Privacy Policy

1. Introduction

This Privacy Policy describes how Etermax S.A. (“etermax,” “we,” “us,” or “our”) collects, uses, and shares information about you when you use our mobile applications, websites, and other online products and services (collectively, the “Services”).

By using our Services, you agree to the collection, use, and sharing of your information as described in this Privacy Policy. If you do not agree, please do not use our Services.

2. Information We Collect

We collect information in the following ways:

• Information you provide directly: account registration data (email, username, profile picture), communications you send us, survey responses, and user-generated content.
• Information collected automatically: device identifiers, IP address, operating system, app version, usage data, gameplay statistics, session duration, and in-app purchase history.
• Information from third parties: advertising partners, analytics providers, social media platforms (when you link accounts), and payment processors.

3. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve our Services
• Process transactions and send related information
• Personalize your experience and deliver relevant content
• Send promotional communications (with your consent)
• Monitor and analyze trends, usage, and activities
• Detect, prevent, and address fraud and security issues
• Comply with legal obligations

4. How We Share Your Information

We may share your information with:

• Service providers: companies that perform services on our behalf (hosting, analytics, customer support, payment processing)
• Advertising partners: to serve and measure ads
• Business transfers: in connection with mergers, acquisitions, or asset sales
• Legal requirements: when required by law, regulation, legal process, or governmental request
• With your consent: when you direct us to share your information with third parties

5. Consent

Where required by applicable law, we obtain your consent before collecting or processing your personal data. You may withdraw consent at any time by contacting us at help@etermax.com.

For users in the European Economic Area (EEA), we process personal data based on: consent, contractual necessity, legitimate interests, and legal obligations.

6. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements.

Account data is retained for the lifetime of your account. After account deletion, we may retain certain data for up to 90 days for backup and fraud prevention purposes.

7. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence, including the United States, Argentina, and Uruguay. These countries may have data protection laws different from your country.

For transfers from the EEA, we rely on Standard Contractual Clauses approved by the European Commission. For transfers from the UK, we use the International Data Transfer Agreement or Addendum.

8. Your Rights

Depending on your jurisdiction, you may have the following rights:

GDPR (EEA/UK)

• Right of access, rectification, erasure, restriction, portability
• Right to object to processing
• Right to withdraw consent
• Right to lodge a complaint with a supervisory authority

CCPA (California)

• Right to know what personal information is collected
• Right to delete personal information
• Right to opt-out of the sale of personal information
• Right to non-discrimination

LGPD (Brazil)

• Right to confirmation and access
• Right to correction and deletion
• Right to anonymization, blocking, or elimination
• Right to data portability

VCDPA (Virginia)

• Right to access, correct, delete, and obtain a copy
• Right to opt-out of targeted advertising and sale of data

To exercise any of these rights, contact us at dpo_gdpr@etermax.com.uy.

9. Security

We implement appropriate technical and organizational measures to protect your personal data, including encryption in transit and at rest, access controls, regular security assessments, and incident response procedures.

No method of transmission or storage is 100% secure. If you have reason to believe your interaction with us is no longer secure, contact us immediately.

10. Cookies & Tracking

Our websites and Services use cookies, pixels, and similar technologies to recognize your browser, remember preferences, and analyze usage.

• Essential cookies: required for the Services to function
• Analytics cookies: help us understand how users interact with our Services
• Advertising cookies: used to deliver relevant ads

You can manage cookie preferences through your browser settings or our cookie consent tool where available.

11. Third-Party Advertising

We work with third-party advertising networks to serve ads in our games. These partners may collect information about your activity across apps and websites to deliver targeted advertising.

Advertising partners include, but are not limited to: Google AdMob, Meta Audience Network, Unity Ads, ironSource, and AppLovin. Each partner has its own privacy policy governing data collection.

You can opt out of personalized advertising through your device settings (e.g., “Limit Ad Tracking” on iOS or “Opt out of Ads Personalization” on Android).

12. Children's Privacy

Our Services are not directed to children under 13 (or the applicable age in your jurisdiction). We do not knowingly collect personal information from children under this age.

If we learn that we have collected personal information from a child under the applicable age, we will take steps to delete it promptly. If you believe a child has provided us with personal data, please contact us at help@etermax.com.

13. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of the Oriental Republic of Uruguay, without regard to conflict of law principles.

Any disputes arising under this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of Montevideo, Uruguay, unless otherwise required by applicable local law.

14. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you through the Services or by other means (such as email) prior to the change becoming effective.

Your continued use of the Services after the effective date of the revised Privacy Policy constitutes your acceptance of the changes.

15. Data Protection Officer

If you have questions or concerns about our data practices, you may contact our Data Protection Officer:

• Email: dpo_gdpr@etermax.com.uy
• Address: Etermax S.A., Dr. Luis Bonavita 1294, Office 1831, Montevideo 11300, Uruguay

16. Contact Us

For general privacy inquiries:

• Email: help@etermax.com
• DPO: dpo_gdpr@etermax.com.uy
• Address: Etermax S.A., Dr. Luis Bonavita 1294, Office 1831, Montevideo 11300, Uruguay