Last Updated Date: September 1st, 2026
PLEASE READ THIS PRIVACY POLICY CAREFULLY. IT DESCRIBES DETAILS ABOUT HOW WE COLLECT, USE AND DISCLOSE PERSONAL INFORMATION YOU SHARED WITH US. IF YOU ARE UNDER THE MINIMUM AGE TO GIVE CONSENT ACCORDING TO APPLICABLE DATA PROTECTION LAWS, DO NOT PROVIDE ANY PERSONAL INFORMATION WITHOUT YOUR PARENT’S OR GUARDIAN’S PERMISSION.
Table of Contents1. Introduction
2. Notice Regarding Current Game Status
3. What Is Personal Information?
4. Personal Information We Collect
5. How We Use Your Personal Information
6. How We Share Your Personal Information
11. Contact Us
13. Special Section for Certain Jurisdictions
- European Economic Area and United Kingdom
- Canada
1.1 Who We Are
Thank you for reading our Privacy Policy. We are a group of global developers and publishers of mobile game applications (“Games”). For the game Frozen Vault: Survival, the data controller is Mangorilla Limited (“Mangorilla” or “Company”). This means that the Company is responsible for determining how and why your personal data is processed.
It is our policy to comply with applicable data protection laws.
1.2 Scope of This Policy
This Privacy Policy (“Policy”) applies to personal information collected through our Games, and other online services. This Policy also summarizes when and how your personal information is collected, used, safeguarded and disclosed in connection with your use of the Games. It also describes your rights and available choices regarding your personal information. The Games and the features, functions, software and services offered through the Games, related websites and other online services collectively constitute the “Service”.
2.1 Test Phase
The Game is currently being offered in connection with a test. During this testing phase, the Game is operational and may be downloaded and played, although access may be limited to a limited number of users and only a limited set of features is available, as described in this Section. During this phase, we collect the personal information described in this Policy that is necessary to operate and improve the test version of the Game. Please note that certain third-party service providers (such as advertising attribution partners, including AppsFlyer) may collect information in connection with your download, installation or use of the Game, as permitted under their respective terms and privacy policies.
2.2 Features Currently Unavailable
Please be advised that the following game features are not available during the small-scale test phase:
• Account registration or third party account log in (during the test, players use a guest account that is automatically assigned and cannot be linked to an email address or a third-party account);
• In-app purchases or any payment processing.
2.3 Impact on Personal Information Collection
Accordingly, no personal information is collected or processed in relation to these features at this time.
The term “personal information” or “personal data” means information that specifically identifies an individual (such as a name, address, telephone number, mobile number, email address, or other account number), and information about that individual’s location or activities, such as information about your use of the Service, IP addresses or mobile device identifiers, when directly linked to personally identifiable information. Personal information also includes demographic information such as date of birth, gender, geographic area and preferences when such information is linked to other personal information that identifies or may identify you.
Personal information does NOT include “anonymized” information, which is data we collect about the use of the Service or about a group or category of products, services or users, or other data from which individual identities or other personal information has been removed so that the individual concerned cannot be identified directly or indirectly. Such data helps us understand trends and our users’ needs so that we can better consider new features or otherwise tailor our Service. This Policy in no way restricts or limits our collection and use of such information.
4.1 Overview
We collect information that you voluntarily provide to us, information that we collect automatically through your use of the services, and certain information we obtain from third party sources.
You can access certain portions of our Service without providing us with certain personal information. However, you will not be able to utilize certain features that require registration or receive materials unless certain information is provided. The processing of this personal information is necessary for the performance of our Service. Where processing is not necessary for the performance of the Service, your consent to such processing will be requested where required under applicable law.
For users in certain jurisdictions, please refer to the Special Section for Certain Jurisdictions for further information about how we collect and process your personal information and your related rights.
4.2 Categories of Personal Information We Collect
Information You Voluntarily Provide |
Information We Automatically Collect |
Information We Obtain from Third Party Sources |
When you are using the game or services within the game:
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Advertising partners: From time to time, we may also receive personal information about you from other third-party sources. For example, if you click on an advertisement to direct you to one of our services or Games (such as an advert of one of our Games in another publisher’s game), we may receive the information from third parties that allows us to know which ad network and advertising campaign your installation was originated from. |
4.3 Special Categories of Information
We do not request or intend to collect any “special categories of information” or “special category data”, as defined in applicable data protection laws and regulations, such as any information on health, race, religion, political opinions or philosophical beliefs, sexual preferences or orientation. We also want to kindly remind you to be cautious when sharing this information about yourself (or others) in our forums.
4.4 Credit Card Information
Our Games currently do not enable in-app purchases and we do not collect information about your purchase or transaction records in the Service.
4.5 Cookies and Other Tracking Technologies
Currently, we do not use cookies and other similar technologies to collect information on our webiste..
4.6 Data Collected to Prevent Cheating and Unauthorized Software
When you run our Game software or receive our Service, this may involve software functions designed to detect cheating or unauthorized and malicious programs. In this context, we access, collect, monitor and/or remotely store screenshots of game play, information relating to hardware capacity, modifications related to our Game software, signatures, profiles or names of known or suspected unauthorized or malicious third party programs, files or processes that enable or facilitate cheating, unfair advantage or hacking of the Games or Service. If circumstances suggesting unauthorized or malicious programs are detected, the Game software also communicates to us the information about the unauthorized or malicious program or its use.
We see this processing as necessary for the legitimate interests in ensuring that fraudulent activity is not carried out in or using our Service. Where legitimate interest is not sufficient for such collection, your consent to such processing will be requested where required under applicable laws or in jurisdictions where consent is required, we will ensure that such consent is obtained prior to engaging in the aforementioned monitoring and data collection activities.
5.1 Purposes of Processing
We use your personal information to provide products and services you ask for, to communicate with you, to improve our services, and for other purposes including those set out in the chart below.
Personal Information |
Purpose |
Legal basis relied on according to GDPR (only users located in the European Economic Area (“EEA”) and United Kingdom (“UK”)) |
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To provide technical support, customer service and ensure the continued smooth operation of our Service |
Necessary for the performance of our customer service, in line with art. 6.1(b) of the GDPR |
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To improve our games and services and to make our application compatible with your device |
Our legitimate interests in performing and improving our Service, in line with art. 6.1(f) of the GDPR |
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To prevent or investigate actual or suspected fraud, hacking, infringement, or other misconduct in any of our products and services |
Our legitimate interests in detecting, preventing and addressing cheating, hacking, bots, modified clients and fraudulent gameplay behaviour, in line with art. 6.1(f) of the GDPR |
Progress in the game:
|
To keep the record of your account, to collect and anonymize usage data and to improve the functionality of our Games and Service (including anti-cheat measures) |
Necessary for the performance of our Service, in line with art. 6.1(b) of the GDPR |
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To ensure the security of your game account and foster a fair, healthy, and safe gaming environment and to know which ad network and advertising campaign your installation was originated from and to pay that advertiser |
Necessary for the performance of our Service in line with art. 6.1(b) of the GDPR |
The information collected via AppsFlyer: |
To know which ad network and advertising campaign your installation was originated from and to pay that advertiser |
Our legitimate interests in promoting our Service, in line with art. 6.1(f) of the GDPR |
The information collected via AppsFlyer: |
To measure the performance of our advertisements. |
Our legitimate interests in monitoring the success of our advertising and marketing programs, in line with art. 6.1(f) of the GDPR |
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To request feedback, perform research and analysis and to enable us to operate, develop, customize and improve the Service and our publications, products and services |
Our legitimate interests in performing research and improving our Service, in line with art. 6.1(f) of the GDPR |
5.2 Compliance with Our Legal Obligations
We use your information when we are required to do so by law, or pursuant to valid law enforcement requests.
5.3 Consent-Based Processing
We also collect and use personal information for specified purposes when you give us your consent to do so.
6.1 General Principle
We will share your personal information with third parties only in the ways that are described in this privacy statement or as otherwise required by law. We do not sell any personal information about our visitors and users to any third parties.
Please note that nothing herein restricts the sharing of anonymized information, which may be shared with third parties without your consent.
6.2 Our Service Providers
We share and/or provide personal information with vendors, consultants and other service providers (“Service Providers”) such as:
• advertising providers who provide advertising attribution services;
• mobile measurement providers who assist us in measuring the performance of advertising;
• cloud service providers who assist us in storing and/or processing your data;
• auditors, accountants, lawyers, financial or professional advisers; and
• Other vendors, if any, who are engaged by or working with us in connection with the operation of the Services and who need access to such information to carry out their work for us.
We provide such Service Providers with access to the information they may need to perform our services under reasonable confidentiality terms. In some cases, the Service Provider may be directly collecting the information from you on our behalf. Our Service Providers are under an obligation to use personal information they obtain from us exclusively to provide the services for us. However, we are not responsible for any additional information you provide directly to these Service Providers and we encourage you to become familiar with their practices before disclosing any personal information directly to such Service Providers.
6.3 Our Subsidiaries
We share information with companies in the same group of companies which includes our subsidiaries (i.e., any organization we own or control) and/or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will only use your personal information in the same way as we do under this Policy.
We share such information in our legitimate interests, where applicable, to organize our business as appropriate. Where we cannot rely on legitimate interests for the sharing in a particular case (e.g. because your privacy rights and freedoms in that case outweigh the legitimate interests), your consent to such processing will be requested as appropriate under the applicable law.
6.4 Sharing with Your Consent
From time to time, we also share personal information with third parties when you give us your consent to do so.
6.5 Sharing in Response to Legal Obligations
We reserve the right to disclose your information (including personally identifiable information) in response to the law, legal processes, litigation, and/or requests from public and governmental authorities within or outside your country of residence. We access, disclose or preserve personal information, including the content of your communications, in good faith that we are lawfully authorized by public authorities or required to do so, including to meet national security or law enforcement requirements, or where reasonably necessary or appropriate to comply with the law, legal processes or authorities, respond to any claims, or to protect the rights, property or safety of the Company, our users, our employees or the public, including but not limited to protect the Company or our users from fraudulent, abusive, inappropriate or unlawful use of our Service.
6.6 Merger, Acquisition or Transfer of Assets
Information we collect, including personal information, may also be disclosed or transferred as part of, or during negotiations concerning, any merger, sale, divestiture, or transfer of all or a portion of the company assets, financing or acquisition or in any other situation where personal information may be transferred as one of the business assets of the Company, in our legitimate interests to ensure continuity of our business. You will be notified via email and/or a notice of any change in ownership, uses of your personal information, and choices you may have regarding your personal information.
6.7 International Transfers
Your personal information will be transferred and shared globally, among Mangorilla Limited and their affiliated companies as necessary. Your information will be accessible from and processed in servers located globally. In particular, your personal information will be stored in our service provider’s servers located in the United States to ensure the proper operation of our services and your experience. We also have support, technical and other teams who may support the service, including from China.As we are a global company, your personal information may be transferred to and processed in countries other than the country in which you reside. Although these countries may have data protection laws that are different to the laws of the country in which you reside, we ensure appropriate safeguards in place so that your personal information will remain protected in accordance with this Policy.
You acknowledge and understand that the laws regarding personal information in the country or region to which the data is transferred may be less stringent than the laws of your country and may not offer the same protections or rights as the laws of your country. If you object to your personal information being transferred or used as described in this Policy, please do not use the Service.
6.8 Third-Party Links and Advertising SDKs
Our Website or Service may contain links to other websites or be accessible from third-party platforms. We do not control such sites, platforms or their activities. Any personal information you provide on linked pages is provided directly to that third party and is subject to that third party’s privacy policy. We are not responsible for the content or privacy and security practices and policies of websites to which we link or platforms from which the Service are accessible. Links from our Website or Service to third parties or to other sites are provided for your convenience only. We encourage you to learn about their privacy and security practices and policies before providing them with personal information.
If you are a consumer that downloads and uses our application implemented with any advertising SDK (software development kits) or otherwise interacts with the Service, the Advertising Company may be an independent controller of the personal data processed in order to provide the Service that it will individually determine the purposes and means of processing such data. Such data refers to any information or data that advertising company collects through the SDK implemented in our application, in connection with any advertisement or otherwise in connection with the Service, e.g. user device information, user identifiers, information about advertisements served, viewed or clicked or other user interactions with advertisements or the Service, information about user applications, network information and header information. Please be aware that in no event will the advertising party and us process personal data as joint controllers.
We use physical, technical, and administrative measures to safeguard information in our possession against loss, theft and unauthorized use, disclosure, or modification. Please note, however, that no data transmission or storage can be guaranteed to be 100% secure. As a result, although we strive to protect the information we maintain, we cannot ensure or warrant the security of any information that you transmit to us.
You should note that our Service Providers may be responsible for processing, handling or storing some of the personal information that we receive. They are not authorized to market to you independently. These Service Providers are contractually required to safeguard and secure the personal information they received from us. Although we strive to protect your personal information, you should be aware, however, that information sent over the Internet is not necessarily secure and may be intercepted or accessed by third parties. Therefore, we cannot guarantee the security of such information, and we are not responsible or liable for any such interception or unauthorized access.
We will only retain your personal information for as long as it is reasonably necessary for the purpose for which that information was collected and to the extent permitted by applicable laws (including for the purpose of satisfying any legal, regulatory, tax, accounting or reporting requirements).
For example, your registration information and any game data generated from your account's activity will be held for as long as your account remains active, or until the Game or platform expires;
We retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation regarding our relationship with you. When we no longer need to use your information, we will remove it from our systems and records and/or take steps to anonymise it promptly so that you can no longer be identified from it.
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.
If you would like to delete your data, please refer to the heading of “What choices do you have regarding the use of your personal information? ” below.
9.1 Overview and How to Exercise Your Rights
As the subject of the personal information, you are entitled to have the rights provided by the privacy laws in your jurisdiction. Your rights may include part or all of those described underneath. You can exercise your rights entitled by the privacy laws in your jurisdiction at any time by sending us relevant requests to FV-sumia@outlook.com. Your rights may include:
9.2 Right to Access Your Data
You have the right to access personal information we hold about you, how we use it, and who we share it with.
9.3 Right to Correct Your Data
You have the right to correct any personal information held about you that is inaccurate.
9.4 Right to Have Your Data Deleted
You can delete your account (i.e. the account on our Service, excluding any account on the third party platforms, such as Sony), or remove certain personal information that we have stored about you. However, please note that we may need to retain personal information if there are valid grounds under data protection laws for us to do so (e.g. for the defense of legal claims or freedom of expression). If that is the case, we will inform you of such valid grounds.
9.5 Right to Restrict Processing and Withdraw Your Consent
You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances (such as where you believe such data to be inaccurate, our processing is unlawful or that we no longer need to process such data for a particular purpose).
In cases where we have requested your consent to process personal information, you may withdraw your consent at any time by sending a communication to us specifying which consent you are withdrawing or by using the consent withdrawal functionalities available in our Service. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.
Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds other than your consent, for example, when the processing is necessary to fulfil the obligations of a contract, where the processing is necessary to protect the vital interest of you or another natural person, or other legitimate reasons under data protection laws.
9.6 Right to Data Portability
You have the right to receive a copy of certain personal information we process about you in a structured, electronic format. For example, you can contact us to receive your data if you want to upload it to another service, where this constitutes (a) personal information which you have provided to us, (b) that we are processing on the basis of your consent or to perform a contract with you and (c) that is processed by automated means. Additionally, you have the right to require us to transmit such personal data directly to another controller, where this is technically feasible. However, please note that we may not be able to provide you with personal information if this would interfere with another individual’s rights (e.g. where this would reveal information about another person or our trade secrets or intellectual property) or there are other limitations recognized under data protection laws.
9.7 Right to Object to the Way Your Data Is Handled
You have the right to object to our processing of personal information about you. In particular, you have the right to object to being profiled for the purposes of direct marketing (e.g. where we collect information about you to decide what marketing information to send to you, based on your preferences or personal characteristics).
You also have the right to object to marketing at any time by opting-out using the unsubscribe function displayed in any such communications from us.
9.8 Right to Lodge Complaints with the Supervisory Authority
To help us verify that you are the subject of the personal information and to exercise your rights outlined above, we may require you to provide sufficient proof of identification. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We will respond to all access requests within thirty days. This period may be extended by two further months where necessary, taking into account the complexity and number of the requests we are handling at the time.
You have the right to lodge complaints about the data processing activities carried out by us before the competent data protection authorities.
The Service is not directed to children under such minimum age. If we discover that we have inadvertently collected information from children under such minimum age, without first obtaining valid parent/guardian consent, we will delete such children’s information from our systems in accordance with applicable law (though we will retain the email address to ensure that the user does not re-sign up to the Service). If you become aware that personal information about a person under such minimum age has been provided to us without valid parent/guardian consent, please immediately contact us at: FV-sumia@outlook.com.
Where the settings or notices in our Service provided in your jurisdiction do not specify a minimum age, children under the age of 18 are not eligible to use our Service.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily; any questions, comments on this Policy; or wish to exercise your rights as described in this Policy, please contact our Data Protection Officer at: FV-sumia@outlook.com.
We reserve the right to change the provisions of this Policy from time to time to reflect changes to the scope of the Service or for other reasons. Therefore, it is important to check the effective date of this Policy posted here each time you use the Service. If we decide to make material changes to this Policy, we will notify you of these changes via an alert on the home page of our website if we have an official website and notify you by email if we have your email address.
If you are located in the EEA or UK, the European Union General Data Protection Regulation (“EU GDPR”) or UK Data Protection Regulation (the “UK GDPR” and, together with the EU GDPR, the “GDPR”) apply to the collection and processing of your personal data by us.
For the purpose of the GDPR, the data controller is Mangorilla Limited. This means that Mangorilla is responsible for determining how and why your personal data is processed.
As outlined in the “Data collected to prevent cheating and unauthorized software” section of the Policy, we may also process your personal information to detect cheating or unauthorized and malicious programs. We see this processing as necessary for the performance of our Service, pursuant to art. 6.1(b) of the GDPR and for our legitimate interests to ensure the functionality of, and prevent the misuse of, our Service, in line with art. 6.1(f) of the GDPR.
Where processing is not necessary for the performance of the Service or where we cannot rely on legitimate interests in a particular case (e.g. because your privacy rights and freedoms in that case outweigh the legitimate interests), your consent to such processing will be requested as appropriate under the applicable law.
For complementary information regarding the purposes for which we use your personal information, please see the “For which purposes do we use your personal information?” section of this Policy.
Software Development Kits. Please note that we have implemented software development kits (“SDK”) in our Service.
International transfers. We are a multinational group with companies registered outside the EEA and UK. Our servers and main business operations are located globally, as described in the “International transfer” section of this Policy. By using our Service and providing us with information, you acknowledge and understand the transferring, storing and processing of your information on computers located in the United States of America and China in the manner described in this Policy. If you object to your personal information being transferred or used as described in this Policy, please do not use this Service.
For any transfers of data outside the EEA or the UK, the data transfer will be under the European Commission’s standard contractual clauses for the transfer of personal data to third countries (specifically, module one (controller to controller transfer) and module two (controller to processor transfer), as relevant), or the UK Information Commissioner’s international data transfer addendum to the EU standard contractual clauses, as relevant, unless the data transfer is to a country that has been determined by the European Commission or the relevant UK authorities, as applicable, to provide an adequate level of protection for individuals’ rights and freedoms for their personal data.
This section provides additional detail for residents of California and certain other U.S. states on how we collect, use and disclose Personal Information, and the rights such residents may have with respect to that Personal Information. For the purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (the “CCPA”), as well the meaning given to “personal data” under other U.S. state privacy laws. Unless otherwise specified, Personal Information includes “sensitive personal information” as defined by the CCPA and “sensitive data” as defined by other U.S. state privacy laws.
Processing of Personal Information
We collect, use and disclose, and have during the past 12 months collected, used and disclosed, the following categories of Personal Information. In the past 12 months, we have disclosed such categories to our Service Providers and Subsidiaries, as described further in the “Do we share personal information? If so, how we share your information?” section above.
The purposes for which we use these categories of Personal Information are described further in the “For which purposes do we use your personal information?” section of our Privacy Policy. Our relevant data retention practices are addressed in the “How long do we retain your personal information?” section of our Privacy Policy.
We do not and have not in the past 12 months “sold” or “shared” your Personal Information, and we do not knowingly sell or share (as defined by the CCPA) the Personal Information of minors under 16 years of age. We also do not process Personal Information for targeted advertising purposes.
Sensitive Personal Information and Deidentified Data
We do not use or disclose Sensitive Personal Information (as defined by the CCPA) for purposes other than those expressly permitted under the CCPA. Additionally, we will not attempt to re-identify de-identified information that we derive from Personal Information, except for the purpose of determining whether our de-identification process satisfies legal requirements.
Your Privacy Rights
Depending on where you live, you may have the rights listed below in relation to Personal Information that we collect about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.
We will not unlawfully discriminate against you for exercising your rights. Please submit your request by sending an email to FV-sumia@outlook.com. Once we receive your request, we may verify it by requesting information sufficient to confirm your identity, including by asking you to verify information about your use of the Services. If you would like to use an authorized agent to exercise your rights, we may request evidence that you have provided such agent with the power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf.
Global Privacy Control
We recognize the Global Privacy Control opt-out preference as a valid request for residents of certain states to opt-out of the sale and sharing of the personal information processed through the browser you are using. This controls whether your browser sets third-party cookies on our websites that are used for targeted advertising. This is only based on browser settings and not your device settings. Please see the list of browsers that support GPC and instructions on how to enable it.
Appeal
If we refuse to take action on your request, you may be entitled to appeal this refusal within a reasonable period after you have received notice of the refusal. You may file an appeal by contacting us at FV-sumia@outlook.com.
Minimum Age
In the United States, the minimum age for users is 18. We do not knowingly collect any personal information online from children under 18 without parental consent, unless permitted by law (COPPA). If we learn that a child under the minimum age has provided us with personal information without parental consent, we will delete it in accordance with applicable law. Certain U.S. states (e.g., California, Texas, Utah, Connecticut) may impose additional obligations regarding the collection of personal information from users under 18, such as data minimization, default privacy settings, and restrictions on targeted advertising. We comply with such applicable state-level requirements.
Do-Not-Track Signals
Some web browsers may transmit “do not track” signals to the websites and other online services with which the browser communicates. Unless otherwise specified, we currently do not take action in response to these signals and we do not process your Personal Information in a manner that would require us to respond to similar opt-out preference signals.
Should you be residing in Canada and have the intention of acquiring written details concerning our policies and procedures regarding service providers operating outside of Canada, you are welcome to get in touch with us through FV-sumia@outlook.com. In cases where we engage service providers who may potentially gain access to your personal data, we mandate that they uphold privacy and security benchmarks equivalent to our own. By means of contracts and additional safeguards with these service providers, we ensure the confidentiality and security of your personal information remains intact and that it is not exploited for any purpose beyond what is stipulated in this Privacy Policy.