Mind the Tracks Privacy Policy

1 Summary

Mind the Tracks does not create player accounts. Your progress stays on your device and, if you are signed in to Apple Game Center or Google Play Games, in that service's saved games. The Game shows ads from Google AdMob and, when AdMob has none, from Unity Ads; offers one optional purchase, Remove Ads, through Apple In-App Purchase or Google Play Billing; and, where it is allowed, uses Google Analytics for Firebase to understand how the Game is played. MirandLuna Studio does not receive your name, contact details, advertising data or payment details.

2 Information stored on your device

Mind the Tracks stores solved levels, the number of hints and the hint refill timer, your settings (text size, colour-blind filter, high contrast, reduced motion, vibration, sound, and music and sound-effects volume), the age range you select before ads are shown, and the version and date of the Terms you accepted. None of this is sent to the Publisher. Uninstalling the Game or clearing its storage deletes it.

On Android, Mind the Tracks uses the internet and network-state permissions (for ads and the consent message), the vibration permission for haptic feedback and, through the Google Mobile Ads software, the advertising-ID permission.

3 Advertising: what Google AdMob and Unity Ads collect

Ads are served by Google AdMob (provided by Google LLC and, for users in the European Economic Area, the UK and Switzerland, by Google Ireland Limited): a banner, an occasional full-screen ad when a level is won, and optional rewarded ads for hints or coins.

When ads are requested or shown, Google AdMob and Google's User Messaging Platform (the consent message) may collect:

• Advertising identifiers: the Apple Identifier for Advertisers (only if you allow tracking) or the Google Advertising ID, and an app-specific identifier.
• IP address, and an approximate location derived from it.
• Device information: model, operating system and version, language, screen size, network type and app version.
• Ad interactions: ads requested and shown, impressions, clicks, viewing time and whether a rewarded ad was completed.
• Diagnostics: crash, performance and error information from the ad software, and fraud-prevention signals.
• Your consent choices.

Google uses this information to deliver, limit, measure and secure ads, to prevent fraud and, only where you consent or where the law allows, to personalize ads. Google's privacy policy: https://policies.google.com/privacy. How Google uses information from apps that use its services: https://policies.google.com/technologies/partner-sites.

When AdMob has no ad, the full-screen and rewarded ads may come from Unity Ads (Unity Technologies ApS and its affiliates), which starts only after the same consent step and collects similar information: advertising identifiers (the Google Advertising ID or, only if you allow tracking, Apple's IDFA), IP address and approximate location derived from it, device and app details, and ad interactions, to deliver, measure and secure ads and to prevent fraud. Unity's ads are personalized only for players aged 16 or older outside the regions where a consent message applies; otherwise they are not. Unity's privacy policy: https://unity.com/legal/game-player-and-app-user-privacy-policy. You can opt out of personalized ads through your device settings as described in Section 4.

4 Your advertising choices

If you are in the European Economic Area, the UK or Switzerland (or another region where the law requires it), the Game shows Google's consent message, provided through a Google-certified consent-management platform, before any ad is requested. You can accept, reject, or choose individual purposes and ad partners. Even non-personalized ads may need to store or read information on your device, so the Game asks before doing so. If no choice has been made, no ads are requested.

You can change or withdraw your consent at any time in the Game's Settings. Withdrawing consent does not affect processing that took place before the withdrawal.

Before any ad, the Game asks your age range on a neutral screen. If you are under 16, ads are requested as for a user under the age of digital consent: no personalized advertising, and a restricted ad-content rating. If you are under 13, ads are also requested as child-directed. You can also limit ad tracking on your device: on iPhone, in Settings, Privacy and Security, Tracking; on Android, in Settings, Privacy (or Google), Ads, where you can delete your advertising ID. Buying Remove Ads stops the banner and the full-screen ads.

5 Purchases

Payments are processed by Apple (App Store) or Google (Google Play) under their own privacy policies. To deliver, restore or reverse a purchase, the Game receives from the store the product identifier, a transaction identifier or purchase token, the purchase status, and notice of any refund or revocation. The Publisher does not receive your name, payment-card or bank details; it receives sales and tax reports from the stores.

The optional Remove Ads purchase is processed by Apple or Google as described in Section 5. The Game keeps the purchase's transaction identifier on your device so it is delivered only once, and the Publisher does not receive your payment details.

6 Cloud saves

If you are signed in to Apple Game Center (iPhone) or Google Play Games (Android), Mind the Tracks keeps a copy of your game progress (which levels are solved, their stars, the daily-puzzle streak and which tips were seen) in that service's saved games, so it can be restored on another device. Apple or Google stores it under your account with them under their own privacy policies; the Publisher does not receive it. Hints, settings and purchases are not included. You can delete it from your Game Center or Google Play Games settings. Mind the Tracks has no leaderboards or achievements.

7 Testing, support and feedback

If you are invited to test the Game, the Publisher holds the email address used for your invitation in Google Play Console or App Store Connect to manage the test, and receives the feedback, screenshots and device details you choose to send through the store's testing tools. If you email the Publisher, your email address, the content of your message and any attachments are used to answer you.

7A Play statistics

Mind the Tracks uses Google Analytics for Firebase (provided by Google) to understand how the Game is played so it can be improved. When it is allowed, the Game sends events such as which puzzle game and level was opened, started, completed, failed or left unfinished (and how long was spent on it), when a stage is finished, when a hint is used or refilled with an ad, and when Remove Ads is bought, together with information Firebase collects automatically: an app-instance identifier, device model, operating-system version, app version, country and language derived from the device and IP address, and session times. No name, email address or other contact information is sent, the data is not used for advertising, and ad storage, ad user data and ad personalisation signals stay denied. Statistics start switched off and are switched on only after you have accepted these documents, only if you are 13 or older, and only where Google's consent message is not shown (it is never switched on in the European Economic Area, the United Kingdom or Switzerland). Legal basis where the GDPR applies: our legitimate interest in improving the Game (Article 6(1)(f)); you may object at admin@mirandstudios.com. Google keeps this data for up to 14 months under the Firebase retention setting, then deletes it. Google's privacy policy: https://policies.google.com/privacy; how Firebase handles data: https://firebase.google.com/support/privacy.

8 Purposes and legal bases

Where the GDPR applies, each kind of processing relies on these legal bases:

• Saving progress and settings on your device: necessary to provide the Game you asked for (performance of a contract, Article 6(1)(b)).
• Personalized advertising, and storing or reading information on your device for ads: your consent (Article 6(1)(a), and the ePrivacy rules on device storage).
• Non-personalized ads, ad measurement, ad security and fraud prevention, where consent is not required: the legitimate interest in funding a free game and keeping ads safe (Article 6(1)(f)).
• Delivering, restoring and reversing purchases: performance of a contract (Article 6(1)(b)).
• Keeping purchase and financial records: legal obligations (Article 6(1)(c)).
• Cloud saves in Game Center or Google Play Games: performance of a contract with you, at your request (Article 6(1)(b)).
• Play statistics (Section 7A): our legitimate interest in understanding how the Game is played so we can improve it (Article 6(1)(f)).
• Managing tests and answering support and privacy requests: performance of a contract and the legitimate interest in supporting players and improving the Game (Article 6(1)(b) and (f)), and legal obligations for rights requests (Article 6(1)(c)).

Where processing relies on legitimate interests, you may object to it.

9 Who receives information

The Publisher does not sell personal information for money. Information is received by:

• Google (Google LLC and Google Ireland Limited): advertising, the consent message, Google Play distribution, testing and payments, Google Play Games saved games, and Google Analytics for Firebase (play statistics).
• Unity Technologies (Unity Software Inc. and its affiliates): backup advertising, as described in Section 3.
• Apple (Apple Inc. and Apple Distribution International Ltd.): App Store distribution, TestFlight testing, payments, and Game Center saved games.
• Payment providers: Apple and Google act as the merchant and payment processor for in-app purchases; no other payment provider is used.
• Professional advisers, authorities when legally required, or a successor in a merger or sale, subject to equivalent protection.

10 How long information is kept

• Information on your device: until you clear the Game's storage or uninstall it. A device backup may keep a separate copy under your Apple or Google settings.
• Advertising data: kept by Google under its retention policy (https://policies.google.com/technologies/retention).
• Purchase records: kept by Apple and Google under their policies; the Publisher keeps sales reports for as long as tax and accounting law requires (generally up to 7 years).
• Tester invitations and feedback: until the test ends, or earlier if you ask to leave it.
• Support emails: up to 2 years after the request is resolved, unless longer is needed for a legal claim.
• Cloud saves: kept by Apple or Google under your Game Center or Google Play Games account until you delete them.
• Play statistics: kept by Google for up to 14 months, then deleted.

11 International transfers

The Publisher is located in the United States, and Google and Apple process information in the United States and other countries. Transfers of personal data from the European Economic Area, the UK or Switzerland to the United States rely on the EU-U.S. Data Privacy Framework (and its UK and Swiss extensions), in which Google LLC and Apple Inc. participate, and on the European Commission's Standard Contractual Clauses. Information you send the Publisher directly, such as an email, is processed in the United States. You can ask for more information about these safeguards at admin@mirandstudios.com.

12 Your rights in Europe and the UK

If the GDPR or UK GDPR applies to you, you have the right to:

• Access the personal data held about you and receive a copy.
• Correct inaccurate data.
• Delete your data.
• Receive your data in a portable format (portability).
• Object to processing based on legitimate interests, including profiling.
• Restrict processing.
• Withdraw consent at any time, in the Game's Settings, without affecting earlier lawful processing.

Your progress is stored on your device and, if you use cloud saves, in your Game Center or Google Play Games account, so you can access or delete it yourself (by clearing the Game's storage, uninstalling it, or deleting the saved game in those services). Advertising data is held by Google; you can exercise your rights with Google at https://myaccount.google.com and https://support.google.com/policies. Purchase data is held by Apple or Google.

You also have the right to lodge a complaint with the data-protection authority where you live, work or think a breach occurred. A list of EU authorities: https://edpb.europa.eu/about-edpb/about-edpb/members_en. In the UK: the Information Commissioner's Office, https://ico.org.uk.

13 Your rights in the United States

Residents of California and of other states with consumer privacy laws may have the right to know what personal information is collected and how it is used and disclosed, to access, correct and delete it, to opt out of its sale, of sharing for cross-context behavioral advertising and of targeted advertising, and not to be discriminated against for using these rights.

In the last 12 months, the categories of personal information handled through the Game were: identifiers (advertising identifiers and IP address, collected by Google AdMob and Unity Ads; the app-instance identifier used by Firebase; email address if you contact the Publisher or are invited to a test); internet or network activity (ad interactions, play statistics and diagnostics); approximate geolocation derived from IP address; and commercial information (purchase records held by Apple and Google). They are used for the purposes in Sections 3 to 8 and disclosed to the recipients in Section 9. The Game does not collect sensitive personal information.

The Publisher does not sell personal information for money. Allowing Google or Unity to show personalized ads may be considered sharing for cross-context behavioral advertising, or targeted advertising, under some state laws. To opt out, choose your age range accurately, limit ad tracking or delete your advertising ID as described in Section 4, or email admin@mirandstudios.com with the subject Do Not Sell or Share. The Publisher does not knowingly sell or share the personal information of consumers under 16. The Game does not respond differently to browser Do Not Track signals, because it is not a website.

You may make a request yourself or through an authorized agent, by email as described in Section 14. The Publisher will confirm your request and respond within 45 days (extendable once by 45 days, with notice). If a request is refused, you may appeal by replying to the decision with the subject Appeal; if the appeal is denied, you may contact your state attorney general. California residents may also ask, once a year, for information about disclosures of personal information to third parties for their own direct marketing; the Publisher makes no such disclosures.

14 How to make a privacy request

Email admin@mirandstudios.com with the subject Privacy Request, saying which right you want to use and where you live. Because the Publisher does not hold accounts, it may ask for information needed to find and confirm the data concerned, such as the email address you used to contact it. It will respond within one month for requests under the GDPR (extendable by two months for complex requests, with notice), or within the period set by your state's law. Requests are free unless they are clearly unfounded or excessive.

15 Children

The Game is not directed to children under 13. Before any ad, the Game asks the player's age range, and for players under 16 restricts advertising as described in Section 4; for players under 13, ad requests are marked as child-directed so that Google treats them under the Children's Online Privacy Protection Act (COPPA). The Publisher does not knowingly collect personal information from children under 13. Play statistics are never switched on for players under 13. If you believe a child has sent the Publisher personal information, contact admin@mirandstudios.com and it will be deleted.

16 Security

Reasonable administrative, technical and organizational safeguards are used for information under the Publisher's control. No method is completely secure.

17 Changes to This Privacy Policy

We reserve the right, at our sole discretion, to modify, amend, update, or replace this Privacy Policy from time to time, for example when the Game, its providers or legal requirements change. If we make material changes, we may provide notice through the Game, the store listing, by email, or by other reasonable means. Unless otherwise required by applicable law, changes will become effective on the date specified in the updated Privacy Policy. Your continued access to or use of the Game after the effective date of the revised Privacy Policy constitutes your acceptance of the revised Privacy Policy. If you do not agree to the revised Privacy Policy, you must discontinue use of the Game. Where the law requires your consent to a change (for example, to new uses of your personal data), we will ask for it.

18 Contact

MirandLuna Studio, 304 Lansdale Ave, Millbrae, California, United States

Phone: +1 (650) 608-5052

Email: admin@mirandstudios.com

Website: https://mirandstudios.com