Privacy Policy - Hole Jam

About Hole Jam

Hole Jam (kts.laboon.holejam) is a swallowing-arcade mobile game (concept stage) published on Google Play by KTS Laboon. Players drag a growing hole around a 3D environment, swallowing objects to grow larger. Concept includes themed worlds (city, beach, candy) and IAP skin packs for the hole and the swallowable objects.

Last updated: 2026-09-29

Effective date: 2026-09-29

Publisher entity: KTS Laboon

1. Information We Collect

1.1 Information you provide directly

We do not require you to create an account or provide personal information to play Hole Jam.

1.2 Information collected automatically

• Game progress data: levels completed, high scores, hole skin packs, world packs, skip-wait timers, daily rewards, in-game currency, selected settings (sound, language). Stored locally on your device (PlayerPrefs / Unity persistent storage). Not transmitted to our servers.
• Device identifiers: platform (Android), OS version, app version, device model, screen size, locale, and a pseudonymous app-instance identifier. Collected by Firebase Analytics and GameAnalytics for product analytics.
• App interactions: gameplay events (level start / complete / fail, scores, booster usage, sessions, soft-churn signals) sent to Firebase Analytics and GameAnalytics.
• Crash reports: anonymized stack traces when the Game crashes, collected by Firebase Crashlytics.
• Advertising data: none. This version of the Game does not contain ads.

1.3 Information collected by third parties

The following third parties may collect information governed by their own privacy policies:

We do not sell your personal information. This Game does not show advertising in the current version.

2. How We Use Information

• To operate and maintain the Game.
• To improve gameplay balance, difficulty, level design, and content.
• To prevent fraud, cheating, leaderboard abuse, and refund abuse.
• To process in-app purchases and restore purchases on reinstall.
• To comply with legal obligations.

We do not build our own advertising profiles. We do not serve advertising in this Game.

3. Legal Basis (GDPR)

For users in the European Economic Area, United Kingdom, and Switzerland:

• Legitimate interests (Art. 6(1)(f) GDPR): game operation, fraud and cheating prevention, analytics that don't require consent.
• Consent (Art. 6(1)(a) GDPR): analytics and any future opt-in features.
• Contract (Art. 6(1)(b) GDPR): processing necessary to deliver the Game and to fulfil in-app purchases.

You have the right to access, rectify, erase, restrict, port, or object to processing. To exercise these rights, email hello@kientaoso.com.

4. Data Retention

• Local game progress is retained until you uninstall the Game.
• Analytics data is retained for 14 months, then aggregated and deleted.
• Crash reports are retained for 90 days.

5. Children's Privacy

The Game is rated Everyone / 4+ and does not knowingly collect personal information from children under 13 (COPPA) or under 16 (GDPR). If you believe we have collected such information, contact us and we will delete it.

6. Your Rights

• Access the personal data we hold about you.
• Request correction or deletion.
• Object to or restrict processing.
• Data portability.
• Withdraw consent at any time (without affecting processing already carried out).

To exercise any right, email hello@kientaoso.com. We respond within 30 days.

7. International Transfers

Your information may be processed in Vietnam, the United States, or the European Union, depending on the third-party services used. We rely on Standard Contractual Clauses (SCCs) for lawful transfers out of the EEA/UK.

8. Security

We use industry-standard measures (TLS in transit, encrypted storage at rest on the device) to protect your information. No method of transmission or storage is 100% secure.

9. Changes to This Policy

We may update this Privacy Policy. We will notify you of material changes by posting the new policy on this page and updating the "Last updated" date.

10. Contact

KTS Laboon (Hole Jam publisher)

For privacy inquiries related to Hole Jam, include "Hole Jam Privacy" in the subject line.

11. Permissions Requested by the Game

The Game does NOT request: camera, microphone, contacts, location, photos, SMS, calendar, call logs, or biometric data.