Privacy Policy
Last updated: 6 August 2026
Setters OÜ (“Setters,” “we,” “us,” or “our”) respects your privacy. This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, and what rights you have — whether you're visiting our website at setters.pro, using one of our mobile applications, or getting in touch with us directly.
This policy is written to cover both our website and our mobile apps under one document, since our apps generally collect similar categories of data. Where a specific app differs, that app's Data Safety section (Google Play) or App Privacy details (Apple App Store) is the source of truth for exactly what that app collects.
1. Who we are
Setters OÜ is a private limited company (OÜ) registered in Estonia.
- Registry code: 16952286
- Registered address: Vaskussi tee 15, Laulasmaa, 76702 Estonia
- Contact: setters.ou@gmail.com
For the purposes of the EU General Data Protection Regulation (GDPR), Setters OÜ is the data controller for the personal data described in this policy.
2. What this policy covers
- Our website, setters.pro, including any contact details you send us.
- Our mobile applications published on Google Play and the Apple App Store (and, in the future, other app stores), except where a specific app's own store listing or in-app disclosure states otherwise.
- Our future services generally — this policy is designed to extend to new apps and features without needing a rewrite for each launch. New apps will link to this same policy from their store listing.
3. Data we collect
3.1 Website (setters.pro)
- Contact information you send us — the site's Contact section uses a form (name, email, and your message); submitting it sends that information to us by email. We only use it to reply to you, and we don't add you to any mailing list from a contact submission.
- Basic analytics — we use, or plan to use, a lightweight analytics tool to understand overall traffic (e.g. number of visits, pages viewed, approximate country/region, device/browser type, referring site). Depending on the specific tool in use at any given time, this may involve cookies or similar technologies; see Section 8, Cookies.
- We do not currently run ads or sell any data collected through the website.
3.2 Our apps (general — applies where relevant per app)
Because Setters builds multiple apps and games for both Android and iOS, this section is deliberately general. Not every category below applies to every app — check the specific app's Data Safety section (Google Play) or App Privacy details (Apple App Store) for what that particular app actually collects. Categories our apps may, depending on the app, collect:
| Category | What it may include | Typical purpose |
|---|---|---|
| Device & usage data | Device model, OS version, app version, crash logs, in-app usage/interaction data | Diagnosing bugs, improving stability and performance |
| Advertising data | Advertising identifier (Google's Advertising ID or Apple's IDFA), coarse device/location signals, ad interaction data | Showing and measuring ads, via ad network partners (e.g. Google AdMob). Where an app tracks users across other companies' apps or websites, we'll request permission first, via Apple's App Tracking Transparency prompt on iOS or the equivalent Android control |
| Purchase data | Purchase history and transaction identifiers, handled via Google Play Billing or Apple's In-App Purchase system | Processing in-app purchases and subscriptions |
| Account data | Email address, display name, or social-login identifiers, if an app has accounts | Letting you sign in, save progress, or sync data across devices |
If a future app collects something outside these categories, we'll update this policy (and that app's store-specific disclosures) before or at launch, not after.
3.3 Information we don't collect
We do not knowingly collect more data than is needed for the purposes above, and we do not sell personal data to third parties.
4. Why we process your data (legal basis)
Under GDPR, we rely on one or more of the following legal bases, depending on the activity:
- Consent — for optional analytics cookies, for ad tracking where required (e.g. Apple's ATT), and for anything else where we ask you directly (e.g. marketing emails, if we ever add them).
- Legitimate interests — for basic website analytics in aggregate/anonymized form, fraud prevention, and keeping our services secure and working correctly — balanced against your right to privacy.
- Contract / pre-contract steps — for responding to your inquiries and, in apps with accounts or purchases, for providing the service you've signed up for.
- Legal obligation — for accounting, tax, and other records we're required to keep as an Estonian company.
5. Who we share data with
We don't sell personal data. We share data only with a limited set of service providers who process data on our behalf (“processors”) — categories such as our website hosting provider, our contact-form delivery service, our website analytics tool, and the platforms our apps run on (Google Play Console/Billing, Apple App Store Connect/In-App Purchase, and — where applicable — an advertising network such as Google AdMob). These providers only receive the data necessary to do their job for us, under their own data protection commitments. We'll name specific providers here once our hosting, form, and analytics stack is finalized.
Beyond service providers, we may also share data:
- For legal or safety reasons — if required by law, court order, or to protect the rights, property, or safety of Setters, our users, or others.
- In a business transfer — if Setters is involved in a merger, acquisition, or asset sale, data may be transferred as part of that transaction, subject to the same protections described here.
6. International data transfers
Some of our service providers (for example, Google, Apple, and Cloudflare) may process data outside the European Economic Area (EEA), including in the United States. Where this happens, we rely on recognized safeguards such as the EU–US Data Privacy Framework or Standard Contractual Clauses to make sure your data stays protected to an EU-equivalent standard.
7. How long we keep data
We keep personal data only as long as necessary for the purpose it was collected for, and in any case:
- Contact inquiries — kept while needed to handle your request and for a reasonable period after, then deleted.
- Analytics data — kept in aggregate or anonymized form where possible; identifiable analytics data is retained only as long as the analytics tool's default retention window (typically a matter of months).
- App account/purchase data — kept for as long as your account is active, plus any period required by law (e.g. tax/accounting records), then deleted or anonymized.
- As a general outer bound, we don't keep personal data for longer than 5 years after your last interaction with us or our apps, unless a longer period is required by law (for example, Estonian accounting-record retention rules) or you're in an active contractual relationship with us.
You can request earlier deletion at any time — see Section 9.
8. Cookies & similar technologies
Our website may use a small number of cookies or similar local-storage technologies, primarily for basic analytics as described in Section 3.1. Where we use non-essential cookies (such as analytics cookies), we show a cookie consent banner on your first visit — no non-essential cookie is set until you actively accept it, and you can change or withdraw that choice at any time (a “Cookie settings” link stays available, typically in the footer). You can also block or delete cookies directly through your browser settings; doing so shouldn't affect your ability to use the site, since it doesn't rely on cookies to function.
9. Your rights
If you're in the EEA/UK (or anywhere GDPR-equivalent protections apply), you have the right to:
- Access the personal data we hold about you.
- Correct inaccurate or incomplete data.
- Delete your data (“right to be forgotten”), subject to legal retention requirements.
- Restrict or object to certain processing, including processing based on legitimate interests.
- Port your data to another provider, where technically feasible.
- Withdraw consent at any time, where processing is based on consent (e.g. analytics cookies, ad tracking), without affecting processing done before the withdrawal.
- Lodge a complaint with a supervisory authority — in Estonia, the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), www.aki.ee, or your own country's equivalent authority.
To exercise any of these rights, contact us at setters.ou@gmail.com. We'll respond within the timeframes required by law (generally one month).
10. Children's privacy
Our apps and website are intended for a general audience and are not directed at children under 13 (or the minimum age defined by local law). We do not knowingly collect personal data from children. If we learn that we've inadvertently collected data from a child without appropriate parental consent, we'll delete it promptly. If a future app is specifically designed for children, we'll publish a dedicated, age-appropriate policy for that app before it launches, rather than relying on this general document.
11. Security
We use reasonable technical and organizational measures to protect personal data against unauthorized access, loss, misuse, or alteration. No method of transmission or storage is 100% secure, so we can't guarantee absolute security, but we work with reputable providers (hosting, analytics, Google and Apple platform services) that maintain their own strong security standards.
If a data breach occurs that affects your personal data, we will notify the relevant supervisory authority (the Estonian Data Protection Inspectorate) within 72 hours of becoming aware of it, where required under GDPR Article 33, and will inform affected individuals without undue delay where the breach is likely to result in a high risk to your rights and freedoms, per Article 34.
12. Links to other websites
Our website and apps may occasionally link to third-party websites or services we don't control (for example, a payment provider or a social media page). We aren't responsible for the privacy practices of those third parties — we'd encourage you to review their own privacy policies before providing any personal data to them.
13. Changes to this policy
We may update this policy as our website, apps, or legal obligations change. We'll update the “Last updated” date above whenever we do, and for material changes affecting how your data is handled, we'll take reasonable steps to make that clear (e.g. a notice on the site, or in an app update).
14. Contact us
Questions about this policy or how we handle your data:
- Email: setters.ou@gmail.com
- Postal address: Setters OÜ, Vaskussi tee 15, Laulasmaa, 76702 Estonia
This document is designed to satisfy Google Play's User Data policy and Apple's App Store privacy requirements (clear “Privacy Policy” title, discloses data collected/shared/retained, names a contact point, publicly accessible at a stable URL) and GDPR's Articles 13–14 (transparency) and 15–22 (data subject rights) requirements for an Estonian data controller. It is not a substitute for legal advice.