Privacy Policy

Last updated March 12, 2025

This Privacy Policy (the "Policy") applies to all products, applications, services, and websites (collectively referred to as the "Services") provided by Skich (hereinafter "we," "our," or "us"), including but not limited to our website https://skich.app/, mobile application Skich and mobile application Skich Store.

This Policy applies to all of our Services unless specified otherwise. Please also read Skich's Terms of Services, which describes the terms under which you use our Services.

We attach great importance to the protection of your personal data, so take a moment to find out more about our Privacy Policy and contact us if you have any questions using the details set out below.

Skich Limited liability Company 
HE428950 
118 Agias Fylaxeos Str. 
3087 Limassol, Cyprus 
email (general questions): support@skich.app 
email (personal data questions): support@skich.app

1. TERMS AND DEFINITIONS  

1.1. For the purposes hereof, the following terms and definitions are used:

We (Skich) - Skich Limited liability company. 
Reg.number: HE428950 
Address: 118 Agias Fylaxeos Str. 3087 Limassol, Cyprus

You (User) – any individual that is using functional features of the Services in accordance with applicable law.

Personal data - any information that can either, by itself identify you as an individual or that can be connected to you indirectly by linking it to personally identifying information.

Services - all products, apps, services and websites offered by Skich, including but not limited to our website https://skich.app/, mobile application Skich Store and mobile application Skich.

2. SCOPE

2.1. This Policy shall govern any interaction between Skich and users related to Personal data when using the Services. 
2.2. This Policy neither governs nor determines the rights and obligations of third parties. It also does not apply to third-party applications or software available to users for integration with the Services. Thus, if you integrate any third-party applications with our Services, we will not be able to control how such applications process your Personal data. 
2.3. Please do not use the Services if you do not agree with the provisions and scope hereof.

3. WHAT PERSONAL DATA WE COLLECT?

3.1. Besides Personal data we also process anonymous data, aggregated or not, to analyze and generate statistics related to the habits, usage patterns, and demographics of users as a group or as individuals. Such anonymous data does not allow the identification of the users to which it relates. We may share anonymous data, whether aggregated or not, with third parties. 
3.2. In accordance herewith, Personal data may be collected both directly and indirectly.

(1) Personal data are collected directly when you provide them voluntarily (e.g. when registering in the Services).

(2) Indirect collection of Personal data may occur automatically when accessing the Services. For example, such Personal data collecting will occur when we receive your Personal data from third parties (e.g. our analytics partners).

(3) We may automatically collect technical data related to your device, browsing behavior, and usage patterns. This data is gathered through cookies, server logs, and similar technologies. Additionally, if you visit other websites that use our cookies, we may receive technical data about you.

3.3. We are processing the required minimum of your Personal data for the purposes hereof:

• authentication data: such as user ID (e.g. Google or Apple), email address, full name, username, profile picture;
• search data: such as subscriptions and subscribers, games added to the wish list, games played, game lists, game reviews;
• game data: such as favorite game genres, favorite game categories;
• technical data: such as user device characteristics, unique device identifier, information about the Services used, IP-address, actions in the Services, authorization and usage history of the Services, login data, browser type and version, time zone setting and location, operating system and platform, other technology on devices;
• interaction data: such as release subscriptions, history of customer and technical support requests, time spent in the Services, query history.

Some of our Services require the processing of a limited amount of Personal data. For example, if you use our website, we will not process any authentication data, as it is currently not possible to create or log in to an account there.

Additionally, another one of our Services may require the processing of an additional amount of Personal data. In particular, if you use the Skich mobile app on an Android device, we will also collect and process:

• installed applications data (required): such as name of application.
• installed applications data (users can turn on/turn off this data collection): such as time in foreground, first timestamp, last timestamp, last time used.

We do not collect any special categories of Personal data about you, including information regarding your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health, or genetic and biometric data. Additionally, we do not gather any details related to criminal convictions or offences.

Failure to Provide Personal Data

If we are legally required to collect Personal data or need it to fulfill a contract with you, and you do not provide the requested information, we may be unable to deliver our services or fulfill our contractual obligations. This could result in the cancellation of a Service you have with us, but we will inform you if this occurs.

4. DATA PROCESSING, STORAGE AND PROTECTION

4.1. “Processing” is understood as at least one of the following: storage, modification, retrieval, disclosure, structuring, use, destruction as well as any other action with respect to your Personal data.

4.2. In general, we can use your Personal data for the following purposes:

Delivering and improving our Services. We use your information for developing, delivering and improving our Services, adapting our Services, providing Services updates, technical troubleshooting, understanding and analyzing trends in connection with usage of the Services, and administering the Services.

Analytics and research. We use your information for understanding and analyzing trends in connection with the usage of the Services, gathering information about our user base, data about where the Services were downloaded from. We may also create reports and analysis for the purposes of research or business intelligence, for example to track potential problems or trends with our Services, or to test our new features and content.

User Support. We use your information for providing user support to you and to respond to your inquiries.

Our legal obligations. We use your information when we are required to do so by law.

We collect a variety of information through your general interaction with the Services offered by Skich. Personal data we collect may include, but is not limited to, browser and device information, data collected through automated electronic interactions and application usage data. Likewise, we will track your process across our websites and applications to verify that you are not a bot and to optimize our Services. 

4.3. Subject to data anonymization, your Personal data may be used by Skich for any other purposes. This allows us to both strictly respect the data protection rights of our users, and not to lose the value of the user experience that they have shared within the Services.

Upon data anonymization activities we might be using further received anonymous statistics and data to improve our Services, relevant user experience as well as to share it with our partners.

4.4. We use profiling to effectively personalize the features of our Services. Nevertheless, we do not not use any other automated decision-making tools in Personal data processing. Automated decision-making tools primarily include those systems that process your Personal data without human intervention to make decisions that may have potential legal consequences for you. All decisions that may significantly affect you are made with human involvement. 

At any time, you may withdraw your consent for the processing of your Personal data under automated decision-making tools. Please note that the withdrawal of consent does not affect the lawfulness of any data processing that occurred prior to the withdrawal. Personal data processed before the withdrawal will remain valid if it was processed in compliance with applicable laws and regulations.

4.5. Your Personal data will be stored on the servers of our counterparties that we are using for operating our Services.

4.6. We use Google Cloud Services (https://cloud.google.com) for operating our Services. Therefore, your data will be stored on the servers of the Google Cloud. 

4.7. Employees of Skich shall also take all necessary organizational, legal and technical measures available to us for protection of your Personal data. Users of the Services shall also be responsible to the maximum possible extent for the provision of accurate account details, keeping passwords and any other information required for authorization confidential and its protection from unauthorized access by third parties.

Any Personal data collected and processed hereunder shall be properly protected unless:

(1) you consent to their disclosure; 
(2) such Personal data are anonymized; 
(3) such Personal data are subject to disclosure under the applicable law.

4.8. We will do our best to keep your Personal data protected. However, despite any possible measures taken on our part, we cannot guarantee full protection of the Services against information security risks.

4.9. Kindly be aware that the features and Services we offer will undergo periodic updates and developments. If a specific feature or Service is not mentioned above, and we obtain your information for it, we will provide a separate explanation through reminders, communications, website announcements, etc., to inform you about the content, scope, and purpose, and seek your consent.

4.10. Purposes for which we will use your Personal data

1. Below, we have provided a table outlining all the ways we intend to use your Personal data, along with the legal bases we rely on for processing. Where applicable, we have also indicated our legitimate interests.
2. Please note that, depending on the specific purpose for which we are using your Personal data, we may process your Personal data under more than one lawful basis. If you have any questions about the specific legal basis we are relying on in cases where multiple grounds are listed, please contact us.

4.11. Some of your information and activity are always public. This means that part of your Personal data is publicly visible even to people who are neither Users, viewers nor persons who are somehow signed in to our Services. The following data may be publicly visible:

• username;
• game related content (e.g. game lists).

4.12. After registration in one of our Services, you can access your Skich account and Personal data associated with it: 

• on the Skich Store mobile application by logging in to it;
• on the Skich mobile application by logging in to it;
• when logging into other Services (existing at the time you accept this Privacy Policy and those that will be created later).

COOKIES

Our Services use cookies to provide you with the best possible service. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Services may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy. 

CHANGE OF PURPOSE

We will use your Personal data only for the purposes for which it was collected, unless we determine that it is necessary for a different but compatible purpose. If you would like an explanation of how the new processing aligns with the original purpose, please contact us. Should we need to use your Personal data for an unrelated purpose, we will inform you and explain the legal basis permitting such use. Please note that, where required or allowed by law, we may process your Personal data without your knowledge or consent in accordance with these rules.

5. DATA RETENTION

5.1. We retain your Personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. Specifically, we retain your Personal data for a period of five (5) years from the date of your last login to your account, unless a longer retention period is required by applicable legal, regulatory, or contractual obligations. Once the retention period has expired, your Personal data will be securely deleted or anonymized to ensure it can no longer be used to identify you.

5.2. In certain circumstances, you have the right to request the deletion of your Personal data. Additionally, we may anonymize your Personal data so that it can no longer be linked to you and use it indefinitely for research or statistical purposes without further notice.

If you would like more information about retention periods for different types of Personal data, please contact us.

6. TRANSFER AND DISCLOSURE

6.1. Your privacy is of utmost importance to us, and we handle your Personal data with the highest level of care and responsibility. While we endeavor to minimize the sharing of your Personal data, there are certain circumstances where it becomes necessary to disclose it to third parties.

6.2. A number of third parties may have access to your Personal data - processors, services of which we use in order to constantly improve our Services, as well as provide you with the opportunity to use all its functionality.

Therefore, the following legal entities will be having the access to your Personal data, but only to the extent necessary to perform their services for us:

(1) Amplitude, Inc. (USA) 
Address: 631 Howard Street, Floor 5, San Francisco, CA 94105 
Amplitude Privacy Policy

Amplitude may have access to the Personal data you provide to us because we use their service to log user’s actions on the Services in order to further improve them.

(2) Google Inc. (Ireland)

Address: Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland

Google Privacy Policy

Google may have access to the Personal data you provide to us because we use their Firebase service to send notifications and their other services for user authentication purposes.

(3) Apple Inc. (USA)

Address: One Apple Park Way, Cupertino, CA 95014

Apple Privacy Policy

Apple may have access to the Personal data you provide to us because we use their services for user authentication purposes.

(4) Twilio Inc. (USA)

Address: 375 Beale Street, Suite 300, San Francisco, CA 94105

Twilio Privacy Policy

Twilio may have access to the Personal data you provide to us because we use their SendGrid service to send transactional emails.

6.3. To ensure the provision of our Services, your Personal data may also be transferred to a legal entity created after reorganization of Skich should it be necessary.

6.4. Please note that your public profile data (name, nickname, profile picture, subscriptions and subscribers, games collections) will be available to other users of the Services.

6.5. We may be required to disclose your Personal data in the following circumstances:

• To comply with legal obligations, judicial proceedings, or requests from public authorities in your country or other jurisdictions.
• When necessary for national security, law enforcement, or to protect the rights, safety, and legitimate interests of Skich, third parties, or the public.
• To fulfill contractual obligations when your data is required for entering into or performing a contract.
• In response to public health emergencies or to protect the life, health, or safety of individuals in urgent situations.
• When processing data that you or others have lawfully disclosed within a reasonable scope.
• Any other circumstances as required by applicable laws and regulations.

6.6. We pay attention to conclude business relationship and to transfer your Personal data only to those partner’s, which operates their business in country acknowledged as “safe” in terms of data privacy policy (countries of EU and acknowledged by the EU Commission decision).

6.7. If your data is transferred outside the European Economic Area (EEA), we ensure it is protected through mechanisms such as Standard Contractual Clauses or equivalent safeguards. 
For further details, see European Commission: Model contracts for the transfer of Personal data to third countries (https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en). 

7. CHILDREN`S PERSONAL DATA

To the extent to which it is not prohibited by the applicable law, we do not authorize the use of our Services by individuals who have not reached the age of full legal capacity in accordance with the legislation of the country of their citizenship. We do not collect and process (at least knowingly) their Personal data without the consent of their legal representatives. If we learn that we have collected data from a child without appropriate consent, we will delete it promptly.

8. USER RIGHTS

8.1. The rights of users related to the collection and processing of Personal data shall be determined in accordance with the applicable law.

8.2. As a data subject, you have specific rights related to your Personal data. We are committed to respecting these rights and ensuring you can exercise them effectively.

Below, you can find the information regarding your rights as a data subject under EU data protection legislation:

1. Right to access allows users to request access to their Personal data stored by us.  
To exercise this right, the user should contact us via the email address provided above. Upon receiving a request, we will provide users with a copy of the Personal data we process in the format requested. Note that in some cases, we may charge a reasonable fee for providing this information. If, for any reason, we cannot fulfill the request, we will provide an explanation and inform the user of their rights to appeal this decision.

2. Right to rectification enables users to request the correction or updating of any inaccurate or incomplete Personal data we hold about them.  
User may exercise this right in two ways:

• Independently by login to their account in the Services and edit their Personal data they wish to correct, after saving the changes the data update will happen immediately.
• You may also contact us at the email address provided above. Upon receiving a rectification request, we will review the accuracy and completeness of the user's Personal data and make any necessary corrections or updates.

3. Right to erasure allows users to request the deletion or destruction of their Personal data under specific circumstances, such as when the data is no longer necessary for the purposes for which it was collected or processed (commonly referred to as the "right to be forgotten"). 
Users can exercise this right by contacting us at the email address provided above. 
Upon receiving a deletion request, we will assess whether the conditions for deletion are met, and if so, we will promptly delete or anonymize the user's Personal data from our systems and notify any third parties to whom the data was disclosed.

4. Right to restrict processing enables users to request the restriction of processing their Personal data under certain circumstances, such as when the processing is unlawful, the data is no longer needed, or the user has objected to the processing. 
To exercise this right, users should contact us via the email address provided above. 
Once processing is restricted, we will not process the user’s Personal data (except for storage) unless it is based on consent, for legal claims, to protect another individual or entity's rights, or due to important public interest.

5. Right to data portability allows users to receive a copy of their Personal data in a structured, commonly used, machine-readable format, if technically feasible, and to transfer this data to another controller. 
To exercise this right, users should contact us via the email address provided above. Upon receiving a data portability request, we will provide a copy of the Personal data in the requested format, provided it is technically possible.

6. Right to object enables users to object to the processing of their Personal data in certain circumstances, such as when processing is based on legitimate interests or for direct marketing purposes. 
To exercise this right, users should contact us via the email address provided above. 
Upon receiving an objection, we will assess its validity and, if justified, stop processing the user’s Personal data for the purposes to which the objection relates.

7. Right to withdraw consent. If we process Personal data based on consent, users have the right to revoke this consent. 
To exercise this right, users should contact us via the email address provided above. Upon receiving a withdrawal request, we will cease processing the Personal data unless there is another legal basis for doing so.

8. Right to lodge a complaint if the user believes that the processing of their Personal data violates applicable laws, they have the right to lodge a complaint with a supervisory authority relevant to the territory of the EU or particular member state of the EU.

8.3. As we are registered under the laws of the Republic of Cyprus, the supervisory authority overseeing us is the Commissioner for the Protection of Personal Data in Cyprus.  We encourage you to contact us first to allow us the opportunity to address your concerns before reaching out to the Commissioner for the Protection of Personal Data in Cyprus.

8.4. If you would like to exercise your data protection related rights you can submit your request to our e-mail: support@skich.app

Please note that these rights are subject to certain limitations and exceptions as provided by law. To exercise any of these rights or for further inquiries, please contact us using the provided contact information.

We will review your request as soon as possible, but not more than within one (1) month. Please keep in mind that this period may be extended for an additional two (2) months, if necessary, based on the complexity and number of your requests. In that case, we will tell you about the extension within one (1) month of receipt of your request and explain the reasons for the delay.

8.5. If you are a California resident, your rights to the collection and processing of Personal data may be determined in accordance with California Consumer Privacy Act (CCPA).

In accordance with CCPA you may have the right to know, right to delete, right to opt-out of sales, right to non-discrimination.

8.6. To exercise any of your rights above and any other rights guaranteed to you by applicable law and if you have any related questions, write to: support@skich.app. For issues related to your Personal data please contact: support@skich.app. 

8.7. Skich reserves the right to verify your identity before exercising any rights at your request. In case we are not able to exercise any of your rights or provide any information, we will also explain the reasons to you.

9. FINAL PROVISIONS

9.1. This Policy may be amended and (or) modified at any time of the Services operation. In this case, a new version of the Policy and date of its adoption will be published in the Services. If you disagree with amendments and/or additions hereto, you must delete your account in the Services.

9.2. The Policy is an agreement between us and the user about the use of the Services. Any other pre-existing written or oral agreements or arrangements with respect to such use are hereby canceled.

9.3. If any provision hereof is invalid or unenforceable, other provisions shall remain valid and enforceable to the fullest extent permitted by applicable law.

9.4. Failure to enforce your strict compliance herewith cannot be construed as our waiver of any provision hereof or any right hereunder.