Privacy Policy

Effective date: 16 November 2026
Last updated: 16 November 2026

1. Introduction

Cyclic Games (“Cyclic Games”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, disclose, store and protect personal data when you visit our website at cyclicdigital.com, use our mobile application (the “App”), play our games, participate in competitions or otherwise interact with us.

Our services include digital trivia and other multiplayer games designed to be played with friends and family, either in person or remotely. Our services may include free games, paid games, in-app purchases, leaderboards, promotional activities and competitions.

This Privacy Policy applies to our website, App, games, competitions and related services, unless we provide a separate privacy notice for a particular service.

By using our services, you acknowledge that you have had the opportunity to read this Privacy Policy. Where applicable law requires consent for particular processing activities, we will seek that consent separately. Using our services does not override any consent or other rights you have under applicable law.

2. Who we are

The organisation responsible for the processing of your personal data is:

Legal entity: Life Transformations Limited
Trading names: Cyclic Games, Cyclic Digital
Registered address: 2302, Tung Chiu Commercial Centre, 193 Lockhart Road, Wan Chai, Hong Kong, Hong Kong SAR, China
Contact email: hello@cyclicdigital.com
Website: cyclicdigital.com

Where required by applicable data protection law, this organisation acts as the data controller or equivalent responsible entity in relation to the personal data described in this Privacy Policy.

For questions about this policy or the handling of your personal data, please contact us using the details above.

3. Personal data we collect

The information we collect depends on how you use our services, which games you play, the features you use and the permissions you grant.

3.1 Account and profile information

We may collect information such as:

• Your username, display name or player name.
• Your email address.
• Your mobile number.
• Your account identifier and authentication information.
• Your profile preferences and selected language.
• Other information you choose to provide to us.

If you can use the App without creating an account, we may instead associate gameplay and technical information with a device identifier or another pseudonymous identifier.

Please avoid including sensitive personal information in a public player name or profile.

3.2 Gameplay and competition information

When you play our games, we may collect and process:

• Games played, participation dates and game settings.
• Answers submitted, scores, rankings and other gameplay results.
• Match identifiers and information needed to coordinate multiplayer sessions.
• Leaderboard positions and competition results.
• Information necessary to administer prizes and verify eligibility.
• Information relating to suspected cheating, manipulation or breaches of competition rules.

Where a leaderboard or competition result is designed to be visible to other players or the public, the relevant information may be displayed in accordance with the rules and settings of that feature.

3.3 Device and technical information

When you access our services, we and our service providers may collect technical information such as:

• IP address.
• Device type, operating system and app version.
• Device or installation identifiers, where available and permitted.
• Language, time zone and general device settings.
• Connection information, diagnostic logs and error reports.
• Information about app performance and technical failures.

We use this information to operate our services, maintain security, troubleshoot problems and improve reliability.

3.4 Location information and geo-blocking

We may use a third-party geo-blocking service to determine the approximate country or region from which you access our services.

For this purpose, the service may process your IP address and associated technical information to estimate your approximate geographic location.

We use geo-blocking to:

• Restrict access to games, features or competitions based on geographic eligibility.
• Enforce competition rules and territorial restrictions.
• Help prevent attempts to circumvent geographic restrictions.
• Support the integrity and security of our services.

For example, a competition may be restricted to eligible participants in a particular country. In such cases, we may use geo-blocking to help determine whether access appears to originate from an eligible country.

An IP-based location estimate does not, by itself, establish a person’s citizenship, residence or legal eligibility. Where a competition requires a particular citizenship or another specific eligibility criterion, we may need to conduct additional verification in accordance with the competition rules and applicable law.

The geo-blocking service may process IP addresses, location estimates and related technical information in accordance with our arrangements with the provider and its applicable privacy terms. We will identify the relevant provider in our privacy information where required by law.

Geo-blocking may not always identify a location accurately. We may use additional verification measures where reasonably necessary to enforce eligibility requirements.

Our geo-blocking process may use IP-based location estimation and/or GPS-based precise location tracking.

3.5 Purchase and transaction information

If you purchase games, subscriptions or other digital products, we may process information such as:

• The product or subscription purchased.
• Transaction identifiers and purchase dates.
• Purchase status, renewal status and refund information.
• Information needed to restore purchases or confirm entitlements.
• Relevant billing country, currency and tax information, where available.

Purchases made through the Apple App Store or Google Play are subject to the applicable store’s payment processes and privacy practices.

We generally receive transaction and entitlement information needed to administer your purchase. We do not ordinarily receive your complete payment card details when payments are processed directly by an app store.

If you purchase products directly through our website, the payment provider and payment information collected will depend on the payment method and provider used.

3.6 Communications and support

If you contact us, we may collect your email address, the contents of your message, attachments you provide and information needed to respond to your enquiry or resolve a complaint.

We may also retain relevant records of communications relating to purchases, competition eligibility, technical issues or suspected misuse.

3.7 Marketing preferences and notifications

If we offer marketing communications, newsletters or promotional notifications, we may process your contact details and preferences to deliver them.

Where required, we will obtain your consent before sending marketing communications or enabling optional tracking or notifications.

You can withdraw marketing consent or change notification settings as described in this policy or within the relevant service.

3.8 Information from third parties

We may receive information from third parties where necessary to operate our services, including:

• Apple and Google, concerning app distribution and purchases.
• Payment providers, concerning transactions and refunds.
• Geo-blocking providers, concerning approximate location.
• Analytics, hosting, security and technical service providers.
• Competition administrators or verification providers, where applicable.

We will handle such information in accordance with this Privacy Policy and applicable law.

4. How we use personal data

We use personal data for the following purposes:

Providing our services

• Creating or maintaining accounts, where applicable.
• Enabling games and multiplayer sessions.
• Saving scores, displaying leaderboards and maintaining game progress.
• Providing purchased games and managing access entitlements.
• Responding to support enquiries.

Administering competitions

• Recording scores and rankings.
• Determining competition results.
• Checking geographic and other eligibility requirements.
• Detecting cheating, fraudulent participation or manipulation.
• Contacting winners and arranging prize fulfilment.

Operating and improving the App

• Diagnosing technical problems.
• Monitoring reliability and performance.
• Understanding how our games are used.
• Improving game functionality, usability and security.

Managing purchases

• Processing or confirming purchases through the relevant provider.
• Managing subscriptions, access rights and purchase restoration.
• Handling refunds, disputes and customer support.

Security and fraud prevention

• Detecting unauthorised access, abuse and suspicious activity.
• Enforcing our terms of service and competition rules.
• Protecting our users, systems and business.

Communications and marketing

• Sending essential service announcements.
• Responding to enquiries.
• Sending promotional communications where permitted.

Legal and regulatory purposes

• Complying with applicable laws and lawful requests.
• Establishing, exercising or defending legal claims.
• Maintaining records required for tax, accounting or other legal obligations.

5. Legal bases for processing

Where applicable data protection law requires us to identify a legal basis for processing personal data, we rely on one or more of the following, as appropriate:

• Contract: Processing necessary to provide the services or products you request, administer purchases or fulfil our obligations under applicable terms.
• Legitimate interests: Processing necessary for purposes such as securing our services, preventing fraud, maintaining leaderboards, improving performance and defending legal claims, provided those interests are not overridden by your rights.
• Consent: Processing based on your consent, where required, including certain marketing activities or optional tracking technologies.
• Legal obligation: Processing necessary to comply with applicable legal or regulatory requirements.
• Other permitted grounds: Any additional legal basis available under the data protection laws applicable to the relevant processing.

Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

6. Leaderboards and public competition results

Some games and competitions may include leaderboards, rankings or published results.

Where you participate in such features, your display name, score, ranking and other relevant results may be visible to other participants or, where the competition is public, to the wider public.

For competitions involving prizes, we may publish information about winners and winning results to demonstrate the integrity of the competition and communicate its outcome.

Where appropriate, published information may include a winner’s display name, score, ranking and competition result. We will limit the publication of personal information to what is reasonably necessary and permitted by applicable law and the relevant competition rules.

We will not intentionally publish sensitive personal information or unnecessary contact, identity or payment details as part of a leaderboard.

If you do not wish your information to be displayed in a particular public feature, please review the relevant competition rules before participating.

7. Competitions and prize administration

We may operate competitions that are subject to separate competition rules.

For example, the 2026 Cyclic Challenge may impose restrictions relating to Indian citizenship, geographic eligibility, minimum participation requirements or other conditions.

If you participate in a competition, we may process personal data to:

• Register or record your participation.
• Check compliance with eligibility requirements.
• Verify scores and rankings.
• Investigate suspected cheating or rule violations.
• Contact winners and confirm their eligibility.
• Arrange the delivery of prizes.
• Meet tax, accounting or other legal obligations.

If you win a prize, we may request additional information reasonably necessary to verify your eligibility and fulfil the prize, such as your name, contact details, evidence of eligibility and prize-delivery information.

We will explain any additional information required and how it will be used when requesting it.

Where we engage a third party to administer a competition or deliver a prize, relevant information may be shared with that provider as necessary for those purposes.

Competition-specific privacy information or rules may supplement this Privacy Policy.

8. Sharing personal data with third parties

We may disclose personal data to the following categories of recipients where necessary and lawful.

8.1 Service providers

We may use third-party providers for services such as:

• App and website hosting.
• Cloud storage and databases.
• Authentication and account management.
• Geo-blocking and location estimation.
• Analytics and diagnostics.
• Security and fraud prevention.
• Customer support.
• Payment and purchase verification.
• Competition administration and prize fulfilment.

These providers may process personal data on our behalf, subject to applicable contractual, confidentiality and data protection requirements.

8.2 Apple and Google

We distribute the App through the Apple App Store and Google Play.

Apple and Google may process personal data under their own privacy policies when you download, purchase or use our App, or make purchases through their platforms.

We may receive purchase, transaction, device or other information from these platforms where necessary to operate the App and administer purchases.

8.3 Other users and the public

Where a game or competition includes multiplayer features, leaderboards or public results, relevant gameplay information may be shared with other participants or made publicly available as described in this Privacy Policy.

8.4 Professional advisers and authorities

We may disclose personal data to lawyers, accountants, auditors, insurers, regulators, law enforcement agencies or other authorities where reasonably necessary to comply with the law, protect our rights or address suspected wrongdoing.

8.5 Business transfers

If our business or relevant assets are sold, reorganised, merged or transferred, personal data may be disclosed to prospective or actual purchasers and their professional advisers, subject to appropriate confidentiality and legal safeguards.

8.6 Other disclosures

We may disclose personal data for other purposes where you have consented or where disclosure is otherwise permitted or required by applicable law.

We do not authorise third parties to use personal data obtained from us for purposes unrelated to their agreed services, except where permitted by law or separately agreed with you.

9. International transfers of personal data

Our service providers and business operations may be located in countries other than the country in which you reside.

As a result, your personal data may be transferred to, stored in or accessed from other countries, including countries that have different data protection laws.

Where applicable law imposes requirements on international transfers, we will take the steps required by that law. Depending on the circumstances, these may include using appropriate contractual safeguards, relying on an applicable adequacy decision or obtaining consent where legally permitted and appropriate.

You may contact us using the details in Section 2 for further information about relevant international transfers and the safeguards applicable to them.

10. Data retention

We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer period is required or permitted by law.

Retention periods depend on the nature of the information and the purpose for which it is processed.

For example:

• Account information: For as long as necessary to maintain your account and provide the relevant services, subject to applicable retention requirements.
• Gameplay and leaderboard data: For as long as needed to operate games, maintain rankings, administer competitions and preserve legitimate records of results.
• Competition and prize records: For as long as reasonably necessary to verify eligibility, resolve disputes, deliver prizes and comply with legal obligations.
• Transaction records: For the period required for accounting, tax, refund, dispute and other applicable legal purposes.
• Support communications: For as long as necessary to resolve the enquiry and maintain appropriate business records.
• Technical and security logs: For a period proportionate to operational, security and fraud-prevention needs.
• Geo-blocking data: For the period reasonably necessary to enforce geographic restrictions, investigate suspected circumvention and meet applicable legal or regulatory requirements.

Where information is no longer required, we will delete it, anonymise it or otherwise dispose of it securely, subject to applicable law and legitimate retention requirements.

Actual retention periods may vary depending on the system and service provider involved.

11. Cookies and similar technologies

Our website may use cookies, local storage and similar technologies to support its operation and security, remember preferences, understand website usage and, where applicable, deliver analytics or marketing functionality.

Some technologies may be essential to provide the website or a feature you request. Others may be optional and require consent under applicable law.

You may be able to manage cookies through your browser settings or through a cookie preference tool provided on our website.

Disabling certain cookies may affect website functionality.

The App may use separate technical mechanisms, such as device identifiers or diagnostic tools, which are not necessarily controlled through browser cookie settings.

Where we use analytics or advertising technologies, we will provide additional information about the relevant providers and choices where required by applicable law.

12. Marketing and notifications

We may send you service-related communications, such as security notices, purchase confirmations, important updates and information necessary to operate the App.

Where permitted, we may also send promotional messages about new games, features, competitions or offers.

You can unsubscribe from marketing emails using the instructions included in the message. You can also adjust push notification permissions through your device settings or the relevant App settings, where available.

Even if you opt out of marketing, we may continue to send essential service communications where necessary.

13. Data security

We take reasonable technical and organisational measures designed to protect personal data against unauthorised access, disclosure, alteration, loss or destruction.

Depending on the circumstances, these measures may include access controls, authentication, encryption, secure development practices, monitoring, backups and contractual safeguards with service providers.

No system, network or method of electronic storage or transmission is completely secure. We therefore cannot guarantee absolute security.

You should protect your account credentials and avoid sharing information that you do not wish other users to see.

If we become aware of a personal data breach, we will assess and respond to it in accordance with applicable legal requirements, including any notification obligations.

14. Your privacy rights

Depending on your location and the laws applicable to you, you may have rights relating to your personal data, including the right to:

• Request access to personal data we hold about you.
• Request correction of inaccurate or incomplete information.
• Request deletion of personal data in certain circumstances.
• Request restriction of, or object to, certain processing.
• Withdraw consent where processing is based on consent.
• Request a copy of certain information in a portable format.
• Object to direct marketing.
• Complain to a relevant data protection authority.
• Exercise additional rights provided by applicable law.

These rights are subject to applicable legal conditions and exceptions. We may need to verify your identity before responding to a request.

To exercise your rights, please contact us at hello@cyclicdigital.com.

We will respond within the period required by applicable law. We will not unlawfully discriminate against you for exercising your privacy rights.

If we cannot comply with a request, we will explain the position where required by law.

15. India-specific privacy matters

Some of our competitions or services may be restricted to participants in India.

Where Indian data protection law applies to our processing, we will handle personal data in accordance with the requirements applicable to our organisation and the relevant activity.

Depending on the applicable law and circumstances, individuals may have rights to access information about processing, request correction or erasure, withdraw consent where relevant, raise grievances and exercise other statutory rights.

For privacy-related requests or complaints, contact hello@cyclicdigital.com. We will provide any additional grievance contact details or procedures required by applicable law.

Where a competition is restricted to Indian citizens, geo-blocking alone will not be treated as conclusive proof of citizenship. Any additional identity or eligibility checks will be conducted in accordance with the applicable competition rules and legal requirements.

16. Children’s privacy

Our games may appeal to families and younger players. However, the availability of a game does not mean that every age group may use every feature without restriction.

Our services must be used in accordance with the minimum-age requirements and parental-consent rules applicable in the user’s jurisdiction and under the relevant app store’s policies.

Where required by law, we will obtain appropriate parental or guardian consent before collecting or processing a child’s personal data.

We do not knowingly collect children’s personal data in circumstances where doing so would be unlawful. If you believe a child has provided personal data in breach of applicable requirements, please contact us so that we can investigate and take appropriate action.

Parents or guardians who have questions about a child’s use of our services may contact us at hello@cyclicdigital.com.

17. Third-party websites and services

Our website and App may contain links to, or integrate with, third-party websites, platforms or services.

Those third parties may process personal data under their own privacy policies and terms. We are not responsible for the privacy practices of independent third parties, except to the extent required by applicable law.

We encourage you to review the privacy information provided by any third-party service you use.

18. Automated processing and fraud prevention

We and our service providers may use automated technical checks to support security, detect suspicious activity, identify possible cheating or enforce geographic restrictions.

Such checks may use technical information, gameplay patterns, transaction status or location estimates.

Where a decision has a legal or similarly significant effect on an individual and applicable law imposes specific requirements on automated decision-making, we will comply with those requirements.

If you believe that an automated check has incorrectly restricted your access or affected your competition eligibility, you may contact us at hello@cyclicdigital.com to request a review, subject to the applicable rules and law.

19. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our services, technology, business arrangements or legal obligations.

When we make changes, we will update the “Last updated” date at the beginning of the policy.

Where required by law, we will provide additional notice or seek consent for material changes.

The updated policy will be made available through our website or another appropriate channel. We encourage you to review it periodically.

20. Contact us

If you have questions, concerns or requests relating to this Privacy Policy or the handling of your personal data, please contact:

Cyclic Games
Legal entity: Life Transformations Limited
Email: hello@cyclicdigital.com
Address: 2302, Tung Chiu Commercial Centre, 193 Lockhart Road, Wan Chai, Hong Kong, Hong Kong SAR, China
Website: cyclicdigital.com

We will review and respond to privacy enquiries in accordance with applicable law.