This policy explains what data is processed when you use my mobile games, who processes it, and what choices you have. It is deliberately written in plain language; if anything is unclear, just write to me.
Piotr Niewolski, an individual developer based in Poland, publishing games under the name Niewolski Games. Contact for any privacy matter: piotr@niewolski.pl. I am the data controller for the (very limited) processing described here.
This policy applies to every mobile app published by Piotr Niewolski (Niewolski Games), whether or not it is named below. Published so far:
Where this policy says "the game", it means any app covered by this policy.
The game keeps a small local file with your progress (which levels are unlocked, results, sound and language settings). It stays in the app's private storage on your phone, contains no personal data, and is removed when you uninstall the game. It is not transmitted to me or to anyone else.
The game is free and financed by full-screen ads shown between levels. The ads are served by Google AdMob (Google Ireland Limited for users in the European Economic Area, the UK and Switzerland; Google LLC elsewhere). To serve, cap and measure ads and to detect fraud, Google's SDK may process:
This data goes to Google, not to me. I only see anonymous, aggregated statistics in the AdMob dashboard (for example the number of ad impressions and revenue), which cannot identify any individual user.
How Google uses this data is described in Google's Privacy Policy and in "How Google uses information from sites or apps that use our services". Google's list of advertising partners is available at support.google.com/admob/answer/9012903.
If you are in a region covered by the GDPR (or its UK / Swiss equivalents), the game asks for your choice before the advertising SDK starts, using Google's User Messaging Platform consent form. You may agree to personalised ads or refuse — if you refuse, the game works exactly the same and you are shown non-personalised or limited ads instead. Non-personalised ads still need some technical data (such as the IP address and basic device information) in order to be delivered and protected against fraud.
You can change your decision at any time: the consent is stored on your device, so clearing the app's data or reinstalling the game makes the form appear again.
The games are not directed to children. In Google Play they are declared for an audience of 13 years and older, and I do not knowingly collect any data from children. If you believe a child has provided personal data through one of my games, write to me and I will help to have it removed.
| Purpose | Data | Legal basis |
|---|---|---|
| Running the game, saving progress | Local file on your device | Not personal data; necessary to provide the service (Art. 6(1)(b) GDPR) |
| Personalised advertising | Advertising ID, device data, IP, ad interactions | Your consent (Art. 6(1)(a) GDPR), collected through the consent form |
| Non-personalised advertising, fraud prevention, frequency capping | IP address, basic device data | Legitimate interest in financing and protecting a free app (Art. 6(1)(f) GDPR) |
I do not sell, rent or share any data. The only recipient is Google, acting in its own role as an advertising provider; Google may transfer data outside the European Economic Area under the safeguards described in its privacy policy (EU standard contractual clauses, EU–US Data Privacy Framework).
I hold no personal data, so there is nothing for me to retain or delete. Data collected by Google is retained according to Google's own policies. Data on your device disappears when you uninstall the game or clear its data.
Under the GDPR you have the right of access, rectification, erasure, restriction, objection and data portability, and the right to withdraw consent at any time. Because I store no personal data about you, requests concerning advertising data are best addressed to Google using the links above — but you can always write to piotr@niewolski.pl and I will help. You also have the right to lodge a complaint with your supervisory authority (in Poland: Prezes Urzędu Ochrony Danych Osobowych, uodo.gov.pl).
The game requests no dangerous permissions, uses the network only for ads, and keeps its local data in Android's private per-app storage.
If a game starts using something new (analytics or in-app purchases, for example), this page will be updated and the date at the top changed. The current version is always available at policy.niewolski.pl/privacy.html.
Piotr Niewolski · piotr@niewolski.pl · Poland