This Privacy Policy explains how personal data is processed when you use the Belot game for Android and iOS and any other game published under the name “Middle Hut” (the “Apps”), and the website www.middlehut.com (the “Website”).
The Apps and the Website are operated by Middle Hut, a game developer based in Bulgaria, trading as “Middle Hut” (“we”, “us”, “our”). We are the controller of your personal data under the EU General Data Protection Regulation and the Bulgarian Personal Data Protection Act.
Contact for all privacy matters: [email protected]
1. Summary #
- The Apps have no user accounts. We do not ask for your name, email address, phone number or precise location.
- The Apps are free and funded by advertising. Ads are personalised if you agree, and you can change your choice at any time in the App.
- We use a small number of service providers (Google, Apple, Unity and Meta) to show ads, measure usage and fix crashes.
- We do not sell your personal data and do not use it for purposes other than those described in this policy.
- The Apps are intended for adults aged 18 and over.
2. Data we process #
| Category | Examples | Where it comes from |
|---|---|---|
| Device and technical data | Device model, operating system and version, language, screen size, app version, IP address and the approximate country or region derived from it | Automatically from your device |
| Device identifiers | Advertising identifier (IDFA on iOS, only if you allow tracking; Google Advertising ID on Android), identifier for vendors, installation IDs created by Firebase | Your device and the services listed in Section 5 |
| Advertising data | Ads shown, ad views and clicks, rewards granted for watching an ad | Our advertising partners |
| Usage data | Sessions, screens viewed, games started and finished | Firebase Analytics |
| Crash and diagnostic data | Crash logs, stack traces, device state at the time of a crash | Firebase Crashlytics |
| Game services data | Player ID, nickname, achievements, scores | Apple Game Center or Google Play Games, only if you sign in to them |
| Communications | Your email address, name and the content of messages you send us, plus any device details you choose to share | You |
Your game settings and statistics are stored locally on your device. We do not collect special categories of data (such as health, religion or political opinions), and we do not knowingly collect data from anyone under 18.
3. Why we use your data and our legal basis #
| Purpose | Data used | Legal basis (GDPR) |
|---|---|---|
| Running the game and its features | Device and technical data | Performing our Terms of Use with you (Art. 6(1)(b)) |
| Showing personalised ads | Identifiers, device and advertising data | Your consent (Art. 6(1)(a)); consent is also asked for storing and reading information on your device where e-privacy law requires it |
| Showing non-personalised ads, measuring ads, limiting how often an ad repeats, preventing ad fraud | Device, technical and advertising data | Our legitimate interest in funding a free game and preventing fraud (Art. 6(1)(f)), or your consent where the law requires it |
| Understanding how the game is used, to improve it | Usage data, installation IDs | Your consent (Art. 6(1)(a)) |
| Detecting and fixing crashes | Crash and diagnostic data | Our legitimate interest in a stable and secure game (Art. 6(1)(f)) |
| Achievements and leaderboards | Game services data | Performing our Terms of Use, at your request (Art. 6(1)(b)) |
| Answering your messages | Communications | Our legitimate interest in providing support (Art. 6(1)(f)) |
| Meeting legal obligations and defending legal claims | Only what is needed | Legal obligation (Art. 6(1)(c)) and legitimate interest (Art. 6(1)(f)) |
Where we rely on consent, you can withdraw it at any time without affecting earlier processing. Where we rely on legitimate interests, you can object at any time.
4. Advertising and your choices #
- Consent message. When you first open the App in the EEA, the UK or Switzerland, it shows a consent message from Google’s User Messaging Platform, a consent management platform certified under the IAB Transparency & Consent Framework. You can accept, reject or choose by purpose and by partner.
- iOS. We ask for permission through Apple’s App Tracking Transparency prompt. If you decline, the App cannot access your device’s advertising identifier. You can change this in iOS Settings > Privacy & Security > Tracking.
- Android. You can reset or delete your advertising ID in your device’s Settings (usually under Google > Ads or Privacy > Ads).
- If you decline. You will still see ads, but they will not be based on a profile of you. They may still use limited data such as your approximate location and device type.
Ads are supplied by third parties. We do not choose individual ads and are not responsible for advertisers’ products, services or websites. If you see an inappropriate ad, please tell us so we can block it.
5. Who we share data with #
We share data only with the providers below, and only for the purposes in Section 3.
| Provider | What they do for us | Their privacy information |
|---|---|---|
| Google (Google Ireland Limited and Google LLC) | AdMob ads and ad mediation, Firebase Analytics, Firebase Crashlytics, Google Play Games | Google Privacy Policy ; how Google uses data from partner apps |
| Unity Technologies | Unity Ads | Unity Privacy Policy |
| Meta Platforms Ireland Limited | Meta Audience Network ads | Meta Privacy Policy |
| Apple | App Store, Game Center, App Tracking Transparency | Apple Privacy Policy |
Firebase processes data on our behalf as our processor. The advertising networks, Apple and Google Play Games act as independent controllers for their own processing, under their own policies. We may also disclose data where the law requires it, or to a successor if the Apps are transferred to another owner, who will be bound by this policy.
6. Transfers outside the EEA #
Some providers process data outside the European Economic Area, for example in the United States. These transfers rely on a European Commission adequacy decision (such as the EU-U.S. Data Privacy Framework, for certified companies) or on Standard Contractual Clauses approved by the Commission.
7. How long we keep data #
| Data | Retention |
|---|---|
| Messages you send us | Until your request is resolved, then up to 2 years, unless needed longer for a legal claim |
| Firebase Analytics data | 2 months, as set in our Firebase settings |
| Crashlytics crash reports | Up to 90 days |
| Data held by advertising partners and Apple or Google | According to their own policies (Section 5) |
| Data stored on your device | Until you delete the App or its data |
8. Your rights #
The Apps are designed to collect as little data as possible, so we hold very little that can be linked to you.
What we hold. The Apps have no accounts, and we receive no names, email addresses or player profiles from them. Analytics and crash data are linked only to random installation IDs, which we cannot connect to a person. The only data we can directly link to you is the emails you send us.
Your rights. Under the GDPR you may ask for access to your data, its correction or deletion, restriction of its processing or a portable copy. You may also object to processing based on our legitimate interests. Where we cannot identify you from the information you give us, the rights of access, correction, deletion, restriction and portability apply only if you provide additional information that allows us to identify your data (Art. 11 GDPR). We will tell you if this is the case.
For any other request, email [email protected] We’ll try to reply as soon as possible.
Complaints. If you think we have breached data protection law, please contact us first so we can put it right.
9. Adults only #
The Apps are intended only for people aged 18 or over and are rated 18+ in the app stores. Do not use the Apps if you are under 18. We do not knowingly process data of minors. If you believe a minor has used the Apps, contact us and we will delete any data we hold.
10. Website #
The Website runs on WordPress. It uses cookies needed for it to work and, only with your consent through the cookie banner. Our hosting provider keeps standard server logs (IP address, browser, pages requested) for security for up to 30 days.
11. Security #
We use reasonable technical and organisational measures to protect data, including encrypted connections to our providers. No method of transmission or storage is completely secure.
12. Changes to this policy #
We may update this policy when the Apps, our providers or the law change. The effective date at the bottom shows the latest version. We will announce material changes in the App or on the Website and, where the law requires it, ask for your consent again.
13. Contact #
Middle Hut, Pleven, Bulgaria Email: [email protected]
Last update: 2 Nov 2026