top of page

Privacy Policy

Last Updated: 4 March 2026

Privacy policy summary

▸ We collect personal information from you when you use our Services, such as email address,

for the purpose of providing the Services to you.

▸ The personal information that we hold may be held on cloud storage services located in

Australia.

▸ We may disclose your personal information within our organisation, to our trusted service

providers and to government or other parties as required, authorised or reasonably necessary

by law.

▸ If you wish to correct, access the personal information we hold about you, or make a complaint

about our privacy practices, you can contact us at admin@96am.com.au.

▸ Some features of our Services use third party services such as Apple, Google and Unity.

These parties may be located outside of Australia and collect, hold or process your personal

information. It is important to review each of their privacy policies, which are listed in

paragraphs 3.2 and 3.4 of this privacy policy.

▸ Please read our Privacy Policy in full for full details.

1. Our commitment to privacy

1.1. Introduction

96AM PTY LTD ACN 695 374 040, its subsidiaries and affiliates in Australia (collectively,

96AM, we, us or our) is committed to protecting your personal information in accordance with

this Privacy Policy.

This Privacy Policy sets out how and why we use your personal information when you access

and use our website, services and/or otherwise communicate and engage with us (our

Services). It also explains certain legal rights that you may have under privacy and data

protection laws.

This Privacy Policy applies to our software/applications, websites, social media accounts and

communications only, and does not apply to any third-party websites, plug-ins or applications

that are linked to in the Services. Third-party websites may be governed by their own terms

and conditions and privacy practices. We will not be liable for the privacy practices of any

third parties. Your use of third-party websites is at your own risk.

If you have any questions about this Privacy Policy, you are welcome to contact us through

the details in paragraph 13.

1.2. Age restriction

Our Services are not directed to children under the age of 13, and we do not knowingly collect

personal information from children under 13 without parental or guardian consent. Parents or

guardians may provide consent for their child’s use of our Services by contacting us.

We do not knowingly use personal information for behavioural advertising targeted at children

or minors under the age of 13. When you first use the Services, you may be asked to select

an age range. We collect this information solely for the purpose of determining whether

certain features, including personalised or behavioural advertising, should be enabled or

disabled.

We do not request your full date of birth. Age range information is used only to configure the

Services and comply with applicable privacy and child protection laws.

If you indicate that you are under a specified age threshold, personalised advertising and

certain tracking technologies will be disabled.

If we become aware that we have collected personal information from a child without

appropriate consent, we will take reasonable steps to delete the information or obtain consent

as required by law.

If you are a parent or guardian and believe your child has provided personal information to us

without your consent, please contact us.

In-app purchases may be available within the Services. Parents and guardians should use

device-level controls to restrict purchases.

2. Collection of personal information

2.1. What personal information we collect

We may collect and hold the following types of personal information:

(a) Contact and age information: If you contact us and provide such information directly,

we may collect and hold details such as your name, email address, and other contact

details that you provide to us.

(b) Age range: We may implement an age range selector which indicates whether you are

under 13 or within another age bracket however, we do not collect date of birth

information.

(c) Payment and transaction information:

(i) In-app purchases are processed through the Apple App Store or Google Play

billing systems. Email, contact and payment information, such as credit card or

billing details, is collected and stored by Apple Inc. (Apple) or Google LLC

(Google) and their payment processors. We do not collect or store your payment

card details. We recommend that you review Apple’s Privacy Policy and Google’s

Privacy Policy for details on how they collect, use, and protect such information.
 

(ii) We may receive limited transaction information, such as purchase confirmations,

product details, and subscription status, for the purposes of providing the

Services, managing subscriptions, and customer support.

(d) Usage Information and logs: Information about how you use our Services, software,

applications, website, products, and services such as progress, interactions, session

length, crash logs and performance data.

(e) Usage, location and device information, including:

(i) device identifiers (such as IDFA, GAID, or other advertising identifiers);

(ii) IP address and approximate location;

(iii) device type, operating system, and language and time zone settings;

(iv) in-app interactions and gameplay activity; and

(v) ad views, clicks, and engagement metrics.

(f) Other Information: Any other information you voluntarily provide to us.

Game data is stored locally on your device.

2.2. How we collect personal information

We may collect and hold personal information in the following ways:

(a) directly from you, when you provide it to us, including where you contact us, enquire

about our Services, make a purchase or otherwise use our Services;

(b) automatically through use of cookies, which is a small data file transferred to your

device by websites for the purposes of Service functionality and to provide more

relevant information to users of the Services, which you can disable via your browser

preferences – this may affect functionality of our Services;

(c) automatically through use of tracking technologies and analytics tools;

(d) from third parties, such as third-party background screening providers, Government

websites, registers and authorities, service providers, business partners such as

working with children or police checks;

(e) if you attend an event with, managed, delivered or held by us, we may take images or

audio-visual records which identify you; and

(f) from publicly available sources, including social media platforms.

2.3. Optional permissions

If the Services requests optional permissions (e.g., notifications, camera, microphone), we

will:

(a) request consent through the platform’s permission prompt;

(b) explain the purpose before or at the time of request; and

(c) allow users to withdraw permissions at any time through device settings.

We do not collect precise geolocation, biometric data, or sensitive information.

2.4. Anonymity

Where possible, you may contact us anonymously or using a pseudonym, such as if you call

us with a general enquiry or email, however for the function of most of our Services, you will

need to provide true and accurate contact details. If we do not collect personal information

about you, you may be unable to utilise our services or participate in our events, programs or

activities we manage or deliver.

2.5. Analytics

The Services may collect personal information to for analytics purposes, including:

(a) information about your browser, network, and device;

(b) web pages you visited prior to coming to this website; and

(c) your IP address.

This information may also include details about your use of this website, including: clicks,

internal links, pages visited, scrolling, searches and timestamps.

We share this information with Squarespace, our website analytics provider, to learn about

site traffic and activity.

3. Purposes for collecting, holding and using Personal Information

3.1. Purposes

We collect personal information reasonably necessary to carry out our business and to

provide our Services. We may also collect information to fulfil administrative functions

associated with these Services.

We may use personal information for the following purposes:

(a) to provide the Services, products, or information you request;

(b) to process purchases, payments, and other transactions;

(c) to communicate with you, including responding to enquiries, complaints, and support

requests;

(d) to send promotional materials, newsletters, and marketing communications where

permitted by law;

(e) to improve and personalise our Services, products, and app experience, including

tracking usage and behaviour to enhance functionality;

(f) for identification, verification, and security purposes, including preventing fraud, money

laundering, or other unlawful activities, and complying with legal obligations;

(g) to manage and collaborate with our service providers;

(h) to conduct research and analysis to improve our operations, customer satisfaction, and

to tailor products or promotional offers;

(i) to detect, investigate, and prevent fraudulent, suspicious, or unlawful activity;

(j) to comply with applicable laws, regulations, or requests from government and regulatory

bodies, and to protect our rights and interests; and

(k) for other purposes disclosed at the time of collection or otherwise authorised by law or

where you have provided consent.

If we do not collect the aforementioned personal information, we may not be able to perform

our Services, purposes or related functions.

In general, the legal ground for which we collect your personal information is for the legitimate

purpose of offering, providing and/or tailoring our Services to, and otherwise engage and

communicate with, you.

By accessing or using our Services, you expressly consent to our collection, storage and use

of your personal information as set out above, for the purposes set out in this policy.

3.2. Tracking and advertising disclosure

Our Services may display advertisements from third-party ad networks. These third parties

may use cookies, device identifiers, or similar technologies to deliver personalised ads and

measure ad performance.

To provide and improve advertising, we and our advertising partners may collect and use

certain information about your device and usage as set out in paragraph 2.1(d).

This information is used to:

(a) deliver relevant advertising to you;

(b) limit the number of times an ad is shown;

(c) measure ad performance and effectiveness; and

(d) prevent fraudulent or invalid traffic.

We encourage you to review the privacy policies of these partners to understand how they

handle your information prior to interacting with any advertisements from that advertising

network. We do not control the data collection practices of these third parties.

Please see the list of our advertising network privacy policies below:

• Google:

https://policies.google.com/technologies/ads https://policies.google.com/technologies/partner-sites

• Unity:

 

https://unity.com/legal/privacy-policy

Consent: If you are using an Apple device, the Services will request your consent through the

Apple App Tracking Transparency (ATT) prompt before tracking you across apps or websites

for advertising purposes.

(a) If you allow tracking, your device identifiers may be used for personalised advertising.

(b) If you deny tracking, you will still see ads, but they will be non-personalised and not

linked across apps or websites.

You can opt out of personalised advertising or manage your advertising and tracking

preferences via your device settings or in-app settings where available. Please note that

opting out will not remove advertisements, but the ads you see may be less relevant.

Children’s Privacy and Advertising: The Services are not directed to children under 13. We

do not knowingly collect personal information from children for behavioural or personalised

advertising.

3.3. Automated Decision-Making and Artificial Intelligence

While our Services do not use automated decision-making that has a significant effect on

users, we may use automated processes to analyse personal information and app usage data

to improve and personalise your experience, including:

(c) delivering in-app content, recommendations, or features;

(d) providing personalised marketing communications and promotions; and

(e) analysing user engagement and app performance.

This automated processing does not make decisions that significantly affect your rights. You

may manage your marketing and personalisation preferences via your device settings or in-

app options.

3.4. Third-party service providers

Some personal information you provide or that is generated through the Services may be

processed by third-party service providers, as outlined below:

• Apple Inc (Apple): In-app purchases on iOS devices are processed by Apple. We do not

access or store your payment information. For details on how Apple collects, uses, and

protects your information, please review their privacy policy: https://www.apple.com/legal/privacy/en-ww/

• Google LLC (Google): In-app purchases on Android devices are processed by Google.

We do not access or store your payment information. For details on how Google collects,

uses, and protects your information, please review their privacy policy: https://policies.google.com/privacy

• Unity Technologies (Unity): We use the Unity game development platform, which may

include Unity-provided modules (e.g., analytics or in-app purchase SDKs). Unity may

collect device-related information or aggregated analytics. We do not control Unity’s

collection of this information. Please review their privacy policy for more information:

https://unity.com/legal/privacy-policy

2. How we hold and keep your personal information secure

Game data is stored locally on your device. We do not operate any servers that collect or

store game data.

The personal information we do collect, including aggregated analytics, download and

retention statistics received from third-party service providers such as Apple, Google and

Unity, may be held on secure cloud storage services located in Australia.

We take reasonable steps to protect personal information within our possession or control.

This includes implementing appropriate physical, administrative, and technological security

measures, such as password-protected encrypted servers and careful selection of staff and

third-party service providers.

While we endeavour to protect your personal information, no method of transmission over the

internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

You understand and agree that your disclosure of personal information to us, or via third-party

services such as Apple or Unity, is at your own risk.

Please note that personal information stored by these third-party service providers may be

held overseas in accordance with their respective privacy policies.

3. How long do we keep your personal information for

We destroy or de-identify personal information in a secure manner when we no longer need it.

We may aggregate anonymous data for statistical analysis.

You may request deletion of your personal information held by us, by contacting us or using

tools within the Services, where available. We may refuse a deletion request to the extent

that retaining the information is necessary to comply with our legal or regulatory record-

keeping obligations.

Our ability to provide delete personal information is limited to personal information within our

possession or control. We do not have access to, and cannot correct, personal information

that is collected, processed, or stored independently by third-party service providers such as

Apple, Google or Unity. Any requests relating to personal information held by those entities

must be directed to them in accordance with their respective privacy policies.

4. Purposes for disclosing your personal information

4.1. Who we may disclose to

We may disclose personal information to the parties below for the following reasons:

(a) Our directors, officers and employees: Your personal information may be disclosed

to and accessible by our directors, officers and employees for the for the purposes set

out in paragraph 3.1.

(b) Our related bodies corporate: We may disclose your personal information to entities

that are considered our ‘related body corporate’ under the Corporations Act 2001

(Commonwealth) for the purposes set out in paragraph 3.1.

(c) Service providers: We may disclose your personal information, or allow access to it, to

trusted third-party service providers who assist us in operating our business and

providing our services. These service providers may include, for example, our platform or app store providers (e.g., Apple or Google), accountants, financial and tax advisors,

legal advisors, translators, administrative support providers, and IT service providers.

The purposes for which these parties may use your personal information may include:

(i) administering billing, payments, and debt recovery;

(ii) planning, managing, monitoring, and evaluating our Services;

(iii) training staff, contractors, and other workers;

(iv) managing risk and legal obligations, including liaising with insurers and legal

representatives;

(v) responding to enquiries and complaints regarding our Services;

(vi) obtaining professional or business advice; and/or

(vii) responding to subpoenas or other legal orders and obligations.

(d) Advertisers and advertising networks: To deliver in-app advertisements, measure ad

performance, and provide targeted marketing where permitted by law and with

appropriate consent.

(e) Parties required by, or reasonably necessary to comply with law or government

requests: We may disclose your personal information to parties, such as government

authorities, legal or regulatory authorities, where we are required to comply with laws,

regulations, legal processes or government requests or otherwise where reasonably

necessary for us to comply with law or government requests.

(f) Successors: Your personal information may be transferred to the acquiring entity or

organisation in the event of a merger, acquisition, sale of all or a portion of our business

for the purpose of effective that transaction.

4.2. Third‑Party SDKs and Analytics

Our Services may use thirdparty tools such as analytics Software Development Kits (SDK) or

crash reporting services. These providers may collect device information and usage data to

help us improve the Services.

We ensure that:

(a) only data necessary for the Service’s functionality is shared;

(b) SDKs comply with Apple and Google’s data minimisation and user data policies;

(c) no third-party SDKs are used for profiling or advertising to children under 13; and

(d) a list of third-party providers is available upon request.

4.3. Overseas processing

You expressly agree that you consent to the disclosure of personal information to parties in

the aforementioned countries, and subclause 8.1 of the Australian Privacy Principles does not

apply to the disclosure.

Some third-party service providers used by the app, including those described in paragraphs

3.2 and 3.4 (e.g., Apple, Google, Unity), may collect, store, or process personal information

on servers located outside Australia as set out in their respective privacy policies.

 

5. Third party links

Our Services may contain links to third-party websites. We are not responsible for the content

or privacy practices of websites that are linked to our Services.

6. How you may access and correct Personal Information held by us

You have the right to request access the personal information we hold about you and seek

corrections if necessary. To exercise these rights, please contact us using the details provided

in paragraph 13.

Our ability to provide access is limited to personal information within our possession or

control. We do not have access to, and cannot correct, personal information that is collected,

processed, or stored independently by third-party service providers such as Apple, Google or

Unity. Any requests relating to personal information held by those entities must be directed to

them in accordance with their respective privacy policies.

We may ask you to verify your identity before providing you with access to personal

information. We may decline your request to access or correct your personal information in

certain circumstances in accordance with the Australian Privacy Principles. If we do refuse

your request, we will provide you with a reason for our decision and, in the case of a request

for correction, we will include a statement with your personal information about the requested

correction.

We may charge you the reasonable cost for giving access in accordance with Australian

Privacy Principle 12.

7. How you can make a complaint

You may make a complaint about our privacy practices, by contacting us using the details

provided in paragraph 13.

All complaints will be dealt with in a fair and timely manner, taking into account the

circumstances of the complaint. We endeavour to investigate and provide a response to

complaints within 30 days of receipt of the complaint, however if further time is required due

to the complexity of the complaint, we will inform you.

If you are dissatisfied with the outcome of the complaint or the way in which the complaint

was handled, you may contact the Office of the Australian Information Commissioner.

8. Changes to this Privacy Policy

We may change this Privacy Policy from time to time by updating this page, with or without

notice to you. We recommend that you visit our website regularly to keep up to date with any

changes.

9. Governing law

This Privacy Policy is governed by the laws of Victoria, Australia. To the maximum extent

permitted by law, you submit to the exclusive jurisdiction of the courts of Victoria, Australia in

relation to any dispute arising out of or in connection with this Privacy Policy.

10. International Users and Additional Privacy rights

We are based in Australia, but our Services may be accessed by users in other countries.

Where the privacy or data protection laws of another jurisdiction apply to our handling of your

personal information, we will comply with those laws to the extent they are mandatorily

applicable.

10.1. European Economic Area (EEA), United Kingdom and similar jurisdictions

 

10.2. If you are located in the European Economic Area, the United Kingdom, or another jurisdiction

with similar data protection laws, you may have additional rights in relation to your personal

information, including the right to:

(a) access the personal information we hold about you;

(b) request correction of inaccurate or incomplete personal information;

(c) request erasure of your personal information where there is no lawful basis for retention;

(d) restrict or object to processing based on legitimate interests;

(e) withdraw consent where processing is based on consent;

(f) request portability of your personal information in a structured, commonly used,

machine-readable format; and

(g) lodge a complaint with a relevant data protection authority.

We will handle such requests in accordance with applicable law.

10.3. United States (Children)

If you are located in the United States, we recognise that additional protections may apply to

children under the age of 13 under applicable laws such as the Children’s Online Privacy

Protection Act (COPPA).

Where these laws apply:

(a) we do not knowingly collect personal information from children under 13 without

verifiable parental consent;

(b) we will provide parents or guardians with the ability to review, request deletion of, or

refuse further collection of their child’s personal information; and

(c) we will take reasonable steps to limit collection of children’s personal information to

what is reasonably necessary for participation in the app.

If you believe we have collected information from a child in a manner inconsistent with

applicable law, please contact us.

10.4. Other jurisdictions

Users in other jurisdictions may have additional rights under applicable privacy laws. We will

respond to verified requests in accordance with applicable legal requirements.

11. Contact us

If you have any concerns, complaints or requests in relation to this Privacy Policy or your

privacy rights, please contact us at admin@96am.com.au.

© 2023 by Whack Privacy Policy. All rights reserved.

bottom of page