Article 1. Purposes of Processing Personal Information
1. Snowpipe Co., Ltd. (the “Company,” “we,” “us,” or “our”) processes personal information for the following purposes. We do not use personal information for purposes other than those specified below, unless required or permitted by applicable law or unless appropriate measures are taken in accordance with applicable law.
Service provision and operation: identifying users, storing and restoring game progress, providing game features such as nicknames, rankings and achievements, maintaining the service environment, responding to errors, preventing misuse, and ensuring service stability.
Age verification and user protection: verifying service eligibility, restricting use by users under the age of nine (9), applying privacy and advertising protections for children and teenagers, and complying with country- or region-specific laws and platform policies.
Advertising and ad performance measurement: providing banner ads, interstitial ads, rewarded ads and other ads; measuring ad impressions, views and performance; providing non-personalized or limited ads; and reflecting users' ad consent status.
Service analytics and improvement: analyzing usage patterns, improving game balance and content, analyzing advertising efficiency, and improving service quality.
Protection of user rights and legal compliance: handling requests for access, correction, deletion or suspension of processing, responding to disputes, and complying with statutory retention obligations.
Article 2. Categories of Personal Information Processed
1. The Company may process the following personal information or service-use information to provide the Service.
| Category | Items | Main Purposes |
|---|---|---|
| Information entered by users | Date of birth, nickname, consent to Terms of Service and Privacy Policy, ad and privacy consent status | Age verification, user identification, service provision, ad restriction processing |
| Inquiry and deletion request information | Email address, inquiry content, information necessary to identify the user | Responding to privacy-right requests, processing deletion requests, dispute handling |
| Automatically generated information | Internal user ID, game progress data, rankings, achievements, play records, app launch records and event logs | Providing game features, restoring data, service improvement, misuse prevention |
| Advertising-related information | Ad impression and ad view records, Android Advertising ID, iOS IDFA, ad consent status, device information | Ad delivery, ad performance measurement, personalized ad restrictions, reflecting consent status |
| Technical information | App version, operating system, device model, language/region settings, network status information, technical logs generated during service use | Service stability, error response, compliance with country- or region-specific policies |
2. The Company does not directly collect users' real names, phone numbers, physical addresses, contact lists, photos, camera data, microphone data or precise location information for the purpose of operating the Service.
3. Third-party SDK or platform providers that provide advertising, analytics, game-service and consent-management functions may process advertising identifiers, device information, IP addresses, approximate country/region information, ad interaction information and similar technical information in accordance with their own privacy policies and applicable laws.
4. The Company does not separately store IP addresses on its own servers as a general principle. However, IP addresses and other technical information may be processed during communications with SDKs or platform services.
Article 3. Methods of Collecting Personal Information
Information entered directly by users when first launching the app or while using the Service.
Information automatically generated during use of the Service.
Information generated through platform services such as Google Play Games Services and Apple Game Center.
Information processed through advertising SDKs, analytics SDKs and consent-management SDKs.
Information provided by users by email for deletion requests or privacy inquiries.
Article 4. Retention and Use Period of Personal Information
1. The Company destroys personal information without undue delay when the purpose of processing has been achieved. However, information that must be retained for a certain period under applicable laws may be separately stored for the period required by those laws.
| Category | Retained Items | Retention Period |
|---|---|---|
| General service-use information | Nickname, internal user ID, date of birth, game progress data | Retained during the period of service use and deleted upon user request or when the processing purpose has been achieved |
| Ad and age-related information | Ad consent status, age verification information | Retained for the period necessary to apply ad restrictions, verify age, and comply with laws and policies |
| App activity and event logs | App launch records, event logs, ad impression and ad view records | Retained until the purpose of service analysis and improvement has been achieved. Statistical or de-identified information may be retained in a form that cannot identify individuals |
| Dispute handling information | Records relating to consumer complaints or dispute resolution, if any | 3 years |
2. Information processed by third-party SDKs and platform providers that provide advertising, analytics, game-service and consent-management functions may be retained and deleted in accordance with each provider's privacy policy and retention policy.
Article 5. Destruction of Personal Information
1. The Company destroys personal information without undue delay when the retention period has expired or the purpose of processing has been achieved.
2. Electronic files are deleted in a manner that makes recovery or reproduction difficult.
3. Information that must be retained under applicable laws is separately stored and destroyed after the legally required retention period has ended.
4. Information that has been de-identified or anonymized so that individuals cannot be identified may be retained to the extent that it no longer constitutes personal information.
Article 6. Third-Party Disclosure of Personal Information
1. The Company processes users' personal information within the scope specified in this Privacy Policy and does not sell or arbitrarily disclose users' personal information to outside parties.
2. The Company may disclose personal information to third parties in the following cases.
Where the user has given prior consent.
Where there is a special provision under applicable law.
Where there is a lawful request from an investigative agency, court, administrative authority or other competent authority.
Where information is processed through a platform or SDK provider to the extent necessary to provide services requested by the user, such as service provision, ad delivery, analytics, game-service integration or consent management.
Article 7. Processing Entrustment and Third-Party SDKs
1. The Company may use the following third-party services, SDKs or platforms to provide the Service smoothly.
| Processor or Provider | Purpose of Use | Information That May Be Processed |
|---|---|---|
| Google LLC | Google Mobile Ads/AdMob, Google UMP, Firebase Analytics, Google Play Games Services | Advertising identifiers, device information, app activity information, ad data, game-service information |
| Unity Technologies and affiliates | Unity Engine, Unity LevelPlay, Unity Ads, ironSource ad mediation and ad delivery | Advertising identifiers, device information, ad impression/view information, app activity information, ad performance information |
| Apple Inc. | Game Center, iOS ATT and platform/game services | Game-service information, IDFA and consent status |
| Other cloud, server and API operation providers | Service server operation, data storage, service stability | Internal user ID, nickname, date of birth, game progress data |
2. Each third-party SDK or platform provider may process information in accordance with its own privacy policy. The Company may update this Privacy Policy if the SDKs or services included in the final build are changed.
Article 8. Overseas Transfer of Personal Information
1. The Company may use SDKs or platform services provided by overseas businesses to provide advertising, analytics, game-service and consent-management functions. In this process, certain information may be transferred overseas or processed on servers located outside the user's country or region.
Google LLC
| Recipient | Google LLC |
|---|---|
| Countries of Transfer | United States and other countries where Google's global infrastructure is located |
| Items Transferred | Advertising identifiers, device information, app activity information, ad data, game-service information |
| Purpose of Transfer | Ad delivery, ad consent management, analytics, game-service provision |
| Timing and Method | Transferred over the network when the user uses the Service, requests ads, uses game services or processes consent |
| Retention and Use Period | Subject to the recipient's privacy policy and retention policy |
Unity Technologies and affiliates
| Recipient | Unity Technologies and affiliates |
|---|---|
| Countries of Transfer | United States and other countries where Unity's global infrastructure is located |
| Items Transferred | Advertising identifiers, device information, ad impression/view information, app activity information, ad performance information |
| Purpose of Transfer | Ad mediation, ad delivery, ad performance measurement |
| Timing and Method | Transferred over the network when ads are requested or viewed |
| Retention and Use Period | Subject to the recipient's privacy policy and retention policy |
Apple Inc.
| Recipient | Apple Inc. |
|---|---|
| Countries of Transfer | United States and other countries where Apple's global infrastructure is located |
| Items Transferred | Game Center information, IDFA and consent status |
| Purpose of Transfer | Game services and iOS tracking consent processing |
| Timing and Method | Transferred over the network when game-service use or ATT processing occurs |
| Retention and Use Period | Subject to the recipient's privacy policy and retention policy |
2. The exact countries of transfer, retention periods and processed items may vary depending on each SDK or platform provider's policy and the final build configuration. The Company will update this Article where necessary based on the final Service configuration.
Article 9. Advertising Identifiers and Personalized Advertising
1. The Company may use advertising identifiers such as the Android Advertising ID and iOS IDFA to provide ads within the Service.
2. For Android users, the Android Advertising ID may be used through advertising SDKs for ad delivery, ad performance measurement and ad restriction processing.
3. For iOS users, IDFA is used only to the extent that consent is required under ATT (App Tracking Transparency). If a user does not consent to ATT, use of IDFA for personalized advertising or tracking purposes is restricted.
4. For users in the European Economic Area, the United Kingdom, Switzerland and other regions where advertising consent is required, the Company may use a consent-management tool such as UMP (User Messaging Platform) to confirm the user's ad consent status.
5. The Company does not provide personalized ads to users under the age of thirteen (13) or users protected as children under applicable laws or platform policies. Non-personalized ads or limited ads may be provided instead.
6. For users aged thirteen (13) or older who are minors, personalized advertising or tracking features may also be restricted depending on country- or region-specific laws, platform policies and the Company's internal operating standards.
7. Users may reset their advertising identifier or limit personalized advertising through their device settings. Non-personalized ads may still be displayed even if personalized advertising is limited.
Article 10. Protection of Children and Teenagers
1. The Service is intended for users aged nine (9) or older.
2. The Company may request the user's date of birth when the Service is first launched to verify age. If a user is confirmed to be under the age of nine (9), the Company may restrict use of the Service or delete related information.
3. The Company processes personal information of children and teenagers only to the minimum extent necessary to provide the Service and applies protective measures in accordance with applicable laws and platform policies.
4. The Company does not provide personalized ads to users under the age of thirteen (13) or users protected as children under applicable laws or platform policies, and may apply non-personalized ad or limited-ad treatment when ad requests are made.
5. A legal representative may request access to, correction of, deletion of, or suspension of processing of personal information of a child or teenager, and the Company will take necessary measures in accordance with applicable laws.
Article 11. User Rights and How to Exercise Them
1. Users may exercise the following privacy-related rights against the Company at any time.
Request access to personal information.
Request correction of personal information.
Request deletion of personal information.
Request suspension of processing of personal information.
Withdraw consent to the collection and use of personal information.
2. Users may exercise these rights by contacting the Company at the email address below.
hoon@snowpipe.co.kr
3. The Company will take action without undue delay in accordance with applicable laws after receiving a user's request. However, the Company may request the minimum information necessary to verify the user or prevent fraudulent requests.
4. Dispute records or other information that must be retained under applicable laws may be stored separately for the legally required retention period even if a deletion request is made.
Article 12. Security Measures
1. The Company takes the following measures to manage users' personal information securely.
Restricting and managing access rights to personal information.
Minimizing personnel who handle personal information.
Secure transmission of data containing personal information.
Access control for service servers and management systems.
Separate storage of information that must be retained under applicable laws.
Processing information only to the necessary extent when using third-party SDKs and platforms.
Regular review of this Privacy Policy and internal operating standards.
Article 13. External Services and Third-Party Privacy Policies
1. The Service may include third-party SDKs and platform services provided by Google, Apple, Unity and others. These providers may process information in accordance with their own privacy policies, and the Company does not directly control all privacy practices of those providers.
2. Users may review each platform or SDK provider's privacy policy to understand the provider's privacy practices, retention periods and methods for exercising user rights.
Article 14. Privacy Contact
1. The Company operates the following contact department to handle privacy-related inquiries, complaints, and requests for remedies.
| Company | Snowpipe Co., Ltd. |
|---|---|
| Address | Room 810, Namjeon Building, 326 Bongeunsa-ro, Gangnam-gu, Seoul, Republic of Korea |
| Privacy Contact Department | Service Operations Department |
| hoon@snowpipe.co.kr |
2. Users may contact the Privacy Contact Department for all privacy-related inquiries, complaints, and requests for remedies that arise while using the Service.
Article 15. Changes to this Privacy Policy
1. The Company may amend this Privacy Policy in response to changes in applicable laws, the Service, personal-information processing methods, SDK configuration, advertising policies or store policies.
2. If this Privacy Policy is changed, the Company will notify users of the changes through an in-app notice, official webpage, store page or other appropriate method.
Article 16. Effective Date
This Privacy Policy is effective as of July 3, 2026.