Legal · Glowbug Swap
Glowbug Swap privacy policy
Draft
This text is a draft under legal review. It describes how things are meant to work, but it is not legal advice and not yet final.
This policy covers Glowbug Swap for Android (package com.kozmaworks.glowbugswap), published on Google Play by Kozma Works.
What the game stores on your phone
The game keeps your progress and settings on your device only: which levels you finished, your best number of swaps and Perfect badges, the last level you played, your volume, animation speed, language and tutorial settings, and whether you bought “Remove ads” (so it works offline too).
There is no account and no login. The game itself sends nothing about you to us: no analytics, no crash reports, no identifiers.
If your phone backs up apps to your Google account (Android backup), this save may be included in that backup, which Google stores for you. Uninstalling the game or clearing its data deletes the save from the phone. We hold no copy of it.
Advertising with Google AdMob
The free version shows ads served by Google AdMob: full-screen ads between levels, and optional video ads you can choose to watch for a hint or to skip a level. To show and measure ads and prevent fraud, Google may collect:
- your device’s advertising ID and app set ID;
- your IP address and the approximate location derived from it;
- how you interact with ads;
- diagnostic information about the app.
Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) acts as an independent controller for this data. Google may also process it in the USA, where Google LLC is certified under the EU–US Data Privacy Framework. How Google uses this data and how long it keeps it: policies.google.com/technologies/partner-sites.
In the EEA, the UK and Switzerland the game shows Google’s consent form before any ad is requested. You can change your choice at any time in the game: Settings → Privacy options. You can also reset or delete your advertising ID in your phone’s settings (Settings → Google → Ads). Ads in the game are limited to AdMob’s PG rating: suitable for most audiences, with parental guidance.
Legal basis: your consent (Article 6(1)(a) GDPR) for storing and reading information on your device and for personalised ads. You can withdraw it at any time in Settings → Privacy options. [TODO: a lawyer decides the legal basis of non-personalised ads.]
Purchases through Google Play
“Remove ads” is a one-time purchase handled entirely by Google Play. We never see or store your payment details. Google Play only tells the game whether the purchase was made, so that the ads can be switched off and the purchase restored on a new phone. Google’s privacy policy: policies.google.com/privacy.
After the purchase no ad is shown. At present, however, Google’s ad software still starts when the game launches: it checks your consent status and loads an ad in the background that is never shown. Google may therefore still receive the data listed above.
Permissions
The game uses these Android permissions: internet access and network status (for ads and purchases), access to the advertising ID (for ads) and Google Play billing (for the purchase). Google’s ad software may add further technical permissions of its own. None of them gives the game access to your contacts, photos, camera, microphone or precise location.
Summary
| Data | Who collects it | Why |
|---|---|---|
| Progress and settings | the game, on your phone only | so you can continue where you left off |
| Advertising ID, app set ID | Google AdMob | showing and measuring ads, fraud prevention |
| IP address, approximate location | Google AdMob | ads, fraud prevention |
| Ad interactions, diagnostics | Google AdMob | measuring ads |
| Purchase history | Google Play | the “Remove ads” purchase |
Age
Glowbug Swap is meant for players aged 13 and over and is not directed at children under 13. The game does not ask your age.
Personalised ads need valid consent. In Hungary, a player under 16 can give it only with a parent’s authorisation, and other countries set their own limit between 13 and 16. If you are under that age, ask a parent before you accept personalised ads on the consent form, or refuse them.
For all our games
Who is responsible for your data
The maker of this game and the controller of the personal data the game itself processes is Árpád Kozma, sole proprietor (egyéni vállalkozó), trading as Kozma Works; registered address: Szabadság tér 6., 2337 Délegyháza, Hungary; registering authority: Ministry of the Interior of Hungary (register of sole proprietors); registration number: 62570660; EU VAT ID: HU92217287; e-mail: hello@kozmaworks.com. In privacy matters, write “Privacy” in the subject line.
Platforms and services we work with (Google, Roblox and others named above) are responsible for the data they collect themselves, under their own privacy policies.
Principles we follow in every game
- We collect only what the game needs to work, to stay fair, and to be improved.
- We do not sell personal data, and we do not build profiles of players ourselves.
- We never ask for your name, address, phone number or any other contact detail inside a game.
Your rights
Under the GDPR you can ask for a copy of the personal data we hold about you, ask us to correct or delete it, ask us to restrict its use, ask for it in a portable format where the law provides for that (Article 20 GDPR), and object to processing based on our legitimate interest. Where we rely on your consent, you can withdraw it at any time; this does not affect what happened before. For data that a platform holds, use that platform’s own tools as well (they are linked above). We answer within one month. To find your data, we may ask for your player name or user ID, but never for a password.
If you think we handle your data unlawfully, you can complain to the Hungarian data protection authority, Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH), Falk Miksa utca 9–11, 1055 Budapest, naih.hu, or to the authority where you live. You can also go to court: in Hungary, the regional court (törvényszék) has jurisdiction, and you can choose the one of your home address.
Children
We design our games to be fair and safe for their audience, and we follow the age rules of the platform the game runs on. Children can play our Roblox games. We treat their data the same way as everyone else’s: we handle only what this policy lists, linked to their Roblox user ID, and we never ask for a child’s name or contact details. For Glowbug Swap, see “Age” above. A parent can ask us at any time what we hold about their child and can ask us to delete it.
Changes to this policy
If this policy changes, the new version will be published at the same address with a new date. If the change is significant, we will also say so in the game or on its store page.