Privacy Policy

Effective date: September 18th, 2025

Navarro Studios sàrl (“us”, “we”, or “our”) operates the FleepFly ™ mobile application and www.fleepfly.com website (hereinafter referred to as the “Service”).

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

1. Definitions

Service

The Service refers to the “FleepFly™” mobile application, any related products, and all other content associated with www.fleepfly.com.

Personal Data

Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data

Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies

Cookies are small files stored on your device (computer or mobile device).

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you. We receive and store any information you knowingly provide to us when you create an account, or fill any online forms in the Mobile Application and Service.

2. Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

  • Name
  • Email address
  • Age
  • Language
  • Cookies and Usage Data

Usage Data

When you access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, date, time, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data (“Usage Data”).

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.

Use of Data

  • We use the collected data for various purposes:
  • To provide and maintain the Service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer care and support
  • To provide analysis or valuable information so that we can improve the Service
  • To monitor the usage of the Service
  • To detect, prevent and address technical issues
  • To use the winner’s name and, where applicable, image in publicity materials related to competitions, provided that the winner (or their parent/legal guardian if under 18) has given explicit consent.

Any of the information we collect from you may be used to personalize your experience; improve our Mobile Application; improve customer service and respond to queries and emails of our customers; send notification emails such as password reminders, updates, etc; run and operate our Mobile Application and Service. Information collected automatically is used only to identify potential cases of abuse and establish statistical information regarding Mobile Application traffic and usage. This statistical information is not otherwise aggregated in such a way that would identify any particular user of the system unless it concerns a misusage of the Mobile Application and Service by a user attempting to cheat, hack or compromise the normal use of the Mobile Application and Service .

We may process Personal Data related to you if one of the following applies: (i) You have given your consent for one or more specific purposes. Note that under some legislations we may be allowed to process information until you object to such processing (by opting out), without having to rely on consent or any other of the following legal bases below. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law; (ii) Provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof; (iii) Processing is necessary for compliance with a legal obligation to which you are subject; (iv) Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; (v) Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party. In any case, we will be happy to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Competition Participation

  • Competitions are open to players 18+, or under 18 with parental/guardian consent.
  • Winners are contacted by email and must claim prizes within 28 days.
  • Prizes are distributed through Google Play or Apple Gift Cards, or an alternative method where not available.
  • Fraudulent activity (cheating, score manipulation) may lead to disqualification and a permanent ban.

For full details, see our Competition Rules.

3. Users rights

You have certain rights regarding the Personal Data we process about you. These include:

  • Withdraw consent: You may withdraw your consent at any time where processing is based on consent.
  • Object to processing: You may object to the processing of your data where it is carried out on a legal basis other than consent.
  • Access your data: You have the right to know whether we process your Personal Data, to receive details about such processing, and to obtain a copy of the data we hold about you.
  • Rectification: You may request that we update or correct inaccurate or incomplete information.
  • Restriction of processing: In certain circumstances, you may request that we limit the processing of your data, in which case we will only store it.
  • Erasure: In certain circumstances, you may request the deletion of your Personal Data.
  • Data portability: Where technically feasible, you have the right to receive your Personal Data in a structured, commonly used, and machine-readable format and to have it transferred to another controller. This applies when processing is carried out by automated means and is based on your consent, a contract with you, or related pre-contractual obligations.

Exercising these rights may limit access to certain features or services, but you will not be denied access to the Service solely for exercising your data protection rights.

4. Transfer Of Data

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside Switzerland and choose to provide information to us, please note that we transfer the data, including Personal Data, to Switzerland and other countries and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Navarro Studios sàrl will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

5. Disclosure Of Data

Legal Requirements

We may disclose your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of Navarro Studios sàrl
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of users of the Service or the public
  • Protect against legal liability

In addition, Personal Data of competition winners (such as name and image) may be disclosed for publicity purposes in accordance with these Terms and Conditions.

If you are an EU or EEA resident, you have specific rights under the GDPR. You also retain rights under Swiss law and other applicable data protection regulations.

Security of Data

The security of your data is important to us, but please remember that no method of transmission over the Internet or method of electronic storage is 100% secure.

We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards to protect against unauthorized access, use, modification, and disclosure of Personal Data in our control and custody. However, no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your Personal Data, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and our Mobile Application and Service cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party, despite our best efforts.

6. Data breach

In the event we become aware that the security of the Mobile Application or Service have been compromised or users Personal Data has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make

reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice in the Mobile Application or on Service, send you an email.

7. Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

Unity Analytics

Unity Analytics is provided by Unity Technologies.

For more information on what type of information Unity Analytics collects, please visit their Privacy Policy page: https://unity3d.com/legal/privacy-policy

Google Analytics

Google Analytics is provided by Google Inc..

For more information on what type of information Google Analytics collects, please visit their Privacy Policy page: https://policies.google.com/privacy

8. Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit and we encourage you to be aware when you leave our Mobile Application or Service and to read the privacy statements of each and every mobile application that may collect Personal Data.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites, mobile applications or services.

9. Children's Privacy

Our Service may be accessed by individuals under the age of 18 (“Children”); however, participation in competitions is limited to users aged 18 and above, or to those under 18 who have obtained the explicit consent of a parent or legal guardian.

Children under the age of 13 may only use the Service with the supervision and explicit consent of a parent or legal guardian.

We provide additional privacy protections for children and do not knowingly collect more Personal Data than is reasonably necessary to operate the Service. We also do not knowingly collect Personal Data from anyone under 18 without parental or guardian consent.

Parents and guardians have the right to review their child’s information, request its deletion, and refuse further collection or use of such information. We encourage children to consult with their parents before submitting any information to our Service or other online platforms, and we encourage parents to take an active role in their children’s online activities.

If you are a parent or guardian and believe your child has provided us with Personal Data without your consent, please contact us. If we become aware that we have collected Personal Data from a child without proper parental consent, we will take immediate steps to delete that information from our servers.

10. Legal disclosure

In the event we go through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, your user account, and Personal Data will likely be among the assets transferred.

11. Changes to This Privacy Policy

We may update our Privacy Policy from time to time in our discretion. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

Any updated version of this Privacy Policy will be effective immediately upon the posting of the revised Privacy Policy unless otherwise specified. Your continued use of the Mobile Application or Service after the effective date of the revised Privacy Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Data in a manner materially different than what was stated at the time your Personal Data was collected.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

12. Acceptance of this policy

You acknowledge that you have read this Policy and agree to all its terms and conditions. By using the Mobile Application or Service you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to use or access the Mobile Application and Service.

13. Contact Us

You may contact us exclusively through the contact form available on our official website www.fleepfly.com.

This form constitutes the sole official channel of communication for any inquiries relating to the Service or the protection of personal data.