Privacy Policy

1. Who is responsible for your data

Kakunyn Studios is the game studio brand of Kakunyn Technology LTDA, a Brazilian company registered under CNPJ 58.285.609/0001-34. Kakunyn Technology LTDA is the data controller for the processing described in this policy.

Our Data Protection Officer (Encarregado) is Rofli Sanches de Souza. For privacy questions or requests, email privacy@kakunyn.com. Requests may be submitted in English or Portuguese.

2. Data we process

• Player identity and progress: a player or account identifier, nickname, profile choices, saved progress and game settings. If you choose an available sign-in service, we receive the identifier and profile information that service makes available with your authorization, such as an email address.
• Multiplayer and leaderboards: match activity, opponents, results, scores, ranking, session timestamps and connection information, including IP address. This supports matches, synchronization, fair play and abuse prevention. Your nickname, public player identifier, chosen avatar where available, scores and rank may be visible to other players.
• Purchases: store transaction identifiers or receipts, purchased items, payment status and the entitlements associated with your player identifier. The app store processes payment details; we do not receive your full payment card number or card security code.
• Game analytics: interactions with game features, session duration, event timestamps, app version, device model, operating system, language and pseudonymous app or installation identifiers. These help us understand gameplay and improve balance, usability and performance.
• Crash and performance reports: error information, stack traces, diagnostic logs, device and operating system details, app version and technical identifiers needed to investigate a failure. Reports can contain information about the game session in which the failure occurred.
• Support and privacy correspondence: your name or nickname, email address, player identifier, messages and any attachments you choose to send. Please do not send passwords, full payment card details or unrelated sensitive information.
• Website access: our hosting provider processes technical request information such as IP address, browser details, requested pages and timestamps to deliver and protect this website.

We receive information directly from you, from your use of the website or game, and from the platform and service providers involved in the features you use. We limit collection to what is needed for the relevant purpose.

3. Purposes and legal grounds

We use personal data to provide game features and player support, maintain progress and purchases, operate multiplayer and rankings, diagnose failures, improve our games, protect players and our services, and meet legal obligations.

Under Brazil's General Data Protection Law (LGPD, Law No. 13,709/2018), the relevant grounds include performance of a contract or steps requested by you, compliance with legal obligations, legitimate interests subject to your rights and reasonable expectations, exercise of legal rights, and consent when required. Optional analytics that require consent are subject to that consent; withdrawing it does not affect processing that was lawful beforehand. Where other data protection laws apply, we rely on the legal grounds required by those laws.

Where the GDPR applies: core game functionality, purchases and requested player support rely on contract necessity (Article 6(1)(b)); applicable legal obligations on Article 6(1)(c); necessary security, fraud prevention and service maintenance on legitimate interests (Article 6(1)(f)), balanced against your rights. Non-essential analytics that need consent rely on Article 6(1)(a). Consent is separate from accepting general terms, and refusing or withdrawing optional consent does not prevent access to features that do not need that processing.

4. Sharing and service providers

We do not sell personal data. We share the information necessary for the purposes above with providers of hosting, game infrastructure, multiplayer connectivity, analytics, crash reporting, email and support. We require providers processing data on our behalf to follow contractual confidentiality and data protection duties and provide protection at least equivalent to this policy and applicable law.

This website is hosted by HostGator, and our company uses Google Workspace for email, including privacy correspondence. Game-specific analytics and diagnostic providers depend on the integrations in the version you use; relevant provider information and choices are made available with those integrations.

Google Play and Apple's App Store process purchases and platform information under their own privacy notices. We exchange transaction information with the relevant platform to validate purchases and provide purchased items. You can read the Google Privacy Policy and the Apple Privacy Policy.

Other players can see the public multiplayer and leaderboard data described above. We may also disclose data where required by law, to protect legal rights and safety, or in a corporate reorganization subject to applicable safeguards and notices.

5. Cookies, device storage and choices

The Studios website does not use analytics cookies, advertising pixels or advertising trackers. Technical hosting logs are separate from cookies. The parent company website and other destinations you visit through links have their own notices and settings.

Games may store settings, progress and session information on your device and use app identifiers for the functions described above. Where optional processing requires consent, you can decline it or withdraw it through the privacy controls offered with that feature, or contact us for help. You can also manage applicable app permissions in your device settings. Withholding information essential to an online feature may prevent that feature from working.

We do not use your personal data for personalized advertising under this policy. Introducing such advertising would require updated disclosures and any legally required choices before it begins.

6. International processing

Our company is based in Brazil. Some providers may process information in other countries. When personal data is transferred internationally, we use the safeguards required by the applicable law, such as appropriate contractual protections and legally recognized transfer mechanisms. You can contact our Data Protection Officer for information about the safeguards relevant to your data.

Where the GDPR requires safeguards for a transfer outside the European Economic Area, we use an applicable adequacy decision or appropriate safeguards, such as approved standard contractual clauses, with additional measures where necessary. You may ask our Data Protection Officer how to obtain information about or a copy of the relevant safeguards.

7. Retention and security

We retain identifiable data only while necessary for its stated purpose, subject to legal requirements. Player profiles, progress and online records are retained while needed to provide the service or until an applicable deletion request is completed. We review analytics and diagnostic records against their improvement and troubleshooting purposes and delete or anonymize them when no longer needed.

In line with our company retention program, website and general company correspondence is normally kept for up to 24 months after the last contact. Player support records are kept while needed to resolve a request or meet an applicable legal requirement. Purchase, security and legal records may need to be kept longer to satisfy tax obligations, prevent fraud or resolve disputes. Any exception is limited to the relevant data, purpose and period. Restricted backup copies can remain until the applicable backup rotation completes and are not used for ordinary operations.

We use technical and organizational measures such as access restrictions, administrative authentication controls, data minimization and encrypted transmission. We investigate security incidents and notify affected people and authorities when required by law. No internet service can guarantee absolute security.

8. Request account or data deletion

You can request deletion of your Smash Kings account and associated personal data, or other personal data we hold about you, by emailing privacy@kakunyn.com with the subject Smash Kings account or data deletion. Include your player identifier or nickname and the email linked to the account, if any, so we can locate the correct records. You do not need to create an account or sign in to submit this request.

We may ask for proportionate verification to protect you from an unauthorized deletion. Do not send your password. For versions that offer account creation, an account deletion request option is also provided within the game.

Deletion covers the account and associated personal data, including identifiable profile, progress and leaderboard records, except data that must be retained for a specific lawful reason described above. We will explain relevant exceptions and the processing timeframe when responding. Deletion can make progress and purchased entitlements unavailable. Uninstalling a game alone does not delete online data, and deleting a game account does not remove transaction records independently held by an app store.

9. Your privacy rights

Depending on the law that applies, you may request confirmation of processing and access to your data, correction, anonymization, blocking or deletion of unnecessary or unlawfully processed data, portability where applicable, information about sharing, and deletion of data processed with consent subject to legal exceptions. You may withdraw consent, ask about the consequences of refusing it, object to processing where permitted, and request review of decisions based solely on automated processing that affect your interests.

Send requests to privacy@kakunyn.com. We respond within the periods required by applicable law and use only the information reasonably needed to verify and handle the request. You may also raise a concern with Brazil's ANPD or another competent data protection authority. Where the GDPR applies, its rights to restriction and objection, among other applicable rights, are also respected.

GDPR requests: where applicable, you have rights to access, rectification, erasure, restriction, objection and data portability, subject to the conditions of that law. We normally respond free of charge within one month. For complex or numerous requests, the law permits up to two additional months; we explain any extension within the first month. You can complain to a supervisory authority, including in the country where you live, work or believe an infringement occurred. For solely automated decisions with legal or similarly significant effects, applicable safeguards include the opportunity to seek human intervention, express your view and challenge the decision.

10. Children, adolescents and COPPA

We consider the best interests of children and adolescents when handling their data. Age eligibility and available features depend on the game, its store listing and applicable law. When a feature requires parental authorization or age-appropriate safeguards, these must be in place before the relevant processing starts. We do not condition a child's participation on providing information beyond what is necessary for that activity.

United States / COPPA: when the Children's Online Privacy Protection Act applies, including to a child-directed service or when we have actual knowledge that a user is under 13, we require direct notice to parents and verifiable parental consent before collecting, using or disclosing the child's personal data, except for limited exceptions allowed by the rule. This policy or an age rating is not parental consent.

Parents may request access to their child's data, deletion and an end to further collection or use by emailing privacy@kakunyn.com with the subject Child privacy request and the relevant player identifier, if known. We use proportionate steps to verify parental responsibility before disclosing or deleting records. The contact details in section 12 are also available for these requests.

Where COPPA requires it, disclosure to third parties that is not integral to the service requires separate verifiable parental consent. Refusing that optional disclosure does not exclude the child from an otherwise available activity. Public profiles and leaderboard disclosures are also subject to the applicable parental-notice and consent requirements.

A feature that processes children's personal data under COPPA must first provide a child-specific notice identifying its operators, providers, data uses, sharing and purpose-based deletion periods. Children's data is not retained indefinitely. Any reliance on the limited internal-operations exception for persistent identifiers must be disclosed and cannot be used to contact or behaviorally profile a child, or for personalized advertising. Our current policy does not authorize personalized advertising.

GDPR consent for children: for consent-based online services offered directly to a child, the relevant national age threshold is between 13 and 16. Below that threshold, consent must be given or authorized by the holder of parental responsibility, with reasonable verification efforts. This threshold does not replace other child-protection or game eligibility requirements.

If you are a parent or guardian and believe that a child has provided personal data in a way that does not comply with applicable law, contact privacy@kakunyn.com so we can investigate and take the appropriate action, including deletion where required.

Age ratings: where a store uses the International Age Rating Coalition (IARC), its regional content rating describes the game's content and relevant interactive elements. A content rating does not establish consent to data processing or certify compliance with privacy law. Refer to the current listing in your region for any assigned rating; this page does not claim a rating or certification for Smash Kings.

11. Updates to this policy

We update this page when our services or data practices change and revise the date shown above. For material changes, we provide additional notice and obtain any required consent before applying the new processing. New game integrations must be reflected in the applicable notices and store privacy disclosures.

12. Contact us

Kakunyn Technology LTDA / Kakunyn Studios
CNPJ: 58.285.609/0001-34
Data Protection Officer: Rofli Sanches de Souza
Email: privacy@kakunyn.com
Company telephone: +55 (11) 91448-8121
Postal address: Avenida Paulista, 726, Suite 1202, Bela Vista, São Paulo/SP, 01310-910, Brazil.