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. With your permission, the game also sends play statistics to GameAnalytics (see Play statistics).

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 (GameAnalytics)

To learn how the game is played and make it better, Gravimax can send play statistics to GameAnalytics (GameAnalytics ApS, Pilestræde 58, 2., 1112 Copenhagen K, Denmark), which processes them on our behalf under a data processing agreement (Art. 28 GDPR). The statistics contain:

• a random ID that the game creates on your device (not your name or your Google or Apple account),
• on iPhone also Apple's identifier for vendors, whether you allowed tracking and, only if you allowed it (see above), Apple's advertising identifier (IDFA); on Android GameAnalytics gets no advertising ID,
• when you play and for how long, which maps you start, finish or fail and your score, tutorial steps, ads shown and purchases made,
• device and app information such as the model, Android or iOS version, game version and country, which GameAnalytics derives from your IP address.

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 (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.

GameAnalytics processes the data in the USA. The transfer is covered by the EU Standard Contractual Clauses in our agreement with GameAnalytics (Art. 46 GDPR). We use the statistics only in aggregated form and keep them only as long as we need them for improving the game; when we stop using GameAnalytics, it deletes them. Because these IDs are not linked to your name or email, we usually cannot find your data that way. More:GameAnalytics' privacy notice.

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, turn off PLAY STATS in the game's settings; uninstalling the game removes its random 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.