This Privacy Policy explains what information is processed when you play Card Champions: Sedma (the "Game") or visit pashylabs.com (the "Website"), why, and what choices you have. We have written it to be read, not skimmed past.
1. Who is responsible for your data
The data controller is Pasol Liviu Persoană Fizică Autorizată, trading as Pashy Labs ("we", "us"), fiscal code (CUI) 54510858, Bld. Bucureștii Noi nr. 136, Sector 1, 012366 București, Romania.
Privacy contact: cardchampionssedma@gmail.com
We have not appointed a Data Protection Officer, because the law does not require one for an activity of our size and type. Privacy questions are handled directly by the developer at the address above.
2. The short version
- The Game works offline. We do not run game servers, user accounts or a player database.
- Your progress, coins and settings are stored only on your device. We never receive them.
- The Game shows ads. Our advertising partners process your device's advertising identifier, IP address and device information to show and measure ads. In the EEA, UK and Switzerland, personalised ads are shown only if you consent.
- Purchases are handled entirely by Google Play or the Apple App Store. We never see your payment details.
- We do not sell your personal data.
3. What is processed and why
Data stored on your device
The Game saves your progress, coin balance, unlocked items, statistics, settings and any display name you choose locally on your device. This data is not transmitted to us or to any server we operate. It is used only to run the Game and remember your progress. It stays on your device until you clear the app's data or uninstall the Game.
Advertising
The Game shows optional rewarded ads and banner ads through Unity LevelPlay (formerly ironSource) mediation, which works with ad networks including Unity Ads and Google AdMob. To show, measure and limit the frequency of ads and to prevent ad fraud, these partners may process:
- your device's advertising identifier (Google Advertising ID on Android, IDFA on iOS where you allow it)
- your IP address, used to estimate your approximate location (country or region)
- device and app information, such as device model, operating system version, language, screen size and app version
- ad interaction data, such as which ads were shown, viewed, completed or tapped
We do not receive this data in a form that identifies you. We receive only aggregated reports, such as how many ads were shown.
Your choices:
- In the EEA, UK and Switzerland, and wherever else the law requires it, the Game asks for your consent before personalised ads are shown. If you decline, you will see non-personalised ads, which use limited data such as approximate location and device type. You can change your choice at any time from the Game's settings.
- Where US state privacy laws apply, you can opt out of the "sale" or "sharing" of personal information for targeted advertising through the same privacy settings.
- On Android you can reset or delete your advertising ID in your device settings. On iOS, the Game asks for permission through Apple's App Tracking Transparency prompt before any cross-app tracking.
Technical diagnostics from the game engine
The Game is built with the Unity engine. Unity's runtime may send limited technical information, such as device model, operating system version, a random installation identifier, and performance or crash information, to help keep the engine stable. This information is not used to identify you or to show ads.
In-app purchases
Optional purchases (coin packs and the Premium upgrade) are processed by Google Play Billing or the Apple App Store, which act as the seller of the purchase. We do not receive your name, payment card details or billing address. The store tells the Game only whether a purchase was completed, so that the item can be delivered.
When you contact us
If you email us, we process your email address and whatever you choose to include in your message, in order to answer you.
What we do not collect
The Game does not request access to your contacts, camera, microphone, photos or precise location, and does not require an account or real name to play.
4. Legal bases (GDPR)
- Running the Game and delivering purchases – performance of the contract with you (Art. 6(1)(b) GDPR).
- Personalised advertising and access to your device's advertising identifier where required – your consent (Art. 6(1)(a) GDPR and the ePrivacy rules). You can withdraw it at any time; this does not affect processing before withdrawal.
- Non-personalised ads, ad fraud prevention and engine diagnostics – our legitimate interest in funding a free game and keeping it working (Art. 6(1)(f) GDPR).
- Answering your messages and keeping business records – legitimate interest, and legal obligations such as accounting rules (Art. 6(1)(c) and (f) GDPR).
Do you have to provide data? No. You can play the whole Game without giving us any personal data and without consenting to personalised ads. Some device data is technically necessary for ads to be shown at all; if you decline personalised ads, you still see non-personalised ones and the Game works the same way.
Profiling and automated decisions. If you consent to personalised ads, our advertising partners may use your device data to estimate your interests and choose which ads to show you. This is a form of profiling. It does not produce legal effects or similarly significant effects on you, and you can turn it off at any time from the Game's privacy settings. We make no other automated decisions about you.
5. Who receives data
We do not sell your personal data. Data is processed by these partners, each under its own privacy policy:
- Unity Technologies (Unity Ads, Unity LevelPlay and the Unity engine) – Unity privacy policy
- Google (AdMob and Google Play) – Google privacy policy and how Google uses information from apps
- Apple (App Store, on iOS) – Apple privacy policy
- Other ad networks selected through LevelPlay mediation, which act under their own policies
- GitHub, which hosts this Website – see section 10
We may also disclose information where the law requires it.
6. International transfers
Some of our partners process data outside the European Economic Area, for example in the United States. Such transfers rely on safeguards recognised under the GDPR, such as the EU–US Data Privacy Framework or the European Commission's Standard Contractual Clauses.
7. How long data is kept
- Game data stays on your device until you clear it or uninstall the Game. We keep no copy.
- Advertising partners keep data according to their own retention policies.
- Emails you send us are kept as long as needed to deal with your request, and then for up to 3 years in case of follow-up questions, unless the law requires longer.
8. Your rights
Under the GDPR and similar laws you have the right to:
- access the personal data we hold about you
- correct inaccurate data
- have data deleted
- restrict or object to processing, including processing based on legitimate interest
- data portability
- withdraw consent at any time, for example for personalised ads through the Game's privacy settings
- lodge a complaint with a supervisory authority. In Romania this is the Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP), or you can contact the authority in your own country.
Because we do not run accounts or servers, we usually hold no personal data about you beyond any emails you have sent us. You can delete all Game data on your device by clearing the app's data or uninstalling the Game. For data held by advertising partners, you can contact them directly, or ask us and we will help.
To make a request, use our data request page or email cardchampionssedma@gmail.com. We will reply within one month.
9. Children
The Game is intended for a general audience and is not directed at children under 13. We do not knowingly process personal data of children under 13, or under the age of digital consent in your country (16 in Romania), for personalised advertising. If you believe a child has provided us with personal data, contact us and we will delete it.
10. The Website
pashylabs.com is a static website hosted on GitHub Pages. It uses no cookies, analytics or trackers of its own. GitHub may log visitors' IP addresses for security and to operate the service; see the GitHub privacy statement. Fonts are loaded from Google Fonts, which receives your IP address when the page loads. The data request form does not send anything to a server: it only prepares an email in your own email app.
11. Security
Because the Game does not send your game data to us, there is no central database of player data that could be breached. Data processed by our partners is protected by their own security measures.
12. Changes to this policy
We will update this policy if what the Game does with data changes, for example if online multiplayer or cloud saves are added. The "Last updated" date at the top will change, and significant changes will be announced in the Game.
13. Contact
Pasol Liviu PFA (Pashy Labs)
Bld. Bucureștii Noi nr. 136, Sector 1, 012366 București, Romania
cardchampionssedma@gmail.com