Privacy Policy

Last updated: August 26, 2026

1. Introduction

This Privacy Policy explains how TwoPaws Games Limited, a company incorporated in the Hong Kong Special Administrative Region ("TwoPaws Games", "we", "us", or "our") collects, uses, shares, and protects information in connection with our games and related services, including Stardoku (collectively, the "Services"). By using the Services, you agree to the practices described in this Policy. If you do not agree, please do not use the Services.

2. Information We Collect

We collect the following categories of information:

We do not require you to create an account or provide your real name, phone number, or email address to play. The nickname and email fields on the web version are optional; declining them does not limit any part of the game.

Sensitive personal data. The Services are not designed to collect, and we do not knowingly collect, sensitive personal data — including data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, health or sex life, sexual orientation, biometric or genetic data, precise geolocation, or government-issued identification numbers. Please do not send us such information in feedback or support messages. If you do, we will delete it once the request is resolved.

3. How We Use Information

We use the information we collect to:

4. Legal Bases for Processing (EEA/UK Users)

If you are in the European Economic Area or the United Kingdom, we process your personal data on the following legal bases: performance of a contract (to provide the Services), our legitimate interests (to improve and secure the Services), your consent (for example, for the optional nickname and email you submit on the web version, and for device notifications), and compliance with legal obligations.

Where we rely on your consent, you may withdraw it at any time by the route described for that processing — see Section 7 for advertising, Section 8 for notifications, and Section 13 for the optional contact details. Withdrawing consent does not affect the lawfulness of processing carried out before you withdrew it, and does not affect processing that rests on another legal basis.

5. Sharing of Information

We may share information with:

"Selling" and "sharing". We do not sell your personal information for money, and we never have. However, like most companies that fund a free game with advertising, we do allow the advertising partners listed in Section 6 to collect the advertising identifier and related device information from your device in order to select and measure ads. Under California law (the CCPA/CPRA) and some other US state privacy laws, that arrangement may count as "sharing" for cross-context behavioural advertising, and in some readings as a "sale", even though no money changes hands for your data. We would rather say so plainly than rely on the narrow everyday meaning of the word. You can opt out — see Section 7 for the in-device controls and Section 15 for how to send us a request.

6. Third-Party Services and Advertising Partners

The Services integrate third-party SDKs that have their own privacy policies.

Service providers. These process data on our behalf under a data processing agreement requiring appropriate confidentiality and security commitments:

Advertising partners. These partners usually collect information through their own SDKs and act as independent controllers for that processing, which means their own privacy policies — not this one — govern it, and you may exercise your rights directly with them. Our current advertising partners are:

This list reflects the partners we work with today. We update it whenever we add or remove a partner, so please check this page for the current version. We encourage you to review these policies.

7. Your Advertising Choices

On Android, you can reset your advertising ID or delete it entirely in Settings › Privacy › Ads. Deleting it stops our advertising partners from using it to build a profile of your interests. Ads will still appear in the Services, but they will be less relevant and measured without that identifier.

See Section 15 for the other rights available to you, including how California residents can ask us to stop the "sharing" described in Section 5.

8. Notifications

The Services can send you notifications on your device — for example, a reminder that your lives have refilled or that a daily puzzle is waiting. These are scheduled by the game on your own device; we do not need to send them from a server, and preparing them does not send your gameplay information anywhere.

Notifications are shown only if you allow them when your device asks. You can turn them off at any time in your device settings — Settings › Apps › [game name] › Notifications on Android — and turning them off does not affect anything else in the game.

9. Your Anonymous Account

The first time you open the game we create an anonymous account for you automatically. It has no name, email, or password, and it is not linked to any social or app-store account; it is only a random identifier that lets the game keep your progress and rewards consistent.

Your game progress is stored on your device. Because the account is anonymous and we do not hold a copy of your progress on our servers, uninstalling the game or switching to a new device will end that account and lose the progress attached to it, and we have no way to recover or transfer it. Please see Section 8 of our Terms of Service before you uninstall or change devices.

10. International Data Transfers

Your information may be stored and processed in countries other than your own, where data-protection laws may differ. Where we transfer personal data out of the EEA, the UK, or Switzerland to a country without an adequacy decision, we rely on appropriate safeguards — principally the Standard Contractual Clauses adopted by the European Commission and, for UK transfers, the UK International Data Transfer Addendum — together with any additional measures required in the circumstances. You may request a copy of the relevant safeguards using the contact details below.

11. Data Retention

We retain information for as long as necessary to provide the Services and for the purposes described in this Policy, unless a longer retention period is required by law, or is necessary to resolve disputes and enforce our agreements. You can stop further data collection by uninstalling the app.

When we no longer need your personal information, we delete or anonymize it. Where deletion is not immediately possible — for example because the information sits in a backup archive — we isolate it from any further processing and apply appropriate security measures until deletion is possible. Once information has been anonymized so that it can no longer be associated with you, it is no longer personal data and we may continue to use it, for example to tune puzzle difficulty.

12. Data Security

We use reasonable and appropriate administrative, technical, organizational, and physical measures to protect your information against unauthorized access, disclosure, alteration, and destruction. These include encryption of data in transit, access controls limiting internal access to those who need it, and periodic review of our security practices. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

13. Optional Contact Details: Retention and Withdrawal

If you submit a nickname and email address on our web version, we keep them only until we have sent the launch notice and gift, and in any case no longer than 24 months, after which they are deleted. We use them for that single purpose, do not sell them, and do not add you to unrelated marketing. You may withdraw at any time by emailing support@twopaws.games, and we will delete your entry. Clearing your browser storage removes the local copy held on your device.

14. Children's Privacy

The Services are not directed to children, and we do not knowingly collect personal information from them. The minimum age to use the Services is:

If we learn that we have collected personal information from a child below the applicable age, we will delete it promptly. If you believe a child has provided us with personal information, please contact us at support@twopaws.games.

15. Your Rights and Choices

Depending on where you live, you may have the right to access, correct, delete, port, or restrict the processing of your personal information, and to object to certain processing. You can also ask not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects; we do not make such decisions.

EEA/UK residents may exercise rights under the GDPR/UK GDPR and lodge a complaint with their local supervisory authority. California residents may exercise rights under the CCPA/CPRA, including the right to know, delete, correct, and opt out of the "sale" or "sharing" of personal information described in Section 5, and the right not to be discriminated against for exercising them.

How to exercise your rights. Email support@twopaws.games with the subject line "Privacy Request", telling us which right you wish to exercise and the advertising identifier or in-game player ID shown on the settings screen so that we can locate your data. California residents may use the same address to submit a Do Not Sell or Share My Personal Information request, and may also use the device controls in Section 7. We will respond within 30 days of receiving a verifiable request, and will tell you if we need to extend that period as permitted by applicable law. Exercising these rights is free of charge unless a request is manifestly unfounded or excessive. An authorized agent may submit a request on your behalf with proof of authorization.

16. Third-Party Links

The Services and this website may contain links to third-party websites, stores, and services that we do not own or control. This Policy does not apply to them, and we are not responsible for their content or their privacy and security practices. Following such a link means the third party's own terms and privacy policy govern, and we encourage you to read them before providing any information.

17. Changes to This Policy

We may update this Privacy Policy from time to time. We will post the updated version on this page and revise the "Last updated" date above. Where changes are material, we will provide additional notice — for example, an in-game notice or an email, if you have given us your address — before they take effect. Your continued use of the Services after changes take effect constitutes acceptance of the updated Policy.

18. Contact Us

If you have any questions about this Privacy Policy or our data practices, contact us:

TwoPaws Games Limited
Room 02, 9/F, Bo Wai Building, 54-62 Lockhart Road, Wan Chai, Hong Kong
香港灣仔駱克道 54-62 號博匯大廈 9 樓 02 室
Email: support@twopaws.games
Website: https://www.twopaws.games/