Privacy policy

Who is responsible

tPiy Inc., Uptown Tower, Level 12, Dubai, United Arab Emirates (“tPiy”, “we”) is the controller of the personal data described in this policy. For the player data that the tPiy SDK collects in a game, see below whether tPiy shares this role with the game’s publisher (as joint controllers).

tPiy is based in the United Arab Emirates. It is a separate company from Zuuks, the studio that makes the games, although both companies have the same owners. Zuuks is responsible for the data that the games themselves collect; please see the privacy policy in each game.

Privacy questions and requests: [email protected]. Business and press: [email protected].

To be announced Whether tPiy alone is responsible for the player data the tPiy SDK collects in a game, or shares that responsibility for part of it with the game’s publisher (joint controllers under Article 26 GDPR), is to be announced on this page. Whatever the answer, you can exercise all your rights with us at [email protected].

To be announced Our representative in the European Union under Article 27 GDPR: to be announced. Their name and contact details will be published here. Until then, please contact us directly at [email protected].

To be announced For users in Türkiye: our registration in the Data Controllers’ Registry (VERBİS) and, where required, our data controller representative in Türkiye under the Personal Data Protection Law No. 6698 (KVKK) are to be announced on this page.

Players: games that show tPiy ads

This section applies to you if you play a game that shows tPiy ads. Today these are only games by Zuuks.

How tPiy ads work

The tPiy SDK is a software component inside the game. When you start the game, or return to it after more than 30 minutes, the SDK asks our server once whether there is an ad for this session.

If there is an ad, its files are downloaded to your device in the background and the ad is shown at a natural break, or when you choose to watch a video for a reward. Every tPiy ad is labelled “Ad” and has a “Why this ad?” button that opens this page. If there is no tPiy ad, the game continues with its other ad partners, whose own privacy policies apply.

Two modes: limited and personalised

At the start of every session our server decides, from the signals that the game and your device send, which of two modes applies to you.

Limited mode — the default

We use only what we need to deliver ads, limit how often you see them, prevent fraud and measure results. Ads are chosen by context — the game, your country, language, device and connection. No profile is built.

Personalised mode — only with your active consent

We also collect information about how you play and build a profile to choose ads for you. This mode applies only when all of these are true:

you are not known to be under 18 (the game tells us whether you are an adult, a minor or of unknown age), and the game is not directed at children — also not as part of a mixed audience;
you have not refused consent in the game;
on iOS, you allowed the game to track you (“Allow” in the App Tracking Transparency prompt);
on Android, you consented to personalised ads in the game’s privacy dialog, ad tracking is not limited on your device and you have not deleted your advertising ID;
in the European Economic Area, the United Kingdom, Switzerland and Türkiye — and whenever your country is unknown or the game reports that the GDPR applies — you have also consented to personalised ads in the game’s privacy dialog (on iOS, in addition to allowing tracking);
if your device holds an IAB Transparency and Consent Framework (TCF) consent string, it records your consent to TCF purposes 1, 3 and 4 (storing or accessing information on a device, creating a personalised advertising profile, and using it to select ads) — a TCF string that refuses any of them makes the session limited;
in the United States, no opt-out signal is present: an opt-out of sale, sharing or targeted advertising in a US Privacy string or in the US national section of a GPP string. We do not yet read the GPP sections of individual US states.

If any of these is not true, or if you have objected to the use of your data (see Your player ID), the session is in limited mode. You can switch to limited mode at any time — see Your choices.

Consent given only through the IAB Transparency and Consent Framework (TCF), for example to TCF purposes, does not count on its own: tPiy is not on the TCF vendor list. A refusal given through the TCF, however, is respected (see above).

What we collect in limited mode

In limited mode the SDK sends us the data below. It never collects your name, e-mail address, precise location (GPS), contacts, photos or any other content of your device.

Device and app information

Operating system and version, device model and type (phone or tablet), screen, language, time zone and connection type (Wi-Fi or mobile); the game’s package name and version, and the SDK version.

When: With every request.
Why: To choose an ad that suits your device and language, and to check that the request comes from a genuine, registered game.

IP address

The internet address your device uses to connect.

When: With every request. tPiy does not store the address itself.
Why: Cloudflare, which delivers our service, passes the address to us with every request, together with the approximate location it derives from it (such as city, region, postcode, coordinates and time zone). Of this location we keep only your country (in personalised mode also your region and city). We use the address to detect fraud and abuse and keep only a keyed hash of it: the hash lets us recognise repeated requests, and only someone holding our secret key could match it to an address. We do not look up your network operator.

Install ID

A random identifier that the SDK creates the first time it runs in a game. It is not derived from your device or from you and differs in every app, so it cannot be matched across apps. It is deleted with the game’s data, and reinstalling the game creates a new one (restoring the game’s data from a backup can bring back the old one).

When: With every request — also when you have not given consent.
Why: To limit how often you see the same ad and to detect fraud. When no advertising ID is available, it takes its place; in personalised mode, your profile is keyed by it only if there is neither an advertising ID nor an IDFV.

Advertising ID (Android advertising ID, iOS IDFA)

The resettable identifier that your device provides for advertising.

When: Only if your device provides it (on iOS, only if you allowed the game to track), you have not refused consent in the game and you are not known to be under 18. In the EEA, the UK, Switzerland and Türkiye we store it only if you have also consented in the game’s privacy dialog; otherwise it is not stored, not even as a hash (if the game has not asked for your consent yet, the SDK may still send it, and our server discards it).
Why: To limit how often you see the same ad, to detect fraud and to measure installs from Zuuks cross-promotion.

IDFV (iOS only)

An identifier that iOS gives to all apps of the same developer on your device.

When: Only if you have not refused consent in the game and are not known to be under 18. In the EEA, the UK, Switzerland and Türkiye we store it only if you have consented in the game’s privacy dialog; otherwise it is not stored, not even as a hash (if the game has not asked for your consent yet, the SDK may still send it, and our server discards it).
Why: To measure installs from one Zuuks game to another (cross-promotion).

Player ID

The ID of your game account (for example your Zuuks player ID), if the game gives it to the SDK.

When: With reward events, clicks and the first launch of a game — also when you have not given consent; in personalised mode also with the session request.
Why: To deliver the rewards you earn and to measure installs from Zuuks cross-promotion; in personalised mode it is also stored on your profile. See Your player ID.

Ad events

Which ads were planned, downloaded, shown, clicked, watched to the end, rewarded or failed, with the time and the ad placement in the game; for rewards, the reward and any extra (“custom”) data the game attaches to it; and, for frequency limits, the tPiy ads shown on your device in the last 24 hours.

When: When these events happen.
Why: To bill advertisers, pay publishers, deliver rewards, limit how often you see an ad, prevent fraud and produce statistics.

Privacy signals

Your consent choice from the game’s privacy dialog and your age group, your iOS tracking permission, your “limit ad tracking” setting, any IAB TCF consent string on your device, and US opt-out signals (a US Privacy string or the US national section of a GPP string).

When: With every request.
Why: To decide the mode of your session and to respect your choices.

What we add in personalised mode

Identifiers: your advertising ID (IDFA or Android advertising ID) and IDFV, stored as they are (not hashed), together with your install ID and player ID.
One profile per device: your profile is keyed by your advertising ID — or, if there is none, by your IDFV, and otherwise by your install ID — never by your player ID. The advertising ID is the same in all apps on your device and the IDFV in all Zuuks games on an iPhone or iPad, so the profile covers the Zuuks games on that device. If that identifier changes, for example because you reset your advertising ID, a new profile is started. We do not combine the profiles of different devices, even if they have the same player ID.
Device details: device model, operating system version, screen size, language, time zone, connection type and app version.
Age group as the game reports it (adult or unknown age).
Approximate location: your region and city, in addition to your country. Cloudflare derives the location from your IP address and passes it to us; we keep only these parts of it and do not store the IP address itself.
Sessions: when you start playing and how long you play.
Game progress, such as your level.
In-app purchases: the product, its price in US dollars and the local price and currency, as reported by the game (not checked against the store receipt). We use them for spending segments such as “payers”. Never payment card numbers or other payment details.
Game events that the game chooses to send, for example reaching a milestone.
All ad interactions: impressions, completed videos, clicks, store page views and installs.

Your profile and audience segments

In personalised mode we combine this data into a player profile and place you in audience segments. We use the profile to choose which ads to show you (personalised advertising), to measure the results of ads and to prevent fraud.

Examples of segments:

Payers
High spenders
New players
Highly engaged players

Advertisers can choose to show their ads to a segment, but from tPiy they receive only aggregated reports — never your profile, your identifiers or your identity. (What an advertiser’s measurement partner can receive when you tap an app ad is explained under When you tap an ad.) We do not use special categories of personal data (such as health, religion or political opinions), and we take no decisions about you that have legal or similarly significant effects.

When you withdraw consent, your next session is in limited mode and your profile is no longer updated. To have it deleted, send us a deletion request.

Your player ID

If the game gives your player ID to the SDK, it is sent with reward events, with clicks and with the first launch of a game — in both modes, also when you have not given consent — and in personalised mode also with the session request. We use it for two purposes:

Rewards. When you finish a rewarded video, we pass your player ID, the reward, any extra data the game attached to it and a transaction number to the game’s server, run by Zuuks as the publisher, so that the game can credit the reward to your account. Legal basis: contract — delivering the reward you chose to watch the ad for.

Cross-promotion measurement. Whenever you tap an ad for an app — from any advertiser — we keep a click record with keyed hashes of your player ID, IDFV and advertising ID (those we receive and may use) for 8 days. When you then open a Zuuks game for the first time, we compare these hashes to count the install for that Zuuks campaign. We look for matches within 7 days, only between Zuuks games. This is a deliberate decision; the legal basis is our and Zuuks’ legitimate interest in measuring Zuuks’ own cross-promotion.

In personalised mode your player ID is also stored on your profile (legal basis: your consent), but your profile is never keyed by it. It is never given to advertisers.

You can object at any time. Send an objection through the privacy request form or to [email protected] with your player ID and the game. We then put keyed hashes of your identifiers on an objection list, which we keep until you withdraw your objection: from then on all your sessions are in limited mode, and your player ID is no longer used for cross-promotion measurement. Rewards from tPiy ads cannot reach your account without the player ID, so it is still passed to the game’s server when you earn a reward.

What we do not do

We never build a profile of you without your active consent, never for players known to be under 18 and never in apps directed at children.
We never collect your name, precise location (GPS), contacts, photos or payment card details through the SDK.
We do not sell personal data, and we never give advertisers your profile, your identifiers or your identity. (What reaches an advertiser’s measurement partner directly from your device in personalised mode is described under When you tap an ad.)
We do not use special categories of personal data for advertising, and we do not combine tPiy data with data from apps other than the Zuuks games that show tPiy ads, or with data from data brokers.

When you tap an ad

If the ad promotes an app, tapping it opens the app’s App Store page inside the game (iOS) or the Google Play app (Android). Depending on the game’s settings, the store page may also open automatically at the end of a video ad. Ads for websites open the website in a browser inside the game.

The advertiser’s tracking link — personalised mode only. Many advertisers measure the installs of their app with a measurement partner such as AppsFlyer or Adjust. If an advertiser has given us such a tracking link for its app ad and your session is in personalised mode, the SDK calls this link in the background, from your device, when you tap the ad and when its store page opens by itself. The call gives the measurement partner your IP address and your device’s user agent (a technical description of the software making the call), which it can use to link the tap to a later install of the app. tPiy adds no identifier of yours, such as your advertising ID or player ID, to the link. Legal basis: your consent to personalised ads.

In limited mode the SDK never calls the tracking link in the background. In either mode, if the app’s store page cannot be opened directly — for example because the advertiser gave us no store address for the app, only its tracking link — tapping the ad may open that link in your browser, which then takes you to the store. As with any web page you open, the measurement partner then receives your IP address and your browser’s user agent.

From that moment the store’s, the advertiser’s or its measurement partner’s own privacy policy applies; tPiy does not control what they collect.

Children and minors

All Zuuks games that show tPiy ads are rated for ages 13 and older, and only ads rated for everyone or 12+ are shown in them.

Players known to be under 18 are always in limited mode: no profile, no segments and no personalised ads. The game tells us whether a player is an adult, a minor or of unknown age.

For apps that are directed at children or at a mixed audience, tPiy stores no device identifiers and no hashes of device identifiers or IP addresses, and does not measure installs; apps directed at children receive only ads rated for everyone. In these apps the player ID is stored and used only with reward events and the reward notification to the game’s server, so that the game can deliver the reward.

If you believe we hold data of a child, please write to [email protected] and we will delete it.

Legal bases

Where the GDPR, the UK GDPR, the Swiss Federal Act on Data Protection, Türkiye’s KVKK or similar laws apply, we rely on these legal bases (see also the notes after the list):

Personalised mode: collecting the additional data, building your profile and segments, showing personalised ads, and calling an advertiser’s tracking link when you tap an app ad: Your consent — under the GDPR, the UK GDPR and the KVKK your explicit consent, given in the game’s privacy dialog (on iOS together with your tracking permission). You can withdraw it at any time; this does not affect earlier processing.
Limited mode: choosing and delivering contextual ads (device and app information, IP address for the country, ad events): Our legitimate interest in offering advertising that keeps games free. For storing the install ID and the ad history on your device, see the note on storage on your device below.
Frequency capping, fraud prevention and measurement, including matching cross-promotion installs with the player ID: Our legitimate interest, and that of advertisers, publishers and Zuuks. You can object — see Your player ID.
Reward notifications with your player ID to the game’s server: Contract: delivering the reward you chose to watch the ad for.
Advertising ID and IDFV in limited mode: Outside the EEA, the UK, Switzerland and Türkiye: our legitimate interest in frequency capping, fraud prevention and measurement. On iOS the advertising ID is available only if you allowed tracking, and you can always switch it off in your device settings. In the EEA, the UK, Switzerland and Türkiye we store these identifiers only with your consent; without it they are not stored, not even as a hash (if the game has not asked for your consent yet, the SDK may still send them, and our server discards them).
Handling your requests, reports and messages: Our legal obligations (for example under the GDPR and the Digital Services Act) and our legitimate interest in answering you.

To be announced We store the install ID, the list of tPiy ads shown and the SDK’s other files on your device (see How long we keep data) without asking for your consent, because we consider this storage strictly necessary to provide the ad service (an exemption in the EU ePrivacy rules and the national laws that implement them). Whether this exemption applies, or consent is needed, is being reviewed by our legal advisers; the outcome is to be announced on this page.

To be announced The legal bases above are our own assessment and have not yet been confirmed by our legal advisers. The result of their review is to be announced on this page.

How long we keep data

Ad events stay in our database for 14 days, with keyed hashes of the device identifier and the IP address, the player ID and any extra reward data from the game. They then move to a closed archive that holds all identifiers, including the player ID, only as keyed hashes and keeps the extra reward data only hashed or not at all, and are deleted after 13 months.
Personalised-mode behaviour (sessions, game progress, purchases and game events) is kept for up to 25 months in an archive that is encrypted with our own key and holds identifiers only as keyed hashes.
Your profile is deleted 13 months after we last saw you in a Zuuks game.
A deletion request removes your profile and anonymises or deletes everything we can link to you: ad events and their archive, the behaviour archive, click and install records, reward notifications and reach records. Ad events that still arrive from sessions started before the deletion are anonymised in the same way and kept only for billing; behaviour data from those sessions is discarded. Deleted data disappears from our database change log within 3 days and from our encrypted database backups within 35 days. To keep the deletion applied, we keep a keyed hash of the deleted identifiers for 26 months. Our audit log, which cannot be changed, permanently keeps keyed hashes of the identifiers we looked up, deleted or put on the objection list. The record of your request keeps the identifiers you gave us for 3 years after the request is closed, and the alert e-mail about it stays in our sending queue for 90 days (for copies in our mailboxes, see Visitors of this website). If you later start a session with consent again, a new profile is started.
Objection list: if you object, keyed hashes of your identifiers stay on our objection list until you withdraw your objection.
Click records, which we keep for every tap on an app ad — from any advertiser — with keyed hashes of your player ID, IDFV and advertising ID, are deleted after 8 days; matched installs after 90 days.
Reward notifications to the game’s server, which contain the player ID and any extra reward data, are kept for 30 days.
Reach records: to count how many different devices saw a campaign each day, we keep a keyed hash of the device for each campaign and day, for 100 days.
Aggregated statistics (for example impressions per campaign, game, country and day) contain no device identifiers or player IDs and are kept for billing and reporting.
Database change log and backups: our database keeps a log of its changes, used for its replica and for recovery, for 3 days; our encrypted database backups expire after 35 days.
On your device, the SDK keeps the following in the game’s data until you delete it: the install ID, in a small state file that also records the mode our server last decided and whether the game’s first launch has been reported for install measurement; the list of tPiy ads shown in the last 24 hours; ad events waiting to be sent; and behaviour (sessions, progress, purchases, game events) recorded before our server has decided the mode of your session, or waiting to be sent in personalised mode — it is sent only if the mode is personalised and deleted otherwise. Waiting ad events and behaviour are discarded once they are more than 24 hours old. Downloaded ad files are cached (up to 150 MB) and the oldest are removed first.

Who receives data

Zuuks, as the publisher of the game, receives your player ID, the reward and a transaction number when you earn a reward, so that the game can give it to you, and aggregated statistics about the ads in its games. The SDK also tells the game the revenue of each ad shown, which the game may record in its own analytics under its own privacy policy.
Zuuks, as our service provider (processor): our file storage, archives and backups are kept in a Cloudflare account that tPiy shares with Zuuks, and Zuuks may host a replica of our database. See International transfers for the agreement that governs this.
Cloudflare, Inc. (United States) delivers our service: content delivery network, DNS, security and file storage. Requests from the game reach us through Cloudflare, which passes us your IP address with every request, together with the approximate location it derives from it (such as city, region, postcode, coordinates and time zone); we keep only your country (in personalised mode also region and city) and a keyed hash of the address. Ad files are delivered through Cloudflare, and our archives — including the encrypted behaviour archive of personalised mode — and our encrypted database backups are stored with Cloudflare.
Advertisers can target segments but receive from tPiy only aggregated statistics — never your profile, your identifiers or your identity.
Advertisers’ measurement partners (such as AppsFlyer or Adjust) receive your IP address and your device’s user agent when the SDK calls an advertiser’s tracking link from your device — in personalised mode only, when you tap the app ad or its store page opens by itself — and, in either mode, when tapping an ad opens such a link in your browser because the store page cannot be opened directly. See When you tap an ad.
Authorities and courts, when the law requires it.
We do not sell personal data.

To be announced Our server hosting provider, which runs the servers of our database and ad service: the provider and the server location are to be announced on this page.

International transfers

tPiy is based in the United Arab Emirates, and our service providers work in several countries, including the United States (Cloudflare). Your data may therefore be processed outside your country, including outside the EU, the UK and Türkiye.

To be announced The agreement between tPiy and Zuuks on the processing Zuuks carries out for us, and the safeguards we use for transfers of personal data to other countries (such as standard contractual clauses), are to be announced on this page.

Your choices

Withdraw consent / switch to limited mode: use the game’s privacy settings; on iOS, open Settings › Privacy & Security › Tracking and turn tracking off for the game; on Android, open Settings › Privacy › Ads and delete your advertising ID. Your next session is then in limited mode and your profile is no longer updated. Menu names vary by device.
Delete your data: send a deletion request. We delete your profile and anonymise or delete everything we can link to you — see How long we keep data. If you later play with consent again, a new profile is started.
Install ID: delete the game’s data or reinstall the game, and a new random install ID is created.
Object: send an objection through the privacy request form. We put your identifiers on an objection list: from then on you are always in limited mode, and your player ID is no longer used for cross-promotion measurement — see Your player ID.

Your rights

Depending on where you live — for example under the GDPR in the EU, the UK GDPR, Türkiye’s KVKK or the privacy laws of US states — you have the right to access your data, to have it corrected or deleted, to restrict or object to its use, to receive it in a portable format, to opt out of targeted advertising and to withdraw consent at any time (this does not affect earlier use). You also have the right to complain to your data protection authority. If you object, we put your identifiers on our objection list, as described under Your choices.

How to exercise them: use the privacy request form or write to [email protected]. To find your records we need an identifier: your install ID (some games show it on their support screen), your player ID, your advertising ID, or the e-mail address of your game account together with the game’s name — we then ask Zuuks for the matching player ID.

We may ask you to confirm that the data is yours. We answer within one month; for complex requests we may need up to two more months and will tell you why.

Advertisers and publishers: our panels

This section applies to people who use the advertiser panel (ads.tpiy.com) or the Monetize panel (monetize.tpiy.com) for their company.

What we collect

Account data: your name, business e-mail address, role in your organisation, language, time zone and notification settings. Your password is stored only as a strong one-way hash.
Two-step verification: the secret of your authenticator app, stored encrypted. Two-step verification is mandatory for owners and finance users.
Organisation data: company name, country, tax number, billing address and e-mail, website; for publishers also bank details (IBAN, SWIFT) for payouts.
Security data: failed sign-in attempts, counted per e-mail address and per network and stored only as keyed hashes (no IP address is stored for this, and the alert our team receives when a staff account is locked does not contain the network address), to stop password guessing; and, for each signed-in session, your browser’s user agent.
Access log: our web server records each request to the panels — time, address requested, response status, referring page and your browser’s user agent — to run and protect the service. The network address in this log is that of Cloudflare’s server, not yours.
Audit log: a record of every change made in the panels — who, what and when. It cannot be edited or deleted.
Business records: campaigns, creatives, apps, credit top-ups, invoices, payouts and our correspondence with you.

Why we use it

To provide the panels under our contract with your company — legal basis: performance of the contract and our legitimate interest in working with the people your company appoints.
To keep accounts and money safe, prevent fraud and trace changes — legal basis: legitimate interest.
To keep invoices and accounting records — legal basis: legal obligation.
To send service e-mails such as invitations, password resets, credit warnings and invoice notices. We send marketing e-mails only with your permission.

The panels’ one cookie

The panels set one cookie, and it is strictly necessary: tpiy_rt, a secure, HttpOnly sign-in cookie that keeps you signed in. It is sent only to the sign-in service, ends when you sign out or your sign-in expires, and is never used for analytics or advertising.

The panels also keep a few preferences in your browser’s local storage — language, light or dark theme, the organisation you last selected and a sign-in hint. These stay on your device. The panels contain no analytics and no third-party trackers.

How long we keep it

Account and organisation data: while the account is open, and afterwards for as long as needed for legal claims and legal obligations.
Invoices and accounting records: as long as tax and accounting law requires.
The audit log is kept permanently, because it documents financial and security events.
Sign-in tokens are deleted 7 days after they expire; service e-mails in our sending queue after 90 days; the access log of our web server after 14 days.

Who receives it

Cloudflare (delivery, security and storage of creatives, invoices and contracts), our server hosting provider, our e-mail provider (see Visitors of this website) and Zuuks as our service provider (see Who receives data).
Banks, for payments and payouts; our accountants and tax advisers; authorities when the law requires it.
Other users in your own organisation, according to their roles.

You have the same rights as described above; write to [email protected].

Visitors of this website

This website (tpiy.com) uses no cookies, no analytics and no third-party scripts, fonts or embeds. All its files, including fonts, are served from tpiy.com. Each language is a separate page, so we do not need to remember your choice.

Like any website, tpiy.com is delivered by a hosting provider — Cloudflare — which processes technical data such as your IP address and browser type to deliver the pages and protect them against attacks.

Forms. When you send a form (contact, request access, report an ad, privacy request), what you enter goes directly to our own server at ads.tpiy.com. It stores your message, sends you a confirmation e-mail that contains only the reference number, and e-mails the contents to our team at [email protected] (reports and privacy requests) or [email protected] (contact and access requests); these e-mails stay in our sending queue for 90 days, and their copies in the [email protected] and [email protected] mailboxes are deleted after 12 months. To prevent spam and abuse we also keep a keyed hash of your network address for 30 days. Our web server’s access log records the request (time, address requested, referring page and browser user agent; the network address in it is Cloudflare’s, not yours) for 14 days. We use the data only to handle your message. We keep contact messages for 2 years after we have dealt with them, and reports and privacy requests — including the identifiers given in a privacy request — for 3 years after they are closed, to document how we handled them. Legal basis: our legitimate interest in answering you, steps before a contract, or our legal obligations (for reports and privacy requests).

To be announced Our e-mail provider, which delivers our e-mails and hosts our mailboxes ([email protected], [email protected]), and so receives what you send us through the forms: the provider and its location are to be announced on this page.

Changes to this policy

We may update this policy when our service or the law changes. We will publish the new version here with a new effective date. If a change is significant, we will inform panel users by e-mail; if a change needs your consent, we will ask for it.

Contact

tPiy Inc., Uptown Tower, Level 12, Dubai, United Arab Emirates.

Privacy requests and questions: [email protected] or the privacy request form. Business, press and authorities: [email protected].