Privacy policy

10Mil LLC ("10Mil", "we", "us") makes games for iPhone. This policy explains what information we collect on this website and in our games, what our ad partners collect, and the choices you have. The short version: there are no accounts, your progress stays on your phone, and ad partners only track you across other companies' apps if you say yes.

1. Who we are

   10Mil LLC is a limited liability company formed in New Mexico, USA. We're responsible for the information described in this policy. Under European privacy law, that makes us the "controller".

   10Mil LLC
   1209 Mountain Road Pl #12045
   Albuquerque, NM 87110
   United States
   hello@10mil.club

2. What this covers

   This policy covers this website (10mil.club), the games we publish for iPhone, and emails you send us. It doesn't cover the App Store itself: when you download one of our games, Apple handles that under Apple's privacy policy. The partners named below have their own privacy policies too, and we link to them.

   We haven't released a game yet. This policy describes how our games will work when they're out, and we'll update it before launch if anything changes.

3. This website

   We don't ask for any personal information on this website. It sets no cookies of its own, and it has no analytics, no ads and no tracking. It doesn't load anything from other companies: the fonts and images come from our own domain.

   The site is hosted by Cloudflare. Like any web host, Cloudflare processes technical information, such as your IP address, browser type and the pages you ask for, to deliver the site and protect it from attacks and abuse. Cloudflare shows us traffic totals, like how many visits the site gets and from which countries, which don't identify you. Cloudflare's handling of this information is covered by Cloudflare's privacy policy. If Cloudflare needs to check that a visitor isn't a bot, it may set a short-lived security cookie (such as __cf_bm or cf_clearance). It's strictly necessary to protect the site and isn't used to track you.

4. Our games

   Our games don't have accounts, and you never need to give us your name, email or phone number to play. Your progress, scores and settings are saved on your phone and aren't sent to us. Deleting a game deletes that information.

   If you've chosen to share analytics with app developers in your iPhone's settings (Settings > Privacy & Security > Analytics & Improvements), Apple gives us crash reports and usage statistics for our games. Apple doesn't tell us who you are, and you can turn this off at any time in the same place.

   If you rate or review one of our games on the App Store, we can see your review and nickname, just like anyone else.

5. Ads

   Our games are free to play, and ads pay for them. When our games show ads, the ads are served by Google AdMob and by other ad networks we may work with through it (together, our "ad partners"). If we add ad partners besides Google, we'll name them on this page.

   To show ads, limit how often you see the same one, measure how ads perform and prevent fraud, our ad partners' software in our games collects information from your device, such as:

   • your IP address, which can be used to estimate your general location, like your city or region (not your exact location)
   • device and app details, like your phone model, iOS version, language, and which of our games and which version you're using
   • device identifiers: identifiers that only apps from the same developer can see (such as Apple's identifier for vendors) and, only if you allow tracking, Apple's advertising identifier (IDFA)
   • how you interact with ads, like which ads you see, tap or watch, and when you open a game
   • diagnostic information, like crashes and performance, used to keep the ad software working

   Ad partners may also place and read cookies or similar technologies (like web beacons) on your device, and use your IP address, to collect this information as a result of showing ads.

   Tracking on iPhone. iPhone apps must ask before they track you across other companies' apps and websites. Our games only let ad partners use your advertising identifier, or track you that way, if you tap Allow when iOS asks. If you tap Ask App Not to Track, you'll still see ads, but they won't be personalized by tracking you. You can change your choice at any time in Settings > Privacy & Security > Tracking.

   Consent in Europe, the UK and Switzerland. If you're in the European Economic Area, the UK or Switzerland, our games use Google's consent tool to ask for your consent before ad partners personalize ads or, where the law requires it, store or read information on your device. If you don't agree, you may see non-personalized or limited ads instead. These are chosen using things like the game you're playing and your general location, not your past activity. You can change your choice at any time in the game's settings (look for Privacy options).

   US states. Depending on where you live, our games may also show a message that lets you opt out of personalized ads. See Personalized ads and US state laws below.

   Google explains how it uses this information, and the controls it offers, in How Google uses information from sites or apps that use our services and in Google's privacy policy. Ad partners make some of their own decisions about the data they collect, and they're responsible for it under their own privacy policies.

6. Sharing from a game

   Some games may let you share a score card using your iPhone's share sheet. What you share, and who you share it with, is up to you, and it goes through the app you pick. We don't see it.

7. Emailing us

   If you email us, we get your email address, your name if your email shows it, and whatever you write or attach, like a screenshot. We use it only to reply, help you and fix problems you tell us about. Our email is hosted by Google Workspace.

8. Why we're allowed to use it

   If you're in the European Economic Area, the UK or Switzerland, the law asks us to give a legal basis for each use of your information:

   • Running this website and keeping it secure: our legitimate interest in delivering the site and protecting it from abuse.
   • Replying to your emails: our legitimate interest in helping you, or taking the steps you ask us to take.
   • Personalized ads, and the device storage they rely on: your consent, which you can withdraw at any time.
   • Non-personalized or limited ads, ad measurement and fraud prevention: our legitimate interest in keeping our games free and our ads honest, plus your consent where the law requires it to store or read information on your device.
   • Meeting legal duties and handling legal claims: legal obligation, or our legitimate interest in protecting our rights.

   Where we rely on legitimate interests, you have the right to object.

   You never have to give us personal information. You can play without telling us anything, and if you say no to personalized ads you'll still be able to play, with less relevant ads.

9. How long we keep it

   • Emails: as long as we need them to help you and keep a record of the conversation, usually no more than two years after it ends. We delete them sooner if you ask, unless the law requires us to keep them.
   • Game progress and settings: on your phone until you delete the game. We never have a copy.
   • Website logs: Cloudflare keeps them for a limited time under its own policies. We don't keep copies.
   • Ad data: ad partners keep it under their own policies. Google explains how long it keeps data in How Google retains data we collect.

10. Who we share it with

    We don't sell your personal information for money. But some US state laws count letting ad partners collect information for personalized ads as "selling" or "sharing" it (see Personalized ads and US state laws). We share personal information only:

    • with service providers that help us run things: Cloudflare (website hosting and security) and Google Workspace (email)
    • with ad partners, as described in Ads, and only as far as your choices allow
    • when the law requires it, or when we need to protect the rights, safety or property of people or of 10Mil
    • with a new owner if 10Mil is ever part of a merger, acquisition or sale of assets, who would have to respect this policy for the information it receives

    Our service providers and ad partners must protect the personal information they get through us with the same or equal protection as this policy and the law require.

11. Personalized ads and US state laws

    Some US state privacy laws, like California's, call it "selling" or "sharing" personal information, or "targeted advertising", when an app lets ad partners collect information to personalize ads based on your activity across other companies' apps and websites. When our games show personalized ads, that may count. Depending on where you live, you have the right to opt out:

    • Tap Ask App Not to Track when iOS asks, or turn tracking off for our games in Settings > Privacy & Security > Tracking. Turning off Allow Apps to Request to Track stops every app from asking.
    • Use the Privacy options in a game's settings.
    • Email us at hello@10mil.club with the subject "Opt out". We can't identify your phone ourselves, so we'll walk you through switching it off in the game and on your iPhone.

    The kinds of personal information involved are identifiers (like your IP address and device identifiers), internet activity (like how you interact with ads in our games), general location estimated from your IP address, and the inferences ad partners draw from these. This information comes from your device, through our ad partners' software in our games. It's used to show and measure ads, limit repeats and prevent fraud, and it's kept as described in How long we keep it. We don't ask for sensitive information like your precise location, health information or government ID numbers. We don't knowingly sell or share the personal information of anyone under 16, and we don't use personal information to make automated decisions that have legal or similarly significant effects on you.

12. Children

    Our games are made for a general audience and aren't directed to children under 13. We don't knowingly collect personal information from children under 13, or under the age of digital consent where they live. If you think a child has sent us personal information, for example by email, contact us and we'll delete it.

13. Your rights

    Wherever you live, you can ask us what personal information we hold about you, and ask us to correct or delete it. Because we don't run accounts or game servers, that's usually only email you've sent us. Depending on where you live, you may also have the right to:

    • get a copy of your information in a portable format
    • opt out of targeted advertising, or of the "sale" or "sharing" of your information (see above)
    • object to, or ask us to restrict, how we use your information
    • withdraw your consent at any time, without affecting anything we did before you withdrew it
    • not be treated differently for using any of these rights
    • appeal if we turn down your request: reply to our answer with the subject "Appeal" and we'll review it. If we still say no, you can contact your state attorney general.
    • complain to a data protection authority: in the European Economic Area, the authority where you live or work; in the UK, the Information Commissioner's Office; in Switzerland, the Federal Data Protection and Information Commissioner

    To make a request, email hello@10mil.club. You can also ask someone you've authorized to make a request for you. We may ask for details to confirm the request is really yours, like the email address you used to write to us, and we'll answer within the time the law requires.

    Ad partners don't give us information that identifies you, so we can't look up or delete what they hold. For that, use the controls in Ads or contact the partner directly.

14. International transfers

    10Mil is based in the United States, and our service providers and ad partners may process information in the US and other countries, where privacy laws may differ from yours. When they receive personal information from the European Economic Area, the UK or Switzerland, they rely on safeguards the law provides, such as the EU-US Data Privacy Framework and its UK and Swiss extensions (which Google and Cloudflare take part in) or the European Commission's Standard Contractual Clauses. 10Mil itself isn't certified under the Data Privacy Framework. You can email us for more information about these safeguards.

15. Security

    We hold very little personal information. We protect what we do hold, mostly email, with reasonable safeguards, and only people at 10Mil who need it can see it. This website is served over a secure (HTTPS) connection. No system is perfectly secure, but if a breach affects your information, we'll tell you when the law requires it.

16. Do Not Track and Global Privacy Control

    No ad or analytics company collects information about you on this website, and neither we nor anyone else tracks your activity on it across other websites (Cloudflare only processes what it needs to deliver and protect the site, as described above). So the site works the same whether or not your browser sends a Do Not Track or Global Privacy Control signal. Our games don't run in a browser, so those signals don't reach them. In our games, ad partners collect information as described in Ads, and they only track your activity across other companies' apps and websites if you allow it. Use the tracking and privacy settings described above.

17. Changes

    If we change this policy, we'll update this page and the date at the top. If a change matters, for example if we start collecting new kinds of information or using it in new ways, we'll also tell you in our games or on this site before it takes effect, and ask for your consent where the law requires. This version takes effect on the date at the top.

18. Contact

    Questions about this policy or your information? Get in touch:

    10Mil LLC
    1209 Mountain Road Pl #12045
    Albuquerque, NM 87110
    United States
    hello@10mil.club

    See also our terms of use.