Privacy Policy

Last updated: 29 May 2026

This Privacy Policy explains how Pomu Network Ltd, having its registered office at Poseidonos Ave 59, Paphos 8042, Cyprus (hereinafter referred to as "POMU", "we", "us" or "our"), collects, uses, stores and protects personal data when users access or use our websites, games, services, content and related online features (collectively, the "Websites").

We are committed to protecting the privacy of our users and handling personal data with care, transparency and respect. We do not collect more personal data than is reasonably necessary for the purposes described in this Privacy Policy.

1. Data controller

This Privacy Policy applies when POMU acts as a data controller with respect to your personal data. This means that we determine the purposes and means of processing personal data collected through our Websites.

2. Information we collect

We may collect information when you use or access our Websites. This information may relate to the way you use our Websites, the device you use, and any information you choose to provide to us.

The information we may collect includes, among others:

• IP address
• Browser type and version
• Device type, operating system and user agent
• Approximate geographic location based on IP address
• Referral source, pages visited, website navigation paths and interaction data
• Date, time, frequency and duration of visits
• Information collected through cookies, pixels, tags or similar technologies
• Information you provide when filling in online forms, surveys, support requests or contact forms
• Email address, where you choose to provide it
• Communications exchanged with us by email, chat, support channels or social media
• Information received from advertising networks, analytics providers, payment providers or other third-party service providers

3. When we collect information

We may collect information when you visit our Websites, play or interact with games or content, subscribe to a newsletter, contact us, respond to surveys or marketing communications, interact with advertisements, or otherwise provide information to us.

4. How we use your information

We may use the information we collect for the following purposes:

• To provide, operate, maintain and improve our Websites
• To personalize your experience and deliver content that may be relevant to you
• To analyze traffic, usage patterns, user behavior and Website performance
• To detect, prevent and troubleshoot technical issues, abuse, fraud or security incidents
• To respond to inquiries, support requests and other communications
• To administer surveys, promotions, contests or other Website features
• To send service-related or marketing communications, where permitted by law
• To measure and improve advertising campaigns
• To comply with legal obligations and enforce our rights and policies

5. Legal basis for processing

Where the General Data Protection Regulation (GDPR) or other applicable data protection laws apply, we process personal data on one or more of the following legal bases:

• Consent: where you have given us permission, for example for certain cookies, analytics, advertising or marketing communications.
• Contractual necessity: where processing is necessary to provide services or features you request.
• Legitimate interests: where processing is necessary for our legitimate business interests, such as improving our Websites, securing our services, measuring performance, preventing fraud and understanding how users interact with our Websites.
• Legal obligation: where processing is necessary to comply with applicable laws, regulatory requirements or lawful requests.

6. Cookies and similar technologies

Yes, we use cookies and similar technologies. Cookies are small files placed on your device that allow websites and service providers to recognize your browser and remember certain information.

We may use the following types of cookies and similar technologies:

• Essential cookies: required for the Websites to function properly and securely.
• Preference cookies: used to remember user choices and settings.
• Analytics cookies: used to understand how users interact with our Websites and improve performance.
• Advertising cookies: used to measure advertising campaigns, prevent repetitive ads and, where applicable, deliver more relevant advertising.

Where required by law, we will ask for your consent before placing non-essential cookies. You may manage or withdraw your consent through our cookie banner or your browser settings.

You can also choose to have your browser warn you each time a cookie is being sent, or you can turn off cookies entirely through your browser settings. If you disable cookies, some features of our Websites may not function properly.

7. Analytics and advertising partners

We may use third-party tools and services to analyze traffic, measure advertising performance, improve our Websites and support advertising activities. These may include, but are not limited to:

• Google Analytics
• Google Ads
• Google Tag Manager
• Google Marketing Platform tools
• Meta Pixel or other Meta business tools
• Other advertising networks, measurement providers or analytics providers

These third parties may collect information through cookies, pixels, tags or similar technologies. Their processing of personal data is subject to their own privacy policies and terms.

You may manage advertising preferences through the relevant platforms, browser settings, cookie tools or available industry opt-out mechanisms.

8. Third-party games, content and links

Our Websites may offer a mix of online games, content or services created by POMU, as well as games, content, advertisements or services created or controlled by independent developers, partners or other third parties.

Certain games, content or advertisements on our Websites may be controlled by third parties, including third parties located outside the European Economic Area (EEA). We make commercially reasonable efforts to work with providers that process personal data in line with applicable data protection laws.

However, third-party websites and services have their own privacy policies. We are not responsible for the privacy practices, content or activities of third-party websites or services. We encourage users to review the privacy policies of any third-party services they access.

9. International data transfers

Some of our service providers, advertising partners, analytics providers or technical providers may process personal data outside Cyprus, the European Union or the European Economic Area.

Where personal data is transferred internationally, we take reasonable steps to ensure that appropriate safeguards are in place, such as contractual protections, adequacy decisions, Standard Contractual Clauses or other lawful transfer mechanisms where required.

10. How we protect your information

We use reasonable technical and organizational measures to protect personal data against unauthorized access, loss, misuse, alteration or disclosure.

Our Websites use SSL/TLS encryption where appropriate to help protect data transmitted between users and our Websites.

However, no method of transmission over the Internet or method of electronic storage is completely secure. Therefore, we cannot guarantee absolute security.

11. Data retention

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

Retention periods may vary depending on the type of data, the purpose of processing, legal requirements, security needs and business requirements.

12. Disclosure of information

We do not sell personal data in the traditional sense. We may share personal data with the following categories of recipients where necessary:

• Hosting providers and infrastructure providers
• Analytics and advertising partners
• Email, communication and support providers
• Payment or fraud prevention providers, where applicable
• Technical service providers and security providers
• Professional advisers, auditors, legal representatives or consultants
• Authorities, regulators or law enforcement bodies where required by law

We may also disclose information where necessary to enforce our policies, protect our rights, protect users, investigate fraud, respond to legal requests or comply with legal obligations.

13. Third-party behavioral tracking

Our Websites may allow third-party behavioral tracking for analytics, advertising measurement and advertising purposes, subject to applicable law and, where required, your consent.

14. Your data protection rights

Depending on your location and applicable law, you may have the following rights regarding your personal data:

• The right to access your personal data
• The right to correct inaccurate or incomplete personal data
• The right to request deletion of your personal data
• The right to restrict processing
• The right to object to processing
• The right to data portability
• The right to withdraw consent at any time, where processing is based on consent
• The right to lodge a complaint with a competent data protection authority

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

15. California privacy notices

If you are a California resident, you may have additional rights under applicable California privacy laws, including the right to know what personal information we collect, the right to request deletion, the right to correct certain information and the right to opt out of certain uses of personal information.

Some advertising or analytics activities may be considered a "share" or "sale" of personal information under certain privacy laws. Where applicable, users may manage these preferences through our cookie tools, browser settings or by contacting us.

16. Children’s privacy

Our Websites are not specifically directed at children under the age of 13, and we do not knowingly collect personal data from children under 13.

If you believe that a child has provided us with personal data, please contact us and we will take appropriate steps to delete such information where required.

17. Email communications and CAN-SPAM

Where you provide your email address, we may use it to send information, respond to inquiries, provide support, send service-related communications or send marketing communications where permitted by law.

To comply with applicable email marketing rules, we aim to:

• Not use false or misleading subjects or email addresses
• Identify marketing messages as advertisements where required
• Include appropriate contact information
• Monitor third-party email marketing services for compliance, where applicable
• Honor opt-out and unsubscribe requests promptly
• Allow users to unsubscribe by using the link at the bottom of marketing emails

You may unsubscribe from marketing communications at any time by following the instructions included in our emails or by contacting us directly.

18. Data breach notification

If a data breach occurs and notification is required by applicable law, we will notify affected users and/or relevant authorities in accordance with the timeframes and requirements established by applicable law.

19. Do Not Track signals

Some browsers offer a "Do Not Track" setting. Because there is no consistent industry standard for responding to Do Not Track signals, our Websites may not respond to such signals in a uniform way.

20. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements or business operations.

When we update this Privacy Policy, we will revise the "Last updated" date at the top of this page. We encourage users to review this page periodically.

21. Contacting us

If you have any questions regarding this Privacy Policy, you may contact us using the information below:

This Privacy Policy is intended to provide clear information about our privacy practices. It should be reviewed periodically to ensure it remains aligned with actual business operations, technologies used and applicable legal requirements.