Privacy Policy

BLACKWHALE ENTERTAINMENT LIMITED | BlackWhale Game

Effective Date: May 12, 2026

1. Introduction

BLACKWHALE ENTERTAINMENT LIMITED ("BlackWhale", "we", "our", or "us") develops and publishes casual mobile games and digital entertainment experiences under the BlackWhale Game brand, including Raven's Whisper: Coloring Book and Block Era: Classic Block Puzzle.

This Privacy Policy explains how information may be collected, used, stored, disclosed, and protected when you use Raven's Whisper: Coloring Book and Block Era: Classic Block Puzzle, our websites, or related services (collectively, the "Services"). This policy applies to the products listed below and may also apply to future applications, games, websites, or services published under the BlackWhale Game label where this policy is linked:

·        Raven's Whisper: Coloring Book

·        Block Era: Classic Block Puzzle

·        Most features of our games can be used without creating an account. We generally do not require users to provide real names, phone numbers, or physical addresses in order to use the Services.

·        We do not intentionally collect highly sensitive personal information such as precise GPS location, biometric data, government-issued identification numbers, health information, or payment card numbers through the Services.

·        This Privacy Policy is intended to describe our privacy practices in a transparent way for users, app stores, advertising partners, and regulators. If you do not agree with this Privacy Policy, please do not use the Services.

2. Information We Collect

When you use the Services, certain information may be collected automatically to help the apps function correctly, improve performance, support advertising, process optional purchases, and maintain a stable user experience. Depending on the features you use, this information may include:

·        Device and technical data: device type, operating system, device language, country or region, app version, device identifiers, advertising identifiers, app instance identifiers, crash logs, and performance diagnostics.

·        Usage and gameplay data: coloring activity, puzzle activity, gameplay progress, completed images or levels, rewards, feature usage, in-app interactions, session duration, app opens, retention events, advertising engagement, and general analytics events.

·        Purchase and subscription data: subscription status, purchase status, entitlement status, refund status, and related app-store transaction information if you make optional in-app purchases. Payment card numbers are processed by the relevant app store or payment provider, not by us.

·        Support data: email address, message content, screenshots, or other information you choose to provide when contacting us for support.

·        Approximate location: approximate country, region, or city inferred from IP address or device settings, used for localization, analytics, fraud prevention, and advertising compliance. We do not intentionally collect precise GPS location.

3. How We Use Information

We use collected information for the following purposes:

·        Operate, maintain, and improve the Services.

·        Save app settings, gameplay progress, rewards, levels, completed pictures, puzzle progress, and user preferences.

·        Improve app stability, loading speed, performance, content quality, and user experience.

·        Understand which features players use and enjoy most.

·        Deliver advertisements, limit ad frequency, measure advertising performance, and prevent invalid traffic or ad fraud.

·        Process optional subscriptions, purchases, refunds, or entitlements.

·        Respond to customer support requests and service-related inquiries.

·        Detect, prevent, and address abuse, fraud, security incidents, unauthorized access, or technical misuse.

·        Comply with legal obligations, app-store requirements, and enforce our policies.

4. Legal Bases for Processing for EEA, UK, and Similar Users

If you are located in the European Economic Area, the United Kingdom, Switzerland, or another jurisdiction with similar privacy rules, we process personal data under one or more lawful bases, depending on the context:

Processing purpose

Primary legal basis

Provide the apps, save progress, and process optional purchases

Performance of a contract and legitimate interests

Analytics, crash diagnostics, performance monitoring, security, fraud prevention, and product improvement

Legitimate interests, or consent where required by local law

Personalized advertising, tracking, and similar technologies

Consent where required; legitimate interests for limited non-personalized measurement where permitted

Customer support and service communications

Legitimate interests and performance of a contract

Legal compliance, platform compliance, recordkeeping, and enforcement

Compliance with legal obligations and legitimate interests

You may withdraw consent at any time where processing is based on consent. Withdrawal does not affect processing that occurred before consent was withdrawn.

5. Advertising, Analytics, and SDK Services

The Services may use third-party SDKs and service providers to support advertising, analytics, attribution, crash reporting, fraud prevention, and app performance. These services may collect limited technical information such as advertising identifiers, approximate location derived from IP address, app activity, crash logs, and device information.

Services we may use include Google AdMob, AppLovin, Unity Ads, Firebase Analytics, Firebase Crashlytics, AppsFlyer, and similar advertising, analytics, attribution, and diagnostics providers. These third-party services operate under their own privacy policies and may process information according to their own legal obligations and data protection standards.

We require service providers and partners that process information on our behalf to use appropriate safeguards and to process information only for authorized purposes, subject to their applicable terms and agreements with us.

6. Personalized Advertising and Consent Choices

Advertising partners may use limited device-related information to provide personalized or non-personalized ads depending on your region, platform settings, consent status, and applicable law.

Where required by law, including in the EEA, United Kingdom, Switzerland, and similar jurisdictions, we may request your consent before processing certain information for personalized advertising, analytics, or similar tracking technologies. You may withdraw or change consent choices through available in-app privacy settings, consent prompts, device settings, or platform-level controls where applicable.

You can also limit ad tracking or reset your advertising identifier through your device settings. For example, iOS users may manage tracking permissions through Apple App Tracking Transparency and device privacy settings. Android users may reset or delete their advertising ID or manage ad personalization through Google or device settings.

7. Data Sharing

We may disclose information in the following situations:

·        Service providers: vendors and contractors that provide services on our behalf, such as hosting, analytics, crash diagnostics, customer support, fraud prevention, and infrastructure.

·        Advertising and analytics partners: partners that help us deliver advertisements, measure ad performance, understand user engagement, attribute installs, and improve marketing performance.

·        App stores and payment providers: Apple, Google, or other platform providers that process purchases, subscriptions, refunds, or entitlement status.

·        Legal requirements: where required by applicable law, regulation, legal process, governmental request, or to protect rights, safety, and security.

·        Business transfers: in connection with a merger, acquisition, financing, asset sale, restructuring, or similar business transaction.

·        With your consent: when you explicitly authorize or direct us to share information.

8. California Privacy Rights and Do Not Sell or Share

If you are a California resident, you may have rights under the California Consumer Privacy Act and California Privacy Rights Act (collectively, "CCPA/CPRA"). Depending on applicable law, you may have the right to know, access, correct, delete, and receive information about certain categories of personal information. You may also have the right to opt out of the sale or sharing of personal information and the right not to be discriminated against for exercising your privacy rights.

We do not sell personal information for money. However, some advertising or analytics activities involving advertising identifiers, app activity, or similar data may be considered a "sale" or "sharing" under California privacy law, especially where data is used for cross-context behavioral advertising.

To exercise a California privacy request or to request to opt out of sale or sharing, please contact us at admin@blackwhalejoy.com. You may also use available device settings, advertising ID controls, consent tools, or in-app privacy settings where provided. We will process verifiable privacy requests as required by applicable law.

9. International Data Transfers

Depending on your location, your information may be transferred to, stored in, or processed in countries outside your country of residence, including the United States, Hong Kong, and other regions where we or our service providers operate.

Where required by law, we implement reasonable safeguards designed to protect personal data during international transfers. These safeguards may include contractual protections, data processing agreements, Standard Contractual Clauses where applicable, and technical and organizational measures intended to protect information.

10. Data Retention

We retain information only for as long as reasonably necessary to operate the apps, maintain records, resolve disputes, comply with legal obligations, enforce agreements, prevent fraud or abuse, and protect our Services.

Retention periods may vary depending on the type of information and the purpose for which it is processed. For example, crash logs and analytics data may be retained for a limited period for diagnostics, while transaction records may be retained longer where required for accounting, tax, legal, or dispute-resolution purposes.

When information is no longer required, we may delete, anonymize, aggregate, or securely isolate it.

11. Your Rights and Choices

Depending on your jurisdiction, you may have rights including:

·        Request access to personal information.

·        Request correction or deletion of information.

·        Withdraw consent where processing is based on consent.

·        Restrict or object to certain processing activities.

·        Request a portable copy of your information.

·        Opt out of targeted advertising, sale, or sharing where applicable.

·        Lodge a complaint with a local data protection authority.

12. Children's Privacy

The Services are intended for a general audience and are not directed toward children under the age of 13, or the equivalent minimum age required by applicable law in the relevant jurisdiction.

We do not knowingly collect personal information from children under 13. We also do not knowingly target children as the primary audience of the Services. If we become aware that personal information has been collected from a child without appropriate consent where required by law, we will take reasonable steps to delete that information promptly.

If any Service is later adapted for children or family-focused experiences, we may update our data practices to comply with COPPA, GDPR-K, platform family policies, or other applicable child privacy regulations.

13. Data Security

We use reasonable administrative, technical, and organizational safeguards designed to help protect information from unauthorized access, loss, misuse, alteration, or disclosure. These safeguards may include access controls, secure transmission, vendor review, monitoring, and other measures appropriate to the nature of the information.

However, no online service or electronic storage method can be guaranteed to be completely secure.

14. Do Not Track and Global Privacy Controls

Some web browsers may transmit "Do Not Track" signals. Because there is no universally accepted standard for these signals, our websites or Services may not respond to all Do Not Track requests.

Where required by applicable law and technically feasible, we will honor legally recognized opt-out preference signals or global privacy controls for relevant web-based processing. App-based privacy choices may also be managed through device settings, app settings, or platform-level controls.

15. App Store and Google Play Disclosures

This Privacy Policy should be made available on our website, in app-store listings, and in an easily accessible location within each applicable app where required by Apple App Store and Google Play policies.

The information in this Privacy Policy should be kept consistent with Apple App Privacy Details, Google Play Data safety disclosures, consent prompts, SDK configuration, and each app's actual data practices. If our SDKs, data practices, advertising configuration, or product features change, we may update this Privacy Policy and related app-store disclosures.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time as our apps, services, technologies, legal obligations, or operational practices evolve.

When important changes are made, the updated policy may be published through our website, app settings, or app-store listings. We encourage users to review this Privacy Policy periodically.

17. Contact Us

If you have any questions, requests, concerns, or privacy-rights requests regarding this Privacy Policy or our privacy practices, please contact us:

BLACKWHALE ENTERTAINMENT LIMITED

Email: contact@blackwhalejoy.com

Location: Hong Kong

Brand: BlackWhale Game