Welcome to the privacy policy of Tofu Drifter. This policy will
help you understand what data we collect, why we collect it, and what
your rights are in relation to it.
Latest update: May 20, 2026
Summary
Data we collect automatically
We automatically collect data from you for example when you visit Tofu Drifter.
Trackers
Usage Data
unique device identifiers for advertising (Google Advertiser ID or IDFA, for example)
We collect the data you give to us while using our service
payment info
email address
Trusted third parties help us to process it
How we use them
Handling payments
Owner and Data Controller
Egor Nemov
Owner contact email: privacy@roachgames.com
Type of Data we collect
Among the types of Personal Data that Tofu Drifter collects, by itself or through third parties, there are:
Trackers
Usage Data
unique device identifiers for advertising (Google Advertiser ID or IDFA, for example)
device information
clicks
page views
time zone
geography/region
Universally unique identifier (UUID)
payment info
email address
Complete details on each type of Personal Data collected are
provided in the dedicated sections of this privacy policy or by specific
explanation texts displayed prior to the Data collection. Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Tofu Drifter. Unless
specified otherwise, all Data requested by Tofu Drifter is mandatory
and failure to provide this Data may make it impossible for Tofu Drifter
to provide its services. In cases where Tofu Drifter specifically
states that some Data is not mandatory, Users are free not to
communicate this Data without consequences to the availability or the
functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner. Any
use of Cookies – or of other tracking tools — by Tofu Drifter or by the
owners of third-party services used by Tofu Drifter serves the purpose
of providing the Service required by the User, in addition to any other
purposes described in the present document.
Users are responsible for any third-party Personal Data obtained, published or shared through Tofu Drifter.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent
unauthorized access, disclosure, modification, or unauthorized
destruction of the Data. The Data processing is carried out using
computers and/or IT enabled tools, following organizational procedures
and modes strictly related to the purposes indicated. In addition to the
Owner, in some cases, the Data may be accessible to certain types of
persons in charge, involved with the operation of Tofu Drifter
(administration, sales, marketing, legal, system administration) or
external parties (such as third-party technical service providers, mail
carriers, hosting providers, IT companies, communications agencies)
appointed, if necessary, as Data Processors by the Owner. The updated
list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in any
other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve
transferring the User's Data to a country other than their own. To find
out more about the place of processing of such transferred Data, Users
can check the section containing details about the processing of
Personal Data.
Retention time
Unless specified otherwise in this document, Personal Data shall be
processed and stored for as long as required by the purpose they have
been collected for and may be retained for longer due to applicable
legal obligation or based on the Users’ consent.
The purposes of processing
The Data concerning the User is collected to allow the Owner to
provide its Service, comply with its legal obligations, respond to
enforcement requests, protect its rights and interests (or those of its
Users or third parties), detect any malicious or fraudulent activity, as
well as the following:
Advertising
Analytics
Remarketing and behavioral targeting
Platform services and hosting
Handling payments
Detailed information on the processing of Personal Data
Advertising
This type of service allows User Data to be utilized
for advertising communication purposes. These communications are
displayed in the form of banners and other advertisements on Tofu
Drifter, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers to identify Users or
they may use the behavioral retargeting technique, i.e. displaying ads
tailored to the User’s interests and behavior, including those detected
outside Tofu Drifter.
For more information, please check the privacy policies of the relevant services.
Services of this kind usually allow Users to opt out of such tracking.
Users may learn how to opt out of interest-based advertising more
generally by visiting the relevant opt-out section in this document.
Unity
Company: Unity Technologies SF
Place of processing: United States
Personal Data processed: Trackers +1
Unity is an advertising service provided by Unity Technologies SF.
Meta Audience Network is an advertising service provided by Meta Platforms, Inc. In order to understand Meta's use of Data, consult Meta's data policy.
Tofu Drifter may use identifiers for mobile devices (including
Android Advertising ID or Advertising Identifier for iOS, respectively)
and technologies similar to cookies to run the Meta Audience Network
service. One of the ways Audience Network shows ads is by using the
User's ad preferences. The User can control this in the Facebook ad settings.
Users may opt-out of certain Audience Network targeting through
applicable device settings, such as the device advertising settings for
mobile phones or by following the instructions in other Audience Network
related sections of this privacy policy, if available.
Personal Data processed:
Trackers
unique device identifiers for advertising (Google Advertiser ID or IDFA, for example)
Unless otherwise specified, Tofu Drifter processes any
payments by credit card, bank transfer or other means via external
payment service providers. In general and unless where otherwise stated,
Users are requested to provide their payment details and personal
information directly to such payment service providers. Tofu Drifter
isn't involved in the collection and processing of such information:
instead, it will only receive a notification by the relevant payment
service provider as to whether payment has been successfully completed.
Payments processed via the Apple App Store
Company: Apple Inc.
Place of processing: United States
Personal Data processed: device information +4
Tofu Drifter uses a payment service provided by Apple
Inc. that allows the Owner to offer the purchase of the app itself or
in-app purchases.
Tofu Drifter uses a payment service provided by Google
Ireland Limited that allows the Owner to offer the purchase of the app
itself or in-app purchases.
These services have the purpose of hosting and running
key components of Tofu Drifter, therefore allowing the provision of
Tofu Drifter from within a unified platform. Such platforms provide a
wide range of tools to the Owner – e.g. analytics, user registration,
commenting, database management, e-commerce, payment processing – that
imply the collection and handling of Personal Data.
Some of these services work through geographically distributed servers,
making it difficult to determine the actual location where the Personal
Data are stored.
App Store Connect
Company: Apple Inc.
Place of processing: United States
Personal Data processed: Trackers +3
Tofu Drifter is distributed on Apple's App Store, a platform for the distribution of mobile apps, provided by Apple Inc.
App Store Connect enables the Owner to manage Tofu Drifter on Apple's
App Store. Depending on the configuration, App Store Connect provides
the Owner with analytics data on user engagement and app discovery,
marketing campaigns, sales, in-app purchases, and payments to measure
the performance of Tofu Drifter.
App Store Connect only collects such data from Users who have agreed to
share them with the Owner. Users may find more information on how to opt
out via their device settings here.
Personal Data processed:
Trackers
unique device identifiers for advertising (Google Advertiser ID or IDFA, for example)
Tofu Drifter is distributed on the Google Play Store, a
platform for the distribution of mobile apps, provided by Google
Ireland Limited.
By virtue of being distributed via this app store, Google collects
usage and diagnostics data and share aggregate information with the
Owner. Much of this information is processed on an opt-in basis.
Users may opt-out of this analytics feature directly through their
device settings. More information on how to manage analysis settings can
be found on this page.
This type of service allows Tofu Drifter and its
partners to inform, optimize and serve advertising based on past use of
Tofu Drifter by the User.
This activity is facilitated by tracking Usage Data and by using
Trackers to collect information which is then transferred to the
partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
Services of this kind usually allow Users to opt out of such tracking.
Users may learn how to opt out of interest-based advertising more
generally by visiting the relevant opt-out section in this document.
VK Ads Audiences
Company: VK LLC
Place of processing: Russian Federation
Personal Data processed: clicks +6
VK Ads Audiences is a remarketing and behavioral
targeting service provided by VK LLC that connects the activity of Tofu
Drifter with the VK Advertising Network.
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by any of the services
listed in this document, Users may follow the instructions provided by
YourOnlineChoices (EU),
the Network Advertising Initiative (US) and
the Digital Advertising Alliance (US),
DAAC (Canada),
DDAI
(Japan)
or other similar initiatives. Such initiatives allow Users to select
their tracking preferences for most of the advertising tools. The Owner
thus recommends that Users make use of these resources in addition to
the information provided in this document.
The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest-based advertising on mobile apps.
Users may also opt out of certain advertising features through
applicable device settings, such as the device advertising settings for
mobile phones or ads settings in general.
Further Information for Users in the European Union
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
Users have given their consent for one or more specific purposes.
provision of Data is necessary for the performance of an
agreement with the User and/or for any pre-contractual obligations
thereof;
processing is necessary for compliance with a legal obligation to which the Owner is subject;
processing is related to a task that is carried out in the
public interest or in the exercise of official authority vested in the
Owner;
processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific
legal basis that applies to the processing, and in particular whether
the provision of Personal Data is a statutory or contractual
requirement, or a requirement necessary to enter into a contract.
Further information about retention time
Unless specified otherwise in this document, Personal Data shall be
processed and stored for as long as required by the purpose they have
been collected for and may be retained for longer due to applicable
legal obligation or based on the Users’ consent.
Therefore:
Personal Data collected for purposes related to the performance
of a contract between the Owner and the User shall be retained until
such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s
legitimate interests shall be retained as long as needed to fulfill such
purposes. Users may find specific information regarding the legitimate
interests pursued by the Owner within the relevant sections of this
document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer
period whenever the User has given consent to such processing, as long
as such consent is not withdrawn. Furthermore, the Owner may be obliged
to retain Personal Data for a longer period whenever required to fulfil a
legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted.
Therefore, the right of access, the right to erasure, the right to
rectification and the right to data portability cannot be enforced after
expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
Withdraw their consent at any time. Users have
the right to withdraw consent where they have previously given their
consent to the processing of their Personal Data.
Object to processing of their Data. Users have
the right to object to the processing of their Data if the processing is
carried out on a legal basis other than consent.
Access their Data. Users have the right to
learn if Data is being processed by the Owner, obtain disclosure
regarding certain aspects of the processing and obtain a copy of the
Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users
have the right to restrict the processing of their Data. In this case,
the Owner will not process their Data for any purpose other than storing
it.
Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller.
Users have the right to receive their Data in a structured, commonly
used and machine readable format and, if technically feasible, to have
it transmitted to another controller without any hindrance.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data
transfers abroad including to any international organization governed by
public international law or set up by two or more countries, such as
the UN, and about the security measures taken by the Owner to safeguard
their Data.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in
the exercise of an official authority vested in the Owner or for the
purposes of the legitimate interests pursued by the Owner, Users may
object to such processing by providing a ground related to their
particular situation to justify the objection.
Users must know that, however, should their Personal Data
be processed for direct marketing purposes, they can object to that
processing at any time, free of charge and without providing any
justification. Where the User objects to processing for direct marketing
purposes, the Personal Data will no longer be processed for such
purposes. To learn whether the Owner is processing Personal Data for
direct marketing purposes, Users may refer to the relevant sections of
this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner
through the contact details provided in this document. Such requests
are free of charge and will be answered by the Owner as early as
possible and always within one month, providing Users with the
information required by law. Any rectification or erasure of Personal
Data or restriction of processing will be communicated by the Owner to
each recipient, if any, to whom the Personal Data has been disclosed
unless this proves impossible or involves disproportionate effort. At
the Users’ request, the Owner will inform them about those recipients.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the
Owner in Court or in the stages leading to possible legal action arising
from improper use of Tofu Drifter or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy,
Tofu Drifter may provide the User with additional and contextual
information concerning particular Services or the collection and
processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, Tofu Drifter and any
third-party services may collect files that record interaction with Tofu
Drifter (System logs) or use other Personal Data (such as the IP
Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal
Data may be requested from the Owner at any time. Please see the contact
information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy
at any time by notifying its Users on this page and possibly within
Tofu Drifter and/or - as far as technically and legally feasible -
sending a notice to Users via any contact information available to the
Owner. It is strongly recommended to check this page often, referring to
the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis
of the User’s consent, the Owner shall collect new consent from the
User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with
other information — including a personal identification number — allows
for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through Tofu Drifter (or
third-party services employed in Tofu Drifter), which can include: the
IP addresses or domain names of the computers utilized by the Users who
use Tofu Drifter, the URI addresses (Uniform Resource Identifier), the
time of the request, the method utilized to submit the request to the
server, the size of the file received in response, the numerical code
indicating the status of the server's answer (successful outcome, error,
etc.), the country of origin, the features of the browser and the
operating system utilized by the User, the various time details per
visit (e.g., the time spent on each page within the Application) and the
details about the path followed within the Application with special
reference to the sequence of pages visited, and other parameters about
the device operating system and/or the User's IT environment.
User
The individual using Tofu Drifter who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body
which processes Personal Data on behalf of the Controller, as described
in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body
which, alone or jointly with others, determines the purposes and means
of the processing of Personal Data, including the security measures
concerning the operation and use of Tofu Drifter. The Data Controller,
unless otherwise specified, is the Owner of Tofu Drifter.
Tofu Drifter (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by Tofu Drifter as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this
document to the European Union include all current member states to the
European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique
identifiers, web beacons, embedded scripts, e-tags and fingerprinting -
that enables the tracking of Users, for example by accessing or storing
information on the User’s device.
Legal information
This policy relates solely to Tofu Drifter, if not stated otherwise within this document.