My Gym Empire

Privacy policy

Last updated: September 27, 2026

This Privacy Policy explains what information the game My Gym Empire (the “Game”) uses, why, who it is shared with, and how you can control it. It applies to the Game on iPhone/iPad (App Store) and Android (Google Play).

By playing the Game, you acknowledge that you have read this policy. If you do not agree with it, please do not use the Game.

1. Quick summary

Question	Short answer
Do I need to create an account or give my name, email or phone number?	No. Signing in with Game Center, Google Play Games, Apple or Google is optional (section 4.7). Without signing in, the Game works normally and your progress stays on your device.
Where is my progress stored?	On your device, in a file that belongs to the Game. Only if you sign in and, where available, a copy is saved in the cloud so you can restore it on another device (section 4.7).
Does the Game access my camera, microphone, photos, contacts or GPS location?	No.
Does the Game show ads?	Yes. Rewarded ads are always optional. Advertising partners receive device data, such as the advertising ID, and use it for personalized ads only if you allow it.
Do you sell my data?	No.
How do I delete everything?	In the Game: Settings › Delete progress and, if you signed in, Delete account. Uninstalling the Game also deletes its data from your device. For data held by partners, see section 7.

2. Who is responsible

The Game is developed and published by:

Ninja Block Studios LTDA
Brazilian company registration (CNPJ): 38.131.443/0001-94
Privacy email: [email protected]

In this policy, “we”, “us” and “our” refer to Ninja Block Studios. We are the controller of the data processed through the Game under Brazil’s General Data Protection Law (Law No. 13,709/2018, the “LGPD”) and the EU/UK General Data Protection Regulation (the “GDPR”). The exception is where this policy says that a partner acts as an independent controller.

3. Data that stays on your device

The Game stores some information locally, on your device’s storage, so that it can work. Without sign-in, this data is not sent to us and does not identify you (if you sign in, see section 4.7):

Game progress: in-game money, gym level, areas and equipment purchased, missions, hired staff and each staff member’s level, loyal members, members’ satisfaction ratings, Strength points, the look and outfits chosen for your character, activities (such as your jiu-jitsu belt) and where you stopped in the tutorial. All member and staff names are fictional and generated by the Game.
Time of the last save: used only to calculate what your gym earned while you were away (“While you were away”). The Game reads your device’s clock, not your location.
Preferences: sound on/off and how the circles on the floor are displayed (Full/Clean).
Technical performance log: frames per second and processing time. It helps us diagnose slowdowns, is reset every time the Game opens and never leaves your device.

If device backup is turned on (iCloud on iPhone or Google backup on Android), your operating system may include these files in your backup. The backup is handled by Apple or Google under your account settings, and we have no access to it.

The vibration when you tap buttons (iPhone) uses the device’s vibration motor and collects no data.

Apart from the optional sign-in (section 4.7), the Game does not ask for or collect: name, email, phone number, date of birth, photos, videos, audio, contacts, precise (GPS) location, health or real-world exercise data, or messages. The Game has no chat and no content created by other players.

4. Data processed by partners

Some features depend on partner companies. They receive certain data directly from your device through software libraries (SDKs) included in the Game.

4.1 Game engine (Unity)

The Game is built with the Unity engine, from Unity Technologies. The engine may send Unity technical data such as device model, operating system, hardware characteristics, language and engine crash information. Unity uses this data to measure compatibility and improve the engine.

4.2 App stores (Apple and Google)

Downloads, installs, updates and reviews are handled by the App Store (Apple) or Google Play (Google) under each store’s own policies. If you have allowed sharing in your device settings, the stores may show us aggregated statistics and crash reports that do not identify you.

4.3 Advertising

The Game is free and is supported by ads:

Rewarded ads (optional): you choose to watch a video in exchange for an in-game reward (for example, doubling your offline earnings or calling the cleaning robot). You are never required to watch them.
Interstitial and banner ads: these appear after some playtime and can be removed with the “No Ads” purchase.

Ads are provided by Google AdMob and/or Unity LevelPlay, which may use other partner ad networks (mediation) to choose the ad that is shown. To serve ads, measure their performance and prevent fraud, these partners may collect:

your device’s advertising identifier (IDFA on iPhone, if you allow it; Google advertising ID on Android) and app-specific device identifiers;
your IP address and the approximate location (country/city) derived from it;
device model and manufacturer, operating system, language, mobile carrier, connection type and time zone;
your interactions with ads (whether an ad was shown, tapped or watched to the end), plus SDK performance and crash information.

Personalized ads only with your permission:

iPhone/iPad: the Game asks for permission through the system prompt (“Allow … to track your activity…”, known as App Tracking Transparency). If you decline, the IDFA is not shared and ads will not be personalized through tracking. You can change this in Settings › Privacy & Security › Tracking.
European Economic Area, United Kingdom and Switzerland: we ask for your consent on a privacy screen before using data for personalized ads. You can review your choice at any time.
Android: you can delete or reset your advertising ID in Settings › Privacy › Ads (the path may vary by device).

If you do not allow personalization, you will still see ads, but they will be non-personalized: based on context and technical data such as approximate location.

4.4 In-app purchases

The Game offers optional purchases such as “No Ads”, diamond packs, special offers and subscriptions. All payments are processed by Apple or Google. We do not receive your card number or any other payment details. We use the Unity IAP library and receive only what we need to deliver and restore your item: the product purchased, the transaction/receipt identifier, the date and the store. Subscriptions are managed and canceled in your Apple or Google account settings.

4.5 Usage analytics and crash reporting

We use Google Firebase (Firebase Analytics and, when enabled, Firebase Crashlytics) to understand how the Game is used and to fix problems. It may collect:

an app installation identifier (randomly generated and different from the advertising identifier);
gameplay events such as session start and length, levels reached, in-game purchases, ads watched and tutorial steps;
device model, operating system, Game version, language, and approximate country and region;
crash reports (what the Game was doing when it closed unexpectedly).

We use this data in aggregated, statistical form: for example, how many players come back the next day, where the Game is too hard, or what causes crashes. We do not use it to find out who you are.

4.6 Notifications

The Game may send local notifications (for example, to tell you that your gym’s earnings are ready to collect). They are scheduled on your device and appear only if you allow them. You can turn them off at any time in your device’s notification settings.

You can sign in to the Game with Game Center (Apple), Google Play Games, your Apple account (“Sign in with Apple”) or your Google account. Signing in is optional and is used to identify you in the Game and, where available, to save and restore your progress and purchases on another device. In that case, your progress and purchases are stored on servers linked to your account. When you sign in, Apple or Google tell us:

an identifier for your player account (different from the advertising identifier);
your name or nickname and, if any, the profile picture of your gaming account;
with “Sign in with Apple” or a Google account, your email — with Apple, you can choose to hide your email and give us a relay address instead.

We never receive your password. Authentication is handled by Apple or Google. The Game has no leaderboards, friends, chat or anything that shows your data to other players.

You can sign out and delete your Game account at any time in Settings. When you delete it, we remove the data linked to it, except what the law requires us to keep (for example, purchase records). You can also remove the Game’s access to your account in your Apple settings (Settings › your name › Sign in with Apple) or Google settings (myaccount.google.com › Security › Third-party apps).

5. How we use data and our legal bases

Purpose	Data	Legal basis (LGPD / GDPR)
Run the Game and save your progress on your device	Progress, preferences and save time (section 3)	Performance of the contract for use of the Game (LGPD art. 7, V / GDPR art. 6(1)(b))
Deliver and restore purchases	Transaction data (4.4)	Performance of contract; compliance with legal obligations (tax and consumer law)
Show personalized ads	Advertising identifier, device data and interactions (4.3)	Consent (LGPD art. 7, I / GDPR art. 6(1)(a)) and App Tracking Transparency permission on iOS
Show non-personalized ads, measure delivery and fight fraud	Technical data and approximate location (4.3)	Legitimate interest in keeping the Game free and secure (LGPD art. 7, IX / GDPR art. 6(1)(f)); consent where local law requires it
Usage statistics, game balancing and crash fixing	Analytics and crash data (4.1, 4.5)	Legitimate interest in improving the Game; consent where local law requires it
Sign-in and, where available, saving/restoring progress and purchases	Account identifier, name/nickname, picture and email (4.7)	Performance of contract, at your request (LGPD art. 7, V / GDPR art. 6(1)(b))
Send notifications	No personal data (scheduled on the device)	Your permission in the operating system
Answer support and privacy requests	Whatever you send us by email	Performance of contract; exercise of rights; legal obligation

We do not make automated decisions that produce legal effects or similarly significant effects on you.

We do not sell your personal data.
We share data only with the partners described in section 4, for the purposes described there. Each partner has its own privacy policy (links in section 11). Some of them act as independent controllers of the data they collect.
We may also share information when required by law (for example, under a court order), to protect the rights and safety of the Game and its players, or in the event of a merger, acquisition or sale of the company. In the last case, this policy continues to apply to data already collected.

California residents (CCPA/CPRA): we do not sell personal data. Using the advertising identifier for personalized ads may count as “sharing” under California law. You can opt out at any time: decline tracking on iPhone, delete your advertising ID on Android, or write to us (section 12). We do not discriminate against anyone who exercises these rights.

7. Your rights and how to exercise them

Under the LGPD (art. 18), the GDPR and other applicable laws, you may request:

confirmation that we process your data, and access to it;
correction of incomplete, inaccurate or outdated data;
anonymization, blocking or deletion of data that is unnecessary or processed unlawfully;
data portability;
deletion of data processed on the basis of your consent;
information about who we share your data with;
information about your option not to give consent and what happens if you don’t;
withdrawal of consent, at any time;
objection to processing based on legitimate interest;
to file a complaint with a data protection authority (in Brazil, the ANPD — www.gov.br/anpd; in Europe, the authority in your country).

Controls you already have, without contacting us:

I want to…	How
Delete my progress	In the Game: Settings › Delete progress (asks for confirmation and cannot be undone)
Delete my Game account	In the Game: Settings › Delete account
Delete all Game data from my device	Uninstall the Game
Stop personalized ads on iPhone	Settings › Privacy & Security › Tracking
Stop personalized ads on Android	Settings › Privacy › Ads › delete/reset advertising ID
Review my consent (EEA/UK/Switzerland)	Privacy option in the Game’s Settings menu
Turn off notifications	Your device’s notification settings
Cancel a subscription	Your Apple account (Settings › your name › Subscriptions) or Google Play (Payments & subscriptions)

For any other request, write to [email protected]. If you don’t sign in, we do not know who you are; if you do, tell us which account (Game Center, Google Play Games, Apple or Google) you use. To find analytics data linked to your installation, we may ask you to send the identifier shown on the Game’s privacy screen. We will never ask for your password or payment details. We respond within the time limits set by law (in Brazil, up to 15 days for a full statement; under the GDPR, within one month).

8. How long we keep data

Data on your device: kept until you use “Delete progress” or uninstall the Game.
Account data (sign-in): kept while the account exists and deleted when you use “Delete account” or ask us to.
Analytics and crash data (Firebase): kept for the period configured in the tool, up to 14 months, then deleted or anonymized.
Advertising data: kept by our advertising partners for the periods set in their own policies.
Purchase records and support emails: kept for as long as needed to help you and for the periods required by tax and consumer protection law.

9. Children

The Game is not directed to children under 13 and we do not knowingly collect personal data from children. In countries where the minimum age to consent to data processing is higher (up to 16 in some European countries), consent to personalized ads must be given by a parent or guardian.

If you are a parent or guardian and believe a child has given us personal data, write to [email protected] and we will delete it. In Brazil, processing of children’s and teenagers’ data follows article 14 of the LGPD and their best interests.

10. International transfers and security

Some partners (Google, Unity, Apple) process data on servers outside Brazil and outside your country, including in the United States. In these cases, the transfer uses the safeguards provided by the LGPD (art. 33) and the GDPR, such as standard contractual clauses and the partners’ own compliance programs.

We take reasonable technical and organizational measures to protect information: we collect the minimum necessary, we do not store payment data, and we use providers with recognized security standards. No system is 100% secure. If a security incident may create a relevant risk or harm, we will notify you and the authorities as required by law.

11. Partner policies

Unity Technologies: https://unity.com/legal/privacy-policy
Google (AdMob, Firebase): https://policies.google.com/privacy — and “How Google uses information from sites or apps that use our services”: https://policies.google.com/technologies/partner-sites
Firebase — privacy and security: https://firebase.google.com/support/privacy
Unity LevelPlay (ironSource): https://developers.is.com/ironsource-mobile/general/ironsource-mobile-privacy-policy/
Apple: https://www.apple.com/legal/privacy/
Google Play: https://policies.google.com/privacy

The list of ad networks used in mediation may change. The current list is available on request at the email in section 12.

12. Contact and data protection officer

Questions, requests or complaints about privacy:

Ninja Block Studios LTDA — Privacy
Email: [email protected]

This contact also acts as our data protection officer (“encarregado”, LGPD art. 41).

13. Changes to this policy

We may update this policy when the Game changes (for example, when a new feature or partner is added) or when the law requires it. The latest version is always available at https://www.ninjastudios.gg/en/mobile/my-gym-empire/privacy, with the “Last updated” date at the top. If a change is significant, we will let you know in the Game and, where the law requires it, ask for your consent again.