Privacy Policy

Last updated 26 August 2026 · Applies to jmak.games and to our games

1. Who is responsible

The controller of the personal data described here is Maksim Pashkevich, trading as JMAK Games, at T. Eristavi Str. N29, building N6, b. N29, Tbilisi, Georgia (taxpayer identification number 300330559) — "JMAK Games", "we", "us".

We are established in Georgia, which is outside the European Union. Where we offer our games to people in the EU, the GDPR still applies to that processing under its Article 3(2), and this policy is written on that basis.

You can reach us about anything in this policy at play@jmak.games.

We have not appointed a Data Protection Officer. We are not required to: we do not process personal data on a large scale, we do not monitor individuals systematically, and we process no special-category data.

2. Our games

This covers Crazy Monkey 67, Paws Off! and MONEV, and, on release, Deep Thicket, Urban Clues, aMaze!, Infinite Tic-Tac-Toe and Ant Colony.

The games do not collect personal data. None of them contain:

• no advertising and no advertising identifiers;
• no user accounts, logins, or profiles;
• no in-app purchases;
• no chat, messaging, or user-to-user features of any kind;
• no third-party trackers.

Paws Off! and MONEV can pass your result to your device's own share sheet, if you press Share on the results screen. That hands a line of text to whichever app you then choose. It sends nothing to us, and we never learn that you used it or which app you picked.

Apart from network access, which the games named in the table below need for the services described there, the games declare no device permissions. They do not ask for and cannot access your contacts, location, camera, microphone, photos, or files.

Urban Clues is the exception, and only for location. It asks for location while you are using it, because reaching a real place is how the game is played. It asks nothing else: no contacts, no camera, no microphone, no photos, no files, and no background or always-on location. See Urban Clues and location below.

Crash reporting and analytics

Some of our games use Firebase, a set of developer services from Google, for two things. Which games use it, and exactly what each one records:

• Crash reporting (Firebase Crashlytics) — if the game crashes, a stack trace and basic device and operating-system information are collected automatically, so we can fix the bug.
• Gameplay analytics (Firebase Analytics) — the game records the events in the table above, so we can tell which parts of the game work and which do not. They describe what happened in the game; they never include anything you typed, and nothing about you.

Both use an app-scoped identifier generated by Firebase — not your Apple ID, Google account, advertising identifier, or anything else tied to you personally. We have not linked Firebase to advertising, and it is not used to track you across other apps or websites. Google's privacy policy is at policies.google.com/privacy, and Firebase's data practices are described at firebase.google.com/support/privacy. Following either link is a request you make to Google, not one this page makes for you.

The three games that use Firebase are fully playable without an internet connection. With no connection there is nothing to send; anything recorded while offline is sent the next time the game runs with one.

Urban Clues and location

Urban Clues is played by walking to real places, so it is the one game of ours that asks for a device permission beyond network access. It asks for location while you are using the app. It does not ask for background or always-on location, and it does not track you when the game is closed.

Your location does not come to us. There is no account, no server of ours and nothing to send it to. The game compares your position against the coordinates of the checkpoint in the case you are playing, entirely on your device, and the only thing that leaves that comparison is the answer to "have you arrived yet". Your position, your route and your progress are held on the phone and are deleted with the app.

The street map is the exception, and it is worth being precise about. The map you see is drawn from tiles served by CARTO (CARTO DB, Inc., United States), built on OpenStreetMap data. To draw the map your device asks CARTO for the tiles covering the area on screen. Those requests necessarily carry your device's IP address and tell CARTO which part of the map you are looking at — which is an approximation of where you are. We receive none of it, and we have no way to see it. If you would rather not make those requests, turning the network off leaves the game playable: the case, its checkpoints and its evidence are stored on the device, and the map falls back to a plain dark background.

Nothing else in the game reaches the network. There is no analytics, no crash reporting, no advertising identifier and no third-party tracker in it.

What is stored on your device

The games save a small amount of information locally, using the operating system's standard app-storage facility, so that the game can remember things between sessions:

• your chosen difficulty, character and settings;
• a local record of games played and their results, and your best survival time;
• flags noting which one-off tutorial tips you have already seen.

This never leaves your device and we have no access to it. It is not transmitted, backed up to us, or shared. Deleting the app deletes it. Because we never receive it, we are not processing it and you do not need to make a request to us to have it erased.

The app stores

We distribute through the Apple App Store and Google Play. When you download or update an app, Apple or Google process your data as controllers in their own right, under their own privacy policies — including any aggregate download and crash statistics they show us. We never see who you are in that data. Please refer to Apple's and Google's privacy policies for how they handle it.

3. This website

jmak.games is a static site. It runs no JavaScript, sets no cookies, uses no local storage, and contains no analytics, tag managers, pixels or embedded third-party content. Typefaces are served from our own server rather than from Google Fonts, so visiting the site makes no request to any third party and reveals your visit to nobody but our host.

Because we set no cookies and use no non-essential tracking, there is nothing here that requires a consent banner under Article 5(3) of the ePrivacy Directive.

Server logs

Our web host records standard technical log entries when a page is served. These can include your IP address, the time of the request, the page requested, the HTTP status, your browser's user-agent string and the referring page.

We use these only to keep the site running and secure — diagnosing faults and identifying abuse or attacks. We do not use them to build profiles, and we do not attempt to identify individual visitors.

4. If you email us

If you write to play@jmak.games we receive your email address, your name if you give it, and whatever you put in the message. We use it only to answer you.

5. Legal bases

Under Article 6(1) GDPR, we rely on the following:

Providing any of this is voluntary. You are not required to give us personal data to play our games or to read this website.

6. Who else sees it

We do not sell personal data and we do not share it for advertising. It is disclosed only to:

• Our web host, DreamHost, LLC (PMB #327, 417 Associated Rd., Brea, CA 92821, USA), which hosts jmak.games and our email, acting as our processor under a data processing agreement.
• Google, as the provider of Firebase Crashlytics and Firebase Analytics in the games named in section 2, acting as our processor under Google's data processing terms. Google receives the crash and gameplay data described in section 2 and nothing else.
• CARTO (CARTO DB, Inc.), which serves the street-map tiles that Urban Clues draws its map from. Your device requests those tiles directly, so CARTO sees the request — the IP address it came from and the area of the map being drawn — and we see none of it. CARTO is not given anything by us, and receives nothing else.
• Professional advisers and authorities, where we are legally obliged to disclose or need advice on a legal claim.

7. Where your data goes

We are in Georgia, and the services we rely on are in the United States, so personal data described here leaves the European Economic Area. There are two recipients of data we hold, and no others; a third, CARTO, is contacted by your device rather than by us, and is covered at the end of this section.

Our web host, DreamHost, LLC, processes server logs in the United States. DreamHost states that it acts as a data processor for its customers and applies appropriate safeguards to that processing; we can provide what its data processing terms say on request.

Firebase data from those games is processed by Google on infrastructure that includes the United States. Google states that it relies on the EU–US Data Privacy Framework and on Standard Contractual Clauses for those transfers; its current terms are at business.safety.google/privacy.

Map tiles for Urban Clues are served by CARTO, a United States company. This is not a transfer we make: your device contacts CARTO directly, and no personal data of ours is passed to it. CARTO's own privacy terms are at carto.com/privacy.

You may ask us for a copy of the relevant safeguards by emailing play@jmak.games.

8. How long we keep it

• Server logs: 30 days, then deleted or anonymised.
• Email correspondence: for as long as needed to deal with your enquiry, and then normally no more than 24 months.
• Records kept for legal reasons: for the period the relevant law requires.

9. Your rights

Where we hold personal data about you, the GDPR gives you the right to:

• Access it, and get a copy (Art. 15);
• Correct it if it is wrong or incomplete (Art. 16);
• Erase it (Art. 17);
• Restrict how we use it (Art. 18);
• Receive it in a portable form (Art. 20);
• Object to processing based on legitimate interests (Art. 21).

Email play@jmak.games and we will respond within one month, as Article 12(3) requires. Exercising these rights is free.

Please note that for most people we hold nothing beyond a short-lived log entry that we cannot connect to a named individual. If you ask us for access, we may need enough detail — such as an approximate time and IP address — to find any record at all, and we may have to tell you we hold nothing.

10. Complaints

If you think we have handled your data badly, please tell us first — we would like the chance to fix it. You can also complain to a data protection authority. If you are in the EU or the EEA, that is the authority in the country where you live or work, and you have that right under Article 77 GDPR — you do not have to complain to an authority in ours. If you are in Georgia, it is the Personal Data Protection Service of Georgia.

11. Children

Our games carry the age ratings shown on their store listings. Nothing they collect identifies anyone: there are no accounts, no contact details and no advertising identifiers, and the analytics described in section 2 are app-scoped and pseudonymous. We therefore do not knowingly hold data that identifies a child, and we do not offer any service that asks a child for personal data.

Deep Thicket is aimed at a mixed audience that includes children under 13, and is distributed under Google Play's Families policy. That game is the simplest case in this policy rather than the hardest one: it has no analytics or crash reporting of any kind, makes no network requests at all, and stores nothing on the device between sessions, so there is nothing about a child — or anyone else — for it to collect, share or retain. It carries no advertising and no in-app purchases. Our other games are suitable for a general audience and are not directed at children.

This website is aimed at a general audience and is not directed at children.

12. Automated decisions

We do not carry out profiling, and we make no automated decisions that produce legal effects for you or otherwise significantly affect you, within the meaning of Article 22.

13. Changes

If we change this policy we will update the date at the top of the page. If a change is significant — for instance, if a future version of a game began collecting data — we will say so clearly on the site and in the app before it takes effect.

14. Contact

play@jmak.games
Maksim Pashkevich, trading as JMAK Games
T. Eristavi Str. N29, building N6, b. N29, Tbilisi, Georgia