BubblePug Privacy Policy – Penguin Splat

This policy explains how BubblePug (ABN 23 109 387 857), an independent games developer in Sydney, Australia ("we", "us"), handles information in our game Penguin Splat (the "Game") and on this website.

Penguin Splat is a general-audience game rated 9+ on the App Store (12+ in Vietnam and South Korea, and A12 in Brazil). It is suitable for players aged 9 and over, and we know children play it. For that reason we treat the Game as child-directed for privacy purposes and have built it to collect as little as possible.

The short version

  • We do not ask for names, email addresses, location, photos or any other personal details.
  • There are no accounts, no analytics and no tracking. The Game does not use the advertising identifier (IDFA) and does not ask for tracking permission (App Tracking Transparency).
  • We do not run servers that receive data from the Game, and we do not sell or share personal information.

Children's privacy

Because children may play the Game, we handle privacy as if every player could be a child. That means following the US Children's Online Privacy Protection Act (COPPA) for children under 13, the children's protections in the EU and UK GDPR (GDPR-K), and the Australian Privacy Act 1988, including the Australian Privacy Principles. We do not knowingly collect personal information from children, and the Game contains no third-party analytics or tracking.

If you are a parent or guardian and believe a child has sent us personal information (for example, by emailing us), contact us at support@bubblepug.com.au and we will delete it.

Data stored on your device

Scores, settings, progress and whether "Remove Ads" has been purchased are saved only on your device. We cannot see this data. Deleting the Game deletes it.

Game Center

If the device is signed in to Apple Game Center, scores may be sent to Game Center leaderboards. Game Center is operated by Apple under Apple's Privacy Policy, and parents can limit or turn off Game Center using Screen Time. We do not receive Apple Account details.

In-app purchase

The optional "Remove Ads" purchase is handled entirely by Apple through the App Store. Apple processes the payment, and we never see payment details. Parents can control purchases with Apple's Ask to Buy and Screen Time.

Advertising

The free version of the Game shows banner ads from Google AdMob. Because children may play the Game, every ad request is configured for child-directed treatment:

  • tagged for child-directed treatment under COPPA (and treated as under the age of consent under the GDPR);
  • maximum ad content rating set to G (suitable for general audiences);
  • non-personalised ads only, with no interest-based advertising or remarketing;
  • no use of the advertising identifier (IDFA).

Google may still process limited technical information, such as IP address and device type, to deliver ads and prevent fraud, as described at policies.google.com/technologies/partner-sites. You can remove all ads with the "Remove Ads" purchase.

This website

This website is a simple static site. It does not use cookies or analytics. Our hosting provider may keep standard server logs (such as IP addresses) for security.

Your rights

You may ask to access or correct personal information we hold about you (for example, emails you have sent us) or ask us to delete it. If you are in the EU or UK you also have rights under the GDPR. If you are not happy with our response you can complain to the Office of the Australian Information Commissioner (oaic.gov.au) or your local data protection authority.

Changes

If we change this policy we will post the new version on this page. We will not start collecting personal information from children without first updating this policy and getting verifiable parental consent where the law requires it.

Contact

BubblePug (ABN 23 109 387 857), Sydney NSW, Australia – support@bubblepug.com.au

Privacy policy last updated 25 October 2026