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Privacy Policy for SprintFall App

Last Updated: January 2025 | Version: 2.1.2

Controller: Umut Yavuz, Unterer Markt 8, 95469 Speichersdorf, Germany

Contact: support@sprintfall.de

1. Controller and Contact

1.1 Data Controller

Umut Yavuz
Unterer Markt 8
95469 Speichersdorf
Germany

Email: support@sprintfall.de
Website: https://sprintfall.de
Imprint: https://sprintfall.de/impressum.php

1.2 Data Protection Officer

A data protection officer is not required pursuant to Art. 37 GDPR, as no extensive processing of special categories of personal data takes place.

2. Scope and Legal Basis

2.1 Scope

This privacy policy applies to the mobile app SprintFall (Version 2.1.2 and higher) for iOS and Android.

2.2 Legal Basis for Data Processing

Data processing is based on the EU General Data Protection Regulation (GDPR), in particular:

Art. 6(1)(a) GDPR – Consent (for leaderboard, advertising, cloud backup)
Art. 6(1)(b) GDPR – Performance of contract (for game functions)
Art. 6(1)(f) GDPR – Legitimate interests (for technical functionality)

2.3 Notice for Children and Minors

⚠️ Important for users under 16 years:

If you are under 16 years old, you need parental or guardian consent to use the app, especially for:

✅ Participating in the public leaderboard
✅ Watching advertisements
✅ Using cloud storage

The app is recommended for users aged 12 and above (USK 0).

3. What Data is Collected?

3.1 Locally Stored Data (on Your Device)

This data remains exclusively on your device and is NOT transferred:

Game Progress: Highscore, coins, diamonds, items
Player Name: Name chosen by you (3-12 characters)
Player ID: Randomly generated anonymous identifier
Skins & Items: Unlocked characters, active skin, power-ups
Achievements: Progress in achievements, collected badges
Settings: Audio, language, leaderboard visibility
Event Data: Event currencies, participation history
Consents: Consent status, tracking status

Storage Location: Exclusively local on your device
Legal Basis: Art. 6(1)(b) GDPR (Performance of contract)
Deletion: When deleting the app or via "Delete Game Data" in settings

3.2 Leaderboard Data (Cloud Storage)

Only when participating in the leaderboard, the following data is transferred:

Player Name: Pseudonymized name (chosen by you, 3-12 characters) – publicly visible
Highscore: Your best score – publicly visible
Player ID: Anonymous identifier for duplicate checking – not public
Timestamp: Date of last update – not public
Visibility Status: Whether your entry is displayed – not public

Server Location: EU (Belgium)
Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
Legal Basis: Art. 6(1)(a) GDPR (Consent at first app launch)
Retention Period: 12 months from last entry
Automatic Deletion: Yes, weekly cleanup process
Manual Deletion: Anytime via "Delete Game Data" in settings

🔒 Privacy in Leaderboard:

✅ Profanity filter prevents offensive names
✅ Duplicate check: Each name allowed only once
✅ Visibility controllable in settings
✅ Only best score is stored
✅ No IP addresses, no location data, no email addresses

3.3 Cloud Backup System (Optional)

Voluntary game save backup – only when actively used:

Player ID: Anonymous identifier for assignment
Game Progress: Highscore, coins, diamonds, items
Skins & Achievements: Unlocked content
Timestamp: Time of last backup

Server Location: EU (Belgium)
Provider: Google Ireland Limited (Firebase Cloud Storage)
Legal Basis: Art. 6(1)(a) GDPR (Consent)
Retention Period: 12 months from last backup
Automatic Deletion: Yes, upon inactivity
Encryption: AES-256 in transit and at rest

3.4 Advertisements (Unity Ads – Rewarded Ads)

Only when you voluntarily watch an advertisement, data is processed:

Advertising ID: Anonymous device advertising identifier (IDFA on iOS, GAID on Android)
Device Information: Device type, operating system version, app version
Interaction Data: Viewed, skipped, clicked
IP Address: For fraud prevention (immediately anonymized)
Approximate Location: Country and region (no GPS data!)

Provider: Unity Technologies ApS, Niels Hemmingsens Gade 24, 3rd Floor, 1153 Copenhagen K, Denmark
Legal Basis: Art. 6(1)(a) GDPR (Consent by watching the advertisement)
Purpose: Provision and personalization of advertisements
Data Transfer: Also possible outside the EU (USA)
Privacy Policy: unity.com/legal/privacy-policy

Opt-Out:

iOS: Settings → Privacy → Tracking → Disable App Tracking
Android: Settings → Google → Ads → Disable Personalized Ads

🎬 Important about Unity Ads:

✅ Advertising is completely optional – You can use the game entirely without ads
✅ Only Rewarded Ads: Ads are only shown when you actively click on them
✅ No Banners or Interstitials: No disruptive advertising during gameplay
✅ You decide when you want to watch ads (e.g., for 100 coins)
✅ Unity processes your Advertising ID exclusively for advertising purposes
✅ Tracking can be disabled at any time in device settings

4. Purpose of Data Processing

Data Type	Purpose	Legal Basis
Game Progress	Storing your progress	Art. 6(1)(b) GDPR
Leaderboard Data	Global highscore comparison	Art. 6(1)(a) GDPR
Cloud Backup	Restoration on new device	Art. 6(1)(a) GDPR
Advertising ID (Unity Ads)	Provision of Rewarded Ads	Art. 6(1)(a) GDPR

4.2 No Profiling or Tracking

What we do NOT do:

❌ No User Tracking: We don't track your behavior beyond the app
❌ No Profiling: We don't create user profiles for advertising purposes
❌ No Location Tracking: We don't collect GPS data
❌ No Contacts: We don't access your contact list
❌ No Camera/Microphone: We don't use camera or microphone

5. Data Transfer and Storage

5.1 Where is Your Data Stored?

Service	Provider	Location
Leaderboard	Firebase (Google Ireland Limited)	🇪🇺 EU (Belgium)
Cloud Backup	Firebase (Google Ireland Limited)	🇪🇺 EU (Belgium)
Advertising (Unity Ads)	Unity Technologies ApS	🇪🇺 EU & 🇺🇸 USA

5.2 Encryption

All data transfers are encrypted:

In Transit: TLS 1.3 (Transport Layer Security)
At Rest: AES-256 encryption on Firebase servers

6. Retention Period

Data Type	Retention Period	Automatic Deletion
Local Data	Until app uninstallation	No
Leaderboard Data	12 months from last entry	Yes, weekly
Cloud Backup	12 months from last backup	Yes, upon inactivity
Advertising ID (Unity Ads)	According to Unity guidelines	Per Unity Policy

7. Your Rights (GDPR)

You have the following rights under the EU General Data Protection Regulation:

7.1 Right of Access (Art. 15 GDPR)

You have the right to obtain information about your stored data.

How to request information:

Email to: support@sprintfall.de
Subject: "GDPR Access Request"
Provide your Player ID (found in: Settings → "Show Player ID")
Response Time: Within 30 days (Art. 12(3) GDPR)

7.2 Right to Rectification (Art. 16 GDPR)

You can have incorrect data corrected.

Example: Incorrect player name in leaderboard → Settings → "Change Player Name"

7.3 Right to Erasure (Art. 17 GDPR – "Right to be Forgotten")

You can request deletion of your data at any time.

How to delete your data:

In-App: Settings → "Delete Game Data" → Confirm
Via Email: support@sprintfall.de with Player ID

What will be deleted:

✅ Leaderboard entry (immediately)
✅ Cloud backup (immediately)
✅ Player ID (within 48 hours)

7.4 Right to Restriction of Processing (Art. 18 GDPR)

You can restrict the processing of your data.

Example: Disable leaderboard participation → Settings → Turn off "Leaderboard Participation"

7.5 Right to Data Portability (Art. 20 GDPR)

You can receive your data in a structured format.

How to export your data:

Settings → "Create Cloud Backup"
Data is saved as JSON file
Upon request via email: support@sprintfall.de

7.6 Right to Object (Art. 21 GDPR)

You can object to the processing of your data at any time.

Object to advertising (Unity Ads):

iOS: Settings → Privacy → Tracking → Disable "Allow Apps to Request to Track"
Android: Settings → Google → Ads → "Opt out of Ads Personalization"

7.7 Withdrawal of Consent (Art. 7(3) GDPR)

You can withdraw your consent at any time.

Examples:

Leaderboard: Settings → Disable "Leaderboard Participation"
Cloud Backup: Settings → "Disable Cloud Backup"

8. Third-Party Services

8.1 Firebase (Google Ireland Limited)

Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
Services: Firebase Realtime Database (Leaderboard), Firebase Cloud Storage (Cloud Backup)
Server Location: EU (Belgium)
Privacy Policy: firebase.google.com/support/privacy
Data Processing: Art. 28 GDPR (Data Processing Agreement)

8.2 Unity Ads (Unity Technologies ApS)

Provider: Unity Technologies ApS, Niels Hemmingsens Gade 24, 3rd Floor, 1153 Copenhagen K, Denmark
Services: Rewarded Video Ads
Server Location: EU and USA
Legal Basis: Art. 6(1)(a) GDPR (Consent by watching the advertisement)
Privacy Policy: unity.com/legal/privacy-policy

8.3 No Other Third-Party Services

What we do NOT use:

❌ No Analytics Tools (no Google Analytics, no Firebase Analytics)
❌ No Crash Reporting Tools
❌ No Social Media Integration
❌ No Payment Providers (no in-app purchases)

9. International Data Transfer

9.1 Data Transfer to Third Countries

Firebase (EU):

✅ All data remains in the EU (Belgium)
✅ No transfer to third countries

Unity Ads (EU & USA):

⚠️ Data transfer to the USA possible
✅ Safeguards: EU Standard Contractual Clauses (Art. 46 GDPR)
✅ Compliance with EU-US Data Privacy Framework

10. Children and Minors

10.1 Age Rating

USK 0: The app is suitable for all age groups.
Recommended for: Ages 12 and above

10.2 Special Notice for Users Under 16 Years

⚠️ Important:

Pursuant to Art. 8 GDPR, users under 16 years need parental or guardian consent for:

✅ Participating in the public leaderboard
✅ Watching advertisements (Unity Ads)
✅ Using cloud storage

Recommendation for Parents: Disable "Leaderboard Participation" in settings if you don't want your child's player name to be publicly visible.

11. Contact and Complaints

11.1 Privacy Inquiries

For questions about privacy or to exercise your rights:

Email: support@sprintfall.de
Postal Address:
Umut Yavuz
Unterer Markt 8
95469 Speichersdorf
Germany

Response Time: Within 30 days (Art. 12(3) GDPR)
Languages: German, English, Turkish

11.2 Supervisory Authority

You have the right to lodge a complaint with a data protection supervisory authority:

Bavarian State Office for Data Protection Supervision (BayLDA)
Promenade 18
91522 Ansbach
Germany

Phone: +49 (0) 981 180093-0
Email: postmaster@lda.bayern.de
Website: https://www.lda.bayern.de