Privacy Policy

Last Updated: March 29, 2026

1. Who We Are

Data Controller: Stanisław Pawluczuk, operating as a sole proprietorship (Jednoosobowa Działalność Gospodarcza) under Polish law.

Address: ul. Świeradowska 47, 02-662 Warszawa, Poland

Contact: Loading...

Business Registration: NIP: 1231476789 | REGON: 387249521

2. Information We Collect

2.1 Information You Provide

• Username: Optional display name for leaderboards
• Support Requests: Email and message content when you contact us

2.2 Automatically Collected Information

• Device Information: Device type, operating system, app version
• Game Data: Scores, achievements, and gameplay statistics are stored locally on your device and synced via iCloud if enabled. If you use leaderboards, your custom username and scores are also stored on our servers via Google Cloud Firestore.
• Analytics: Pseudonymous usage data via Firebase Analytics to improve the game (app-instance identifiers, not linked to your identity)
• Transaction Data: If you make in-app purchases, we receive non-financial transaction identifiers and purchase status from Apple StoreKit to unlock content. We do not process or store your payment card details.

2.3 Information from Third Parties

• Advertising Partners: AdMob may collect device identifiers for ad personalization (only with your consent, obtained via our in-app consent screen and/or App Tracking Transparency on iOS)
• Game Center: Player ID, scores, and achievements when you sign into Apple Game Center
• iCloud: Game progress and settings synced via Apple CloudKit
• Analytics: Firebase Analytics for pseudonymous usage statistics

3. How We Use Your Information

Purpose	Legal Basis (GDPR)
Display leaderboard rankings	Consent
Show personalized advertisements	Consent
Sync game progress via iCloud	Contract Performance
Improve game performance (Analytics)	Consent (EEA/UK) / Legitimate Interest (elsewhere)
Respond to support requests	Contract Performance
Prevent fraud and abuse	Legitimate Interest

4. Advertising & Tracking Consent

In the European Economic Area (EEA) and the UK, we use an in-app consent screen to collect your preference for analytics and personalized advertising before any non-essential tracking begins. On iOS, Apple's App Tracking Transparency (ATT) framework provides additional control over cross-app tracking.

If you decline personalized advertising or deny ATT permission, we will serve non-personalized ads and will not access your device's advertising identifier. Our ad partners may use non-identifying contextual signals for ad delivery and fraud prevention, but will not use device identifiers for behavioral targeting. You can change your ATT preference at any time in your device's Settings → Privacy → Tracking.

5. Children's Privacy (COPPA Compliance)

If a user indicates they are under 13 (or under the applicable age of digital consent in their jurisdiction), we automatically:

• Disable Firebase Analytics and all non-essential tracking
• Disable personalized advertising — only contextual, child-directed ads are shown
• Do not request tracking consent (ATT prompt is not shown)
• Configure AdMob with child-directed treatment flags and G content rating
• Disable custom username creation — under-age users are assigned an auto-generated player name to prevent accidental sharing of personal information

We do not require children to provide any personal information to use the game. Because child profiles are entirely anonymous and store no personal identifiers on our servers, data must be managed directly on the child's device using the in-app "Delete Account" feature or by uninstalling the app. Parents may contact us at Loading... with any questions about our child safety practices.

6. Your Rights

Depending on your location, you may have the following rights:

• Access: Request a copy of your data
• Correction: Request correction of inaccurate data
• Deletion: Request deletion of your data ("Right to be Forgotten")
• Portability: Receive your data in a machine-readable format
• Object: Object to processing based on legitimate interests
• Withdraw Consent: Withdraw consent at any time
• Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority. Our lead supervisory authority is the President of the Personal Data Protection Office (UODO) in Poland — uodo.gov.pl

To exercise these rights, use the "Delete Account" feature in Settings or contact us at Loading.... We will respond without undue delay, in accordance with applicable statutory timeframes (within 15 days for access requests under Brazil's LGPD, and within 30 days under GDPR/CCPA).

6.1 United Kingdom

If you are located in the United Kingdom, your rights under the UK General Data Protection Regulation (UK GDPR) mirror those listed above. You may also lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.

6.2 California (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) provide you with the following rights:

• Right to Know: You may request the categories and specific pieces of personal information we have collected about you.
• Right to Delete: You may request deletion of your personal information.
• Right to Opt-Out: You may opt out of the "sale" or "sharing" of your personal information. Glowby does not sell personal information. When personalized advertising is enabled, AdMob may share device identifiers with advertising partners, which may constitute "sharing" under the CCPA. You can control this through App Tracking Transparency (iOS) or by contacting us.
• Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

To exercise these rights, contact us at Loading....

6.3 Brazil (LGPD)

If you are located in Brazil, you have equivalent rights under the Lei Geral de Proteção de Dados (LGPD), including access, correction, deletion, portability, and the right to information about data sharing with third parties. To exercise these rights, contact us at Loading....

7. Data Retention

• Game Progress: Stored locally on your device and in iCloud until you delete the app or your data
• Leaderboard Data: Custom usernames and Firestore leaderboard data are retained while your account is active, and deleted upon request or after 2 years of inactivity. Scores submitted to Apple Game Center are retained by Apple and must be managed in your iOS device Settings.
• Support Requests: Retained for 2 years for quality assurance
• Analytics: Pseudonymous user-level event data is retained in Firebase for up to 14 months, after which only fully anonymized, aggregated statistics are kept.

8. International Data Transfers

Your data may be transferred to and processed in countries outside your residence, including the United States (Firebase/Google services). We ensure appropriate safeguards through:

• EU Standard Contractual Clauses
• UK International Data Transfer Agreement (IDTA) or UK Addendum to EU SCCs, where applicable
• Data Processing Agreements with all service providers

9. Third-Party Services

Service	Purpose	Privacy Policy
Google AdMob	Advertising (interstitial and rewarded video)	Link
Firebase Analytics	Pseudonymous usage analytics	Link
Google Cloud Firestore	Leaderboard profiles, usernames, account data	Link
Apple Game Center	Leaderboards & achievements	Link
Apple iCloud (CloudKit)	Game progress sync	Link
Apple StoreKit	In-app purchases	Link

10. Security

We implement appropriate technical and organizational measures to protect your data, including:

• Encryption in transit (HTTPS/TLS)
• Secure cloud infrastructure (Firebase, iCloud)
• Regular security reviews
• Minimal data collection principle

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes via an in-app notification. Where required by applicable law, we will request your explicit consent to the updated policy before continuing to process your personal data under the new terms.

12. Contact Us

For privacy-related questions or to exercise your rights: