PRIVACY POLICY
1. SCOPE AND IDENTITY OF THE CONTROLLER
This Privacy Policy (the "Policy") explains how personal data are processed in connection with each game or application published by Daniel Viktorin that refers or links to this Policy, regardless of the device, operating system, storefront, or distribution platform through which it is made available (each an "App"). Because individual Apps and platforms may provide different functionality, a provision of this Policy applies only where the relevant processing actually takes place.
For processing whose purposes and essential means I determine, the controller is:
Daniel Viktorin
Country: Czech Republic
Email: info@daniel-viktorin.com
A third-party provider is a separate controller where it independently determines why and how it processes personal data. Each such provider is responsible for its own processing under applicable law and its own privacy policy. My responsibilities are limited to processing that I determine and to the obligations arising from my selection and integration of the relevant services, as further described in Section 4.
2. CATEGORIES AND SOURCES OF PERSONAL DATA
Depending on the App, platform, location, device settings, and privacy choices, I or the service providers identified below may process the following categories of personal data:
Technical and device data, including IP address, device and operating-system information, App version, language, country or approximate location derived from the IP address, and installation-specific, device, advertising, or similar identifiers where available and permitted by law.
Usage, analytics, and diagnostic data, including sessions, play time, progress and in-game events, feature interactions, advertising and reward events, purchase-status events, crash or error information, and performance data. In jurisdictions where consent is required, Unity Analytics data are collected only after the relevant consent has been granted. In other jurisdictions, limited analytics may be processed on the basis of legitimate interests where permitted by law, unless the user disables analytics.
Advertising and privacy-choice data, including consent status and preferences, advertising identifiers where available, contextual information relating to an ad request, ad impressions and interactions, reward confirmation, and information used for measurement, security, and fraud prevention.
Storefront and transaction data, including product identifiers, purchase, receipt, entitlement, refund, and restoration status, and a platform or account identifier where necessary to provide or verify an entitlement. Payment credentials are processed by the applicable storefront and are not provided to me.
Communications data, including your name, email address, correspondence, attachments, and any technical, transaction, or diagnostic information that you voluntarily provide when requesting support or otherwise contacting me.
Game progress, settings, virtual balances, and similar information may be stored locally on your device and are not ordinarily accessible to me. Where an App supports a platform backup, cloud save, achievement, or similar feature, the relevant platform provider may process the associated data in accordance with its own terms and privacy policy. Unless an App expressly provides otherwise, no separate player account is created or operated by me.
3. PURPOSES AND LEGAL BASES OF PROCESSING
Personal data are processed only for the following purposes and on the corresponding legal bases:
Performance of a contract. Data may be processed where necessary to provide the App and functionality that you request, verify purchases and entitlements, restore eligible purchases, deliver an earned advertising reward, or respond to a support request relating to the App.
Consent. Where required by law, consent is used for Unity Analytics, personalized advertising, advertising measurement, tracking, and the storage of or access to device identifiers or similar information. The relevant choices are requested separately where applicable. Consent may be refused or withdrawn at any time. Withdrawal does not affect processing that was lawful before withdrawal.
Legitimate interests. Data may be processed where necessary for my legitimate interests in operating and distributing the Apps, maintaining their security and technical reliability, detecting fraud or misuse, complying with contractual requirements of distribution platforms, responding to communications, using limited Unity Analytics data to understand and improve the Apps only in jurisdictions where this processing may lawfully rely on legitimate interests without consent and where the user has not disabled analytics, and establishing, exercising, or defending legal claims. Limited technical processing for contextual or restricted advertising, delivery verification, security, and fraud prevention may also rely on legitimate interests only where that particular processing does not require consent. These interests are relied upon only where they are not overridden by your rights and freedoms. Non-personalized advertising is not treated as automatically free from consent requirements.
Legal obligations. Data may be processed where necessary to comply with a binding obligation under applicable law, including accounting, tax, consumer-protection, regulatory, and lawful authority requirements.
Refusing or withdrawing optional consent does not prevent access to the essential functionality of the App. It may, however, disable analytics, personalized advertising, or an optional feature that depends on the availability of advertising. Third-party controllers determine and disclose their own legal bases for processing carried out for purposes that they independently determine.
4. RECIPIENTS AND SERVICE PROVIDERS
Personal data may be disclosed to or otherwise processed by the following categories of recipients, but only to the extent relevant to the particular App and platform:
Unity Technologies. Where an App uses Unity Analytics, I determine whether and for what App-related purposes analytics is used and act as controller for that decision. Unity processes the analytics data on my behalf as a processor under its applicable data-processing terms. Unity may act as a separate controller only for a service or processing activity whose purposes and means Unity independently determines (privacy policy; data-processing addendum).
Google and advertising partners. Google Mobile Ads (AdMob), Google's consent-management service, and participating advertising technology providers may process data for ad selection and delivery, reporting, security, and fraud prevention. Google or another advertising provider acts as a separate controller where it determines its own advertising or measurement purposes; it acts as a processor only where the applicable service terms require it to process data on documented instructions. The providers and purposes available for the relevant App may be identified in its advertising privacy controls (Google privacy policy; partner technologies).
Non-personalized advertising may still use device storage or identifiers for purposes such as frequency capping and aggregated reporting where the required permission has been granted. Where such permission is not available, Google may serve limited advertising, or no advertisement may be available, depending on applicable law and current service settings. Limited advertising may still process technical information necessary to transmit an ad and protect the service against fraud.
Apple, Google Play, Valve/Steam, and other applicable storefront or platform providers, in connection with distribution, platform accounts, purchases, receipts, refunds, ownership and entitlement verification, security, compliance, and supported platform functionality. These providers generally act as independent controllers in respect of the storefront, account, payment, security, and platform processing that they determine (Apple privacy policy; Google privacy policy; Valve privacy policy).
I do not offer personal data for sale as a separate commercial product. The use of advertising services may nevertheless be considered a "sale" or "sharing" of data for targeted or cross-context behavioural advertising under some privacy laws, including where no money is exchanged. Where applicable, you may opt out through the privacy controls described in Section 7 or by contacting me. Each independent controller remains legally responsible for the processing activities that it determines.
5. INTERNATIONAL TRANSFERS
Unity, Google, storefront providers, and their service providers operate internationally. Personal data may therefore be processed outside your country of residence, including in the United States and other countries that may not provide the same level of legal protection as your country.
Where I arrange a transfer of personal data for processing that I control from the European Economic Area, the United Kingdom, or Switzerland to a country without an applicable adequacy decision, the transfer is protected by an approved transfer mechanism, normally standard contractual clauses, together with supplementary measures where required. Unity's data-processing addendum incorporates the relevant transfer terms and standard contractual clauses (Unity DPA). Google explains its use of adequacy frameworks and standard contractual clauses for advertising data transfers in its data-transfer information and controller standard contractual clauses.
Independent controllers may use their own lawful transfer mechanisms, as described in their respective privacy terms. You may obtain further information about the applicable safeguards, including where a copy may be obtained, through the linked documents or by contacting me at the address in Section 12.
6. RETENTION AND DELETION
Personal data are retained only for the period necessary for the relevant purpose or for an applicable legal requirement. The following periods and criteria generally apply:
Local game data and preferences ordinarily remain on your device until they are reset or deleted or the App is uninstalled, subject to any backup or cloud functionality controlled by you or the relevant platform provider. Locally stored privacy choices remain until they are changed, reset, or removed with the App.
Unity currently states that raw Unity Analytics event data are retained for 13 months. Analytics metric data and user profiles may be retained until a player-initiated or developer-initiated deletion is completed, subject to Unity's service lifecycle and applicable law (Unity Analytics retention information). Where supported by the App, disabling analytics submits or queues a request to Unity to delete the associated analytics data.
Google, advertising providers, and independent storefront or platform providers determine their own retention periods for processing that they control. Those periods vary according to the type of record and whether it is required for advertising delivery, reporting, security, fraud prevention, transactions, or legal compliance, and are described in the provider policies linked in Section 4.
Support correspondence is ordinarily retained until the request has been resolved and thereafter only for as long as necessary to address follow-up issues, establish or defend legal claims, or comply with a legal recordkeeping duty. Transaction, tax, and accounting records are retained for the statutory period applicable to the particular record.
Where deletion is requested and the relevant data can reasonably be identified, data under my control will be deleted or anonymized unless continued retention is required or permitted by law. Because I do not ordinarily operate player accounts, a request concerning provider-held data may require an installation, advertising, platform, or transaction identifier. Deletion of provider-held analytics data does not delete local gameplay progress, and deletion of local App data may be irreversible.
7. PRIVACY CHOICES AND DATA-SUBJECT RIGHTS
Where available, advertising, analytics, tracking, and similar privacy choices may be reviewed or changed through the privacy controls in the App, the operating system, or the relevant platform. You may withdraw analytics consent separately from advertising choices. You may also contact me using the details in Section 12. Storefront or platform account, cloud, purchase, and privacy controls remain subject to the procedures of the relevant provider.
Subject to applicable law, you may have the right to request access to and rectification or erasure of personal data, restriction of processing, data portability, or a copy of your personal data; to object to processing based on legitimate interests; to withdraw consent at any time; and to opt out of targeted advertising, sale, or sharing where those terms are recognized by applicable law. Withdrawal does not affect the lawfulness of processing carried out before withdrawal. The exercise of these rights may be subject to lawful limitations and reasonable verification of identity.
If you are in the EEA, you may also complain to your local supervisory authority. In the Czech Republic, this is the Office for Personal Data Protection (Úřad pro ochranu osobních údajů): uoou.gov.cz.
8. WHETHER DATA ARE REQUIRED AND AUTOMATED DECISIONS
You are not legally or contractually required to provide data for optional analytics, personalized advertising, or tracking. Where analytics, advertising, or tracking relies on consent, if you do not provide or later withdraw that consent, the corresponding consent-based processing will be disabled. Where limited analytics lawfully relies on legitimate interests rather than consent, you may disable analytics through the privacy controls available in the App. In either case, the essential functionality of the App remains available. Personalized, non-personalized, or limited advertising may nevertheless be unavailable, and as a result, an optional feature that requires completion of an advertisement, including an advertising reward, may not be available.
Certain technical data are necessary to establish a network connection, secure the App and related services, or provide a feature that you request. Storefront and transaction data are necessary when you make, restore, or ask for support concerning a purchase. Communications data are necessary if you want me to investigate and respond to your request. If the necessary data cannot be processed, the corresponding online, purchase, advertising, or support function may not be provided.
Advertising and analytics providers may perform profiling as described in their own policies. I do not use personal data to make decisions based solely on automated processing that produce legal effects or similarly significantly affect you within the meaning of Article 22 of the GDPR.
9. CHILDREN AND MINORS
The Apps are not directed or marketed to children. Eligibility to use an App is governed by the applicable Terms. I do not knowingly solicit personal data from children. Where processing relies on consent, I do not knowingly rely on consent given by a child who cannot lawfully provide it under applicable law. If I become aware that personal data relating to a child or minor have been processed contrary to applicable law or the Terms, I will take reasonable steps to investigate and, where appropriate, delete the data. A parent or legal guardian who has concerns may contact me using the details in Section 12.
10. SECURITY
Appropriate technical and organizational measures are used to protect personal data against unauthorized or unlawful processing and against accidental loss, destruction, alteration, or disclosure, taking into account the nature of the processing and the risks involved. No method of transmission or storage can, however, be guaranteed to be completely secure, and third-party providers remain responsible for the security of systems under their control.
11. CHANGES TO THIS POLICY
This Policy may be amended from time to time to reflect changes in the Apps, service providers, processing activities, or applicable law. Material amendments will be communicated by reasonable means where required by law. Where renewed consent is legally required, the relevant processing will not be undertaken on the basis of the amended terms until that consent has been obtained.
12. CONTACT
Any question, request, or complaint relating to this Policy or the processing of personal data may be directed to:
Daniel Viktorin
Country: Czech Republic
Email: info@daniel-viktorin.com
© 2026 Daniel Viktorin, all rights reserved.
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Contact: info@daniel-viktorin.com