Last updated: 27 June 2026
Firezoo Ltd (“Firezoo”, “we”, “us”, “our”) respects your privacy and is committed to protecting your personal data. This policy explains how we collect, use, share and protect your personal data when you play Smash Dude or use our websites, and the rights you have under UK data protection law.
This policy is written to comply with the UK GDPR, the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations (PECR), each as amended by the Data (Use and Access) Act 2025.
1. Who we are (the data controller)
Firezoo Ltd is the controller responsible for your personal data.
- Legal entity: Firezoo Ltd
- Data privacy manager: Jack Everitt
- Email: smashdude@firezoo.com
- Postal address: 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ
- ICO registration number: [to be confirmed]
If you have any questions or wish to exercise your rights, contact us at smashdude@firezoo.com. You can complain to us directly (see section 12) and to the Information Commissioner’s Office (ICO), the UK regulator (transitioning to the Information Commission), at ico.org.uk.
2. The personal data we collect
Smash Dude is designed to be played without creating a named account. We follow the principle of data minimisation and collect only what we need:
- Anonymous account & game data — an anonymous identifier used to back up, sync and authenticate your game progress.
- Device & technical data — IP address (and approximate, non-precise location derived from it), device make/model and operating system, language, time zone, app version, network information, and mobile advertising identifiers (Apple IDFA, Google AAID).
- Usage & gameplay data — how you interact with the game and site, features used, in-game progress, and crash/diagnostic data.
- Purchase data — records of in-app purchases. Payments are processed by Apple, Google or Amazon; we do not receive your full payment-card details.
- Support & communications — messages, support tickets and chat logs when you contact us or reach us via social media.
- Marketing preferences — your choices about marketing and your engagement with our communications.
We also use aggregated and anonymised data (for example, the percentage of players who use a feature). This is not personal data in law.
We do not collect special category data (such as health, race or ethnicity, religious or philosophical beliefs, sex life or sexual orientation, political opinions, trade union membership, or genetic or biometric data), nor data about criminal convictions or offences.
3. Children
Smash Dude is rated 13+ and is not directed at children under 13. We do not knowingly collect personal data from children under 13. We design our services in line with the ICO’s Age Appropriate Design Code (the Children’s Code), and for users in the United States we comply with the Children’s Online Privacy Protection Act (COPPA). If you believe a child under 13 has provided us with personal data, contact smashdude@firezoo.com and we will delete it promptly.
4. How we collect your personal data
- Directly from you — when you contact support, give feedback, sign up for marketing, or enter a competition, survey or promotion.
- Automatically — through SDKs, server logs and similar technologies as you use the game and site.
- From third parties — analytics, attribution and advertising partners, and the app store platforms.
5. How we use your personal data and our lawful bases
We only use your personal data where the law allows. The table below sets out our main purposes and the lawful basis we rely on. We may rely on more than one basis for a given purpose.
| Purpose | Data used | Lawful basis |
|---|---|---|
| Provide and operate the game (anonymous account, save/sync, core features) | Anonymous account, Technical, Usage | Performance of a contract; legitimate interests (to run the game) |
| Process in-app purchases | Purchase, Technical | Performance of a contract; legal obligation (tax/accounting) |
| Provide support and communicate with you | Support, Contact | Performance of a contract; legitimate interests (to help you) |
| Improve, troubleshoot and secure the game and site (analytics, fault detection, fraud/security) | Technical, Usage | Legitimate interests (to keep our service working, safe and improving); legal obligation |
| Show non-personalised (contextual) ads | Technical, Usage | Legitimate interests (to fund a free game) |
| Show personalised advertising and measure ad performance | Technical, Usage, advertising identifiers | Consent (which you can withdraw at any time) |
| Send electronic direct marketing | Contact, Marketing preferences | Consent, or PECR “soft opt-in” for our own similar products |
We do not generally rely on consent except for personalised advertising/tracking and electronic marketing. Where the Data (Use and Access) Act 2025 designates certain recognised legitimate interests, we may rely on those without carrying out a separate balancing test.
6. Device identifiers and similar technologies
We use SDKs and device identifiers (such as mobile advertising IDs) on our game to run core features, understand usage, and — where you consent — show advertising. Under PECR as amended by the Data (Use and Access) Act 2025, certain low-risk technologies may be used without consent: for statistical/analytics purposes to improve our service, for functionality you have asked for, for software updates, for fault and error detection, and for security and fraud prevention.
We ask for your consent before using device identifiers for personalised advertising. You can manage your choices through your device settings (see section 7).
7. Advertising, analytics and SDK partners
Our game and site use third-party SDKs and services for analytics, attribution, advertising and (where used) surveys. Depending on the service, these partners act as our processors or, for some advertising, as independent or joint controllers.
Your controls:
- iOS — App Tracking Transparency (ATT): you choose whether apps may track you. You can change this in your device Settings at any time.
- Android — you can reset or delete your advertising ID and opt out of ad personalisation in your device settings.
- Web — adjust the tracking settings in your browser; industry opt-outs are available at youradchoices.com and youronlinechoices.eu.
A current list of our advertising, analytics and SDK partners (sub-processors) is available on request from smashdude@firezoo.com.
8. How we share your personal data
We share personal data only where necessary:
- Service providers (processors) — hosting, analytics, attribution, customer support and advertising partners, under contract and acting on our instructions.
- App store platforms — Apple, Google and Amazon, for distribution and payment processing.
- Group companies — acting as joint controllers or processors.
- Legal and regulatory bodies — such as HMRC, regulators and law enforcement, where we are required to share.
- Business transfers — a buyer or seller in connection with a sale, merger or restructuring of our business.
We require all third parties to protect your personal data and to process it only for specified purposes in accordance with our instructions. Apple, Google and Amazon are not sponsors of, and are not responsible for, any promotion or contest in the game.
9. International transfers
We are based in the UK. Some of our partners are located outside the UK. Whenever we transfer personal data outside the UK, we ensure a comparable level of protection by relying on at least one of:
- a UK adequacy decision/regulations covering the destination country;
- the UK International Data Transfer Agreement (IDTA), or the UK Addendum to the EU Standard Contractual Clauses; or
- for US partners certified under it, the UK Extension to the EU-US Data Privacy Framework (the “UK-US Data Bridge”).
(The EU-US Privacy Shield referenced in older policies was invalidated in 2020 and no longer applies.) Contact smashdude@firezoo.com for details of the safeguard used for a particular transfer.
10. Data security
We have appropriate technical and organisational measures in place to prevent your personal data from being accidentally lost, used, altered, disclosed or accessed without authorisation. Access is limited to those with a genuine business need, who are under a duty of confidentiality. We have procedures to deal with suspected personal data breaches and will notify you and the ICO/Information Commission where we are legally required to do so.
11. Data retention
We keep personal data only for as long as necessary for the purposes we collected it, taking into account the amount and sensitivity of the data, the risk of harm, the purposes, and applicable legal requirements. By law we keep certain records (including purchase and tax records) for at least six years. We may anonymise personal data for research or statistical purposes, in which case we may keep it indefinitely. You can request details of our retention periods at smashdude@firezoo.com.
12. Your rights
Under UK data protection law you have the right to:
- access your personal data;
- request rectification of inaccurate or incomplete data;
- request erasure of your data;
- object to processing based on legitimate interests, and an absolute right to object to direct marketing;
- request restriction of processing;
- request portability of data you provided, in a structured, machine-readable format;
- withdraw consent at any time where we rely on it; and
- not be subject to solely automated decisions with legal or similarly significant effects (see section 13).
To exercise any right, contact smashdude@firezoo.com. This is usually free, though we may charge a reasonable fee or refuse to act on a request that is manifestly unfounded or excessive. We aim to respond within one month. Under the Data (Use and Access) Act 2025 we may pause that period (“stop the clock”) where we reasonably need to verify your identity or seek clarification, and we may extend it by up to two further months for complex requests, telling you if so.
Complain to us: from 19 June 2026 you have a right to complain directly to us if you believe we have infringed your data protection rights. Email smashdude@firezoo.com; we will acknowledge within 30 days. You also have the right to complain to the ICO (transitioning to the Information Commission) at ico.org.uk — though we would appreciate the chance to address your concerns first.
13. Automated decision-making and profiling
We do not make decisions that produce legal or similarly significant effects on you based solely on automated processing. We use limited profiling to show relevant advertising and to improve the game. Where this relies on consent you may withdraw it at any time, and you may object to profiling for direct marketing at any time.
14. Marketing and your choices
We will only send you electronic marketing where you have consented, or under PECR’s “soft opt-in” for our own similar products and services. You can opt out at any time using the unsubscribe link in our messages or by emailing smashdude@firezoo.com. Opting out of marketing does not stop service messages relating to a purchase or your use of the game.
15. Changes to this policy
We may update this policy from time to time; the “last updated” date at the top shows the current version. We will notify you of material changes in-game or on our site. Historic versions are available on request.
16. Contact
Firezoo Ltd · 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ · smashdude@firezoo.com · ICO: ico.org.uk