Mobile games
Privacy Policy for our games
This policy explains what data our mobile games on iOS and Android collect, why, how long we keep it, and how to exercise your rights. It applies to every game listed below and covers the GDPR, United States state privacy laws and Brazil's LGPD.
1. Data controller
Our games are published by Athosian SAS (SIREN 952 255 727, 12 Avenue des Prés, 78180 Montigny-le-Bretonneux, France), the data controller for the processing described below.
Contact: dpo@athosian.com.
2. Games covered by this policy
Our games are available worldwide, except in mainland China.
- Pendulum Drop: iOS (App Store) and Android (Google Play). Store links coming soon.
3. What we collect
Our games have no account system and never ask for your name, e-mail or precise location.
Advertising (Google AdMob)
Our games show ads served by Google AdMob (Google Ireland Ltd). The Google Mobile Ads SDK may collect your device's advertising identifier, IP address (used to estimate a general location), app interactions such as ad views and taps, and diagnostic data.
On iOS, the advertising identifier is only accessed if you allow tracking in the App Tracking Transparency prompt. In the European Economic Area, the United Kingdom and Switzerland, personalized advertising is only enabled after you consent in the message shown at first launch; you can change your choice at any time with the "Privacy options" button in the game's menu (when it is offered in your region), or by reinstalling the game.
See how Google uses data from apps that use its services.
Analytics (PostHog)
To understand how our games are played we send anonymous gameplay events (app opened, game started, score reached, ad shown) to PostHog (PostHog Inc., hosted in the European Union). Events carry a random identifier generated by the game on your device; it is not linked to your identity, is not shared with advertisers and is not used to track you across apps.
4. Legal basis and retention
- Personalized advertising: your consent (Article 6(1)(a) GDPR).
- Non-personalized advertising, fraud prevention, analytics and app functionality: our legitimate interest in funding and improving free games (Article 6(1)(f) GDPR).
Analytics events are retained for 12 months. Advertising data is retained by Google according to its own policies.
5. Your rights
You may request access, rectification, erasure or restriction of your data, object to processing, or withdraw consent at any time by writing to dpo@athosian.com, stating which game is concerned.
Uninstalling a game deletes all data it stored on your device. You may lodge a complaint with your supervisory authority (in France, the CNIL: cnil.fr).
6. United States residents
If you live in the United States, the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA) and similar state laws, for example in Virginia, Colorado, Connecticut, Utah and Texas, may give you the rights described below.
Categories of personal information we collect
- Identifiers: your device's advertising identifier (on iOS, only if you allow tracking), IP address, and the random identifier generated by the game.
- Internet or other electronic network activity: app interactions such as ad views and taps, gameplay events and diagnostic data.
- Approximate geolocation: inferred from your IP address. We never collect your precise location.
Sale and sharing for targeted advertising
When personalized advertising is enabled, the data collected by the Google Mobile Ads SDK is used by Google AdMob to show you targeted ads. This may constitute a "sale" or "sharing" of personal information under the CCPA/CPRA, or "targeted advertising" under similar state laws.
Your right to opt out
You can opt out of the sale or sharing of your personal information, and of targeted advertising, at any time:
- with the "Privacy options" button in the game's menu (when it is offered in your region), which reopens Google's form where you can choose "Do not sell or share";
- or by writing to dpo@athosian.com.
Global Privacy Control (GPC) signals are sent by web browsers; our games are mobile apps and do not receive them. Please use one of the methods above instead.
Your other rights
You may ask to know and access the personal information we hold about you, to delete it or to correct it, by writing to dpo@athosian.com and stating which game is concerned. We respond within 45 days.
Appeals. If we decline to act on your request, in whole or in part, you may appeal our decision by replying to our response or by writing to dpo@athosian.com with the subject "Appeal". We will respond in writing within 45 days, explaining our decision. If your appeal is denied, you may contact your state's Attorney General.
We will not discriminate against you for exercising any of these rights: you keep full access to our games.
We do not knowingly sell or share the personal information of consumers under 16 years of age.
7. Brazil (LGPD)
If you are in Brazil, the processing described in this policy is subject to the Lei Geral de Proteção de Dados (LGPD, Law No. 13,709/2018).
Legal bases
- Personalized advertising: your consent (Article 7, I).
- Anonymous analytics: our legitimate interest (Article 7, IX).
Your rights (Article 18)
You have the right to:
- confirmation that your data is being processed;
- access your data;
- correct incomplete, inaccurate or outdated data;
- anonymization, blocking or deletion of unnecessary or excessive data;
- portability of your data;
- deletion of data processed with your consent;
- information about the entities with which we share your data;
- revoke your consent at any time.
To exercise these rights, contact the controller, Athosian SAS, at dpo@athosian.com. You can also revoke your consent to personalized advertising with the "Privacy options" button in the game's menu (when it is offered in your region), or by reinstalling the game.
International transfers
Your data is transferred outside Brazil to Google (advertising) and to PostHog, hosted in the European Union (analytics). These transfers are governed by contractual clauses.
Complaints
You may lodge a complaint with the Brazilian data protection authority, the ANPD (gov.br/anpd).
8. Children
Our games are not directed at children under 13 (or the age of digital consent in your country) and we do not knowingly collect data from them.
9. Changes
We will update this page when our games' data practices change or when a new game is added. The date at the top of this page tells you when it was last revised.