Effective Date: July 23, 2025
Moonfrog Labs Private Limited ("Moonfrog Labs") respects your right to control your privacy. We have put in place security measures for your personal data and manage your personal data in accordance with applicable data protection and data privacy regulations. This Privacy Policy explains how we handle and treat your data when you (i) register an account or visit our site, www.moonfroglabs.com, www.teenpattigold.com, www.ludoclub.com (the "Websites") (ii) use our services (iii) engage or communicate with us. It also provides information about your rights relating to your Personal Data.
Throughout this Privacy Policy the following terms have the following meanings:
"Data Privacy Laws" means applicable data protection and data privacy laws and regulations, including but not limited to the EU General Data Protection Regulation (2016/679) (the "GDPR") and the Information Technology Act, 2000 read with Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.
"Processing" and "Process" means all activities involving your Personal Data, including collecting, handling, storing, sharing, accessing, using, transferring and disposing of information.
"Services" means our applications, games and other products, Websites, Forums, Web shop, email communications, social media accounts and any related services or properties we control.
"Personal Data" means Personal Data that relates to you as an identified or identifiable individual. All capitalised terms not specifically defined herein shall have the meaning ascribed to such terms in the GDPR.
While operating the Services, Personal Data will be shared with partners we work with. Some of these partners are Controllers independently of us and, therefore, independently determine how and why they process your data. For more information on these partners and the ways in which they may process your data, please refer to section 4 of this Privacy Policy. Under certain circumstances we may be required to transfer your Personal Data to countries outside the European Economic Area. Such transfers will be done in accordance with section 5 of this Privacy Policy.
Our Services are not directed to children and we do not knowingly collect Personal Data from children under 16 years of age.
The Controller responsible for your Personal Data for the purposes of the GDPR is:
Moonfrog Labs Private Limited
Unit No. 101, 1st Floor, Tower-D, RMZ Infinity
Municipal No. 3, Old Madras Road, Benniganahalli
Bangalore – 560016, Karnataka, India
Email: contact@moonfrog.com
www.moonfroglabs.com
hereinafter referred to as the "Company", "we", "us" or "our".
The principles set out in this Privacy Policy apply to all instances in which the Company Processes your personal data as a Controller for the purposes described in this Privacy Policy. The Company is part of the Stillfront Group, a global group of gaming studios with its parent company, Stillfront Group AB (publ), incorporated in Sweden and listed on Nasdaq First North Premier Growth Market.
The data protection officer of the Controller for the purposes of the GDPR is:
Name: Peter Birgersson, Deloitte AB
Email: dpo@stillfront.com
| Source | The information collected includes/may include the following data |
|---|---|
| Information you provide voluntarily when using our Services. |
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| Information you provide when using our games. |
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| Directly from you and/or your device by automatic means. |
The Company collects Personal Data directly from you and/or your device (such as your phone or computer) by automatic means when you use our Services or interact with our ads outside of our Services on third-party websites or applications, including through cookies or similar technologies or software development kits (SDKs).
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We do not expect or intend to collect or otherwise process any special categories of data relating to you. By special categories of data, we mean genetic, biometric or health information, information revealing racial or ethnic origin, sex life or sexual orientation, political opinions, religious or philosophical beliefs or trade union membership, or information about your criminal offences or convictions. Please do not provide this kind of information to us or use the Services to make it available to others.
We use/may use your Personal Data for different purposes. We will for example use the Personal Data to provide you with the Services you have requested, to improve and develop our Services, to predict user trends, to make recommendations and marketing activities based on your usage and to customize our Services to you, these include the following processing activities:
| Lawful basis | Purpose of the processing |
|---|---|
| To perform our contract with you in respect of our Services. |
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| Based on your given consent when using our services. |
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| Based on our legitimate interest to make our Services the best they can be and provide you with the best possible user experience in our Services. |
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| Based on our legitimate interest to make our services more intuitive and evaluate user behaviours and preferences. | Automatically generated data, that is not identifiable to you, specifically aggregated data regarding recency and frequency of player events such as "game closed" or "in-app purchases" is analysed to understand retention patterns and player behaviour. |
| Based on our legitimate interest to facilitate performance marketing. | Automatically generated data, that is not identifiable to you, specifically aggregated data regarding recency and frequency of player events such as "watched in-game advertising" or "in-app purchases" is used to understand and measure player lifetime value. Through this data, we can analyse expected future revenue from our players. |
| Based on our legitimate interest to provide you with interest-based services and advertisement. | We use ad identifiers, third-party tracking IDs (such as AppsFlyer ID) and similar technologies to collect data from your device. Information from third party providers is combined with features including device type, system language and IP address to create a unique player ID. This is done for the purpose of recognising you and your device and provide you with customized player experiences and interest-based advertising. |
| Based on our legitimate interest to safeguard our operations. | Audit our operations or processes (for example, to verify that they function as intended). |
| Based on our legitimate interest to establish, exercise and defend legal claims. | E.g. in the unlikely event of a dispute or a criminal investigation. Where required by law, your Personal Data will be disclosed to an applicable governmental, regulatory, sporting or enforcement authority. Your Personal Data will also be disclosed to any regulatory body in connection with prevention and detection of crime and where the Company considers that there are reasonable grounds to suspect that you may be involved in a breach of the law. |
In addition, we may process your data for additional purposes which are compatible with any of the purposes listed above.
Your Personal Data will (for the purposes described in this Privacy Policy) be transferred or disclosed to third parties, for the processing of that Personal Data on our behalf, such as to:
When Personal Data is shared with our business partners, group affiliates or other trusted entities stated above, we always require them to only use information in accordance with our instructions.
In connection with the processing activities described in this Privacy Policy, we share information outside of the European Union ("EU") and the European Economic Area ("EEA"). For example, a number of servers we use for hosting data are located in the United States, and some of our group companies, advertising partners or the service providers we use to provide the Services may be located outside of the EU and the EEA. Where the Company transfers Personal Data outside the EU/EEA, the Company will ensure that Standard Contractual Clauses have been entered into between the transferring entity and the receiving external party. Alternatively, other safeguards will be put in place prior to such transfers.
Data shared will consist of information you provide voluntarily when using our Services and data collected from your device by automatic means. You are under Data Privacy Laws upon request entitled to receive a copy of any documentation demonstrating that appropriate safeguards have been taken in order to protect your Personal Data during a transfer outside the EU/EEA. You can do so by reaching out to our Data Protection Officer at dpo@stillfront.com.
We will retain your information only for as long as is necessary for the purposes set out in this Privacy Policy. We are using the following criteria to establish our retention period: (i) as long as we have an ongoing relationship with you; (ii) as required by legal obligations to which the Company is subject (such as tax and accounting obligations); and (iii) as advisable in light of our legal position (such as applicable statutes of limitations). For more specific information about data retention terms, please contact our Data Protection Officer at dpo@stillfront.com and we will provide the specific data retention terms for your jurisdiction.
We will ensure that the access to your data is accurately secured by applying appropriate safeguards, depending on the circumstances taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk. In support of this commitment, we have implemented appropriate technical, physical and organizational measures to protect your Personal Data against unauthorised or accidental destruction, alteration or disclosure; misuse; damage; theft or accidental loss; or unauthorised access.
Providing data to us is not mandatory. However, we are unable to provide the Services, or some parts or features of the Services, without processing your data. If you use our Services, we will collect data relating to you for some or all the purposes described in this Privacy Policy, depending on the Services you decide to use and your choices when using them. You have a number of options to limit or control the extent to which your data is processed. For example, you can choose to not connect your third-party accounts with our Services, use your device settings to reset or limit the use of your Advertising ID, or disable some or all cookies from your browser settings.
You may have the right to request deletion of your Personal Data unless an exception applies. Upon receiving such a request, we will take reasonable steps to delete your data from our systems within 30 (thirty) days from the date of the request, unless retention is required by law or for legitimate business purposes (such as fraud prevention, regulatory obligations, or dispute resolution). Subject to the above, upon any withdrawal, revocation, cancellation, opt-out, objection, refusal, or termination of consent to the processing of personal data, Moonfrog shall cease the collection of your data. Additionally, any previously collected and stored user data shall be deleted in accordance with applicable data protection laws.
In relation to our processing of your Personal Data you have, under certain circumstances, the right to exercise the following rights:
You may request confirmation whether or not Personal Data is processed and, if that is the case, access to your Personal Data and additional information such as the purposes of the processing. You are also entitled to receive a copy of the Personal Data undergoing processing. If the request is made by electronic means the information will be provided in a commonly used electronic format if you do not request otherwise.
We will provide you with the copy of your data within 30 days of receiving your request. If we are processing many requests at the same time, or if your request is especially complex, we may extend this period by another 30 days.
You may object to the processing of your Personal Data on the basis of a legitimate interest, on grounds relating to your particular situation and to the processing for direct marketing purposes.
To unsubscribe from our marketing communications, please use the unsubscribe link provided in the messages we send. The unsubscribe link is typically found at the end of the message.
You have at any time the right to have inaccurate Personal Data rectified, as well as, taking into account the purposes of the processing, the right to have incomplete Personal Data completed.
You may have your Personal Data erased under certain circumstances such as when your Personal Data is no longer needed for the purposes for which it was collected.
You may ask us to restrict the processing of your Personal Data to only comprise storage of your Personal Data under certain circumstances, such as when the processing is unlawful, but you do not wish your Personal Data erased.
You have the right to at any time withdraw your consent to processing of Personal Data to the extent the processing is based on your consent. This does not affect the lawfulness of processing based on consent before its withdrawal.
You may ask to receive a machine-readable copy of Personal Data processed and ask for the information to be transferred to another Controller (where possible). This only refers to such Personal Data processed on the basis of your consent or on the basis that the processing is necessary in order to perform an agreement with you and only to the extent the Personal Data has been provided to the Company by you.
You have the right to lodge complaints pertaining to the processing of your Personal Data to the relevant data protection supervisory authority.
To access your data in our Services or to request its deletion, please use the automatic tools provided in our Services. These tools are specific to each of our Services. You can choose to prevent your device's ad identifier by changing the settings of your device.
We ask you to primarily use these tools to submit requests, because that helps us validate, process, and fulfil your request more quickly and reliably.
If you have any questions about this Privacy Policy or our data collection practices, please contact us at the address or email set out under section 1 of this Privacy Policy and specify your country of residence and the nature of your question.
If you are based in the United States and connecting from states in which data protection laws have been enacted this section forms part of the Privacy Policy and should be read together with the other sections of the Privacy Policy. If there is any conflict between this section and the remainder of the Privacy Policy, this section shall prevail. Moonfrog Labs does not sell personal data and has not done so in the last 12 months. We may share identifiers and cookie information with our third-party advertisement platforms to provide you with interest based and personalized advertisements, attribute installs and optimize our marketing; to the extent such practices are considered a "sale" under Applicable Data Protection Law you may opt out by following the steps below. For more information on our personal data collection please see the sections in this Privacy Policy concerning our data processing.
How to opt out is dependent on the service you use; for more information see section 8 of this Privacy Policy.
You may have the right to request details about the Personal Data we have collected about you. You may also have the right to receive a copy of your Personal Data.
You may have the right to request we correct incorrect or inaccurate Personal Data, subject to restrictions regarding the determination of accuracy of the existing Personal Data.
You may have the right to request deletion of your Personal Data unless an exception applies. Upon receiving such a request, we will take reasonable steps to delete your data from our systems within 30 (thirty) days from the date of the request, unless retention is required by law or for legitimate business purposes (such as fraud prevention, regulatory obligations, or dispute resolution).
We will not change the quality of our services, deny you access or provide a different level of quality if you choose to exercise these rights, unless allowed or required under applicable law. Some rights might impact the usage and availability of certain services, such as personalization and deletion.
If we deny or reject your privacy rights request, you may have a right to appeal our decision if permitted by your state's privacy law.
Depending on your state of residence you may have the right to ask us to limit the use of your sensitive personal information if we use it to infer characteristics about you. To exercise this right please use the provided opt out tools or contact us under the method described in section 8. Your right to limitation is subject to exception and depending on the state we will obtain your consent before collection of sensitive personal information.
Under California's "Shine the Light" law, California residents who provide personal information (as defined by applicable California law) in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the prior calendar year. To obtain this information please send an email message to contact@moonfroglabs.com with "Request for California Privacy Information" on the subject line and in the body of your message. We may require you to verify your identity, and the information is limited to that covered by the California Shine the Light law under this request.
We may update this Privacy Policy from time to time, for example due to changes in our operations or the legal obligations that apply to us. Updates will be made available here. We will also inform you of any changes by other means that are appropriate to the significance of the changes.