Privacy Policy

Last updated: 23 May 2026

This Privacy Policy explains how Egor Golovitsyn ("I", "me", "my") collects, uses, and shares information when you play the mobile game Snappy (the "Game") on iOS or Android, or when you visit the website at golovitsyn.com (the "Website").

I am the data controller responsible for your personal data within the meaning of the EU General Data Protection Regulation (GDPR). If you have any questions, you can reach me at support@golovitsyn.com.

1. Summary

The Game does not require an account. You can play without giving me your name or email.
The Game uses third-party services (ad networks, analytics, the app stores) that collect some data automatically. The main ones are listed below.
Most of your game progress (level, gold, gems, skins) is stored on your device, not on a server I control.
On first launch, you are asked to declare your age range (Under 13 / 13–15 / 16 or older). The data the Game and its partners collect depends on what you pick — under-13 players never have their advertising identifier collected and only see contextual, non-personalised ads.
You can change your privacy choices at any time inside the Game (Settings → Privacy choices) or revoke consent altogether.
You have the right to access, correct, delete, or restrict use of your personal data at any time.

2. Information collected

2.1 Information you provide

If you contact me by email, I receive your email address and whatever you put in the message. That's it.

2.2 Information collected automatically

When you play the Game, the following information may be collected automatically — either by the Game itself or by the third-party services it uses. What gets collected depends on the age range you declare (see Section 9) and the consent choices you make in the in-game dialog:

Device information: device model, operating system and version, language, country, screen size. Collected for all players to keep the Game working.
Mobile advertising identifier (Apple IDFA / Google AAID): collected only if you (a) declared an age range of 16 or older, (b) gave consent in the in-game GDPR dialog, and (c) allowed tracking in your device settings (iOS: App Tracking Transparency dialog). Never collected for players who declared under 13, and never collected for players in the EU who declared 13–15.
IP address: used briefly for ad delivery, connectivity checks, and fraud prevention. Not stored long-term.
Gameplay events: level reached, in-app purchases made, ads watched, sessions started, skin equipped, and similar in-game actions. Used to keep the Game working, fix bugs, and decide which ads to show. Sent to GameAnalytics (see 5.2). Only collected when the analytics consent toggle is on in the GDPR dialog.
Ad interaction events: ad requested, ad shown, ad clicked, rewarded-ad completed — sent to LevelPlay (see 5.1) so the right ads can be served and counted.
Crash and performance data: if the Game crashes, technical information about the crash (stack trace, device model, OS version — no personal identifiers) may be sent to GameAnalytics so I can fix the bug. Only when the crash-reporting toggle is on in the GDPR dialog.
Push notification token (Apple APNs / Firebase FCM): collected only if you opt in to notifications after your first game and only used to send you in-game reminders. You can disable any time in Settings.

2.3 Information stored locally on your device

Your game progress (level, currency, owned skins, settings, purchase status) is stored on your device using the operating system's standard storage (PlayerPrefs on Unity). I do not have access to this data. Uninstalling the Game removes it.

3. How information is used

To run the Game and save your progress on your device.
To show ads (free version) and to remember if you bought the "Remove Ads" upgrade.
To process in-app purchases through Apple's App Store and Google Play.
To fix bugs and improve the Game.
To respond to support emails.
To comply with legal obligations.

4. Legal basis (GDPR)

Contract: processing needed to deliver the Game and any purchases you make (Art. 6(1)(b) GDPR).
Consent: for personalised advertising, analytics, crash reporting, and any tracking that uses your advertising identifier — you can grant or withdraw this consent at any time in your device settings or in the in-game Settings → Privacy choices menu (Art. 6(1)(a) GDPR).
Legitimate interest: for fraud prevention, security, and showing non-personalised (contextual) ads (Art. 6(1)(f) GDPR).
Legal obligation: when I have to keep records (e.g. for tax purposes) (Art. 6(1)(c) GDPR).
Special protection for children: for players who declare an age below 16 (in the EU) or below 13 (elsewhere), the Game does not rely on consent for advertising-related processing — instead, only contextual (non-personalised) ads are shown and no advertising identifier is collected. This implements Art. 8 GDPR (children's consent) and the U.S. Children's Online Privacy Protection Act (COPPA).

5. Third-party services

The Game uses the following third parties. Each has its own privacy policy and acts as an independent data controller or processor for the data it collects.

5.1 Advertising — LevelPlay / ironSource (Unity)

The Game displays banner and rewarded ads through LevelPlay (formerly ironSource), part of Unity Technologies. LevelPlay and its mediated ad partners may collect your advertising identifier, IP address, device information, and ad interaction events to deliver and measure ads. The Game is configured as a Mixed Audience app in LevelPlay; when a player has declared an age below 13 (or below 16 in the EU), LevelPlay receives a child-directed flag and only serves contextual ads from COPPA-compliant demand sources — no advertising identifier is shared in that case. If you are 16 or older and have not given consent to personalised advertising, only non-personalised (contextual) ads will be shown.

5.2 Analytics — GameAnalytics

The Game uses GameAnalytics (operated by GameAnalytics ApS, Denmark) to collect anonymous gameplay statistics: sessions, levels played, levels completed or failed, in-app purchases, ads watched, currency earned and spent, and crash reports. GameAnalytics receives a randomly-generated user ID, device model, OS version, country (derived from IP, but the IP itself is not stored), and game build version. Data is collected only when the analytics toggle is enabled in the in-game GDPR dialog. For players who declared under 13, GameAnalytics is configured in child-directed mode, which suppresses device identifiers.

5.3 In-app purchases — Unity IAP (App Store / Google Play)

In-app purchases (gems, gold, "Remove Ads", skins, starter packs) are processed by Apple's App Store or Google Play depending on your device. I do not see your payment card details or your full Apple/Google account. I only receive a transaction receipt confirming the purchase so I can deliver the item.

Apple privacy policy: https://www.apple.com/legal/privacy/

Google privacy policy: https://policies.google.com/privacy

5.4 Apple App Tracking Transparency (iOS only)

On iOS 14.5 and later, before any tracking using your advertising identifier (IDFA) takes place, the operating system shows you a system-level dialog asking whether to allow tracking. If you tap "Ask App Not to Track", no IDFA is shared with LevelPlay or any other party, regardless of what the in-game GDPR toggle says. You can change this choice at any time in Settings → Privacy & Security → Tracking on your device.

5.5 Push notifications — Apple APNs / Firebase Cloud Messaging

If you opt in to notifications, the operating system generates a push token used to deliver reminders such as "Snappy misses you!". This token is not linked to your real identity. You can disable notifications at any time in your device's Settings or in the in-game Settings menu.

5.6 Hosting — IONOS

The Website is hosted by IONOS SE, Germany. IONOS may process server access logs (including your IP address) for security and operational reasons.

6. International data transfers

Some third-party services listed above are based outside the European Economic Area (mainly in the United States). When your data is transferred outside the EEA, those services rely on appropriate safeguards under GDPR, such as the EU Standard Contractual Clauses or the EU-U.S. Data Privacy Framework.

7. Data retention

Local game data: kept on your device until you delete the Game or clear its data.
Support emails: kept for as long as needed to handle your request and up to 12 months afterwards.
Third-party services keep data according to their own policies.

8. Your rights under GDPR

If you are in the EU, the UK, or another region that grants similar rights, you have the right to:

Access the personal data I hold about you.
Correct any data that is wrong.
Ask me to delete your data ("right to be forgotten").
Restrict or object to certain processing.
Receive your data in a portable format.
Withdraw consent at any time (without affecting the lawfulness of processing done before withdrawal).
Lodge a complaint with a supervisory authority. In Germany, this is the Data Protection Authority of your federal state (Landesdatenschutzbehörde).

To exercise any of these rights, email support@golovitsyn.com. I will respond within 30 days.

9. Children

Snappy is a family-friendly casual game rated 4+ in the Apple App Store and Everyone in Google Play. It is designed as a Mixed Audience app: it can be played by both adults and children, with different data-collection rules depending on the age the player declares.

9.1 Age declaration on first launch

The first time you launch the Game, you are asked to pick your age range from three options: Under 13, 13–15, or 16 or older. This declaration is stored locally on your device and used to decide which categories of data the Game and its partners may collect.

9.2 What changes per age range

Under 13: COPPA-compliant mode is applied worldwide. No advertising identifier (IDFA / AAID) is collected. Only contextual (non-personalised) ads from COPPA-certified demand sources are shown. The personalised-ads toggle in the in-game GDPR dialog is disabled and cannot be turned on. GameAnalytics runs in child-directed mode, suppressing device identifiers.
13–15: Treated the same as Under 13 inside the European Union and EEA (in accordance with Art. 8 GDPR, which sets the digital consent age at 16). Outside the EU/EEA, the player can opt into personalised ads in the GDPR dialog, but defaults remain off.
16 or older: The full GDPR consent dialog is shown. The player can opt into personalised ads, analytics, and crash reporting independently. Each choice can be changed later in the in-game Settings → Privacy choices menu.

9.3 Honesty of the declaration

The age picker is a self-declaration; the Game cannot verify the player's actual age. Where stronger verification is required by law in a particular country, the in-game declaration is supplemented by Apple's App Tracking Transparency dialog (iOS) and Google Play's age-aware ad routing (Android), which provide additional platform-level protection regardless of what the player picked.

9.4 Parental rights

If you are the parent or guardian of a child who has played the Game and you believe data has been collected without your authorisation, you can:

Open the Game on your child's device and tap Settings → Privacy choices to review and revoke any consent given.
Email me at support@golovitsyn.com to request deletion of any data linked to the device.
Reset the device's advertising identifier in the operating system's privacy settings.

I will action verified parental requests within 30 days.

10. Security

I use reasonable technical and organisational measures to protect personal data. No method of transmission over the internet is 100% secure, however, so I cannot guarantee absolute security.

11. Changes to this policy

I may update this Privacy Policy from time to time. The "Last updated" date at the top tells you when it last changed. Significant changes will be announced in the Game or on this Website.

12. Contact

Egor Golovitsyn
Email: support@golovitsyn.com
Full contact details: see the Imprint.