Spry Fox Privacy Policy

Spry Fox

Privacy Policy

Last modified:  March 31, 2026

 

Introduction

Spry Fox, Inc. (“Company” or “We”) respects your privacy and is committed to protecting it through our compliance with this policy. This privacy notice describes the types of information we collect or that you may provide when you use our games, Spirit Crossing, Cozy Grove, Cozy Grove: Camp Spirit, Alphabear, Alphabear 2, Bushido Bear, Road Not Taken, and TripleTown (each a “Game” and collectively our “Games”), our websites, spryfox.com, splyspiritcrossing.com, cozygrovegame.com and support.spryfox.com (each a “Site” and collectively our “Sites”) and our marketing communications channels including our newsletters, creator program and player surveys (each of the forgoing together with the Games and the Sites, our “Services”); and our practices for collecting, using, maintaining, protecting, and disclosing that information. It is limited to information collected directly through the Services. This policy DOES NOT apply to information that you provide to or is collected by any third party, or which is collected outside of the Services (see “Third-Party Information Collection”).

 

Before using the Services or submitting any Personal Data to Company, please review this Privacy Policy carefully and contact us if you have any questions. By using the Services, you agree to the practices described in this Privacy Policy.

 

If you do not agree with our policies and practices, do not download, register with, or use the Services. By accessing, downloading, registering for or otherwise using any of the Services you consent to our processing of your Personal Data as described in this Privacy Policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Services after we revise this policy means you accept those changes, so please check the policy periodically for updates. 

 

  1. DATA CONTROLLER

 

Spry Fox, Inc. will be the entity responsible for your data. To ask questions or comment about this privacy policy and our privacy practices, you can contact us at:

 

Email:                     privacy@spryfox.com

 

Address: Spry Fox, Inc. 

1522 Western Avenue

Suite 24350

Seattle, WA 

98101

  

  1.     CHILDREN

 

Protecting children’s privacy is extremely important to us. We also encourage parents and/or guardians to play an active role in their children’s online experiences at all times. 

Our Services are not intended for children under the age of 13 and we do not knowingly collect any personal information from children under the age of 13. 

If you are a resident of the European Economic Area (EEA) under 16 years of age or a minor in your country of residence, please ask your legal guardian’s permission to use or access our Services. 

If you believe we have inadvertently collected information about your child, please contact us (information below) so we can promptly remove the information. 

  1.     PERSONAL DATA WE COLLECT

 

We collect information that alone or in combination with other information in our possession could be used to identify you (“Personal Data”) as follows:

 

Information You Provide to Us Directly

We collect the Personal Data that you provide us directly, such as via an online form,  when you register for our newsletter, when you communicate with our customer support team or when you send us an email. We also collect inputs that you provide directly within our Games, such as player generated chats.

 

Information Collected Automatically When You Use Our Services

When you visit, use, and interact with the Services, we may receive certain information about you, your visit, use, or interactions.

 

Information collected through our Games: We have two separate systems for collecting information about users who interact with our Games. The first collects player analytics by assigning an arbitrary ID to each player progression. It does not collect IP addresses, device IDs or browser IDs. This system collects information about the country-level location which we use to segment our analysis of retention and player behavior generally. It collects device language data which enables us to understand which localization is being presented to the player. It collects certain other device information (including make, model, OS and OS version) that we use to diagnose performance issues and platform-specific bugs. It collects player generated text from player chats, in-game mail messages and in-game player handles which we use for moderation purposes. It also collects player behavior data including sessions times, in-game actions, in-game UI interactions, player to player social interactions and information about the content and resources that players access within the Games. This information allows us to understand if players are engaging with Game features as expected and, thereby, to improve and optimize our Games.

 

Our second system collects player contact information such as their name and email address and is used for business communications and to resolve customer support issues. 

 

Information collected through our Sites: When you visit our Sites we may collect information through cookies and other similar technologies (see below). This includes information about your behavior on the Sites. YouTube also collects information about which of our trailers you watch and your video preferences through cookies on our Sites.

 

Cookies: We use cookies and other similar technologies to operate and administer our Sites, gather usage data on our web applications, and improve your experience on them. A “cookie” is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it) and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). For more details on cookies, please visit All About Cookies.

 

On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:

 

 Note: The links provided above and elsewhere herein are provided solely for your convenience. We do not warrant their accuracy.

Do Not Track Signals: Our web applications currently do not respond to “Do Not Track” (“DNT”) signals and operate as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so.

 

Social Media Accounts: We also have accounts on social media sites like Discord, Bluesky, Instagram and TikTok (our “Social Media Accounts”). The Social Media Accounts are operated by the owners of the relevant social media platforms and the collection of information by third parties on the Social Media Accounts is governed by the privacy policy of the applicable platform. When you interact with our Social Media Accounts, we may collect Personal Data that you choose to provide to us, such as your contact details. We use this information solely for the purpose for which it was provided. In addition, the companies that host our Social Media Accounts may provide us with aggregate information and analytics regarding the use of our Social Media Accounts.

 

Links to Other Websites: The Services may contain links to other websites not operated or controlled by Company, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links, we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their

privacy practices and policies.

 

  1.     Our Legal Bases For Processing Your Information 

 

When we collect or otherwise process any of your Personal Data, we do so in reliance on the following legal bases:

 

  • Your consent. If you have provided us with your consent to process your information for a specific purpose, we will do so based on your consent. You may withdraw your consent at any time by following the instructions provided below in the “Your Rights and Choices” section below.

 

  • Performance of a Contract with You. When the processing of your Personal Data is necessary in order for us to perform a contract with you, such as the EULAs or Terms of Service associated with the Services, or when you request that we process your information prior to entering into a contract with you, we will do so on this basis.

 

  • Our Legitimate Interests. When we believe the processing of your Personal Data is reasonably necessary in order for us to achieve our legitimate interests in conducting and managing our business and our relationship with you, we will do so on this basis, including the legitimate interest we have in:

o   personalizing, enhancing, modifying or otherwise improving the services and/or the communications that we provide to you;

o   retaining and engaging you and our other users;

o   detecting and preventing fraud and operating a safe and lawful business; and

o   improving the security and optimization of our network, products and services.

 

When we use your information for our legitimate interests, we take into account any potential impact that such use may have on you by balancing our legitimate interests against your interests, rights, and freedoms. We will not use your information if there is a less intrusive way for us to achieve our legitimate interests or if we believe your interests should override ours unless we have other grounds to do so (such as your consent or a legal obligation).

 

  • Our Legal Obligations. When we believe that the processing of your information is necessary in order for us to comply with our legal obligations (such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved) we will do so on this basis.

 

  • Vital Interests. When we believe that the processing of your information is necessary in order to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person, we will do so on this basis.

 

  1.     HOW WE USE PERSONAL DATA

 

We may use Personal Data for the following purposes:

 

  • To provide, support, develop, optimize and improve the Services and their contents.
  • To provide you with customer support.
  • To communicate about promotions, upcoming events, and other news about the Services and services with your consent.
  • To respond to your inquiries, comments, feedback, or questions regarding the Services.
  • To serve you with ads that align with your preferences.
  • To send administrative information to you, for example, information regarding the Services and changes to our terms, conditions, and policies.
  • To respond to you if you contact us.
  • To fulfill any other purpose for which you provide it.
  • To analyze how you interact with our Services;
  • To recognize you when you use the Services.
  • To estimate our audience size, demographics and usage patterns.
  • To collect and store your preferences, consents and other user settings locally on your device.
  • To comply with your consents.
  • To understand how well Services features are working and whether users are having issues.
  • To diagnose and fix software defects, system errors and bugs within the Services.
  • To moderate user behavior and help ensure a safe experience for all of our players.
  • To identify and correct software defects and other technical issues.
  • To understand how our Services are used in different markets.
  • To attribute clicks, installs and events to specific marketing efforts.
  • To localize communications and present the user with regional content.
  • To develop new products and services;
  • To prevent fraud, criminal activity, or misuse of our Services, and to ensure the security of our IT systems, architecture, and networks; and
  • To comply with legal obligations and legal process and to protect and defend our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.
  • For any reason that we described to you when collecting your Personal Data or for any reason for which you’ve provided us with your consent.
  • To create anonymous, de-identified, or aggregated datasets (“Aggregated Information”). Such datasets would not be “Personal Information” subject to this Privacy Policy. We may use anonymous, de-identified, or aggregated datasets for any purpose. For more information about Aggregation Information, see below.

  

Aggregated Information: We may aggregate Personal Data and use the aggregated information to analyze the effectiveness of our Services, to improve and add features to our Services, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Services and share aggregated information like general user statistics with prospective business partners. We may collect aggregated information through the Services, through cookies, and through other means described in this Privacy Policy.

 

  1.     SHARING AND DISCLOSURE OF PERSONAL DATA

 

In certain circumstances, we may share the categories of Personal Data described above without further notice to you, unless required by the law, with the following categories of third parties:

 

  • Vendors and Services Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with vendors and service providers, including providers of hosting services, cloud services, and other information technology services providers, email newsletter services, moderation services, advertising and marketing services, customer support services, and analytics services. Pursuant to our instructions, these parties will access, process, or store Personal Data in the course of performing their duties to us.

 

  • Business Transfers: We may disclose your information to our subsidiaries and affiliates. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider (collectively a “Transaction”), your Personal Data and other information may be shared in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.

 

  • Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a court order, regulatory request or other legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Services, or the public, or (v) protect against legal liability.

 

  • Enforcing our Rights: We may disclose your information as necessary to enforce our rights arising from any contracts entered into between you and use, such as our EULAs and Terms of Service.

 

  • Necessary for Purpose: We may disclose your information as necessary to fulfill the purpose for which you provided it.

 

  • With Your Consent: We may disclose your information with your consent.

 

  • Other purposes: We may disclose your information for any other purpose disclosed by us and accepted by you when you provide the information.

 

  1.   WHERE, HOW AND HOW LONG WE STORE YOUR INFORMATION

 

We store all Personal Data securely in the U.S. using third-party vendors who implement industry-standard security measures. 

 

We keep your information only for the length of time necessary to fulfill the purposes for which the information was collected. For example, if you have an account with us, we will retain the Personal Data associated with your account for the lifetime of your account and for a reasonable period of time thereafter if necessary. If you provide us with your email for our newsletter, we will delete your email after you unsubscribe from our newsletter. Some of the information collected via cookies is retained only for your session. Other cookie information is retained anywhere from 90 days to just over a year. Necessary cookies may be set indefinitely, but you can delete these by clearing your cache and opting to clear cookies and site data. If applicable laws require us to store your information for a longer period, then we will keep your information for the period required by law. When it is no longer necessary or required for us to retain your data, we will delete it.

 

  1.     DATA SECURITY

 

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure by partnering with third parties who use industry-standard security measures to protect your information.

 

Unfortunately, the transmission of information via the Internet and mobile platforms is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted through our Services. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

 

  1.     YOUR RIGHTS AND CHOICES

 

In certain circumstances, providing Personal Data is optional. However, if you choose not to provide Personal Data that is needed to use some features of our Services, you may be unable to use those features.

 

We strive to provide you with choices regarding the Personal Data you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of your information.

 

  • Opting out of ad tracking through preferences: When you first visit our Games that serve ads, you will have the option of opting out of ad tracking. For more information about our cookies click here.
  • Opting out of ad tracking through ad networks and browser settings: Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative’s online resources at http://www.networkadvertising.org and follow the opt-out instructions there. You can also opt out of ad tracking using your browser settings.
  • Updating or correcting your information: Please contact us at privacy@spryfox.com to request changes or corrections to your Personal Data.

 

  • Deleting Your Personal Data: We provide all of our data subjects with the Right to be Forgotten (also known as the Right to the Deletion of your Personal Data ), whether or not you reside or are a citizen of a jurisdiction that provides you this right. Please contact us at the email above to request the deletion of your Personal Data.

 

Please note, however, that the Right to be Forgotten is not an absolute right. The Right to be Forgotten only applies to the following types of Personal Data that are held by us at the time of the request:

  • Personal Data that was processed on the basis of consent,
  • Personal Data processed on a basis other than consent or legitimate interests that is no longer required for the purpose for which it was originally collected or processed,
  • Personal Data that was processed unlawfully,
  • Personal Data that must be deleted in order to comply with a legal obligation, or
  • Personal Data of a child.

 

  • Third parties: We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.

 

For more information about the third parties that collect data through the Services, see the “Third Party Information Collection” section above to understand which third parties have access to your Personal Data through the Services. You can consult their privacy policies to see if they offer additional options for limiting collection.

 

Personal Data Rights: Most comprehensive consumer privacy laws provide those that they protect certain data protection rights. While the precise rights vary from jurisdiction to jurisdiction, most include all or a number of the following: 

 

  • The right to confirm – You have the right to confirm whether a controller is processing your Personal Data;

 

  • The right to access/obtain – You have the right to request copies of your Personal Data. We may charge you a small fee for this service.

 

  • The right to correct/rectify – You have the right to request corrections to any Personal Data you believe is inaccurate and/or incomplete.

 

  • The right to be forgotten/deletion – You have the right to request that Company erase certain types of Personal Data (see Deleting Your Personal Data above).

 

  • The right to restrict processing – You have the right to request that Company restrict the processing of your Personal Data, under certain conditions.

 

  • The right to object to processing – You have the right to object to Company’s processing of your Personal Data, under certain conditions, such as for targeted advertising.

 

  • The right to data portability – You have the right to request that Company transfer the Personal Data that we have collected to another organization, or directly to you, under certain conditions.

 

We are happy to provide the above rights to all of our users, regardless of their residence or location. If you make a verified request, we have one month to respond to you. If you would like to exercise any of these rights, please send us a request at privacy@spryfox.com. Note that we may require you to provide certain information in order to verify your request. We are only required to act on to verified requests.

 

Personal Information Rights for California Residents:

Shine the Light. Under California Civil Code Section 1798.83, ( the “Shine The Light” law), California residents who use the Services may request and obtain from us, once a year and free of charge, information about categories of Personal Data (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared Personal Data in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

 

Minors. California residents who have an account with us and who are under 18 years of age have the right to request deletion of any data that such users post on the Services, if any. To request deletion of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

 

  1.   CHANGES TO THE PRIVACY POLICY

 

The Services and our business may change from time to time. As a result, we may change this Privacy Policy at any time. When we do we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our Services or providing us with Personal Data after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.

 

  1.   CONTACT US

 

If you have any questions about our Privacy Policy or information practices, please feel free to contact us at privacy@spryfox.com or by mail at the address provided in Section 1 above.