Bountiful Games, LLC

Instant Garden Privacy Policy

Last Updated: November 22, 2025

Welcome to Instant Garden, a game by Bountiful Games, LLC (“Bountiful,” “we,” or “our”). This Privacy Policy (the “Policy”) explains how Bountiful collects, uses, discloses, and safeguards your information when you use Instant Garden (the “Game”) and any related websites, content, and other services Bountiful may provide (collectively, the “Services”).

This Policy is incorporated into and subject to our Terms of Service for the Game.

By using the Services, you agree to the terms of the Policy and the Terms of Service, so please read both agreements carefully.

1. INTRODUCTION

This Policy describes our practices regarding the personal data we collect from our players. We are committed to protecting your privacy and handling your data in an open and transparent manner.

This Policy is intended to comply with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines (the “DPA”), and to meet the requirements of the Apple App Store.

2. INFORMATION WE COLLECT

We do not knowingly collect Personally Identifiable Information (“PII”) except the information explicitly set forth herein.

The information that we collect is collected automatically, and we may also collect information from other sources.

1. Information Collected Automatically:

• Identifiers: We automatically collect your User ID and Device ID.

• Device and Network Information: We collect your IP Address for security and to determine your general location (e.g., country).

• Usage Data: We collect data about how you interact with the Game, such as app launches, taps, clicks, and in-game progress.

• Diagnostic Information: We collect crash data and performance data to help us identify and fix bugs and improve the Game's performance.

• In-Game Chat (processed by Photon Chat): If you use the in-game chat or other communication features, the content of messages you send and receive, together with associated metadata (such as your Photon User ID, channel name, timestamps, and message delivery information), is processed by Photon Chat, a service provided by Exit Games. Photon Chat processes this information on our behalf to deliver real-time messaging, channel management, and social interaction features. Photon Chat does not require or collect your real name, email address, phone number, or other direct identifiers in order to operate.

• Social Interaction Data: We collect information necessary to operate social features in the Game, including friend connections, garden visits, gifting actions, Help/Protect/Steal actions, referral codes, invite metadata, and other player-to-player interactions ("Social Data"). This may include timestamps, sender/recipient identifiers, and action metadata.

2. Information from Third Parties

We may receive information about you from third-party services, such as social media platforms, if you choose to link an external account with our Game.

3. HOW WE USE YOUR INFORMATION

We use your information for the following purposes:

• App Functionality: To operate and manage your account, provide you with the Game and its features, and ensure the security of our services.

• Analytics: To understand how our players use the Game and improve the Game and our services.

• Social and Multiplayer Features: To enable in-game chat, multiplayer interactions, garden visits, gifting, and other social features, which require processing through Photon Chat and our networking systems

• Communications: To respond to your comments and questions and to provide customer service.

• Moderation, Safety, and Abuse Prevention: To monitor, review, or filter in-game chat or social interactions for safety, fraud prevention, anti-spam, anti-cheat, and enforcement of our Terms of Service. Photon Chat may process chat content and metadata as part of these safety features.

• Legal Obligations: To comply with our legal obligations under applicable law.

4. SHARING OF YOUR INFORMATION

We may share your information in the following situations:

• With Service Providers: We may share your information with third-party vendors and service providers that perform services for us or on our behalf, such as data analysis, hosting services, and customer service.

• Photon Chat (Exit Games): We share chat content and related metadata with Photon Chat, which provides our real-time messaging and communication infrastructure. Photon Chat processes and temporarily stores chat messages solely for the purpose of delivering chat functionality, supporting moderation, and ensuring service stability. Photon Chat does not sell your data or use it for advertising.

• Visibility to Other Players: When you use in-game chat or social features, certain information—such as your username, actions taken in another player's garden, or referral activity—may be visible to other players as part of normal gameplay.

• For Legal Reasons: We may disclose your information if we are required to do so by law or in the good faith belief that such action is necessary to comply with a legal obligation, protect and defend our rights or property, or in urgent circumstances to protect the personal safety of our users or the public.

We do not sell your personal data.

5. CHILDREN'S PRIVACY

We are committed to protecting the privacy of children. Generally, the Services are not directed to children under the age of 13 (or other age as required by local law), and the Services do not knowingly collect PII from any users, children included. If we become aware that a child has provided or that we have collected PII from a child, we will take steps to delete it promptly.

To exercise these rights, please contact us at the email address provided below.

Certain features, including in-game chat and social interactions, may be disabled, restricted, or filtered for users identified as under the applicable minimum age, or where required by platform rules or local law. If chat is disabled for a user, Photon Chat will not process message content for that user.

6. YOUR RIGHTS AS A DATA SUBJECT

Under the Philippine Data Privacy Act of 2012, you have the following rights:

• The Right to be Informed: You have the right to be informed about the collection and processing of your personal data.

• The Right to Access: You have the right to request access to your personal data.

• The Right to Rectification: You have the right to have any inaccurate personal data corrected.

• The Right to Erasure or Blocking: You have the right to have your personal data erased or blocked under certain conditions.

• The Right to Object: You have the right to object to the processing of your personal data.

• The Right to Data Portability: You have the right to receive a copy of your data in a structured, commonly used, and machine-readable format.

• The Right to Lodge a Complaint: You have the right to file a complaint with the National Privacy Commission.

To exercise any of these rights, please contact us.

7. DATA SECURITY

We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information that you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable.

8. DATA RETENTION

We will retain your personal data only for as long as is necessary for the purposes set out in this Policy, or as required by law. Photon Chat retains chat data only transiently and for the minimum time required to deliver messages, maintain channel history settings, support moderation, and comply with applicable law.

9. INTERNATIONAL DATA TRANSFERS

Your information, including personal data, may be transferred to – and maintained on – computers located outside of the Philippines where the data protection laws may differ. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy. Because Photon Chat operates global infrastructure, chat data and metadata may be processed on servers located in the United States, Europe, or Asia as necessary to provide real-time communication.

10. THIRD-PARTY SERVICES USED BY THE GAME

The Game uses Photon Chat (Exit Games) to provide its in-game messaging features. Photon Chat processes chat messages and metadata solely to operate real-time chat and associated safety systems. More information about Photon Chat can be found at: https://doc.photonengine.com/chat/current/getting-started/chat-intro.

11. CHANGES TO THE PRIVACY POLICY

We may update this Policy from time to time. We will notify you of any changes by posting the new Policy on this page and updating the “Last Updated” date.

12. CONTACT US

If you have any questions about this Policy, please contact us at: privacy@bountifulgames.com