Privacy Policy

As used in this Privacy Policy, “LAKE”, “We”, “Us” or “Our”, refers to LAKE, razvojni studio d.o.o., registered at Ljubljanska cesta 24D, Kranj, Slovenia.

This Privacy Policy is part of and incorporated by reference into the Terms of Service (the “Terms”) governing the use of all “LAKE” branded software applications (the “Application/s”), which may operate on any type of computing device (including without limitation, a mobile device), and applies to your use of the Applications and/or, and/or URL which may replace it or which may be added to the list of websites published by us and linking to this Privacy Policy (the “Website/s”).

By agreeing to the Terms and/or using the Websites or the Applications, you particularly agree to the collection, use and disclosure of your information (including personal information) in accordance with this Privacy Policy. We may collect and/or you may be asked to provide us with your information (including personal information) any time you are in contact with us or use the Applications or the Websites.

We take the privacy of our users and data security very seriously and believe in the right of our users to know which data is collected and for what purpose. We therefore strive to make our actions transparent and allow our users to control the collected data and remove it if they so wish, and we take all reasonable precautions to prevent unauthorised access to this data.

We value your privacy and will never sell your information to anyone without your knowledge and consent.

When accessing to our website and using any of our services you consent to the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this Privacy Policy. Irrespective of which country you are based in, you authorize Lake to use your information in, and as a result to transfer it to and store it in Slovenia and any other country where Lake, or any third party service providers acting on its behalf, operates. Privacy and data protection laws in some of these countries may vary from the laws in the country where you are based, but we will always take appropriate steps to safeguard the privacy of your personal information. 

Only when the transfer is based on one of the following safeguards, we will transfer your personal information:

  1. If a country outside of EEA ensures an adequate level of protection in accordance with EEA data protection legislation.

  2. If we have entered into standard contractual clauses with our contractual partner that are adopted by Commission of European Union in accordance with EEA data protection legislation and are deemed to offer sufficient safeguards with respect to the protection of the privacy rights.

Please read this Privacy Policy in order to learn more about the data we collect, what do we use it for and how we protect your privacy.

Collected information

We may collect any or all of the information that you give us together with data about your use of the website and applications, but we will primarily use the collected data to provide you with a satisfactory service and enhance your Lake experience.

We use information for (i) delivering and improving our services and products, providing updates, technical troubleshooting, understanding and analyzing trends in connection with usage of the apps, and administering the apps; (ii) analytics and research in a way that we use your information for understanding and analyzing trends in connection with usage of the apps, gathering demographic information about user base, data about where download of our app was performed, and we might use created reports and analysis for the purpose of business intelligence; (iii) security in a way to use your data for enhancing the safety and security of our products and services; (iv)providing customer support to you and to respond to your inquiries; and (v) our legal obligation when we are required to do so by law.

Collection of device and technical information

We might collect the data necessary for you to use our app and for us to maintain and analyze the functioning of the app and to personalize the content of the app.

We automatically obtain certain information about your computing device, including IP address; Country code; Time zone; session start/stop time; IDFVs, Language; Network status (WiFi, etc.), browser plug-in types and versions; platform, SDK version, timestamp; Technical device information (e.g. device model and name, operating system name and version, CPU information, storage size, screen size, firmware, software API key identifier for application, Push notifications token. Although some of this information (such as IDFA, IDFV, IP address) may uniquely identify your device, this information does not identify you personally. Some legislation (such as US) may treat information that uniquely identifies your device as personal information.

Collection of classical personal information

We may also collect personally identifiable information about you (such as your name and surname, email address), as well as non-personally identifiable information (such as age range and gender) that you provide us by using our Applications or contact us directly via email.

We will only use the contact information you provide to us (for example, your name and email address) for the purpose for which you provided it to us. We will not share this data with third parties.

If you wish to delete your contact information that we received upon your specific email inquiry, please send an e-mail to and your e-mail will be deleted from our database.

What is collected data used for

In general

We use the information collected from you for delivering and promoting our services, internal analysis and research to improve the services. You hereby allow us to collect, process and store the data as stated in this Privacy Policy. We use the information we collect about you/your computing device to deliver services to you and to operate our business.

Such use by us and by our Partners may include:

  1. Delivering our services: developing, delivering and improving our products, services, and content, tailoring our products and services, providing software updates and product support, understanding and analyzing trends in connection with usage of the Applications and the Websites, administering the Applications and the Websites, and customer communications. For information that can be treated as personal information in some legislation, we use only device identifiers.

  2. Analytics and research: Understanding and analyzing trends in connection with the usage of the Applications and the Website, auditing, learning about user behavior within the Applications and the Websites (how often you use the Application/Website, the events that occur within the Application/Website, aggregated usage, performance data etc.), gathering demographic information about our user base, data about where the Application was downloaded from. For information that can be treated as personal information in some legislation, we use only device identifiers. We use the data we receive from Third Party Social Network for internal analytics.

For a detailed explanation about what information is being used for what purposes and by which Partners please see the “Cookie” section of this Privacy Policy.

We cannot provide all services necessary for the successful operation of our products by ourselves. We must therefore share collected information with third parties (collectively referred to as “Partners”). We share information that can be used to personally identify your device (e.g. persistent identifiers such as IDFA, IDFV, advertising ID and IP address) for the purposes of developing and delivering our services and conducting analysis and research. We also reserve the right to disclose your information (including personally identifiable information) when we are legally required to do so, to disclose your information in an anonymous and aggregated manner, meaning you could not be personally identified from it.

Push notifications

We will only use push notifications to remind you about your activities within the Application. You will receive push notifications only if you are subscribed to push notifications in the Application. You can unsubscribe in accordance with instruction provided for your device. We collect push notification tokens in order for us to be able to determine whether you are subscribed to push notifications. When you decide to unsubscribe from push notifications, such push notification tokens will be deleted from our database. You can do that by opening “Settings” menu and tapping “Notifications”, find our app, tap on the icon of our app, manage the “Notification” option by sliding it OFF or ON.

Third Party Social network connections

Users may choose to connect with third party social network connections for posting, if they do so, they will have those connections saved in Lake. By logging in to the Application using Third Party Social Network or by using the Application to share content on such Third Party Social Network, you are authorizing us to collect, store, and use any and all information, in accordance with this Privacy Policy, that you agreed that such third parties could provide to us through the Application Programming Interfaces (“API”).

Your agreement takes place when you “accept” or “allow” (or similar terms) one of our applications on such Third Party Social Networks. The information you allow us to access varies by Application, and it is affected by the privacy settings you and your friends establish on those Third Party Social Networks. You can control and find out more about these settings at Facebook and Game Center. Please bear in mind that while using such third party offerings, you are using products or services developed and administered by people or entities not affiliated with or controlled by us. We cannot control the actions of those people or entities, their content, their products and services and the use of information you provide to them.

We access your social network profile if you allow us to for the purposes of using in-app features.

These third party sites are governed by their own privacy policies and end user agreements and we are not responsible for, and have no control over, the sharing practices or policies of the third parties that operate those sites.

We may access and store some or all of the following information, as allowed by you, Third Party Social Networks and your preferences: (i) your basic information from your profile, such as your name, surname, email address, login ID, player identifier string; (ii) your photos and videos. The Application may further ask you to allow us to (i) post on such Third Party Social Networks on your behalf (e.g. photos, e-cards, videos and status updates) and to (ii) manage your notifications (access your notifications and mark them as read). Please keep in mind that we will only do that if specifically directed by you and we will store ID and your full name for the purposes of user identification. Other information will be merely stored within the Application on your device so that the Application will be able to communicate with Third Party Social Network directly.

If you use Third Party Social Networks to participate in app related activities, including but not limited to participation in downloading and uploading of content, Lake may also collect, use, store, transmit and publicly display statistical data regarding app. Data that personally identifies you is collected, used, stored and transmitted in accordance with this Privacy Policy.

We may publicly display your data when you participate in app related activities for the purposes of user identification.

User experience surveys

From time to time we invite our users to give their opinion about their experience with Lake and other similar products. By conducting such surveys, we do not collect any personal information from the respondent, except for their email address if they wish to provide it. We will retain their email address for 3 years and we will only use it if they expressly wished to be contacted. We will use the responses to better understand our users' preferences and what they expect from Lake. We will not disclose personal information to third parties, except if required by law.

Storing of information

**We store your information for as long as needed to provide you with our services and for as long as we are legally obliged to do so. We may store information longer, but only in a way that it cannot be tracked back to you. We delete the information as soon as we do not need them for providing our services and in any event no later than five (5) years after your interaction with our products has ceased. **

For EU Countries

We store personal information as long as it is needed for the provision of our services. Traffic information is erased or made anonymous when it is no longer needed for the purpose of the transmission or, in the case of payable services, up to the end of the period during which the bill may lawfully be challenged or payment pursued. Location information is stored to the extent and for the duration necessary for the provision of a value-added service. Cookies, direct marketing and provision of value-added services information (including traffic information used for these purposes) is stored as long as the same is necessary for the provision of these activities, or up to the time when a user opts out from such use in accordance with this Privacy Policy and the “Access to Personal Information” section herein. Other information is stored for as long as we consider it to be necessary for the provision of our services. This section shall not prevent any technical storage or access to information for the sole purpose of carrying out the transmission of a communication or as strictly necessary in order for us to provide the service you requested.

For US

We will retain collected information for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by applicable legislation.

Storing might be different depending on the territory of collecting the information and the applicable legislation, but we always strive to store the information only as long as it is needed for the purposes of providing, improving or personalizing our services.

Deletion of information

When information is no longer needed, we shall delete it using reasonable measures to protect the information from unauthorized access or use.

Protection of personal information

We have implemented: reasonable security measures to protect the confidentiality, security and integrity of the collected information, and to prevent unauthorized access and the use of information contrary to this Privacy Policy. Although we use commercially reasonable efforts to assure that your information remains secure when maintained by us, please be aware that no security measures are perfect or impenetrable.

Integrity of personal information

We strive to enable you to keep your information accurate, complete and up to date. You can access, check and ensure the integrity of your information as described below.

Information collection relating to children

We do not knowingly collect personal information from, children under 13. If we learn that we have collected personal information of a child under 13, we will take all reasonable steps to delete the information as soon as possible. If you become aware that your child has provided us with personal information without your consent, please contact us at

In-app purchases

Our Applications enable in-app purchases. We do not process payments for in-app purchases nor have access to your credit card information.

Use of our App is free of charge, however they might include in-app purchases. In-app purchases may be made only upon entering the app store password and you are responsible for maintaining the security of such password. You should be aware of the 20-minute window after the downloading of an Application, during which in-app purchases may be made without inserting an in-app store password. You should also take into account that some operating systems on mobile phones do not require entering of the app store account password to carry out in-app purchases.


You are always free to opt out from the future collection of your personal information by LAKE in accordance with this Privacy Policy by uninstalling all the Applications from each of your computing devices and discontinuing use of the Websites.


A cookie is a piece of data stored on the user’s computer tied to information about the user. ​Most browsers allow you to disable cookies or set your browser to alert you when cookies are being sent to your computer. Please note that removing or blocking cookies may affect your user experience and you may have to manually adjust some preferences every time you visit our website and some functionalities may not work.

When you visit our website, you agree that we may place cookies to your computer that uniquely identify your browser. We use cookies for very limited purposes, that is to improve the quality of our service by storing user preferences and other customization functions and to track usage information. ​Cookies also enable us to provide you a personalized experience, which is in line with your settings.

We use the following cookies:

Cookie nameDescriptionExpiration time
_gaUsed to distinguish users.2 years
_gatUsed to throttle request rate.10 minutes

Social network cookies

If you are a user of various social networks you very likely already have cookies provid​ed by those social networks on your computer. As we use the Like / Tweet/ +1 buttons on our title page those social networks are able to detect your presence on using their cookie already stored on your computer. These cases are covered by the privacy policies of the social networks that you use.

As a great number of internet sites, we use Google analytics to measure the usage of our website. Google Analytics uses a cookie to more efficiently track individual users of the site.


We use:

Google Analytics

Lake utilizes Google Analytics, a web analytics tool, that helps Lake understand how users engage with our Site, so that we can review and improve our Services. Google Analytics collects information anonymously. It provides a report to Lake with website trends without identifying individual visitors. Site usage is tracked using Google Analytics in accordance with ​their Privacy Policy​. However, if you do not want your data to be used by Google Analytics, you may opt-out by installing ​Google Analytics Opt-out Browser Add­on​.

Do Not Track

“Do Not Track” is a feature enabled on some browsers that sends a signal to request that a web application disable its tracking or cross-site user tracking. We do not do any cross-site user tracking for advertising purposes, we only use cookies for analytical/sharing/authentication purposes mentioned above. We are however legally obliged to disclose that: “At present, Lake does not respond to or alter its practices when a Do Not Track signal is received.”

Fabric SDK

Fabric SDK provides us with the ability to capture and collect crash logs through the Crashlytics service (Crashlytics privacy policy can be found at​), and​ we collect statistical data on the usage of our app through Answers (Answers privacy policy can be found at ​​).

Firebase SDK

Firebase SDK provides us with the ability to and collect statistical data on the usage of our app (Firebase privacy policy can be found at ​​).

AppsFlyer SDK

AppsFlyer SDK provides us with the ability to and collect statistical data on the usage of our app (AppsFlyer privacy policy can be found at ​​).

Facebook SDK

Facebook SDK provides us with the ability to interact with the Facebook Platform for integration with Facebook. The Facebook Platform Privacy Policy can be found at: ​ and the Facebook Privacy Policy can be found at: ​ Facebook SDK also collects statistical data on the usage of our app.​

Mixpanel SDK

Mixpanel SDK provides us with the ability to and collect statistical data on the usage of our app (Mixpanel privacy policy can be found at :

Third Parties terms of service

We may provide links and/or connections to third-party websites or services from our website and our mobile applications. We are not responsible for the practices employed by websites or services linked to or from Lake website or applications, including the information or content contained therein.

Please remember that when you use a link to go from the Lake website or applications to another website or service, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those linked on our website or in our applications, are subject to that third party’s own rules and policies. We are not responsible for the privacy practices or content of these third-party sites.

In each case where we process your information, we do so lawfully in accordance with one of the legal bases set out.

Our legal basis for collecting and using the personal information will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where: (i) we have your consent to do so, (ii) where we need the personal information to perform a contract with you (e.g. to deliver a service you have requested), or (iii) where the processing is in our legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms). In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person.


If you have further questions or any concerns regarding privacy with Lake and have already signed up in Lake, the best way to get the answers is to contact us by email at ​​​.

If you submit a support request, we may receive your email address and other information you provide related to your support request (“Support Information”). We use Support Information only to provide support to you. We don’t rent, sell or share your email address unless we have your express consent and in the following circumstances:

  1. We may share your Support Information with our support providers, but only for the purpose of providing support to you.

  2. We may share your email address and Support Information to enforce compliance with our mobile application license agreements and user agreements, to respond to legal requirements, when legally required to do so, and at the request of governmental authorities.

  3. We may share your email address and Support Information with a successor entity or in connection with a corporate merger, consolidation, sale of assets or other corporate reorganization provided that use of your email address is otherwise in compliance with this Privacy Policy.


You have numerous rights in connection with your personal information and how we handle it, i.e to access, correct, update or request deletion, object the processing, restrict processing, request portability, withdraw your consent and right to file a complaint.

Your rights:

1. To access, correct, update or request deletion of your personal information. You may do so by contacting us at

2. To object to the processing of your personal information ask us to restrict processing of your personal information or request portability of your personal information. You may do so by contacting us at

3. If we are processing your personal information with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted pursuant to lawful processing grounds other than consent. You may do so by contacting us using the details at

4. You have the right to file a complaint with a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

You can control and limit the type of personal information we collect and process about you in a number of ways. For example, you can disconnect your social media account(s) from our games or control your social media privacy settings to limit the information shared with us. You can also reset your mobile advertising identifier or limit ad tracking altogether using the settings on your phone. You can also limit or disable the use of cookies (or similar technologies).

We will respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Changes to this Privacy Policy

We may amend this Privacy Policy from time to time. Any changes will be placed here and the amended version will supersede this version of our Privacy Policy. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected. We will take reasonable steps to draw your attention to any changes in our Privacy Policy. However, to be on the safe side, we suggest that you read this document each time you use the website to ensure that it still meets with your approval.

If we make changes in the way we use your email address, we will notify you in advance of posting by email. Such modifications will become effective on the date set forth in the email.

For general information please feel free to contact us via contacts provided on and for privacy question via

Last revised 7th of April 2021

Lake d.o.o.