Your Privacy Matters

1. Introduction

Top G Labs Ltd ("we," "our," "us," or the "Company") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use any of our services, including:

• Our Website: topglabs.co.uk and any associated subdomains
• Mobile Applications: All mobile apps published by Top G Labs Ltd on Google Play Store, Apple App Store, or any other platform
• Games: All games developed and published by Top G Labs Ltd
• Related Services: Any APIs, SDKs, cloud services, or other digital products we offer

This Privacy Policy applies globally to all our products and services. By using any of our services, you agree to the collection and use of information in accordance with this policy. If you do not agree with our policies and practices, please do not use our services.

Our apps and games fall into different categories based on their data collection practices. Each app's specific data practices are disclosed in its Google Play Data Safety section and/or App Store privacy label.

Category A: Offline Apps & Games (No Data Collection)

Some of our apps and games operate entirely offline and do NOT collect any personal data. These applications:

• Do not require internet connectivity to function
• Do not collect, store, or transmit any personal information
• Do not use analytics, advertising, or tracking services
• Do not require user registration or sign-in
• Store all game progress and settings locally on your device only

Category B: Apps with User Accounts

Apps that offer account creation and cloud synchronization will collect:

• Account information (email, password hash, username)
• User-generated content and data you input
• Device information for app functionality
• Usage analytics for app improvement (where disclosed)

Category C: Games with Analytics & Advertising

Some games may include analytics and/or advertising. These will collect:

• Device identifiers (Advertising ID, where permitted)
• Gameplay analytics (levels completed, session duration, in-game actions)
• Crash reports and performance data
• Ad interaction data (impressions, clicks)

Category D: Apps with In-App Purchases

Apps with in-app purchases may additionally process:

• Purchase history and transaction records
• Payment verification data (processed by Google Play / Apple App Store)
• Subscription status and renewal information

Note: We do not directly process payment card details. All payments are handled securely by the respective app store platforms.

3.1 Website (topglabs.co.uk)

When you visit our website, we may collect:

• Contact Information: Name, email address, phone number (when you submit our contact form)
• Usage Data: IP address, browser type, device information, pages visited, time spent on pages
• Cookies and Tracking Technologies: See our Cookie Policy for details
• Communication Data: Records of correspondence if you contact us

3.2 Mobile Applications (General)

Depending on the app category (see Section 2), we may collect:

• Account Information: Email address, password (securely hashed), display name
• User Content: Data, items, notes, or content you create within the app
• Device Information: Device model, operating system version, app version, unique device identifiers
• Usage Data: App features used, interaction patterns, session information
• Location Data: Only if you explicitly grant permission for location-based features (optional)
• Crash & Performance Data: Error logs, performance metrics for app stability

3.3 Games

For our games, depending on the specific game, we may collect:

• Gameplay Data: Levels completed, scores, achievements, in-game progress
• Analytics Data: Session duration, feature usage, game events (for improving game experience)
• Advertising Identifiers: For games with ads, we may collect advertising IDs to serve relevant ads
• Purchase Data: In-app purchase history (processed via app store)
• Leaderboard Data: Username/display name, scores (if game includes social features)

4. Legal Basis for Processing (UK/EU GDPR)

We process your personal data based on the following legal grounds:

• Contract Performance: Processing necessary to provide our services to you (e.g., account creation, app functionality)
• Consent: Where you have given explicit consent (e.g., marketing communications, optional analytics, personalized advertising)
• Legitimate Interests: For purposes that are in our legitimate business interests, provided they do not override your rights (e.g., fraud prevention, security, service improvement, basic analytics)
• Recognized Legitimate Interests (UK): Under the UK Data (Use and Access) Act 2025, certain processing activities qualify as recognized legitimate interests, including safeguarding users and ensuring service security
• Legal Obligations: Processing required to comply with applicable laws and regulations

5.1 Service Provision

• Provide, operate, and maintain our apps, games, and services
• Create and manage your user account
• Process transactions and send related information
• Sync your data across devices (where applicable)
• Send push notifications and reminders (with your permission)
• Provide customer support and respond to inquiries

5.2 Improvement & Analytics

• Analyze usage patterns to improve our products
• Identify and fix bugs, crashes, and performance issues
• Develop new features based on user behavior
• Conduct A/B testing to optimize user experience
• Generate aggregated, anonymized statistics

5.3 Advertising (Where Applicable)

• Display advertisements in free versions of our apps/games
• Serve personalized ads based on your interests (with consent)
• Measure ad performance and effectiveness
• Frequency capping to limit repetitive ads

5.4 Security & Compliance

• Detect, prevent, and address fraud and abuse
• Protect the security and integrity of our services
• Comply with legal obligations and respond to legal requests
• Enforce our Terms of Service and other policies

6. Third-Party Services & SDKs

Our apps and games may integrate third-party services that have their own privacy policies. These may include:

Analytics Providers

• Google Analytics / Firebase Analytics
• Unity Analytics (for games)
• Crashlytics (crash reporting)

Advertising Networks (Where Applicable)

• Google AdMob
• Unity Ads
• AppLovin
• ironSource

Cloud & Infrastructure

• Google Cloud Platform / Firebase
• Amazon Web Services (AWS)
• Vercel (website hosting)

Authentication Services

• Firebase Authentication
• Google Sign-In
• Apple Sign-In

Each app's specific third-party integrations are disclosed in its app store listing and Data Safety section. We recommend reviewing the privacy policies of these third-party services.

7. Data Sharing and Disclosure

We do NOT sell your personal information. We may share your information only in the following circumstances:

• Service Providers: With trusted third-party service providers who assist us in operating our services (e.g., cloud hosting, analytics, email services). These providers are contractually obligated to protect your data and may only process it on our behalf.
• Advertising Partners: For apps with ads, limited data may be shared with advertising networks to serve and measure ads. You can opt-out of personalized advertising through your device settings.
• Legal Requirements: When required by law, court order, or government regulation, or to protect our legal rights
• Business Transfers: In connection with a merger, acquisition, or sale of assets (users will be notified)
• Safety & Security: To protect the safety of users, prevent fraud, or address security issues
• With Your Consent: When you explicitly authorize us to share your information

We implement industry-standard security measures to protect your information:

• Encryption of data in transit (TLS 1.3) and at rest (AES-256)
• Secure password hashing using bcrypt or Argon2
• Regular security audits and penetration testing
• Access controls and authentication mechanisms
• Secure cloud infrastructure with SOC 2 certified providers
• Regular backups and disaster recovery procedures
• Employee security training and data access policies

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your data using commercially acceptable means, we cannot guarantee absolute security.

Depending on your location, you have the following rights regarding your personal data:

UK & EU Residents (GDPR)

• Right to Access: Request a copy of your personal data
• Right to Rectification: Correct inaccurate or incomplete data
• Right to Erasure: Request deletion of your data ("right to be forgotten")
• Right to Restrict Processing: Limit how we use your data
• Right to Data Portability: Receive your data in a structured, machine-readable format
• Right to Object: Object to processing based on legitimate interests or for marketing
• Right to Withdraw Consent: Withdraw consent at any time (where processing is based on consent)
• Right to Complain: Lodge a complaint with the ICO (UK) or your local data protection authority

California Residents (CCPA/CPRA)

• Right to know what personal information is collected, used, shared, or sold
• Right to delete personal information held by businesses
• Right to opt-out of the sale or sharing of personal information
• Right to non-discrimination for exercising your CCPA rights
• Right to correct inaccurate personal information
• Right to limit use and disclosure of sensitive personal information

To exercise these rights, please contact us at contact@topglabs.co.uk. We will respond within 30 days (or as required by applicable law).

For apps that allow account creation, you can request account deletion:

• In-App: Through the app's settings or profile section (where available)
• Public Deletion Page: App-specific instructions are available on our Expiry Tracker account deletion page
• Email: By contacting us at contact@topglabs.co.uk
• Web Form: Through our contact page

Upon receiving a deletion request:

• Your account and associated data will be deleted within 30 days
• Some data may be retained for up to 90 days in backups
• Data required for legal compliance may be retained as required by law
• Anonymized, aggregated data may be retained for analytics

11. Data Retention

• Website Contact Forms: Retained for 2 years or until you request deletion
• App Account Data: Retained while your account is active, plus 30 days after deletion request
• Gameplay/Analytics Data: Retained for up to 2 years, then anonymized or deleted
• Purchase Records: Retained for 7 years as required for tax/legal compliance
• Security Logs: Retained for 1 year for fraud prevention and security purposes
• Anonymized Data: Aggregated, anonymized data may be retained indefinitely for statistical purposes

12. Children's Privacy

Our services are not directed at children under 13 years of age (or 16 in the EU/UK). We do not knowingly collect personal information from children.

For apps/games rated for younger audiences, we take additional precautions:

• No collection of personal information beyond what is necessary for gameplay
• No behavioral advertising to children
• Compliance with COPPA (Children's Online Privacy Protection Act) requirements
• Compliance with UK Age Appropriate Design Code where applicable

If you believe we have collected information from a child, please contact us immediately at contact@topglabs.co.uk, and we will delete such information.

13. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence, including the United States and other countries where our service providers operate.

We ensure appropriate safeguards are in place to protect your data, including:

• Standard Contractual Clauses (SCCs) approved by the UK/EU
• UK International Data Transfer Agreements (IDTAs) where applicable
• Adequacy decisions for transfers to approved countries
• Binding Corporate Rules where applicable

14. Google Play Data Safety Disclosure

In compliance with Google Play requirements, each of our apps includes a Data Safety section in its store listing that discloses:

• What data is collected and for what purpose
• Whether data is shared with third parties
• Data security practices
• Whether users can request data deletion
• Whether the app follows Google Play's Families Policy (if applicable)

We keep our Data Safety sections up-to-date with any changes to our data practices. For the most current information about a specific app, please refer to its Google Play Store listing.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by:

• Posting the new Privacy Policy on this page
• Updating the "Last Updated" date at the top
• Sending an email notification (for significant changes, where we have your email)
• Displaying a notice within our apps (for significant changes)

We encourage you to review this Privacy Policy periodically. Your continued use of our services after changes become effective constitutes acceptance of the updated policy.