you:
Sensitive Information: We do not request or collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, health data, biometric data, or sexual orientation.
Payment Information: Our mobile applications may offer in-app purchases. All payment processing is handled exclusively by Apple Inc. (iOS) or Google LLC (Android). We do not receive or store your full payment card numbers, security codes, or billing details. Please refer to Apple's Privacy Policy
(<https://www.apple.com/legal/privacy/>) and Google's Privacy Policy
(<https://policies.google.com/privacy>) for information on how they handle your payment data.
B. Information Collected Automatically
When you download, install, or use our mobile applications, or visit our website, certain information is collected automatically by our systems:
| Category | Specific Data Points | Purpose |
| Device Identifiers | Advertising ID (IDFA on iOS, GAID on Android), device ID, IP address | Ad delivery, analytics, fraud prevention |
| Device Details | Device model, manufacturer, operating system version, screen resolution | Ensuring compatibility, troubleshooting crashes |
| Usage Data | App launch events, session duration, feature usage, level completion data | Understanding user behavior, improving game design |
| Location Data | Approximate location inferred from IP address (city/country level) — not precise GPS | Geo-targeting for ads, regional compliance, content localization |
| Crash Logs | Error reports, stack traces, hardware/software state at time of crash | Debugging, stability improvements |
We do not collect precise GPS location data, contact lists, photos, calendar entries, or files from your device.
2. HOW WE USE YOUR INFORMATION
We use the information we collect for the following purposes:
| Purpose | Why We Do It | Legal Basis (EU/UK users) |
| Providing the Service | To enable you to play our games, track progress, and deliver in-app content. | Performance of a contract |
| Analytics & Improvement | To understand how users interact with our games, identify bugs, and improve user experience. | Legitimate interest (improving our products) |
| Advertising | To display ads (including personalized ads) through third-party ad networks, which helps keep our games free. | Consent (for personalized ads) / Legitimate interest (for non-personalized ads where permitted) |
| Customer Support | To respond to your inquiries and resolve issues. | Performance of a contract / Legitimate interest |
| Legal Compliance | To comply with applicable laws, regulations, and enforceable governmental requests. | Legal obligation |
| Security | To detect and prevent fraud, cheating, and unauthorized access. | Legitimate interest (protecting our services and users) |
Push Notifications: We may ask your permission to send push notifications for game updates, events, or reminders. You can opt out at any time by adjusting the notification settings on your device.
3. WHO WE SHARE YOUR INFORMATION WITH
We share information with third-party service providers that help us operate, analyze, and monetize our Services. These providers process information on our behalf and are contractually required to protect it.
Advertising Partners
We work with the following advertising networks to display ads within our mobile applications:
This list may be updated from time to time. If we add or remove partners, we will revise this list accordingly. We encourage you to check this section periodically for the most current list.
Other Disclosure Scenarios
We may also share your information in the following situations:
We do not sell your personal information for monetary compensation. However, as is common in the mobile advertising ecosystem, we share advertising identifiers with ad networks to facilitate interest-based advertising. Under California law, this activity may be characterized as a "share" of personal information for cross-context behavioral advertising, and you have the right to opt out as described in Section 8.
4. INTERNATIONAL DATA TRANSFERS
Our servers and the servers of many of our service providers are located in the United States. If you are located outside the United States, your information will be transferred to and processed in the United States and potentially other countries.
For users in the European Economic Area (EEA), United Kingdom, or Switzerland:
The United States may not have data protection laws equivalent to those in your country. To ensure an adequate level of protection for your personal information, we rely on the European Commission's Standard Contractual Clauses (SCCs) as the legal mechanism for transferring data from the EEA, UK, and Switzerland to countries outside these regions. A copy of these clauses is available upon request at <support@tunergystudio.com>.
The transfer of your information is necessary for the performance of our contract with you (i.e., to provide the Services you have requested). By using our Services, you acknowledge that your information will be transferred to and stored in the United States as described in this section.
5. DATA RETENTION
We retain your personal information only as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law (for example, tax, accounting, or legal compliance requirements).
When we no longer have a legitimate business need to process your information, we will either:
The retention period for advertising identifiers is governed by the policies of our advertising partners and your device settings.
6. SECURITY
We implement appropriate technical and organizational measures to protect your personal information against accidental loss, unauthorized access, use, alteration, or disclosure. These measures include:
However, no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security. You use our Services at your own risk, and we encourage you to keep your device operating system and applications updated.
7. CHILDREN'S PRIVACY
Our Services are not directed at children, and we do not knowingly collect personal information from children under the age of 13 (or such higher age as may be required by applicable law in your jurisdiction, such as 16 in the EU/UK).
If you are under the applicable minimum age, please do not use our Services or provide any personal information to us. If we become aware that we have collected personal information from a child under the applicable age, we will take reasonable steps to delete that information as soon as possible.
If you believe we may have collected information from a child under the applicable age, please contact us at <support@tunergystudio.com>.
8. YOUR PRIVACY RIGHTS
A. Rights Under GDPR (EU/UK Users)
If you are located in the European Economic Area or the United Kingdom, you have the following rights under the General Data Protection Regulation (GDPR):
To exercise any of these rights, please email us at <support@tunergystudio.com>. We will respond within 30 days.
You also have the right to lodge a complaint with your local data protection supervisory authority if you believe we have violated your rights.
B. Rights Under CCPA/CPRA (California Residents)
If you are a resident of California, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) provide you with the following rights:
| Right | Description |
| Right to Know | Request that we disclose the categories and specific pieces of personal information we have collected about you, the sources, purposes, and third parties with whom we have shared it. |
| Right to Delete | Request deletion of your personal information (subject to exceptions). |
| Right to Correct | Request correction of inaccurate personal information. |
| Right to Opt-Out | Opt out of the "sharing" of your personal information for cross-context behavioral advertising (targeted ads). |
| Right to Non-Discrimination | You will not be discriminated against for exercising any of these rights. |
To Opt Out of Sharing: You can opt out of the sharing of your personal information for targeted advertising by adjusting your device settings:
Alternatively, you can email us at <support@tunergystudio.com> and we will process your opt-out request manually.
Authorized Agents: You may designate an authorized agent to make a request on your behalf. We will require written proof of authorization.
We do not sell your personal information for money. However, as noted in Section 3, we share advertising identifiers with ad networks, which qualifies as a "share" under California law. You have the right to opt out of this sharing.
C. Rights Under Other US State Laws
If you are a resident of Colorado, Connecticut, Utah, Virginia, or other states with comprehensive privacy laws, you may have similar rights to:
Please email us at <support@tunergystudio.com> to exercise these rights.
9. COOKIES AND OTHER TRACKING TECHNOLOGIES
When you visit our website at https://www.tunergystudio.com, we and our third-party partners may use cookies, web beacons, pixels, and other tracking technologies to:
You can manage your cookie preferences through your browser settings. Most browsers allow you to block or delete cookies. However, please note that disabling cookies may affect certain features of our website.
For our mobile applications, we do not use cookies in the traditional sense. However, the advertising and analytics SDKs listed in Section 3 use device advertising identifiers and similar technologies for the purposes described.
Do-Not-Track (DNT): We do not currently respond to DNT browser signals because no uniform standard has been adopted.
Global Privacy Control (GPC): For California residents, we recognize GPC signals as a valid opt-out request regarding the sharing of personal information for cross-context behavioral advertising.
10. THIRD-PARTY WEBSITES AND SERVICES
Our Services may contain links to third-party websites or services (for example, links within advertisements). We do not control these third parties and are not responsible for their privacy practices.
When you leave our Services and interact with a third-party website or service, any information you provide to them is governed by their own privacy policies. We encourage you to read their privacy policies before sharing your personal information.
11. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. The "Effective Date" at the top of this page indicates when this version was last revised.
If we make material changes to this Privacy Policy, we will notify you by:
We encourage you to review this Privacy Policy periodically to stay informed.
12. CONTACT US
If you have questions, comments, or concerns about this Privacy Policy, or if you wish to exercise any of your privacy rights, please contact us:
Tunergy Studio
63 MODY ROAD, TSIM SHA TSUI, HONG KONG
Phone: +852 57006428
Email: support@tunergystudio.com
Website: https://www.tunergystudio.com