Wersja polska: https://echo-signal.github.io/odlot-game-docs/polityka-prywatnosci.html
The controller is echo signal, based in Poland, e-mail: support@echosignal.dev (“we”). The game has no user accounts and no server of our own. We never ask for your name, e-mail, phone number or photos.
a) Data kept only on your device (not sent to us; deleted when you uninstall the game or clear its data):
If Android backup is on, the system may save this data in your own backup in your Google account. We cannot access it.
b) Data collected by Google services used in the game (see section 5):
c) Downloading game settings. The game may download a file with new settings or a new version of the model from section 4b from an address given in the game’s remote configuration. The server hosting it sees your IP address in its logs, like any website. We send no data about you there.
| Purpose | Data | Legal basis (GDPR) |
|---|---|---|
| a) Running the game, saving progress, in-game purchases | progress, settings, purchases | Art. 6(1)(b) – contract (use of the game) |
| b) Adapting the game (difficulty, help, offers) – profiling, see below | data from 3a | Art. 6(1)(f) – our legitimate interest in an engaging game funded by ads. You may object (section 8) |
| c) Personalised ads | data from 3b (AdMob) | Art. 6(1)(a) – your consent via the consent form |
| d) Non-personalised (limited) ads | as above, to the extent needed to serve an ad | Art. 6(1)(f) – funding the game |
| e) Statistics, improving the game, training the model from 4b | data from 3b (Analytics) | in the EEA, UK and Switzerland Art. 6(1)(a) – your consent via the consent form (without it Analytics stores no identifiers); elsewhere Art. 6(1)(f) |
| f) Crash reports | data from 3b (Crashlytics) | Art. 6(1)(f) – game stability |
| g) Settling purchases, legal obligations | purchase data | Art. 6(1)(b) and (c) |
| h) Age-appropriate experience | age signal | Art. 6(1)(c) and (f) – protection of minors |
4b. How the game adapts (profiling). A model running on your phone estimates, at the start of every session, how much ad revenue the game may earn over the next 7 days. It uses the data from 3a: phone model and memory, Android version, country, settings, play history, revenue from ads shown, and ad consent. Based on this, the game plans the session, e.g.:
This profiling has no legal or similarly significant effects on you (it only affects gameplay). The model runs on your phone; its inputs and result are also sent to Google Analytics, where they are used for statistics and to train future versions of the model.
| Recipient | Role | More information |
|---|---|---|
| Google Ireland Ltd / Google LLC – AdMob | serving and measuring ads; independent controller for personalised ads | https://policies.google.com/privacy, https://policies.google.com/technologies/partner-sites |
| Google – consent form (User Messaging Platform, IAB TCF v2) | storing your choices and passing them to the ad partners listed in the form | partner list in the consent form |
| Google – Google Play (store, Billing, Age Signals) | sales and payments (Google is the merchant), age signal | https://policies.google.com/privacy, Google Payments Privacy Notice |
| Google – Firebase (Analytics, Crashlytics, Remote Config) | processor acting on our behalf | https://firebase.google.com/support/privacy |
Google may process data outside the European Economic Area (including the USA) under an adequacy decision (EU-US Data Privacy Framework) or standard contractual clauses. We do not sell personal data.
Data sent over the internet is encrypted (HTTPS). Game data on your phone is stored in the app’s private storage, which other apps cannot read.
You have the right of access, rectification, erasure, restriction, portability, to object (including to the profiling in 4b), to withdraw consent at any time (without affecting earlier processing), and to lodge a complaint with a supervisory authority – in Poland the President of the Personal Data Protection Office (UODO, ul. Stawki 2, 00-193 Warsaw), or the authority in your country.
How:
The game is intended for adults (18+) and is not directed at children. We do not knowingly collect children’s data. If you believe a child has used the game, contact us and we will delete the data we can access.
Where Google Play provides an age signal (Play Age Signals API, currently e.g. in Brazil and some US states), the game checks the account’s age range once a day. If it indicates a minor, the game does not use deliberately harder endings, does not show rewarded-ad offers at the predicted end of a session, and marks ad requests as under the age of consent with ad content limited to the “T” (teen) rating. The age signal stays on the phone; we do not send it to analytics and do not use it for ad personalisation or profiling.
If you live in a US state with a consumer privacy law (e.g. California, Virginia, Colorado, Connecticut, Texas), you have additional rights:
We do not knowingly sell or share personal information of consumers under 16.
We will announce material changes in this policy (date at the top) and in the game’s update notes.
echo signal, support@echosignal.dev