Privacy Policy

Do Not Sell or Share My Personal Information · Limit the Use of My Sensitive Personal Information

Owner and Data Controller
Ben Willes Games S.L.
Camino del Arroyo de Arnao 18
11138 Chiclana de la Frontera
Contact: privacy@benwillis.com
Data Protection Officer: Benjamin Thorn

1. Data We Collect

Usage Data: device info, OS, IP, session duration, number of sessions, app launches, region, in-app purchases, gameplay statistics.
Identifiers: Advertising IDs (GAID/IDFA), cookies and other trackers.
Preferences: language, push-notification settings.
Payment data: processed by App Stores (Apple / Google); we do not receive full payment details.
Error & crash data: logs and bug diagnostics.

2. Purposes and Legal Bases

Provide and operate the game (contract necessity, Art. 6(1)(b) GDPR)
Advertising & monetization (consent where required, Art. 6(1)(a) GDPR)
Analytics & performance measurement (consent or legitimate interest, Art. 6(1)(a)/(f) GDPR)
Payment processing (via App Stores) (contract, Art. 6(1)(b) GDPR)
Security, troubleshooting, error monitoring (legitimate interest, Art. 6(1)(f) GDPR)
Push notifications (consent/legitimate interest; opt-out in device settings)

Automated decision-making / profiling: We do not engage in automated decision-making that produces legal or similarly significant effects. Personalized ads may involve limited profiling to show relevant advertising, without significant impact on users.

3. Services We Use

Advertising

Analytics

Unity Analytics
Google Analytics for Firebase
Tenjin
Meta Events Manager
In-house analytics (anonymised IDs, gameplay events, bug data)

A/B Testing

Firebase Remote Config

Payments

Hosting & Backend

Monitoring & Crash Reports

Sentry

4. Retention

Analytics data: up to 24 months
Crash logs / diagnostics: up to 90 days
Server logs (security): up to 12 months
Purchase records (billing/tax): up to 10 years
Push notification tokens & preferences: up to 24 months or until you opt out
Other data is deleted once it is no longer necessary for the purposes described or where legal retention ends.

5. International Transfers

Processing may occur outside the EU/EEA, including (as applicable for the services above) the United States, Israel, Singapore and China. We use appropriate safeguards such as EU Standard Contractual Clauses where required.

6. Your Rights (GDPR)

Access, rectification, erasure, restriction
Data portability
Object to processing (especially advertising)
Withdraw consent at any time
Complain to a supervisory authority

Requests: privacy@benwillis.com

7. US State Privacy Rights (e.g., CCPA/CPRA)

California residents have the right to know, access, correct, delete, and to opt out of the sale or sharing of personal information. We do not sell personal information, but advertising may involve sharing identifiers with partners. To exercise your rights, email privacy@benwillis.com.

Do Not Track (DNT): We do not respond to DNT signals. Global Privacy Control (GPC): We honor GPC signals where required by law.

Sensitive Personal Information: We do not use Sensitive Personal Information for purposes that require a “Limit the Use” option. If you still wish to limit processing, contact us at the email above.

8. Advertising Choices

Device settings: reset ad ID, disable personalized ads
AppChoices (DAA)
YourOnlineChoices (EU)
Network Advertising Initiative (US)
Service-specific opt-outs (see provider links above)

9. Push Notifications

You can disable push notifications in your device settings at any time.

10. Children

This game is not directed at children under 13/16 years. We do not knowingly collect personal data from children. If you believe a child provided data, contact us to delete it or obtain verifiable parental consent where required by law.

11. Changes to this Policy

We may update this Privacy Policy from time to time. Users will be notified of material changes by an in-app notice or by updating this page. Where required by law, we will seek renewed consent.

Last updated: August 18, 2025