Passive Investments Learning Ltd.

Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how Passive Investments Learning Ltd. ("Company", "we", "us", or "our") collects, uses, discloses, and protects information when you use our mobile applications: Farm Gamee, distributed through the Apple App Store, and Free Cash – Earn Real Money, distributed through Google Play (each an "App", together the "Apps").

By downloading, installing, or using the Apps, you acknowledge that you have read and understood this Policy. If you do not agree with this Policy, please do not use the Apps.

This Policy is designed to comply with the requirements of Apple's App Store (App Privacy / App Tracking Transparency), Google Play's User Data and Data Safety policies, the EU General Data Protection Regulation (GDPR), the California Consumer Privacy Act / CPRA (CCPA), and the Children's Online Privacy Protection Act (COPPA).

2. Information We Collect

We collect a limited set of information necessary to operate and monetize the Apps. The categories below reflect the data processed by us and by our third-party advertising partner (Google AdMob).

2.1 Information collected automatically

• Device & technical information: device model, operating system and version, language, time zone, mobile network and country, screen size, and crash diagnostic information.
• Advertising identifiers: the Google Advertising ID (GAID) on Android and the Identifier for Advertisers (IDFA) on iOS, where the user has provided consent through the Apple App Tracking Transparency (ATT) prompt.
• Approximate location: coarse, IP-based geographic location (country / region level) — used by AdMob to serve relevant ads and to comply with regional regulations.
• Usage data: in-app events such as game sessions, levels reached, ads viewed, and rewards earned. This is used to operate game features and to measure ad performance.
• Internet activity related to advertising: ad impressions, ad clicks, and similar interactions delivered through the AdMob SDK.

2.2 Information you provide

The Apps do not require account creation. If you choose to contact us by email (for example, for support or to exercise a privacy right), we will receive your email address and the content of your message.

2.3 Information we do not collect

• We do not ask for your real name, address, phone number, or government ID.
• We do not collect precise GPS location.
• We do not access your camera, microphone, photos, or contacts.
• We do not collect payment card information; the Apps do not process direct payments.

3. How We Use Information

• Provide the Apps: deliver game functionality, save in-app progress, and operate reward mechanics.
• Display advertising: show ads (including personalized ads where lawful and consented to) via Google AdMob in order to keep the Apps free.
• Analytics & quality: understand aggregate usage, diagnose crashes, and improve stability and performance.
• Security & abuse prevention: detect fraud, abuse, and violations of our terms.
• Legal compliance: comply with applicable law and respond to lawful requests.

4. Legal Bases for Processing (GDPR / EEA & UK)

If you are located in the European Economic Area, the United Kingdom, or Switzerland, we rely on the following legal bases under the GDPR / UK GDPR:

• Consent (Art. 6(1)(a)) — for personalized advertising and the use of advertising identifiers, collected through the in-app Consent Management Platform (Google's User Messaging Platform / UMP).
• Legitimate interests (Art. 6(1)(f)) — for non-personalized advertising, fraud prevention, and basic analytics, balanced against your rights.
• Performance of a contract (Art. 6(1)(b)) — to provide the Apps and their features.
• Legal obligation (Art. 6(1)(c)) — where processing is required by law.

You may withdraw consent at any time from within the App ("Privacy settings" / "Ad settings") or by following Section 9 below.

5. Advertising — Google AdMob

The Apps display advertising delivered through Google AdMob, a service provided by Google Ireland Limited / Google LLC ("Google"). AdMob is a third-party SDK integrated into the Apps. Google may, acting as an independent controller or as our processor depending on the configuration, collect and process certain information for the purpose of serving and measuring ads, including device identifiers, IP address, coarse location, ad interactions, and limited device/app information.

Depending on your region and your consent choices, ads shown to you may be personalized (based on data that Google associates with you over time and across apps) or non-personalized (based only on contextual signals such as your approximate location and the current app content).

• iOS users: the Apps comply with Apple's App Tracking Transparency (ATT) framework. We will only request access to the IDFA, and Google will only use it for cross-app tracking, if you grant permission through the system ATT prompt. You can change this choice at any time in Settings → Privacy & Security → Tracking.
• EEA / UK / Swiss users: consent for personalized advertising and for any storage or reading of identifiers is collected via a Google-certified Consent Management Platform (the User Messaging Platform / UMP) consistent with the IAB Transparency & Consent Framework (TCF v2.2).
• Other regions: personalized ads may be shown by default, subject to local law. You can opt out of personalized advertising as described in Section 9.

For more information about Google's data practices, please review:

• Google Privacy Policy
• How Google uses information from sites or apps that use our services
• AdMob & AdSense personalized vs. non-personalized ads

6. Sharing & Disclosure

We do not sell your personal information for money. We share information only as described below:

• Advertising partner: Google AdMob, as described in Section 5.
• Platform providers: Apple Inc. and Google LLC, in connection with App distribution, crash reporting, and store analytics.
• Service providers: hosting, email, and customer-support vendors acting on our instructions and under written confidentiality obligations.
• Legal & safety: when required by law, valid legal process, or to protect the rights, safety, or property of the Company, our users, or the public.
• Corporate transactions: in connection with a merger, acquisition, financing, or sale of assets, subject to standard confidentiality protections.

Under the CCPA / CPRA, the "sharing" of identifiers and online activity with advertising partners for cross-context behavioral advertising may be considered a "sale" or "share". California residents may opt out as described in Section 9.

7. International Data Transfers

The Company is established in Israel. Our advertising partner Google operates infrastructure globally, including in the United States and the European Union. Where personal data is transferred outside your country of residence, we rely on appropriate safeguards such as Standard Contractual Clauses (SCCs) and the EU-U.S. Data Privacy Framework, as applicable.

8. Data Retention

We retain information only as long as necessary for the purposes described in this Policy:

• Aggregate analytics and ad-serving logs: retained by Google AdMob according to Google's retention policies.
• Support correspondence: retained for up to 24 months after resolution of your request, unless a longer period is required by law.
• Anonymized or aggregated data may be retained indefinitely.

9. Your Rights & Choices

Depending on your jurisdiction, you have the right to: access, correct, delete, port, restrict, or object to processing of your personal data; withdraw consent at any time; lodge a complaint with a supervisory authority; and opt out of personalized advertising and the "sale" or "sharing" of personal information.

9.1 Controls inside the App

• Reset advertising consent (EEA / UK / Switzerland): open Settings → Privacy → Manage consent inside the App to re-display the consent dialog.
• Opt out of personalized ads: open Settings → Privacy → Ad settings inside the App.

9.2 Controls on your device

• iOS: Settings → Privacy & Security → Tracking to revoke ATT permission; Settings → Privacy & Security → Apple Advertising to limit Apple's personalized ads.
• Android: Settings → Privacy → Ads to reset or delete your Advertising ID and to opt out of personalized advertising.
• You may also uninstall the App at any time, which stops further collection.

9.3 Exercising other rights

To exercise any data-protection right, contact us at bomickethomasernst@gmail.com. We will respond within the period required by applicable law (typically 30 days under GDPR, 45 days under CCPA). We will not discriminate against you for exercising your rights.

10. Children's Privacy

Our Apps are rated for a general audience and are not directed to children under the age of 13 (or the equivalent minimum age in your jurisdiction, such as 16 in parts of the EEA). We do not knowingly collect personal information from children. We have configured our AdMob integration to comply with Google Play's Families policy and Apple's Kids-related rules where applicable, and we instruct AdMob to treat traffic as child-directed when required by law. If you believe a child has provided us with personal information, please contact us so we can promptly delete it.

11. Security

We use commercially reasonable technical and organizational measures designed to protect information from unauthorized access, disclosure, alteration, or destruction. However, no method of transmission or storage over the internet is 100% secure, and we cannot guarantee absolute security.

12. Store-Specific Disclosures

Google Play Data Safety: the disclosures in our Google Play Data Safety form are consistent with this Policy. Data types collected: device or other IDs, app interactions, crash logs, diagnostics, approximate location, and advertising data. Data is encrypted in transit; users can request deletion as described above.

Apple App Store App Privacy: the "Data Linked to You" and "Data Used to Track You" categories declared on our App Store product page (where applicable, subject to ATT consent) are consistent with this Policy, and include device identifiers, coarse location, advertising data, and product interaction data.

13. Changes to This Policy

We may update this Policy from time to time. The "Last updated" date at the top of this page reflects the latest revision. For material changes, we will provide notice within the Apps or by other reasonable means before the changes take effect. Your continued use of the Apps after the effective date constitutes acceptance of the updated Policy.

14. Contact Us

If you have any questions, requests, or complaints regarding this Privacy Policy or our data practices, please contact:

Passive Investments Learning Ltd.
Email: bomickethomasernst@gmail.com
Website: www.passiveinvestmentslearning.online

Google Play and the Google Play logo are trademarks of Google LLC. Apple, App Store, IDFA, and App Tracking Transparency are trademarks of Apple Inc. AdMob is a service provided by Google.