This Privacy Policy explains how Claudiu Ardelean ("we," "us," or "our"), a sole developer based in Romania, collects, uses, shares, and protects information when you use our mobile games and website (collectively, the "Service"). By using the Service, you acknowledge that you have read and understood this Privacy Policy.

1. Data Controller

The data controller responsible for your personal data is:

• Name: Claudiu Ardelean
• Location: Romania, European Union
• Contact: ardelean.claudiu.m@gmail.com

2. Information We Collect

We do not collect personal names, email addresses, or phone numbers directly through our games. However, data is collected automatically through the Service and our third-party partners:

A. Data Collected Automatically

• Device Information: Device make/model, operating system and version, screen resolution, and language settings.
• Network Information: IP address and approximate location (country/region level only).
• Advertising Identifiers: IDFA (iOS) or GAID (Android), subject to your consent where required.
• Gameplay Data: Game progress, scores, achievements, session duration, and crash/error logs.
• Purchase Data: Records of in-app purchases (transaction IDs and items purchased — we never receive or store payment card details).

B. Data You Provide

• If you contact us via email, we collect the information you include in your correspondence.
• Consent preferences you set through the in-game consent dialog (CMP).

3. Legal Basis for Processing (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, we process your data on the following legal bases:

• Consent (Art. 6(1)(a) GDPR): For personalized advertising and non-essential analytics. You can withdraw consent at any time via the in-game consent dialog or your device settings.
• Legitimate Interest (Art. 6(1)(f) GDPR): For essential game functionality, fraud prevention, security, and contextual (non-personalized) advertising.
• Contract Performance (Art. 6(1)(b) GDPR): For processing in-app purchases you initiate and delivering the virtual goods you buy.
• Legal Obligation (Art. 6(1)(c) GDPR): Where we are required to retain data by law (e.g., tax records for purchases).

4. Third-Party Partners (SDKs)

Our games integrate third-party software development kits (SDKs) that may independently collect and process data. Each partner acts as an independent data controller for the data they collect. We encourage you to review their privacy policies.

A. Ad Networks & Mediation

We use the following providers to serve advertisements within our games:

• AppLovin (MAX Mediation): Ad mediation platform that manages ad delivery and collects data for ad personalization and measurement.
  AppLovin Privacy Policy
• Unity Ads: Collects device data for ad serving, targeting, and performance measurement.
  Unity Ads Privacy Notice
• InMobi: Collects device and usage data for ad targeting and analytics.
  InMobi Privacy Policy

B. Consent Management

• InMobi Choice (CMP): We use InMobi Choice as our Consent Management Platform to collect and manage your privacy preferences in compliance with GDPR (TCF 2.2) and other applicable regulations.
  InMobi Privacy Policy

C. Game Services & Infrastructure

• Unity Services (Analytics, Cloud Save, Authentication, Remote Config): Used for gameplay analytics, cloud-based save data, player authentication, and remote game configuration.
  Unity Privacy Policy
• Google Play Services: Used for In-App Purchases, Achievements, Leaderboards, Cloud Saves, and In-App Reviews on Android.
  Google Privacy Policy
• Apple Game Center & StoreKit: Used for Achievements, Leaderboards, authentication, and In-App Purchases on iOS.
  Apple Privacy Policy

5. How We Use Your Data

We use the data collected to:

• Provide, maintain, and improve our games.
• Save and synchronize your game progress across devices.
• Process in-app purchases and deliver virtual goods.
• Display advertisements (personalized or contextual, depending on your consent).
• Analyze gameplay trends and fix technical issues (crash logs, performance data).
• Prevent fraud, cheating, and abuse.
• Comply with legal obligations.

6. Ad Tracking & Your Choices

Apple App Tracking Transparency (ATT)

On iOS 14.5 and later, our games request your permission before accessing your IDFA for ad tracking purposes via Apple's ATT framework. You can change this at any time in your device Settings > Privacy & Security > Tracking.

Google Advertising ID

On Android, you can reset or delete your advertising ID via Settings > Privacy > Ads. Our games respect your device-level advertising preferences.

In-Game Consent Dialog

When you first launch the game, our CMP (InMobi Choice) presents a consent dialog where you can choose to accept or decline personalized advertising and non-essential data processing. You can revisit this choice at any time through the game's settings menu.

7. International Data Transfers

Our third-party partners may transfer your data to servers located outside the EEA, including the United States. When such transfers occur, they rely on appropriate safeguards such as:

• European Commission adequacy decisions.
• Standard Contractual Clauses (SCCs) approved by the European Commission.
• The EU-U.S. Data Privacy Framework, where applicable.

8. Data Retention

• Analytics data: Retained for up to 24 months, then aggregated or deleted.
• Cloud save data: Retained as long as your account is active on the respective platform (Google Play / Apple).
• Ad-related data: Retention periods are determined by each ad partner (typically 13–24 months). Refer to their privacy policies for details.
• Support correspondence: Retained for up to 3 years after the last communication.
• Purchase records: Retained as required by applicable tax and accounting laws.

9. Your Rights

A. Rights Under GDPR (EEA, UK, Switzerland)

You have the right to:

• Access: Request a copy of the personal data we hold about you.
• Rectification: Request correction of inaccurate data.
• Erasure ("Right to be Forgotten"): Request deletion of your personal data, subject to legal retention requirements.
• Restriction: Request that we restrict processing of your data in certain circumstances.
• Data Portability: Receive your data in a structured, commonly used, machine-readable format.
• Object: Object to processing based on legitimate interests, including profiling for advertising.
• Withdraw Consent: Withdraw consent at any time without affecting the lawfulness of prior processing.

You also have the right to lodge a complaint with your local data protection authority. In Romania, this is the ANSPDCP (Autoritatea Nationala de Supraveghere a Prelucrarii Datelor cu Caracter Personal) — www.dataprotection.ro.

B. Rights Under CCPA/CPRA (California, USA)

If you are a California resident, you have the right to:

• Know: Request disclosure of the categories and specific pieces of personal information collected.
• Delete: Request deletion of your personal information.
• Opt-Out of Sale/Sharing: We do not "sell" personal information in the traditional sense. However, sharing data with ad partners for personalized advertising may constitute a "sale" or "sharing" under CCPA/CPRA. You may opt out via the in-game consent dialog or by emailing us.
• Non-Discrimination: We will not discriminate against you for exercising your rights.

C. Exercising Your Rights

To exercise any of the above rights, contact us at ardelean.claudiu.m@gmail.com. We will respond within 30 days (or within the timeframe required by applicable law). We may need to verify your identity before processing your request.

10. Children's Privacy

Our games are not directed to children under 13 (or under 16 in jurisdictions where GDPR applies a higher age of consent). We do not knowingly collect personal data from children below these age thresholds. If you are a parent or guardian and believe your child has provided us with personal data, please contact us at the email below. We will promptly investigate and delete any such data.

11. Security

We implement reasonable technical and organizational measures to protect data, including encrypted local storage (AES encryption for sensitive game data) and HTTPS for all network communications. However, no method of electronic transmission or storage is 100% secure, and we cannot guarantee absolute security.

12. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the "Last Updated" date at the top of this page. We encourage you to review this page periodically. Your continued use of the Service after changes constitutes acceptance of the updated policy.

13. Contact Us

If you have any questions about this Privacy Policy, wish to exercise your data rights, or have concerns about our data practices, please contact us at:

• Email: ardelean.claudiu.m@gmail.com
• Website: claudiu-ardelean.com