1. WHO WE ARE AND CONTACT
The data controller is Paul Hickmott, a sole trader trading as Make Phantom in the United Kingdom. You can contact us through the Contact page or at info@makephantom.com. Our contact form collects your name, email address, subject and message so we can answer your enquiry and maintain support records. Enquiries are delivered by email and may be backed up securely. We normally retain contact enquiries for up to 12 months, or longer where reasonably needed to resolve an ongoing matter or meet a legal obligation, after which they are deleted or anonymised.
2. GAME DATA AND LEADERBOARDS
Our games may store profile settings, avatars, progress, completion times, achievements, earned rewards and preferences locally on your device until you reset progress, clear app storage or remove the relevant game. Platform backups are controlled by your device and store settings. Where a game offers an online leaderboard, we will process a display name chosen by you and the gameplay records needed to rank your entry. That display name and ranking will be visible to other players; you do not need to use your real name. You may ask us to correct or delete leaderboard data through the Contact page.
3. ADVERTISING & ADMOB
Our games may show regular and optional rewarded adverts supplied by Google AdMob where offered. In Tilo, regular adverts may appear after every four completed non-tutorial levels. Optional rewarded adverts can provide a Hint, Undo or Scramble, with a shared limit of two successfully earned rewards per UTC day. Buying Ad-Free removes regular adverts in Tilo; optional rewarded adverts remain available only when you choose them. Google and its advertising partners may process device identifiers, IP address, advertising identifiers, advert interactions, diagnostics and consent choices to deliver, measure and protect advertising. Where required, we show a consent message that lets you make or change available privacy choices. Tilo is configured to request non-personalised advertising, disable publisher first-party IDs and apply Google's protective under-age-of-consent treatment to all players without collecting their ages. Tilo does not request access to Apple's advertising identifier. Non-personalised advertising can still involve technical data processing for delivery, security and measurement; it does not mean no data is collected. Other games' advertising behaviour, where offered, depends on their configuration, available consent choices and applicable law. We do not sell personal data. You can reopen available choices in Tilo under Settings > Privacy > Advertising privacy choices. Advertising consent is separate from accepting the game terms. Refusing optional consent does not prevent ordinary gameplay, although advert availability may change. For information about Google's use of data, see How Google uses information from sites or apps that use its services.
4. IN-APP PURCHASES
Apple App Store and Google Play process in-app purchases and payment details under their own terms and privacy policies. We do not receive or store your payment-card or bank details. To verify purchases, prevent duplicate grants, restore eligible entitlements, respond to refunds and disputes, and protect against fraud, we may process a pseudonymous player identifier, an installation identifier, an app-account token, platform and store environment, product and transaction identifiers, original transaction identifier, purchase date, quantity, customer-price and currency metadata, storefront, entitlement state, and refund or revocation status. Signed store evidence is independently verified; our normal transaction record retains a cryptographic hash rather than the raw signed payload. Apple or Google remains responsible for charging the store account and for store refunds.
5. PRIVACY RIGHTS
Depending on where you live, you may have rights to access, correct, delete, restrict or object to processing, withdraw consent and receive a copy of personal data. You may exercise these rights through our Contact page or at info@makephantom.com. We may need to verify your request. You may also complain to the UK Information Commissioner's Office or your local data-protection authority. Withdrawing consent does not affect processing already carried out lawfully.
6. WHY WE USE INFORMATION
We process information where needed to provide a requested game, purchase or support service and perform our contract with you; to comply with legal, accounting and tax obligations; and for legitimate interests including securing our games, preventing duplicate or fraudulent grants, maintaining reliable transaction and entitlement records, resolving disputes, and improving service reliability. Where consent is required for advertising or optional cookies, we rely on that consent and you may withdraw it through the available privacy controls. We do not make decisions that have legal or similarly significant effects using automated profiling.
7. SHARING AND INTERNATIONAL TRANSFERS
We share information only as needed with providers that operate our website, email, hosting and database services, app-store purchases, advertising and any game feature expressly described to you, including Wix, our infrastructure providers, Apple, Google Play and Google AdMob. These providers process information under their own terms or on our behalf. Some providers may process information outside the United Kingdom. Where required, transfers use an applicable adequacy decision or approved contractual safeguards. We do not sell personal information.
8. WEBSITE COOKIES, LOGS AND SECURITY
Wix may use cookies and similar technologies that are necessary to operate this website. Optional analytics or advertising cookies are used only where permitted and, when required, after consent. Our game services and hosting providers may also process limited technical logs such as request time, IP address, response status and security events to operate, diagnose and protect the service. Administrative access to commerce information is restricted and audited. Downloaded transaction exports expire automatically. We use reasonable organisational and technical safeguards, but no online service or storage method can be guaranteed completely secure.
9. AGE AND RETENTION
Our games and services are intended for people aged 13 or older, and we do not knowingly collect personal information from children under 13. If you believe a child has provided personal information, contact us so we can investigate and delete it where appropriate. Contact enquiries are normally retained for up to 12 months after the matter is closed. Local game data remains until you reset it, clear app storage or remove the game. Commerce transaction, entitlement, refund and associated audit records are normally retained for up to six years after the end of the relevant tax year so that we can meet legal, accounting, fraud-prevention and dispute-handling obligations. Short-lived CSV exports expire after approximately 15 minutes. At the end of a retention period, information is deleted or anonymised unless a legal claim, investigation or other obligation requires it for longer.
10. CHANGES AND CONTACT
We may update this Privacy Policy when our games, website, service providers or legal obligations change. The latest version will be posted on this page. Questions or privacy requests can be sent through the Contact page or to info@makephantom.comLast updated: 12 October 2026.
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