Privacy Policy

TRLBLZR LIMITED

Effective date: 2 October 2026. Version 2.0.

We are committed to protecting and respecting your privacy and personal data and will only collect and use personal data in ways that are described here and ways that are consistent with our obligations and your rights under applicable law relating to the protection of personal data.

This Privacy Policy aims to give you information about how we collect and process your personal data when you visit our website(s), including subdomains of our website(s) and websites through which we make our products/services available, and when you download, install, or use the Orbo mobile application, however you access it, including via the Apple App Store, Google Play, Telegram, or Jest (together, “our site” and “the App,” and collectively “our Services”), regardless of where you visit these from, including any data that you may provide through our Services, when you purchase our products/services, or when you otherwise interact with us.

Orbo is developed and operated by TRLBLZR LIMITED. This Privacy Policy is presented within the App and describes the personal data we collect. On the Apple App Store and Google Play (together, the “App Stores”), the App is published by Mirols OU (“the Publisher”), whose own privacy policy is linked from each store listing and is available at https://mirolsou.com/privacy-policy.html. The Publisher is a separate and independent controller for data collected through its own advertising, attribution, and crash-reporting SDKs, and will ask for any consent it needs separately.

This Privacy Policy explains what personal data we collect, how we use it, and the legal bases on which we do so. Where we rely on your consent for any processing, we will ask for it separately and you can withdraw it at any time. It is important you read this Privacy Policy carefully so that you are fully aware of how and why we are using your data.

References to “you” or “your” are to you as an individual using our Services or otherwise contacting us (whether on behalf of yourself, or another individual or organisation).

1.Information About Us

1.1.
Our Services are owned and operated by TRLBLZR LIMITED, a business company incorporated and registered in the British Virgin Islands with company number 2161090 whose registered office is at Second Floor, O’Neal Building, 78 Main Street, P.O Box 2132, Road Town, Tortola, British Virgin Islands VG1110 (“we”, “us”, or “our”). We are the controller and responsible for your personal data when you use our services or visit our Services directly.
1.2.
We are bound by applicable data protection laws in respect of the handling and collection of your personal data.

2.Data We Collect

2.1.
We collect the following personal data in connection with your use of our Services. Specifically, we may collect:
  1. Account identifier, a device-generated ID created when you set up an account. We do not require your name, email address, or date of birth to create an account. If you access the App via Telegram, we also receive your Telegram user ID and username from Telegram.
  2. Gameplay and progression data, including your in-game activity, achievements, and progress.
  3. Purchase history, including records of in-app or in-game purchases you make. We do not collect or store your payment card details or other financial information - payments are processed by the relevant Platform's payment system, as applicable.
  4. Analytics and attribution data, collected via PostHog (product analytics) and Adjust (install attribution and campaign measurement), to understand how our Services are used, measure the performance of our marketing, and improve the App.
  5. Device data and IP address, collected automatically when you use our Services, for security, operational, and analytics purposes.
  6. Advertising identifiers. On iOS, we and the Publisher only access the Identifier for Advertisers (IDFA) if you allow tracking through Apple's App Tracking Transparency prompt. You can change this at any time in your device settings under Privacy & Security > Tracking. On Android, the Publisher may access your Google Advertising ID (GAID) in accordance with Google Play's advertising ID policies and any settings you control on your device.
  7. Push notification tokens, where you enable push notifications (App only, where supported by your device).
  8. Support communications, if you contact us for help, the email address you write from and the content of your messages.
2.2.
Where the App is distributed by the Publisher on the App Stores, the Publisher's SDKs may collect personal data for advertising, attribution, and crash reporting. The Publisher is an independent controller for that data, will request any consent it needs through its own consent surface (including Apple's App Tracking Transparency prompt), and describes its processing in its privacy policy at https://mirolsou.com/privacy-policy.html. We are not responsible for the Publisher's processing.

3.Eligibility

3.1.
Our Services are not intended for children under the age of 13, or under the age of digital consent in your country where that is higher. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us at contact@playorbo.fun and we will delete it.

4.Third Party Links

4.1.
Our Services may include links to third party websites, plug-ins, and applications. Clicking on third-party links or enabling third-party connections may allow third parties to collect or share data about you. Third-party sites are not under our control, and we are not responsible for its content. When you leave our Services, we encourage you to read the privacy policy of every website you visit.

5.If You Fail To Provide Personal Data

5.1.
Where we need to collect personal data by law, or under the terms of a contract we have with you, or pursuant to a service that we have been asked to supply to you, and you fail to provide that data when requested, we may not be able to perform the applicable contract or service. In this case, we may have to cancel any arrangement you have with us. We will notify you if this is the case.

6.Purposes For Processing Personal Data

6.1.
We will only use and process your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
  1. Where we need to provide services or information to you or to perform the contract we are about to enter or have entered with you.
  2. Where we have a legal or regulatory obligation we must comply with.
  3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  4. Where we have your express consent to process your data.
6.2.
Specifically:
  1. Account identifier, gameplay and progression data, and purchase history.
  2. Analytics and attribution data, device data, and IP address.
  3. Push notification tokens.
  4. Advertising identifiers.
  5. Support communications.
6.3.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

7.How We May Share Your Personal Data

7.1.
Professional Advisors and Authorities. We may share your personal data with professional advisors (e.g., lawyers, bankers, auditors, and insurers), regulators, and other authorities as required by law.
7.2.
Service Providers. We may share your personal data with third parties that provide services to us, including PostHog (product analytics), Adjust (install attribution), Apple (payment processing), Telegram and Jest (to the extent necessary to operate the App on those platforms), and our cloud hosting providers, to support our business operations and improve our services. These providers are bound to protect your data and use it only for the specified purposes in accordance with our instructions.
7.3.
Business Transfers. If we choose to sell, transfer, or merge parts of our business or our assets, or if we seek to acquire other businesses or merge with them, we may share your personal data with the third parties involved in the transaction. If a change happens to our business, the new owners may use your personal data in the same way as set out in this Privacy Policy.
7.4.
Third-Party Data Protection. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes. They are only permitted to process your personal data for specified purposes and in accordance with our instructions.
7.5.
International Transfers. We may transfer your personal data outside the UK and/or EEA. Whenever we do so, we will always process your personal data in accordance with applicable data protection laws and regulations, including but not limited to the UK GDPR and the EU GDPR. Where a transfer requires compliance with adequacy provisions or other transfer mechanisms under applicable law, we will ensure that at least one of the following safeguards is in place:
  1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
  2. Where no adequacy decision applies, we will ensure there is a valid legal basis for the transfer and, where required, implement an appropriate safeguard mechanism to ensure your personal data is treated consistently with applicable data protection laws and regulations in the UK and/or the EEA (as applicable).
  3. Where we use certain service providers outside of the UK and/or the EEA (as applicable), we may use specific contracts approved for use in the UK and/or the EEA (as applicable) which give personal data the same protection it has in the UK and/or the EEA (as applicable).

8.Do Not Track

8.1.
We do not alter our data collection and use practices when we see a Do Not Track signal from your browser. We do not sell your personal data.

9.Your Rights

9.1.
You can delete your account and the personal data associated with it at any time from within the App via Settings > Delete Account. Deletion is completed within 30 days, except for data we must keep to comply with legal obligations.
9.2.
You have the right to request access to, rectification of, or erasure of your personal data, as well as the right to restrict or object to its processing. Where we process your personal data on the basis of your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing. To exercise any of these rights, please contact us at contact@playorbo.fun. This applies to personal data for which we are the controller, as described under this Privacy Policy. If your request relates to data collected by the Publisher via its SDKs, please contact the Publisher directly using the details in its privacy policy at https://mirolsou.com/privacy-policy.html.

10.Retention Of Your Personal Data

10.1.
We retain your personal data while your account is active and for 12 months after your last activity. If you delete your account, we delete your personal data within 30 days, except where we must keep it to comply with legal obligations or to resolve disputes, in which case we keep only what is necessary for as long as required. If you have any further questions, please contact us at contact@playorbo.fun.

11.Changes To This Privacy Policy

11.1.
We keep this Privacy Policy under regular review and may update it from time to time. We reserve the right to make amendments to our Privacy Policy at any time. Historic versions can be obtained by contacting us.
11.2.
Any changes we may make to this Privacy Policy will be posted on our website.