Privacy Notice

PRIVACY NOTICE

Updated May 29, 2026

This Privacy Notice explains how Frogwares Ireland Limited (hereinafter referred to as “Frogwares”, “we”, “us”, “our”) collects, processes, uses, shares, and discloses data, including  personal data, related to individuals (hereinafter referred to as “you”, “individual”, “natural person”),  when you browse our websites, including but not limited to https://frogwares.com/ (“Websites”), use our services (“Services”), and products, including games (“Products”), or otherwise interact with Frogwares, and how you can exercise your rights provided by the applicable data protection laws, in particular the General Data Protection Regulation (GDPR), Irish Data Protection Act 2018 and other applicable data protection laws (“Data Protection Laws”). 

Frogwares always respects your privacy and your rights related to your privacy. Therefore, we hereby declare that Frogwares is committed to protecting your privacy and handling your data, including personal data, openly and transparently in accordance with the applicable Data Protection Laws, implementing relevant security measures to ensure the highest level of privacy protection. 

BY ACCESSING OR USING OUR WEBSITES, PRODUCTS, INCLUDING GAMES, OR SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THIS PRIVACY NOTICE. IF YOU DO NOT AGREE WITH THIS PRIVACY NOTICE, PLEASE DO NOT ACCESS OR USE OUR WEBSITES, PRODUCTS, INCLUDING GAMES, OR SERVICES.

1. WHAT DATA WE COLLECT AND HOW WE USE IT

1.1. Personal data that we collect from you directly

We collect personal data directly from you when you voluntarily provide it to us while using or interacting with our Websites, Products, or Services, including when contacting customer or technical support, subscribing to newsletters or marketing communications, participating in surveys, playtests, promotional activities, or community initiatives, submitting forms on our Websites, communicating with us, supporting our crowdfunding campaigns, applying for employment or cooperation opportunities with Frogwares, using certain features of our Products or Services, or otherwise engaging with Frogwares.

Such personal data may include your name, surname, email address, telephone number, postal address, and other contact information.

In connection with customer support, troubleshooting, technical assistance, or service improvement purposes, we may also receive certain non-personal or non-identifiable technical and diagnostic information, such as DXDiag files or similar system reports containing information about your device hardware, operating system, graphics card, technical settings, gameplay environment, Product performance, or error logs.

As part of recruitment or hiring processes, you may provide us with personal data, including your name, surname, email address, telephone number, postal address, date of birth, educational background, employment history, professional qualifications, certifications, references, CV or résumé, portfolio materials, social media or professional profile links, and other information relevant to recruitment. We may also create internal interview notes or candidate assessments for purposes related to evaluating your suitability for a role.

1.2. Information we collect automatically

When you access or use our Websites, Products, or Services, we may automatically collect certain technical, analytical, usage, and device-related information through cookies, analytics tools, log files, and similar technologies.

Such information may include your IP address, approximate geographic location, browser type, device type, operating system, language settings, referring websites or traffic sources, pages viewed, duration of visits, interactions with website elements, gameplay-related interactions, crash reports, technical performance data, and similar usage or diagnostic information.

We may also receive aggregated or inferred demographic information, such as estimated age ranges, interests, preferences, or gender-related analytics, from third-party analytics or advertising providers, including Google Analytics or similar services. Such information is generally provided to us in aggregated, anonymized, statistical, or non-identifiable form and is used for analytical, marketing, audience measurement, service improvement, and advertising optimization purposes.

Cookies and Similar Technologies

We use cookies and similar technologies to help operate, improve, analyze, personalize, and secure our Websites, Products, and Services.

Cookies are small text files placed on your device when you visit a website. We may also collect certain information automatically through cookies, analytics tools, log files, and similar technologies when you visit or interact with our Websites, Products, or Services. Such technologies help us understand how users interact with our Websites and Services, remember certain preferences or settings, improve functionality and user experience, analyze audience engagement, measure website traffic and marketing effectiveness, maintain security, and support business and operational activities.

In particular, we may use third-party analytics and advertising technologies, including Google Analytics or similar services, which may collect information regarding user interactions with our Websites, advertisements, content, videos, or other online features. In many cases, such information is provided to us in aggregated, anonymized, statistical, or otherwise non-identifiable form, and we are generally unable to identify individual users from such information.

Some cookies and similar technologies may be placed or operated by third-party service providers or partners in accordance with their own privacy policies and terms. You may control, restrict, or disable cookies through your browser or device settings. However, disabling certain cookies or similar technologies may affect the availability, functionality, or performance of some parts of our Websites, Products, or Services.

By continuing to use our Websites, Products, or Services, you acknowledge our use of cookies and similar technologies as described in this Privacy Notice.

1.3. Personal data obtained from third parties

We may also obtain personal data from third parties, publicly available sources, business partners, service providers, distribution platforms, or other websites and services where you choose to share your information.

For example, we may receive personal data when you submit applications or communicate with us through third-party recruitment or professional networking platforms, including LinkedIn, Djinni, DOU, rabota.ua, work.ua, Upwork, Jobble, grc.ua, Fiverr, or similar services, or when you make information publicly available for recruitment or professional purposes on such platforms.

We may also receive certain personal data from crowdfunding platforms, including Kickstarter or similar services, when you support Frogwares projects as a backer. Such information may include your name, nickname, username, email address, pledge amount, selected reward tier, shipping-related information, and other information made available to project creators in accordance with the applicable platform policies and settings. We process such information for purposes including campaign administration, reward fulfillment, communication with backers, customer support, compliance with applicable legal obligations, and, where applicable, acknowledging backers within the Product credits, promotional materials, or related community content using the name, nickname, username, or other identifier selected or made available by the backer through the relevant crowdfunding platform or directly to Frogwares.

We generally do not receive payment card information or financial payment credentials from third-party services. Payment processing is typically performed independently by the relevant platform operator, retailer, or payment service provider in accordance with their own privacy policies and terms.

The collection, processing, use, and transfer of personal data by third parties are governed by the respective privacy policies and terms of such third parties, and we encourage you to review those policies carefully.

Information Related to the Use of Products

In connection with the distribution, activation, purchase, downloading, licensing, or use of Products, including, but not limited to, within The Sinking City™ and Sherlock Holmes™ series through third-party services, including digital storefronts, gaming platforms, console ecosystems, retail activation services, analytics providers, or cloud-related services, we may also receive certain non-personal data, including anonymized, aggregated, statistical, technical, gameplay-related, non-identifiable information, or telemetry data from such third parties. Depending on the relevant platform, service, and your privacy settings, such information may include:

• The platform via which the game is played
• Where required, a randomly generated device ID (which we are not able to trace back to any individual);
• Game settings linked to the device ID;
• In-game statistics and metrics linked to the device ID;

1.4. Non-personal data

Notwithstanding anything else specified in this Privacy Notice, in connection with customer support, technical assistance, troubleshooting, Product maintenance, analytics, and service improvement purposes, we may collect, receive, generate, or process certain non-personal, anonymized, aggregated, statistical, technical, diagnostic, gameplay-related, or otherwise non-identifiable information.

Such information may include the content of support requests, randomly generated device identifiers that cannot reasonably be linked to a particular individual, platform information, product version numbers, driver dates and versions, operating system details, hardware and system information (including processor type, memory capacity, and graphics card information), game settings linked to device identifiers, gameplay statistics and metrics, country or regional information, telemetry data, crash reports, error logs, performance data, gameplay progression metrics, and other technical or analytical information generated through your interaction with the Products or Services.

We use such information for purposes including providing customer and technical support, troubleshooting, maintaining and improving the Products and Services, fixing bugs, analyzing gameplay balance and technical performance, improving stability and compatibility, conducting analytics, protecting security and integrity, and supporting business and operational decisions.

To the extent reasonably possible, non-personal data is processed in anonymized, aggregated, statistical, or otherwise non-identifiable form and is not intended to identify you personally. To the extent such information does not constitute personal data under applicable Data Protection Laws, including the GDPR, Frogwares does not act as a data controller within the meaning of the GDPR with respect to such information.

2. LEGAL BASIS FOR COLLECTING DATA 

Where required under applicable Data Protection Laws, including the GDPR, Frogwares processes personal data on one or more of the following legal bases:

• where processing is necessary to comply with a legal obligation applicable to Frogwares; 
• where you have provided your consent; 
• where processing is necessary for the performance of a contract, provision of Services, fulfillment of your requests, or taking steps at your request prior to entering into a contract, including providing customer or technical support; 
• where processing is necessary for the purposes of the legitimate interests pursued by Frogwares or third parties, provided that such interests are not overridden by your rights and freedoms under applicable Data Protection Laws. 

Our legitimate interests may include operating, maintaining, protecting, improving, developing, analyzing, promoting, and supporting our Websites, Products, and Services; conducting analytics; measuring audience engagement and marketing effectiveness; administering surveys, playtests, and community activities; communicating with users; preventing fraud, abuse, unauthorized activities, or security incidents; and supporting our business and operational activities.

When we receive personal data from third parties, we expect such third parties to provide assurances that the personal data has been lawfully collected and transferred to us in accordance with applicable Data Protection Laws. Please note that third parties, including social media platforms, gaming platforms, crowdfunding services, recruitment websites, analytics providers, advertising partners, payment service providers, or other third-party services, may process personal data independently from Frogwares in accordance with their own privacy policies and terms.

To the extent Frogwares processes non-personal, anonymized, aggregated, statistical, technical, diagnostic, gameplay-related, or otherwise non-identifiable information that does not constitute personal data under applicable Data Protection Laws, including the GDPR, the legal bases for processing personal data under the GDPR do not apply to such information. Any processing of such non-personal information is performed in accordance with applicable laws and legitimate business and operational purposes.

3. HOW WE SHARE PERSONAL DATA

We may share personal data with third-party service providers, contractors, business partners, platform operators, vendors, analytics providers, advertising partners, recruitment platforms, crowdfunding platforms, payment service providers, and other entities that help us operate, manage, improve, support, secure, market, distribute, or provide our Websites, Products, Services, business operations, or community activities.

Such third parties may assist us with website hosting, technical infrastructure, customer and technical support, mailing list management, analytics, advertising, audience measurement, marketing campaigns, crowdfunding campaign administration, reward fulfillment, shipment organization, payment processing, recruitment activities, social media communications, content delivery, security, operational support, and similar services.

We may use third-party analytics, advertising, and marketing technologies, including Google Analytics, Google Ads, Meta/Facebook Pixel, X (Twitter) analytics and advertising tools, Mailchimp, Mailmunch, and similar technologies or services, to better understand audience engagement, improve user experience, measure the effectiveness of marketing campaigns, personalize content, communicate with users, and support business and operational activities.

Please check the privacy policies and notices of some third parties that help us to run our business:

https://mailchimp.com/legal/privacy/

https://legal.mailmunch.com/privacy/

https://policies.google.com/privacy?hl=en-US

https://www.facebook.com/policy.php

https://twitter.com/en/privacy 

https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads 

When you interact with our Websites, Products, Services, advertisements, newsletters, crowdfunding campaigns, social media pages, or other online content, certain information may be collected, processed, shared, or otherwise made available to relevant third-party providers in accordance with their applicable privacy policies, terms, settings, and practices.

Where required, Frogwares implements appropriate contractual, organizational, technical, and security measures designed to protect personal data shared with third parties in accordance with applicable Data Protection Laws.

Our Websites, Products, Services, newsletters, social media pages, crowdfunding campaigns, advertisements, or other communications may also contain links to third-party websites, platforms, storefronts, applications, or services operated by entities other than Frogwares. Frogwares does not own or control such third-party services and does not make any representations or warranties regarding their content, availability, security, or privacy practices. Such third parties may independently collect, use, process, transfer, or store personal data under their own privacy policies and terms, which may differ from those of Frogwares. We encourage you to review the applicable privacy notices and terms of any third-party services you access or use.

Frogwares does not sell personal data to third parties for monetary compensation. However, certain third-party analytics, advertising, marketing, or platform providers may process information collected through cookies or similar technologies in accordance with their own privacy policies and applicable laws

4. DATA RETENTION PERIOD

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected and processed, including providing our Websites, Products, and Services, managing customer support, administering crowdfunding campaigns, recruitment activities, business operations, and complying with applicable legal obligations.

In certain cases, personal data may be retained for the duration of a particular Frogwares project, crowdfunding campaign, or related business relationship, as well as for additional periods where necessary to comply with legal, regulatory, tax, accounting, reporting, security, or contractual obligations, resolve disputes, enforce agreements, protect our rights and legitimate interests, prevent fraud or abuse, maintain business records, or otherwise operate our business in accordance with applicable laws.

When personal data is no longer required for the purposes for which it was collected, we will delete, anonymize, aggregate, or otherwise securely dispose of such information in accordance with applicable laws and internal retention practices.

5. YOUR RIGHTS

Depending on your country, state, or place of residence and the applicable Data Protection Laws, including the GDPR and the California Consumer Privacy Act of 2018, as amended (“CCPA”), you may have certain rights regarding the processing of your personal data by Frogwares.

Subject to applicable laws and certain legal limitations or exceptions, such rights may include:

• the right to be informed about the collection and use of your personal data; 
• the right to access and obtain a copy of the personal data processed about you; 
• the right to request correction, update, or rectification of inaccurate or incomplete personal data; 
• the right to request deletion or erasure of your personal data under certain circumstances; 
• the right to object to or restrict certain types of processing of your personal data; 
• the right to withdraw consent at any time where processing is based on consent; 
• the right to data portability, including the right to receive certain personal data in a structured, commonly used, and machine-readable format and transmit it to another controller where technically feasible; 
• the right not to be subject solely to automated decision-making, including profiling, that produces legal or similarly significant effects on you, where such rights are provided under applicable laws; 
• the right to opt out of certain data-sharing or advertising activities where required under applicable laws; 
• the right not to receive discriminatory treatment for exercising your privacy rights. 

Where Frogwares processes non-personal, anonymized, aggregated, statistical, technical, diagnostic, gameplay-related, or otherwise non-identifiable information that does not constitute personal data under applicable Data Protection Laws, privacy rights provided under such laws may not apply to that information.

If you wish to exercise your privacy rights, submit a request, withdraw consent, or make a privacy-related complaint, you may contact Frogwares at: marketing@frogwares.com.

Before responding to certain requests, Frogwares may require verification of your identity and may request additional information where reasonably necessary to authenticate your request, protect personal data, comply with legal obligations, or prevent unauthorized access or fraudulent requests.

You also have the right to lodge a complaint with the competent supervisory authority, data protection authority, or other regulatory authority in your jurisdiction if you believe that the processing of your personal data violates applicable Data Protection Laws.

6. INTERNATIONAL DATA TRANSFERS

When you access or use our Websites, Products, or Services, your personal data may be transferred to, accessed from, stored, processed, or used in countries outside of your country or region of residence, including by Frogwares, its affiliates, service providers, contractors, business partners, platform providers, or other third parties described in this Privacy Notice.

The data protection and privacy laws applicable in such countries may differ from those in your jurisdiction and may not provide the same level of protection as the laws of your country or region of residence.

Where required under applicable Data Protection Laws, including the GDPR, Frogwares implements appropriate safeguards and measures designed to ensure that international transfers of personal data are performed lawfully and that your personal data remains adequately protected. Such safeguards may include contractual protections, data processing agreements, standard contractual clauses approved by competent authorities, adequacy decisions, technical and organizational security measures, or other transfer mechanisms recognized under applicable laws.

By using our Websites, Products, or Services, you acknowledge that your personal data may be transferred and processed internationally in accordance with this Privacy Notice and applicable Data Protection Laws.

7. DATA SECURITY

Frogwares is committed to protecting the security, confidentiality, and integrity of personal data. We implement appropriate technical, organizational, administrative, and security measures designed to protect personal data against unauthorized or unlawful access, disclosure, alteration, loss, misuse, destruction, or other unauthorized processing.

Such measures may include access controls, internal policies and procedures, contractual safeguards, network and system security protections, restricted access to personal data, encryption or pseudonymization where appropriate, and other industry-standard security practices reasonably designed to protect personal data processed by Frogwares.

Frogwares does not intentionally use solely automated decision-making, including profiling, that produces legal effects or similarly significant effects on individuals within the meaning of applicable Data Protection Laws, including the GDPR.

8. CHILDREN’S PRIVACY

Frogwares recognizes the importance of protecting children’s privacy and encourages parents and legal guardians to educate children regarding the safe and responsible use of the Internet and online services, including the importance of not sharing personal data without appropriate permission and supervision.

Our Websites, Products, and Services are not directed to children below the minimum age required under applicable laws in their country or region of residence. For purposes of this Privacy Notice, Frogwares generally considers children to be individuals under the age of 16 unless a higher minimum age is required under applicable laws.

We do not knowingly collect or solicit personal data from children below the applicable minimum legal age without appropriate parental or legal guardian consent where such consent is required under applicable laws. If a child provides personal data to Frogwares without the necessary consent, such information should not be submitted and may be subject to deletion.

If Frogwares becomes aware that personal data has been collected from a child in violation of applicable Data Protection Laws or without required parental or legal guardian authorization, Frogwares will take reasonable steps to delete or otherwise appropriately handle such information in accordance with applicable laws.

If you believe that a child has provided personal data to Frogwares in violation of this Privacy Notice or applicable laws, please contact us at: marketing@frogwares.com

9. PRIVACY NOTICE UPDATE 

Frogwares reserves the right to modify, amend, update, or revise this Privacy Notice from time to time at its discretion, including to reflect changes in applicable laws, regulatory requirements, industry practices, technologies, business operations, Products, Services, or feedback from users and customers. When this Privacy Notice is updated, Frogwares may revise the “Last Updated” date and publish the updated version through the relevant Websites, Products, Services, or other appropriate communication channels.

We encourage you to review this Privacy Notice periodically to remain informed about our privacy practices and any updates or changes. Your continued access to or use of our Websites, Products, or Services following the publication or effectiveness of an updated Privacy Notice constitutes your acknowledgment of such updates to the extent permitted under applicable laws.

10. HOW TO CONTACT US

If you have any questions, comments, requests, or concerns regarding this Privacy Notice, the processing of your personal data, or your privacy rights, or if you believe that your personal data has been processed in violation of applicable Data Protection Laws, you may contact Frogwares at: marketing@frogwares.com 

Frogwares will make reasonable efforts to review and respond to your request in accordance with applicable laws and within the timeframes required under applicable Data Protection Laws.