Privacy Policy for Mobile Games

In short: my games have no accounts, no sign-in, no forms, no chat and no contact between players. The game does not send any data to me. I do not run my own servers for the games and I do not use analytics SDKs. Data is processed by the store (App Store or Google Play) and, in the phone and tablet versions, by Google AdMob, which shows the ads.

The only third-party libraries in the games are the Google Play billing library (on Android) and the Google Mobile Ads SDK, that is AdMob (on iPhone, iPad and Android). Jelly Jars also uses the Google UMP consent form (User Messaging Platform).

Who is the data controller

The data controller is MG PERFECT Sp. z o.o., based in Jelenia Góra, Poland, tax ID (NIP) 6112837338. This company publishes the games on the App Store and on Google Play (in the stores its name may appear as “MG PERFECT SP Z O O”).

• e-mail: m.gosk@nperfect.pl
• phone: +48 666 282 392

Which games this policy covers

This policy applies to games published by MG PERFECT:

• Splash Patrol (iPhone, iPad, Mac, Android), a family game rated 4+, also suitable for children
• Jelly Jars (iPhone, iPad, Mac, Android), a game for teens and adults, not directed at children

It also applies to future MG PERFECT games. If one of them works differently from what is described here, I will change this document.

What the game stores on your device

Game progress, coins, settings and purchased products are saved locally on your device, in a file in the app’s storage. The game does not send them to me or to any cloud, and I have no access to them.

If device backup is turned on (iCloud backup on iPhone and iPad, Google backup on Android), the system may include this file in the backup. That backup is kept by Apple or Google in your account, not by me.

You can erase your progress in the game settings with the “Start over” button (“Zacznij od nowa”). Deleting the app deletes all of this data from the device.

In-app purchases

Purchases in the games go through the App Store (Apple) and Google Play (Google). The store handles the payment and your account. I do not see your payment details or your account details.

The store gives the game on your device a purchase confirmation with a transaction identifier. The game checks it on the device, unlocks the product and uses it to restore purchases. It does not send it to me.

The stores give me sales reports, which I use for settlements and accounting. Apple’s reports are aggregated. In Google Play reports I see the order number, the product, the price, the device model and the buyer’s country, and, for sales where Google lists me as the merchant, also the region, city and postal code. They contain no name, e-mail address or card details.

Refunds are handled by Apple or Google, depending on the store where the purchase was made.

In Splash Patrol a parental gate always works before the store opens: a multiplication task that has to be solved. In Jelly Jars the same gate is on by default, and a parent can turn it off in the game settings.

Ads

Ads are shown by Google AdMob (Google LLC, and Google Ireland Limited for the European Economic Area). They appear only in the iPhone, iPad and Android versions. The Mac version does not show ads and does not include AdMob.

The ads are full-screen ads between levels and rewarded ads that the player starts on their own. Buying “No ads” (or the bundles that include it) turns ads off.

To show an ad and settle it, AdMob automatically collects data from the device. According to Google’s documentation, this is:

• the IP address, from which Google estimates approximate location,
• interactions with the app and the ads (for example app launch, taps, watching a video ad),
• diagnostic data (for example app launch time and performance),
• device data and device identifiers; the advertising identifier (IDFA on iOS, Android Advertising ID on Android) only under the rules described below for each game.

Purpose: showing and settling ads, measuring their performance, and preventing abuse. Google states that data collected by the AdMob SDK is encrypted in transit (TLS). Google processes this data as a separate controller, under its own privacy policy.

Jelly Jars and other games for everyone

Jelly Jars also has a banner on the game board, in addition to full-screen and rewarded ads.

Advertising identifier:

• iOS (IDFA): AdMob gets it only if you agree to tracking in Apple’s system prompt (ATT). The game shows this prompt in every country.
• Android (Android Advertising ID): in the European Economic Area and the United Kingdom AdMob uses it only with the consent you give in Google’s form. In other countries it may use it without a separate prompt. You can reset or delete the identifier at any time in the Android settings.

In the European Economic Area and the United Kingdom you will see a Google consent form (UMP) the first time you start the game. There, I show personalized ads only with your consent. The form also asks for consent to store and access information on your device, where the law requires it. Refusing consent does not block the game, it only affects which ads you see.

Outside these areas, on Android, ads may be personalized until you delete the advertising identifier in the Android settings.

Splash Patrol

Children may play Splash Patrol, so on iPhone, iPad and Android AdMob works in child-directed mode for every player (tag for child-directed treatment, TFCD, content rating G). The Mac version has no ads. This means that:

• only non-personalized ads with content suitable for children are shown,
• the game does not pass on an advertising identifier (on Android I removed the AD_ID permission, on iOS the game shows no ATT prompt, so the IDFA is not available),
• there is no tracking and no remarketing,
• the game has no links leading outside the game, and the in-game store is behind a parental gate.

AdMob still receives the technical data needed to show and settle an ad and to prevent abuse (IP address, device data, interactions with the ad, diagnostic data), but this data is not used for personalized ads.

Google AdMob is on the list of self-certified ads SDKs of the Google Play Families program (Families Self-Certified Ads SDK). I set up the ads to meet the requirements of the US COPPA law and the Google Play Families program.

Consent and how to change it

• Jelly Jars: you can change your consent for personalized ads in the game settings, under “Ad privacy options” (“Opcje prywatności reklam”). This option appears where the law requires a consent form, including the European Economic Area and the United Kingdom.
• Tracking consent on iOS: change it in the iPhone or iPad Settings, under Privacy & Security, Tracking.
• Advertising identifier on Android: reset or delete it in the Android settings, in the Ads section.
• Splash Patrol: there is nothing to change. Ads there are always non-personalized and without an advertising identifier.

You can withdraw consent at any time. Withdrawing consent does not affect the lawfulness of processing that took place before the withdrawal. You can remove ads completely by buying “No ads”.

Who receives data

• Apple (App Store, purchases and restoring purchases, sales reports)
• Google (Google Play, purchases and restoring purchases, sales reports; Google AdMob, ads)

Data that reaches Google in connection with ads is processed under Google’s policy: policies.google.com/privacy. How Google uses data from partners’ apps is described at policies.google.com/technologies/partner-sites.

Apple Inc. and Google LLC are based in the USA, so data may be processed outside the European Economic Area. According to these companies’ privacy policies, this is done on the basis of mechanisms provided for in the GDPR, for example standard contractual clauses.

The game does not send data to me. I do not run my own servers for the games and I do not use analytics SDKs. I do not sell data.

Legal basis

• Purchases and running the game: performance of a contract, Art. 6(1)(b) GDPR.
• Sales reports, settlements and accounting: legal obligation, Art. 6(1)(c) GDPR.
• Non-personalized ads and security: legitimate interest, Art. 6(1)(f) GDPR.
• Personalized ads and, in Jelly Jars, storing information on the device where the law requires consent for it: your consent, Art. 6(1)(a) GDPR.
• Replying to your message: legitimate interest, Art. 6(1)(f) GDPR.

With personalized ads, Google chooses ads based on a profile of interests (profiling). I do not make automated decisions about you that have legal effects.

Security

Game data sits in the app’s private storage, which the system does not let other apps access. The game has no server it could send it to. Purchases are handled by Apple’s and Google’s mechanisms, and the AdMob SDK sends data encrypted (TLS).

How long data is kept and how to delete it

• Game data: I do not store it, because the game sends nothing to me. On the device you can erase it with the “Start over” button or by deleting the app.
• Sales reports: I keep them as company records for as long as tax and accounting laws require.
• E-mail correspondence: I keep it as long as it is needed to deal with the matter and any claims. I will delete it at your request, unless the law requires me to keep it.
• Ad data: Google keeps it under its own policy. On Android you can reset or delete the advertising identifier in the system settings, on iOS you can turn off tracking, and you can change your consent in Jelly Jars as described above.
• Purchase history: Apple and Google keep it in your store account.

Your rights

You have the right to: access your data, rectify it, erase it, restrict processing, data portability, object, and withdraw consent at any time.

Write to m.gosk@nperfect.pl. Because the game does not send me data, in many cases I will have nothing to hand over or delete. In that case I will tell you whether to contact Apple or Google.

If you think I process data unlawfully, you can lodge a complaint with the President of the Personal Data Protection Office in Poland (UODO, uodo.gov.pl).

Children

Children may play Splash Patrol, so it runs in child-directed mode for every player, without personalization and without tracking, and purchases are behind a parental gate. I do not knowingly collect children’s data.

Jelly Jars is not directed at children. If you are under 16 (in some EU countries the age limit is lower), only a parent or guardian can give consent to personalized ads.

If the data concerns a child, a parent or guardian can contact me about it.

Contact

MG PERFECT Sp. z o.o., Jelenia Góra, Poland, tax ID (NIP) 6112837338.

• e-mail: m.gosk@nperfect.pl
• phone: +48 666 282 392

Changes to this policy

When I change this document, I will also change the update date at the top. Significant changes will additionally be described in the game’s update notes.

Wersja polska

Polska wersja tej polityki jest tutaj: Polityka prywatności gier mobilnych.