Cozy Hold'em

Privacy Policy

Last updated: October 5, 2026

This Privacy Policy explains how FreiLabs (“we”, “us”) handles information in the game Cozy Hold'em (the “Game”) on iPhone and iPad (iOS/iPadOS), Android and Steam, and on the website cozyholdem.com (the “Website”).

The short version
  • You don't need an account. We don't run servers that collect your game data.
  • Your progress, settings and statistics are stored only on your device.
  • On iOS/iPadOS and Android, the Game shows ads through Google AdMob, which may collect device data such as your advertising ID. You decide whether ads can be personalized.
  • On iOS/iPadOS and Android, purchases are processed by Apple or Google. We never see your payment details.
  • On Steam, the Game currently has no ads and no in-app purchases.
  • The Website has no cookies, no analytics and no trackers.

Contents

  1. Who we are
  2. Data stored on your device
  3. Advertising (iOS/iPadOS and Android)
  4. In-app purchases (iOS/iPadOS and Android)
  5. Platform services
  6. Steam
  7. The Website
  8. Legal bases
  9. Retention and deletion
  10. International transfers
  11. Your rights and choices
  12. Children
  13. No real-money gambling
  14. Security
  15. Changes to this policy
  16. Contact

1. Who we are

Cozy Hold'em is developed and published by FreiLabs, the controller responsible for the processing described in this policy that is carried out by us. You can reach us at support@freilabs.com.

2. Data stored on your device

The Game works fully offline and does not require registration. To let you continue where you left off, it saves on your device:

  • game progress (career stars, current match, Gold, experience and level);
  • cosmetic items you own and have equipped, and your avatar;
  • statistics, daily challenges and achievements;
  • settings (language, sound, graphics quality, difficulty);
  • on mobile, a local record of whether “Remove Ads” was purchased and of when the last ad was shown (used to limit how often ads appear).

This data is not sent to us. It may be included in your device's own backups (for example, iCloud or Google backups), under the terms of Apple or Google. Uninstalling the Game deletes it.

3. Advertising (iOS/iPadOS and Android only)

The free mobile versions are supported by ads served by Google AdMob (Google LLC / Google Ireland Limited). We use:

  • Rewarded ads, always optional — for example, “watch to double your Gold” or “watch to swap one more daily challenge”;
  • Interstitial ads, only between matches (never during a hand), with a frequency limit.

We do not show banner ads. If your device is offline, no ad is shown and you lose nothing: match rewards never depend on ads.

What Google may collect

When an ad is requested or shown, the AdMob SDK may collect and process, under Google's own responsibility:

  • device identifiers, such as the advertising ID (IDFA on iOS — only with your permission — or the Android Advertising ID) and app-set ID;
  • IP address and approximate location derived from it;
  • device and app information (model, operating system, language, app version);
  • ad interactions (views, taps) and diagnostic data, used for measurement, frequency capping and fraud prevention.

We do not receive this data in a form that identifies you. We only see aggregated reports (for example, how many ads were shown). Learn more in How Google uses information from sites or apps that use its services and in the Google Privacy Policy.

Your choices about ads

  • Consent (EEA, UK, Switzerland, Brazil and other regions where required): on first launch, the Game shows a consent form from Google's User Messaging Platform (UMP). You can accept or decline personalized ads. You can change your choice at any time in the Game's settings under “Privacy options”.
  • App Tracking Transparency (iOS/iPadOS): the Game asks for permission before accessing your device's advertising identifier (IDFA). If you decline, ads are still shown but without the IDFA. You can change this in Settings › Privacy & Security › Tracking.
  • Android: you can reset or delete your advertising ID in Settings › Privacy › Ads (path may vary by device).
  • Remove Ads: the one-time “Remove Ads” purchase permanently removes interstitial ads. Optional rewarded ads remain available only if you choose to watch them.

If you decline personalized ads, Google may still show non-personalized (contextual) ads, which still use limited data such as IP address for delivery, frequency capping and fraud prevention.

4. In-app purchases (iOS/iPadOS and Android only)

The mobile versions offer optional purchases at a fixed price: “Remove Ads” (non-consumable) and cosmetic packs. There are no paid random items (loot boxes) and chips are never sold.

Payments are processed entirely by the Apple App Store or Google Play. We never receive your name, e-mail, card number or billing address. The Game only receives from the store a confirmation of which products your store account owns, so it can unlock them and let you “Restore purchases”. See the Apple Privacy Policy and the Google Privacy Policy. Refunds are handled by the store where you made the purchase.

5. Platform services

  • Game Center (Apple): if you are signed in to Game Center, the Game reports unlocked achievements to Apple. This is handled by Apple under its privacy policy; we do not receive your Game Center profile data.
  • App stores and operating systems: Apple, Google and Valve may collect information (such as crash reports or usage statistics) according to your device or account settings and their own policies. We may see this information only in aggregated, non-identifying form in their developer consoles.

6. Steam

The Steam version is a paid game and currently contains no ads and no in-app purchases, and the Game itself sends no data to us. Your purchase, Steam account and any Steam features (such as cloud saves or achievements, if available) are handled by Valve Corporation under the Steam Privacy Policy. If this changes, we will update this policy before the change takes effect.

7. The Website

cozyholdem.com is a static website hosted on Cloudflare Pages. It uses no cookies, no analytics and no third-party trackers, and it loads no external fonts or scripts. Your language choice is saved only in your browser's local storage. Like any web host, Cloudflare processes technical data such as your IP address to deliver the site and protect it from abuse; see the Cloudflare Privacy Policy.

If you e-mail us, we use your address and message only to answer you, and delete them when they are no longer needed.

8. Legal bases

Where the GDPR (EU/UK) or Brazil's LGPD apply:

PurposeLegal basis
Personalized adsYour consent (you can withdraw it at any time)
Non-personalized ads, ad measurement and fraud preventionLegitimate interest in funding the free version, or consent where required by law
Processing purchases and restoring themPerformance of a contract
Answering support e-mailsLegitimate interest / your request
Website delivery and securityLegitimate interest

9. Retention and deletion

Game data stays on your device until you uninstall the Game or reset it. We do not hold copies. Data collected by Google, Apple, Valve or Cloudflare is retained according to their own policies. Support e-mails are kept only as long as needed to resolve your request.

10. International transfers

Our service providers (Google, Apple, Valve, Cloudflare) may process data in countries other than yours, including the United States. They rely on safeguards recognized by law, such as the European Commission's Standard Contractual Clauses and the EU–U.S. Data Privacy Framework.

11. Your rights and choices

Depending on where you live (for example, under the GDPR, LGPD or the CCPA/CPRA in California), you may have the right to access, correct, delete or port your personal data, to object to or restrict processing, to withdraw consent and to complain to a data-protection authority (in Brazil, the ANPD).

Because we don't hold personal data about players, most requests are best handled directly through the controls above (Privacy options, tracking permission, advertising ID) or with Google, Apple or Valve. We are glad to help: write to support@freilabs.com.

We do not sell your personal information for money. Personalized advertising through AdMob may be considered “sharing” for cross-context behavioral advertising under California law; you can opt out by declining personalized ads in Privacy options, declining tracking on iOS or deleting your advertising ID on Android.

12. Children

The Game is not directed to children under 13 (or the minimum age in your country) and is rated for older audiences by the app stores because it simulates poker. We do not knowingly collect personal information from children. If you believe a child has provided us personal information, contact us and we will delete it.

13. No real-money gambling

Cozy Hold'em does not offer real-money gambling or prizes. Chips and Gold have no monetary value, cannot be purchased with or exchanged for real money, and Gold only unlocks cosmetic items.

14. Security

Because the Game keeps data locally and we run no game servers, there is no player database to breach. The Website is served only over HTTPS. Purchases and ads are handled by Apple, Google and their partners, who apply their own security measures.

15. Changes to this policy

We may update this policy, for example when we add features or platforms. The “Last updated” date at the top will change, and significant changes will be announced in the Game or on this page before they take effect.

16. Contact

FreiLabs — support@freilabs.com