Privacy Policy

Tensflare Ltd. ("Tensflare", "we", "us") runs Tens Games, its games studio, and the website at tens.games and the game 9ja Heat Race (together, the "Services"). We are committed to protecting your personal data and to complying with the Nigeria Data Protection Act 2023 (the "NDPA") and its implementing regulations.

This Privacy Policy explains what personal data we collect when you play our games or visit our website, how we use it, who we share it with, and the choices you have. It applies to the Services listed above. It does not cover other Tensflare products, which have their own policies, or third-party sites and apps that we link to.

1. Personal data we collect

1.1 Data you give us

• Nickname. The name shown on leaderboards, result cards and ghost replays. Please don't use your real name or any personal details.
• Account details. If you choose to save your progress, we collect your email address, and a sign-in identifier. You can sign in with an emailed link or with Google; if you use Google, we receive your Google account ID, name and profile picture. We never see your Google password.
• Messages and feedback. What you write to us, including support emails, bug reports and early-access sign-ups.
• Purchase details. Payments for premium garage items and ad campaigns are handled by Paystack. We receive confirmation of the payment (amount, date, reference and payment method type), but never your card number or bank login.
• Advertiser details. If you book ads through Tens.Games for Brands, the business details you give for your invoices (business name, phone, website, billing address, TIN or RC number), your campaigns and the artwork you upload.
• Guardian contact details. If a parent or guardian gives permission for a young player, the contact details they give us for that purpose.

1.2 Data collected automatically

• Guest and device identifiers. A random guest ID stored on your device so we can remember your progress.
• Gameplay data. Your vehicle and city choices, run results (time, bounty, heat reached, near misses), upgrades and cosmetics you own, leaderboard rank, and the recording of your ranked runs (a compact record of your car's position and direction over time) used to create ghost replays.
• Device and technical data. Device type, operating system, browser, screen size, language, network type, and performance and error logs. We also use your IP address to protect the Services against abuse and attacks. We do not use it to work out where you are.
• Ad measurement. When a sponsored billboard or placement appears in your game, the game reports that it was loaded, shown, viewed or clicked, with a random ID that lasts for one play session. We store only daily totals per campaign; the session ID is not kept or linked to you.
• Usage analytics. How the game is used, such as screens visited and features used. We collect this only if you agree (see section 9). We do not currently use any analytics tools.
• Local storage on your device. Settings, guest progress and cached game files (see section 9).

1.3 Data from other sources

From your sign-in provider (the identifier and email you allow it to share), from payment providers (purchase confirmation), and and nothing from our sponsors or advertisers about you: they receive only aggregate results from us, never data about individual players.

1.4 Google user data

If you choose "Continue with Google" to sign in to 9ja Heat Race or Tens.Games for Brands, Google shares with us, with your permission, only:

• your email address and whether Google has verified it;
• your name and profile picture; and
• your Google account ID (a number that lets us recognise you the next time you sign in).

We ask only for the basic sign-in permissions (openid, email, profile). We do not get access to your Gmail, contacts, Drive, calendar, YouTube or any other Google data, and we never see your Google password.

How we use it. Only to create and sign in to your account, keep your progress and purchases on it across devices, send you service emails (such as receipts and sign-in links), and show your name in your account menu.

Sharing. We do not sell Google user data, use it for advertising, share it with advertisers or sponsors, or use it to train artificial intelligence models. It is stored with our database provider (section 3) and is not shared with anyone else, except where the law requires.

Keeping and deleting it. We keep it while your account exists. When you delete your account (section 5), your email, name, picture and Google account ID are deleted. You can also remove our access at any time from your Google Account, under Third-party apps and services.

Our use of information received from Google APIs follows the Google API Services User Data Policy, including its Limited Use requirements.

1.5 What we do not collect

We do not collect your precise location, your contacts, your photos, your camera or microphone, or free-text chat. At launch, in-game communication is limited to preset emotes and stamps.

2. How we use personal data

• To run the game. Save your progress, show your nickname, rank and vehicle on leaderboards, and replay your ghost for players who challenge you.
• To keep the game fair. Check ranked runs against distance, speed and time to spot cheating, bots and exploits, and to protect the in-game economy.
• To improve and balance the game. Understand how vehicles, cities and features are used, fix bugs and measure performance on low-end phones and slow networks.
• To communicate with you. Send service messages, answer your questions and, only if you agree, send news about new games and events. You can unsubscribe at any time.
• For security and safety. Prevent abuse, fraud and attacks, and enforce our Terms of Play.
• For legal reasons. Meet our legal obligations, resolve disputes and respond to lawful requests from authorities.

We do not use your gameplay data to train artificial intelligence models. We do not make decisions about you that have legal or similarly significant effects by automated means, other than automated cheat detection, which may remove a ranked score or restrict access (you can ask for a person to review it).

3. How we disclose personal data

We do not sell your personal data. We share it only in these ways:

• Publicly in the game. Your nickname, vehicle, state or region, bounty and rank appear on leaderboards and result cards. Players who challenge you can race a ghost of your ranked run. Anything you choose to share on WhatsApp, X, TikTok or elsewhere is then governed by those services.
• Service providers. Companies that help us run the Services, such as hosting, sign-in, databases, email delivery, analytics (if you agree), crash reporting and payments. They may use the data only for us and under contract.
• Affiliates. Tensflare group companies that support the Services.
• Legal and safety. Authorities, courts or other parties where the law requires it, or to protect rights, safety and security.
• Business changes. A buyer or partner, if Tens Games or part of it is merged, sold or reorganised. We will tell you if your data is affected.
• With your consent. For any other purpose, if you agree.

Our main service providers are:

We will update this list when it changes.

4. Data security

We use administrative, technical and physical safeguards to protect your data, including encryption in transit, access controls, and server-side validation so that game currency and rankings cannot be set by the player's device. No system is completely secure, and we cannot guarantee absolute security. Please tell us right away if you think your account has been misused.

5. Your rights and choices

Under the NDPA, and subject to its conditions, you have the right to:

• be informed about, and get access to, the personal data we hold about you;
• have inaccurate data corrected and, where appropriate, deleted;
• object to or ask us to restrict certain processing;
• withdraw your consent at any time, such as for analytics or marketing (this does not affect what we did before);
• receive your data in a portable format, where applicable;
• ask for a person to review an automated decision that affects you;
• opt out of marketing messages at any time using the link in a message or by contacting us.

To use these rights, email privacy@tensflare.com. We may need to confirm who you are before we act. You can also delete your account yourself: in the game, open your account menu and choose "Delete account"; advertisers can do the same under Business details in Tens.Games for Brands. You can clear local data from your browser at any time. If you are not satisfied with our response, you can complain to the Nigeria Data Protection Commission (NDPC).

6. Data transfers

We are based in Nigeria. Our servers are in Germany and our database is in Sweden, both in the European Union, and some service providers (listed in section 3) process data in the United States. When we transfer personal data outside Nigeria, we do so in line with the NDPA's cross-border transfer rules, using safeguards such as adequacy findings, contractual protections or other lawful mechanisms.

7. Data retention

We keep personal data only as long as we reasonably need it for the purposes above, or as the law requires. Our current targets are:

When we no longer need data, we delete it or make it anonymous. We may keep anonymous, aggregated data, which can no longer identify you, for research and planning.

8. Young players

9ja Heat Race is a game for a general audience, and we know many players are young. Under Nigerian data protection law, a child is a person under 18, so we design the Services to collect as little as possible: guest play needs no personal details, free-text chat is switched off, paid items are fixed-price unlocks you can see before you buy, there are no loot boxes, and analytics stay off unless consent is given.

You must be at least 13 to save progress to an account. Players aged 13 to 17 need a parent's or guardian's permission to save progress with an email address or to buy anything, and only adults can book advertising.

If you are under 18, please ask a parent or guardian before you save your progress with an email address or make a purchase. We do not knowingly collect personal data such as an email address from a person under 18 without the permission of a parent or guardian. If you think a child has given us personal data without permission, contact privacy@tensflare.com and we will delete it. Parents and guardians can ask to see or delete their child's data at any time.

9. Cookies, local storage and similar technologies

The game is a web app that you can install on your phone's home screen. To work, and to work offline, it uses:

• Essential storage. Local storage and a service worker that save your settings, guest progress and game files on your device. The game cannot work properly without these.
• Sign-in cookie. One first-party cookie (tg_session) keeps you signed in, for up to 30 days. It is set only when you sign in and is not used for tracking or advertising.
• Analytics (optional). We do not currently use analytics tools. If we add them, they will run only if you agree in a consent prompt or settings.

You can clear this data in your browser settings. Doing so may remove your guest progress if you have not saved it to an account. The game sets no other cookies, and no third-party cookies.

10. Sponsored content and third-party links

Our business model includes sponsored in-game content such as billboards and radio ads. We do not use behavioural advertising, build advertising profiles or track you across other sites. Sponsored placements are booked for dates and places in the game, not targeted at you, and sponsors see only aggregate results. Third-party sites and apps we link to, and services you use to share your results, have their own privacy policies, which we do not control.

11. Changes to this policy

We may update this policy from time to time. We will post the new version on this page and change the "Last updated" date. If a change is material, we will also tell you in the game or by email. Earlier versions are available on request.

12. Contact us

Tensflare Ltd. (Nigeria) is the data controller for the Services.

• Privacy requests and questions: privacy@tensflare.com
• Game support: support@9jaheat.com
• Registered office: Tensflare Ltd., FEPA Quarters, Karu Site, Abuja FCT, Nigeria
• Data protection contact: our privacy team, at privacy@tensflare.com

13. Legal bases for processing

Under the NDPA, we need a lawful basis for each use of your personal data:

14. Region-specific information

Nigeria. Your rights are set out in section 5 and under the NDPA. You may complain to the Nigeria Data Protection Commission.

Other countries. If you live outside Nigeria, you may have extra rights under your local law, which we will respect where they apply. Contact us at privacy@tensflare.com.