Gravimax privacy policy

This policy covers Gravimax, our game for Android and iPhone (app ID com.smartargs.gravimax on Google Play and the App Store). Where the two versions differ, the sections below say so. This website has its own policy: privacy policy for smartargs.com.

Controller

The controller responsible for processing personal data in Gravimax under the EU General Data Protection Regulation (GDPR) is:

Overview

Gravimax has no user accounts and no server of ours. Your progress (coins, cubes, accessories, records and settings) is saved only on your device and is not backed up to the cloud. We never see it. Uninstalling the game, or DELETE DATA in the game's settings, erases it.

Both versions show ads from Google AdMob. On Android, purchases go through Google Play Billing and the leaderboards through Google Play Games Services; on iPhone, purchases go through Apple's App Store and the leaderboards through Apple's Game Center. These services process data as set out here and inGoogle's privacy policy andApple's privacy policy. On Android the game also sends play statistics to Google Analytics for Firebase (see Play statistics) and, outside Europe, app events to Meta so that we can measure our ads on Facebook and Instagram (see Ad measurement by Meta).

Ads (Google AdMob)

Gravimax is free and shows ads: a full-screen ad between some runs, and videos you can choose to watch for a reward. The ads come from Google AdMob (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland). To deliver and measure ads and to prevent fraud, the Google Mobile Ads SDK in the game collects:

• your device's IP address, which can be used to estimate your general location,
• device and app identifiers: on Android the advertising ID and the app set ID; on iPhone the identifier for vendors and, only if you allow tracking (see below), Apple's advertising identifier (IDFA),
• how you interact with ads and the app, for example app launches, taps and video views,
• diagnostic information such as app performance and crashes.

In the European Economic Area, the United Kingdom and Switzerland, the game asks for your consent through Google's consent tool before ads are personalised. You can change your choice at any time under PRIVACY OPTIONS in the game's settings. Without consent you see non-personalised or limited ads. The legal basis for personalised ads, and for storing or reading information on your device for them, is your consent (Art. 6(1)(a) GDPR, § 165(3) TKG 2021). For non-personalised ads it is our legitimate interest in financing a free game (Art. 6(1)(f) GDPR).

On iPhone, after a short explanation from Google, the game also asks through Apple's App Tracking Transparency prompt whether it may track you across other companies' apps and websites. Only if you allow it can the ads use Apple's advertising identifier; if you decline, you still see ads, but not ones based on tracking. You can change this at any time in your iPhone's Settings under Privacy & Security → Tracking.

Where US state privacy laws apply (for example in California), you can opt out of the sale or sharing of your personal information for targeted advertising: the game's settings then show PRIVACY OPTIONS, which opens Google's opt-out. On Android you can also reset or delete your advertising ID in your device's settings; on iPhone, declining tracking (see above) keeps the advertising identifier from the ads.

Google may process this data outside the EU, including in the USA. Google LLC is certified under the EU-U.S. Data Privacy Framework, for which the European Commission has adopted an adequacy decision (Art. 45 GDPR). More:how Google uses information from apps that use its services.

Players who buy REMOVE ADS or the SUPPORTER PACK no longer see full-screen ads between runs.

Purchases (Google Play and the App Store)

Gravimax offers optional one-time purchases (REMOVE ADS and the SUPPORTER PACK). Google Play processes them on Android and Apple's App Store on iPhone; we never receive your payment details. The game learns from the store only which products you own and the state of each purchase, and keeps that on your device to unlock them (on iPhone, RESTORE PURCHASES fetches them again). We see orders in the Google Play Console and sales reports in App Store Connect, as needed for accounting and refunds. Refunds of App Store purchases are handled by Apple.

The legal basis is the purchase contract (Art. 6(1)(b) GDPR) and our retention duties under Austrian commercial and tax law, seven years under § 132 BAO (Art. 6(1)(c) GDPR).

Leaderboards (Google Play Games and Game Center)

Every map has a leaderboard: on Google Play Games on Android, and on Apple's Game Center on iPhone. While you are signed in, which usually happens automatically when the game starts, the game sends your best score on a map with a short tag: the cube you used, its accessories and trail, your player level, whether you are a supporter and, if you are a supporter and chose to show one, the flag of the country your phone's region is set to (only that country's flag can be picked). Other players see your profile name and avatar, your score and that cube, with its trail and flag. Android and iPhone players have separate leaderboards.

Google processes your Play Games profile, player ID and scores underGoogle's privacy policy; Apple processes your Game Center profile, player ID and scores under Apple's privacy policy. You can play without either. You can change your profile's visibility or delete your data in the Google Play Games settings, or in your iPhone's Settings under Game Center. The legal basis is providing the leaderboards (Art. 6(1)(b) GDPR).

Play statistics (Google Analytics for Firebase)

To learn how the game is played and make it better, and to see which of our ads bring players, the Android version of Gravimax can send play statistics to Google Analytics for Firebase (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland), which processes them on our behalf under Google's data processing terms (Art. 28 GDPR). The iPhone version currently sends no play statistics. The statistics contain:

• an app instance ID that Firebase creates on your device (not your name or your Google account),
• when you play and for how long, which maps you start, finish or fail and your score, tutorial steps, ads shown and what each one earned, and purchases made,
• where the game was installed from, for example one of our ads or the Play Store's search,
• device and app information such as the model, Android version and game version, and your approximate location (country or region), which Google derives from your masked IP address,
• outside the European Economic Area, the United Kingdom and Switzerland also your device's advertising ID, so that Google Ads can tell which installs from our ads went on to play. Inside these regions the game never allows this, even when you agree to play statistics; elsewhere it stops for good once you have switched PLAY STATS off or on yourself.

In the European Economic Area, the United Kingdom and Switzerland, and wherever the game cannot tell where you are, it asks first and sends nothing unless you agree. The legal basis is then your consent (Art. 6(1)(a) GDPR, § 165(3) TKG 2021). Elsewhere the statistics are on by default, based on our legitimate interest in improving the game and measuring our ads (Art. 6(1)(f) GDPR). Everywhere you can turn them off at any time with PLAY STATS in the game's settings; the game then stops sending them. You can also reset or delete your advertising ID in your device's settings.

Google may process this data outside the EU, including in the USA. Google LLC is certified under the EU-U.S. Data Privacy Framework (Art. 45 GDPR), and Google's data processing terms include the EU Standard Contractual Clauses (Art. 46 GDPR). We use the statistics only in aggregated form and never for remarketing or personalised ads. Google Analytics deletes the data tied to your app instance ID after 14 months and keeps only aggregated reports; if we copy the raw statistics into Google's BigQuery for our own analysis, we delete them there after 14 months too. Because these IDs are not linked to your name or email, we usually cannot find your data that way. More:how Google uses information from apps that use its services.

Ad measurement by Meta (Facebook and Instagram)

We advertise Gravimax on Facebook and Instagram. To learn which installs and players these ads bring, and so that Meta can show our ads to people likely to enjoy the game, the Android version contains Meta's SDK for app events from Meta Platforms Ireland Limited (Merrion Road, Dublin 4, D04 X2K5, Ireland). The iPhone version does not.

In the European Economic Area, the United Kingdom and Switzerland, and wherever the game cannot tell where you are, the SDK stays switched off and sends nothing. Elsewhere it is on by default and sends Meta:

• your device's advertising ID and IP address,
• that the game was installed and each time it is opened, and when you first finish the tutorial,
• purchases made through Google Play (the product, its price and currency),
• device and app information such as the model, Android version, language, time zone and game version.

It never sends your name, your Google account, your scores or anything you type. Meta matches this data with ad views and clicks on its platforms to measure our campaigns and may use it under its own terms to deliver and improve ads; for that use, Meta is responsible itself, as set out inMeta's privacy policy. If you have a Facebook or Instagram account, you can disconnect such data from it under Your activity off Meta technologies in Meta's Accounts Center.

The legal basis is our legitimate interest in measuring and improving the ads that finance and grow a free game (Art. 6(1)(f) GDPR). You can object at any time: switching PLAY STATS off in the game's settings also switches off Meta's SDK for good, and you can reset or delete your advertising ID in your device's settings. Meta may process this data outside the EU, including in the USA; Meta Platforms, Inc. is certified under the EU-U.S. Data Privacy Framework (Art. 45 GDPR).

App stability

Depending on your device's diagnostics settings, Google Play may report crashes and freezes of the game to us as aggregated statistics (Android vitals). On iPhone, Apple shares crash reports and usage statistics with us only if you turn on Share With App Developers in your iPhone's Settings under Privacy & Security → Analytics & Improvements. We use them only to fix problems.

Children

Gravimax is not directed at children under 13, and we do not knowingly collect personal data from them. Ads are limited to content rated for general audiences.

Your rights

With regard to your personal data, you have the right to:

• access the data we hold about you (Art. 15 GDPR),
• have it corrected (Art. 16 GDPR) or erased (Art. 17 GDPR),
• restrict its processing (Art. 18 GDPR),
• receive it in a portable format (Art. 20 GDPR),
• object to processing based on our legitimate interests (Art. 21 GDPR),
• withdraw a consent at any time, without affecting what happened before (Art. 7(3) GDPR).

Because the game has no accounts and no server of ours, we usually hold no data that identifies you (Art. 11 GDPR). To stop play statistics and Meta's app events, turn off PLAY STATS in the game's settings; uninstalling the game removes its app instance ID. You can manage the data Google processes in your Google accountand the data Apple processes at privacy.apple.com. For anything else, email contact@smartargs.com. You also have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR). In Austria this is the Datenschutzbehörde, Barichgasse 40–42, 1030 Vienna (dsb.gv.at).

Changes

We update this policy when the game or the legal requirements change. The current version is always on this page; the game links to it under Credits → Privacy policy.