Elephant Pop! Privacy Policy

1. Who we are, and what this covers

This Privacy Policy (the "Policy") is issued by Cygnus Works LLC ("Cygnus Works", "we", "us" or "our"), which is the controller of the personal data described below.

This Policy applies to the game Elephant Pop! (the "Game") as the Android application (com.cygnusworks.elephantpop) and the accompanying website (together, the "Services"). "You" means the person using them.

Links from the Services to other sites lead to pages run by other people under their own policies. This Policy does not cover them.

2. Data stored on your own device

Your save game, including level completion, coins, upgrades, unlocked skins, charms, records, daily challenge state and settings, is written to the Game's private storage on your device, under the key elephantpop.save.v1.

That data stays there unless you switch on the cloud save described in section 6. Either way it is not transmitted to us. We do not receive it, hold it, back it up, or have any means of reading it. Deleting it from the device is within your control: uninstalling the application removes it, and section 6 covers the separate copy Google holds once cloud save is on. Once it is gone we cannot restore it.

3. Permissions the Android application declares

The Play Games Services library described in section 6 requires no additional permissions.

The Game does not request, and cannot obtain, access to your contacts, camera, microphone, photos or files. It declares no location permission, coarse or fine, so it cannot read your device's position.

Approximate location is a separate matter. Every request made over the internet carries an IP address, and an IP address implies a rough location, ordinarily no finer than a city or a region. Google's advertising libraries use that inference to select and measure advertisements, as described in section 4. It needs no permission and it does not reach us. It is reported as approximate location in the Data safety section of the Game's Google Play listing.

4. Advertising

The Game shows advertisements supplied by Google AdMob, a Google service. There are two kinds: a full-screen advertisement shown between levels, and an optional advertisement played in exchange for an in-game reward.

To select and measure those advertisements, Google receives and processes information from your device. That includes your device's advertising identifier, your IP address and the approximate location that address implies, general device and operating system information, and data about how you interacted with an advertisement, such as whether it was shown, viewed or clicked. Google acts as an independent controller of that data and processes it under Google's own privacy policy, which we do not control and cannot vary. Google describes how it uses data in advertising products at policies.google.com/technologies/partner-sites.

We do not receive any of it. We are not given your advertising identifier, your IP address, or any per-person record of what you were shown. What reaches us from Google is aggregate reporting: totals and revenue, with no individual identified.

Your controls. The advertising identifier is designed to be under your control, and resetting it breaks the link between past and future advertising data:

• Reset or delete it in Android under Settings, then Privacy, then Ads. Deleting it causes apps to receive a string of zeros instead.
• Opt out of personalized advertising in the same place. Advertisements still appear; they are simply chosen without a profile.
• Remove advertising entirely by making the purchase described in section 5.

If you are in the European Economic Area, the United Kingdom or Switzerland, the Game asks for your consent before it requests its first advertisement, using Google's consent form. The form lets you accept, decline, or set each purpose individually, and you may change or withdraw your choice at any time from the Game's settings screen, where an Ad privacy option appears for as long as this applies to you.

Declining does not stop the Game working. It may mean you see fewer advertisements, or none, and some advertising may still be served on the basis of legitimate interest where that is permitted and you have not objected to it. Any advertisement served at all, personalized or not, requires limited data including your IP address, both to deliver it and to guard against fraud. Declining costs you no progress, no feature and no content: the Game treats an advertisement it is not allowed to request exactly as it treats one that fails to load.

If you are in California or another US state with a consumer privacy law, personalized advertising through Google AdMob may count as "sharing" your personal information for cross-context behavioral advertising, as California law defines it. You can opt out. The Game's settings screen shows Do not sell or share my personal information, which opens Google's form for that choice. After you opt out, Google serves only advertising that is not personalized. Opting out costs you nothing in the Game. Section 15 sets out the rest of your rights.

5. The in-app purchase

The Game offers one purchase, a one-off payment that permanently removes advertising. It is processed entirely by Google Play under Google's own terms and privacy policy.

We never receive your payment card details, your billing address, or your Google account credentials. The Game asks Google Play whether this device's Google account holds the purchase and shows the price Google Play reports for your country.

Because the entitlement is held by your Google account rather than by us, it survives a reinstall or a new phone. The Restore option in the Game's settings asks Google Play to confirm it again.

6. Cloud save and the leaderboards

The Game includes Google's Play Games Services library, which provides two optional features: a backup of your progress kept under your Google account, and two public leaderboards. Both are off until you switch them on in the Game's settings, and the Game plays the same without them.

Sign-in. The library signs a player in to their Google account when the Game starts. That happens as part of setting the library up rather than because you asked for a feature, so on a device where Play Games is already configured, Google may record that this Game was opened before you have chosen anything here. From that sign-in the Game receives two things, both used only to draw its own settings screen: whether a player is signed in, and the Play Games display name, which is the gamer tag you chose with Google rather than your legal name. Nothing is written to Google and no score is posted until you press Turn on cloud save.

What the backup holds. Once switched on, the Game writes a copy of the save described in section 2 to the saved-games storage that Play Games Services provides. It carries level completion, coins, upgrades, unlocked skins, charms, records, daily challenge state and settings, together with a one-line summary such as campaign finished · 1,240 coins that Google may display in the Play Games app. The advertising counter and the record of your purchase are left out of it.

Where it goes. Google stores it on Google's servers against your Google account, at no charge to you, under Google's own privacy policy. It is not our storage. We are not sent a copy and cannot read one. Pulling it down onto another device is done from the Game's settings screen, and it replaces that device's progress rather than merging with it.

The leaderboards. The same switch allows the Game to post two numbers, the deepest endless level reached and the Daily Run score, to Play Games leaderboards. A leaderboard is public. Your Play Games display name and avatar appear beside your score to anyone who opens the board, which includes other players of this Game and the Play Games app itself. What the Game posts is the score and nothing about how it was reached. What reaches us is the same public board anybody can open, plus aggregate counts in the Google Play Console.

Switching it off, and deleting it. Erasing the save from the Game's settings screen turns cloud save off on that device and stops any further backup, and it leaves the copy Google already holds untouched. Deleting that copy, and the leaderboard entries with it, goes through Google rather than through us: your Play Games profile settings offer both per-game deletion and deletion of the whole profile, and Google sets out the steps at support.google.com/googleplay/answer/9130646. We cannot delete it on your behalf, and we hold no copy of our own to delete.

7. Usage analytics

The Android application includes Google Analytics for Firebase, a Google service, which we use to understand how the Game is played so that we can tune it: chiefly how often players run out of plays, whether they then watch an advertisement or leave, and whether that advertisement loads.

Who it applies to. Analytics is switched off when the Game starts. It is switched on only for players to whom Google's European consent form in section 4 does not apply. If you are in the European Economic Area, the United Kingdom or Switzerland, or if the Game cannot establish whether the form applies to you, no analytics data is sent, whatever you choose on the form. The US state opt-out in section 4 concerns advertising; the analytics are never used to personalize advertising, so they carry on for a player who opts out. The website described in section 8 runs no analytics.

What it records. Events such as a level starting or ending (the mode, the level number, whether it was won, the stars earned and the number of pops), running out of plays, tapping to watch an advertisement and whether it paid out, leaving the out-of-plays screen, and tapping or completing the purchase in section 5. Firebase adds its own standard events: the first launch, sessions, time spent in the app, advertisements shown, in-app purchases, and removal of the app. Each event is sent with an app instance identifier generated by Firebase, your device's advertising identifier, the device model, operating system and app version, the device language, and the country or region derived from your IP address.

No event carries your name, email address, Google account, Play Games name, the contents of your save, or any text you type.

Who handles it. Google processes this data on our behalf under the Firebase and Google Analytics data processing terms. We see it as reports aggregated across players in the Firebase and Google Analytics consoles. We do not export it, sell it, or combine it with data from other sources.

Your controls. Resetting or deleting your advertising identifier, as set out in section 4, breaks its link to past events. Uninstalling the application stops collection and discards the app instance identifier. Because we cannot connect an app instance identifier to you, we cannot look up your events on request, and the Game does not display the identifier.

8. Fonts and hosting

The Game loads its typeface from Google Fonts. As with any request made over the internet, Google receives your IP address and user-agent string in the ordinary course of serving that request. If the font cannot be fetched the Game falls back to a typeface already on your device and plays normally.

This website is served by our hosting provider and the content delivery network in front of it, which receive and may log requests, including your IP address, the file requested, the time and your user-agent string, to keep the site running and secure. We do not analyze those logs, build profiles from them, or combine them with anything else.

9. What we do not do

• No account with us, no password, no email collection and no newsletter. The optional sign-in in section 6 is to your Google account, not to one of ours.
• No crash reporting or session recording. The only analytics is the Google Analytics for Firebase integration in section 7, and it does not run for players Google's consent form applies to.
• No advertising or analytics trackers besides Google AdMob, described in section 4, and Google Analytics for Firebase, described in section 7.
• No cookies set by us, and no third-party tracking scripts on this website.
• No location permission, and no access to contacts, camera, microphone, photos or files. Approximate location reaches Google by IP address, as set out in sections 3 and 4.
• No server of ours holding your progress, your scores or any record of your play. The cloud save and the leaderboards in section 6 are Google's storage, the analytics in section 7 are held by Google on our behalf, and we hold no copy of either.
• No sale of personal information for money. Personalized AdMob advertising may count as sharing for cross-context behavioral advertising under California law, and section 4 explains how to opt out of it. The analytics in section 7 are never used to personalize advertising.

10. Retention

We operate no system of our own that stores personal data. Google holds the event-level analytics data in section 7 on our behalf for two months, after which only reports aggregated across players remain. Google retains advertising and purchase data under its own retention schedules, which we do not control. Where you have switched cloud save on, Google keeps the backup and the leaderboard entries until you delete them by the route in section 6, or until you delete your Play Games profile. Our hosting and content delivery providers keep their own request logs under their own schedules.

11. Legal bases for processing

Where the EU or UK General Data Protection Regulation applies, we rely on the following legal bases. For personalized advertising: your consent, under Article 6(1)(a), given through the consent prompt and withdrawable at any time. For non-personalized advertising and for fraud prevention: our legitimate interests, under Article 6(1)(f), in funding a game distributed at no charge and in preventing advertising fraud. For cloud save and the leaderboards: your consent, under Article 6(1)(a), given by switching the feature on in the Game's settings and withdrawable through the route in section 6. For processing the purchase: performance of a contract with you, under Article 6(1)(b). For operational logging: our legitimate interests in keeping the Services available and secure. The analytics in section 7 are not collected from players to whom Google's consent form applies, which includes everyone in the EEA and the UK, so no legal basis under those regulations is relied on for them.

12. International transfers

Google processes advertising, purchase, cloud save, leaderboard and analytics data on infrastructure that may sit outside the country you are playing from, under the transfer mechanisms set out in Google's own policy and data processing terms. We store no personal data on systems of our own.

13. Security

This website and the Game's network requests are served over HTTPS. No system is perfectly secure, but the surface here is deliberately small: there is no database of ours to breach, no credential store to steal, and no archive of player data on our side to lose.

14. Children

The Game is not directed to children under 13, and we do not knowingly collect personal information from any person under 13, or under 16 where local law sets that threshold. We have no actual knowledge of selling or sharing the personal information of consumers under 16 years of age, and we do not do so.

If you believe a child has provided personal information to us, contact us at section 17. In practice we hold nothing to delete, but we will act on any request concerning data held by Google on our behalf.

15. Your rights

Depending on where you live, you may hold rights under the EU or UK GDPR, the California Consumer Privacy Act as amended by the CPRA, or comparable legislation. These typically include the right to know what personal data is held about you, and to obtain access to it, correct it, delete it, receive it in a portable form, restrict or object to its processing, withdraw consent, and not to be treated worse for having asked.

California residents. In the last twelve months the Services have collected the following categories of personal information, all directly from your device: identifiers (the advertising identifier, the Firebase app instance identifier, your IP address and, if you switch on cloud save, your Play Games player identifier and display name); internet or other electronic network activity (interaction with advertisements and with the Game, as set out in sections 4 and 7); approximate geolocation derived from your IP address; and commercial information (whether you bought the purchase in section 5). They are used for the purposes in sections 4 to 7 and kept for the periods in section 10. They go to Google, as described in those sections. We do not sell personal information for money. Identifiers, network activity and approximate location may be shared with Google for cross-context behavioral advertising through personalized AdMob advertising, and you can opt out as section 4 describes. We collect no sensitive personal information and have no actual knowledge of consumers under 16 whose data is sold or shared.

We can act on those rights directly only to the extent that we hold data about you, and we hold none that we can connect to you. There is no account to access, no profile to correct and no record to export; the analytics in section 7 are keyed to a random app instance identifier that we have no way to match to a person. Data the Game creates lives on your device and is under your sole control at all times, as set out in section 2. For data held by Google in connection with advertising, the controls in section 4 are the effective route. For a cloud save or a leaderboard entry, it is the route in section 6. Google's own policy sets out how to exercise your rights against it.

You may nonetheless write to us at the address in section 17 to exercise any right, and we will respond within thirty (30) days. If you are in the EEA or the UK, you also have the right to lodge a complaint with your local supervisory authority.

16. Changes to this Policy

We may revise this Policy from time to time. The effective date at the top of the page changes when we do, and the current version is always published at this address. Continuing to use the Services after a revision takes effect means you accept the revised Policy.

17. Contact

Questions, requests and complaints about this Policy go to [email protected], addressed to Cygnus Works LLC.