Privacy Policy

Last updated: 4 November 2026

This Privacy Policy explains what personal data is processed when you use the Happy Tree Games website (happytreegames.com) and the mobile games published under the Happy Tree Games name on Google Play and the Apple App Store, why it is processed, and what rights you have. We have written it to describe what our games and our website actually do.

1. Who is responsible for your data

The data controller is Imre FARKAS, a private individual (natural person) who publishes the games under the name Happy Tree Games, a project of Emma Wolf.

We have not appointed a data protection officer, as this is not required for our activity. Please send any privacy question or request to the e-mail address above.

2. The short version

  • Our games do not ask for your name, e-mail address, phone number or any account. You can play without registering.
  • Your scores, best times, settings and unfinished games are saved only on your device. We do not receive them.
  • The free editions show advertisements from Google AdMob. Personalised ads are shown only if you agree; you can change your choice at any time in the game.
  • The Plus editions contain no advertising and no advertising technology. On Apple devices they can submit your results to Game Center leaderboards.
  • Where a game or app uses the camera (Movie Puzzle, AI Face Info), the picture is processed live on your device and is never recorded, saved or sent anywhere.
  • We do not sell your personal data, and our games do not access your location, contacts, microphone or photo library.

3. Data processed in our games

This policy applies to the following games and apps and, where they exist, to their Plus editions: Movie Puzzle, Domino Order, Bubble Remover, Maze Touch, Itch Ninja, Egg Hopper, Devil Snake, 2048 Gyro, Sway Way, ScandiCross, Mirror Maze, Deep Peek, Supermarket Rush and AI Face Info, and to any other game we publish under the Happy Tree Games name unless that game has its own privacy policy.

3.1 Game progress stored on your device

The games use the local storage of the app on your phone or tablet to remember your results (for example best times and scores), your selected difficulty and settings, an unfinished game so that you can continue it, and a small counter that decides when the next advertisement may be shown. This data stays on your device, is not sent to us or to anyone else, and is deleted when you clear the app's data or uninstall the game.

Legal basis: storing this information is strictly necessary to provide the game you asked for (Art. 6(1)(b) GDPR; the exemption for strictly necessary storage under Art. 4(5) of Romanian Law no. 506/2004).

3.2 Advertising in the free editions (Google AdMob)

The free editions are financed by full-screen advertisements, shown between rounds (after every 5 to 10 completed games). The ads are delivered by Google AdMob, a service of Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland). To deliver and measure ads, the Google Mobile Ads SDK built into the game collects and processes, under Google's responsibility:

  • your device's advertising identifier (Android Advertising ID; on iOS the IDFA, only if you allow tracking, see 3.3);
  • your IP address and the approximate location derived from it;
  • technical information about your device, operating system and the app (for example model, language, app version);
  • information about the ads shown and your interactions with them (views, clicks), and diagnostic data.

Your consent. When you first start a free edition in the European Economic Area, the United Kingdom or Switzerland (and in other regions where the law requires it), a consent form provided by Google (User Messaging Platform, based on the IAB Transparency & Consent Framework) asks whether you agree to the storage of and access to information on your device and to personalised advertising. If you agree, Google may use the data above to show you ads based on your interests. If you do not agree, Google shows non-personalised or limited ads, which are based on the context (for example the game itself) and not on a profile about you.

Changing your choice. You can review or withdraw your consent at any time with the privacy settings button on the game's information (About) screen. Withdrawing consent does not affect the lawfulness of processing before the withdrawal. You can also reset or delete your advertising ID, or opt out of ad personalisation, in your device settings (Android: Settings > Google > Ads or Settings > Privacy > Ads; iOS: Settings > Privacy & Security > Tracking).

Legal basis: your consent for personalised ads and for accessing information on your device where consent is required (Art. 6(1)(a) GDPR, Art. 4(5) of Law no. 506/2004); our legitimate interest in financing free games for non-personalised ads (Art. 6(1)(f) GDPR).

Google acts as an independent controller for this data. We do not receive your advertising identifier or any information that identifies you; we only see aggregated reports (for example how many ads were shown). To learn more, see How Google uses information from sites or apps that use its services and the Google Privacy Policy.

3.3 App Tracking Transparency on iPhone and iPad

On iOS and iPadOS, after the consent form, the system asks whether you allow the game to track you across apps and websites owned by other companies. Only if you tap Allow can the advertising identifier (IDFA) be used for advertising; otherwise it is not available to the game or to Google. You can change this at any time in Settings > Privacy & Security > Tracking.

3.4 Plus editions and Game Center

The Plus editions do not contain advertisements, the Google Mobile Ads SDK or any other advertising or tracking technology. On Apple devices they use Game Center, Apple's game service: if you are signed in to Game Center, the game submits your results (for example your completion time) to the game's leaderboards and can show those leaderboards to you. Game Center is operated by Apple, which processes your Game Center profile (player ID, nickname) and scores under the Apple Privacy Policy. Leaderboard entries (your Game Center nickname and score) are visible to other players and to us as the developer. You can sign out of Game Center or change its privacy settings in your device settings.

Legal basis: providing the leaderboard feature you use (Art. 6(1)(b) GDPR).

3.5 Camera (Movie Puzzle)

Movie Puzzle can use your device's front or rear camera so that you can solve a puzzle made of your live camera picture. The camera is used only after you choose this option and after you grant the camera permission. The picture is processed in real time on your device to draw the puzzle tiles; it is not recorded, not saved and not transmitted to us or to anyone else. You can withdraw the camera permission at any time in your device settings; the other puzzles keep working.

3.6 Face analysis (AI Face Info)

AI Face Info asks for the camera permission when it starts, because reading faces from the live camera picture is all it does. For every face it sees, AI models built into the app estimate the age, gender, emotion, facial expression, gaze, eye colour and distance, and the app writes these estimates on the screen. The results are estimates for fun and can be wrong.

All of this happens on your device. The camera picture is processed in the memory of the app and is not recorded, not saved and not transmitted to us or to anyone else. To keep the results of the same person together while the app is open (for example for the flatter mode, which shows a person a little younger), the app computes a numeric description of each face; this description, the flatter-mode choice and the mood graph of the last minutes are kept only in the app's memory and are forgotten when you close the app. AI Face Info contains no advertisements, no in-app purchases and no analytics, and the Android version has no permission to use the internet.

The app finds faces with MediaPipe, a library from Google. MediaPipe can collect technical usage statistics about itself (for example the app and library version, the platform, how often a function was used and errors); these statistics contain no pictures and no face data. As the Android version cannot use the internet, they cannot leave an Android device.

You can withdraw the camera permission at any time in your device settings; without it the app cannot show any results.

3.7 Links

Apart from the advertisements in the free editions (see 3.2) and Game Center in the Plus editions (see 3.4), the games load nothing from the internet: all their program code, pictures and videos are inside the app. Their information screens contain links to our websites and to the app stores. A link opens only when you tap it, in your device's browser, and the website then processes the data described in section 4.

3.8 Sharing

If you use the share button, the game opens your device's standard share menu with the game's name and its store link. Whatever you share goes through the app you choose (for example a messaging app) under that app's terms; we do not receive it.

3.9 App stores

You download our games from Google Play or the Apple App Store, and Plus editions are purchased there. Google and Apple process your account, download and payment data as independent controllers under their own privacy policies. We do not receive your payment details; the stores provide us only with aggregated statistics and, where you contact us through a review, the content of that review.

4. Data processed on our website

4.1 Server logs

When you visit happytreegames.com, our web server automatically records your IP address, the date and time of the request, the requested address, the referring page, and the browser or app identification (user agent). We use this data only to operate and secure the website and to detect abuse. Log files are deleted automatically after about 14 days, unless a specific entry is needed to investigate a security incident.

Legal basis: our legitimate interest in a secure and working website (Art. 6(1)(f) GDPR).

The website is hosted on a server of OVHcloud in the European Union, which acts as our processor.

4.2 Support and contact

If you write to us by e-mail or through the support form (provided by our own help desk at osticket.emmawolf.com), we process your name, your e-mail address, the content of your message and any information you choose to include, in order to answer you. We keep this correspondence for as long as needed to handle your request and for up to 3 years after it is closed, in case of follow-up questions or legal claims; after that it is deleted.

Legal basis: answering your request (Art. 6(1)(b) GDPR, or our legitimate interest under Art. 6(1)(f) GDPR where no contract is involved).

4.3 Donations

If you choose to support us through the PayPal donation button, the payment is processed by PayPal (Europe) S.à r.l. et Cie, S.C.A. as an independent controller. PayPal notifies us of the payment, including the name, e-mail address and amount you used. We keep this data as long as accounting and tax law requires.

4.4 Cookies and third-party content

The website uses only the cookies described in our Cookies Policy. To display the pages, your browser also loads:

  • fonts from Google Fonts (Google Ireland Limited), which receives your IP address;
  • the image of the PayPal donation button from PayPal, which receives your IP address;
  • a QR code image (to continue on another device) from qrcode.xoo.tools and a sign-in script from overallid.com; both are services of Emma Wolf, operated by the same controller.
  • JavaScript libraries (such as jQuery) from Google Hosted Libraries (ajax.googleapis.com, www.gstatic.com) and from cdnjs (Cloudflare, Inc.), which receive your IP address.

Community comments (Disqus)

The community page shows a comment section provided by Disqus, Inc. (United States). When you open that page, your browser loads Disqus, which receives your IP address and information about your browser and device and may set its own cookies, including for analytics and advertising. If you post a comment, you do so with a Disqus or social account, and your comment and profile name are public. Disqus processes this data as an independent controller and may transfer it to the United States; see the Disqus Privacy Policy. The other pages of the website do not load Disqus.

5. Who receives data

  • Google (AdMob in the free editions, Google Fonts and Google Hosted Libraries on the website, Google Play);
  • Disqus, only when you open the community page;
  • Apple (Game Center in the Plus editions, App Store);
  • OVHcloud (hosting, as our processor);
  • Cloudflare (cdnjs, which delivers some JavaScript libraries of the website);
  • PayPal, only if you make a donation;
  • public authorities, only where we are legally obliged to disclose data.

We do not sell personal data and we do not share it with anyone else.

6. Transfers outside the European Union

Google, Apple and Cloudflare may process data in the United States and other countries. These transfers are based on the EU–U.S. Data Privacy Framework, under which these companies are certified, and on the European Commission's Standard Contractual Clauses. Disqus describes the safeguards for its transfers in its own privacy policy.

7. How long data is kept

  • Game progress on your device: until you clear the app's data or uninstall the game.
  • Advertising data: retained by Google according to its own policies; your consent choice is stored on your device until you change it or uninstall the game.
  • Game Center leaderboard entries: until you or Apple remove them, or until we reset the leaderboard.
  • Web server logs: about 14 days.
  • Support correspondence: up to 3 years after the request is closed.
  • Donation records: as long as accounting and tax law requires.

8. Children

Our games are made for a general audience; they are not specifically directed at children. We do not knowingly collect personal data from children: the games have no registration, chat or other way to enter personal information. In Romania and in several other EU countries, consent to personalised advertising can be given by a child only from the age of 16; younger players should ask a parent or guardian before answering the consent form. Parents can switch off personalised ads at any time with the game's privacy settings button and in the device settings (see 3.2 and 3.3), and can use the parental controls of Google Play (Family Link) and Apple (Screen Time). If you believe that a child has sent us personal data, for example by e-mail, please contact us and we will delete it.

9. Your rights

Under the General Data Protection Regulation (GDPR) you have the right to:

  • access the personal data we hold about you and receive a copy;
  • have inaccurate data corrected;
  • have your data erased;
  • restrict the processing of your data;
  • receive your data in a portable format;
  • object to processing based on our legitimate interests;
  • withdraw your consent at any time, without affecting earlier processing.

To exercise these rights, write to hello@emmawolf.com. We answer within one month, free of charge. Because our games do not identify you, we usually hold no data that can be linked to you; data stored on your device can be deleted by you directly, and advertising data is held by Google, which you can manage at My Ad Center. We do not make decisions about you based solely on automated processing.

You also have the right to lodge a complaint with a data protection supervisory authority, in particular in the EU country where you live. In Romania this is the National Supervisory Authority for Personal Data Processing (ANSPDCP), B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, 010336 Bucharest, www.dataprotection.ro, anspdcp@dataprotection.ro.

10. Security

Our website is served only over encrypted connections (HTTPS), access to the server is restricted, and we keep the amount of data we process to the minimum described in this policy.

11. Changes to this policy

We update this policy when our games, our website or the law change. The current version is always available at happytreegames.com/en/privacy.html, with the date of the last update at the top.

See also our Terms of Use and Cookies Policy.

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