Spila privacy statement

This statement covers Spila, our games app for iPhone and Android (nl.stroetenga.Spila). It explains what stays on your phone, what the ads involve, and what we never see.

Who is responsible

Stroetenga Technologies B.V.
Chamber of Commerce (KvK): 77277260
VAT (BTW): NL860956817B01
Email: privacy@stroetenga.nl

We are the data controller under the General Data Protection Regulation (GDPR) for what this statement describes. A question about anything on this page reaches us at the email address above.

What Spila is

Spila is a collection of small games. The games are built into the app and run on your phone. There is no account, no login and no online leaderboard.

Your player name

Spila asks for a player name so your scores have a name beside them. It is optional: the app fills in "Player" if you leave it, and it does not have to be your real name. The name stays on your phone. It is never sent to us or to anyone else.

What is stored on your phone

Spila keeps these files in the app's own storage:

• settings.ini: your player name, game settings (sound, hints, speed, theme, mode), your best score and the number of games played, and which games you unlocked with a video;
• scores.ini: your top ten per game mode, with the player name and date;
• run.ini: the game in progress, so you can continue where you stopped;
• trace.log: a technical log the app writes to find faults. It can include your player name and when ads were requested.

These files stay on your phone, are never sent to us, and are removed when you delete the app. They are needed for the app to work as you expect, so they do not need your consent.

Advertising

Spila is free. Some games are marked "coming soon"; the first time you open one, Spila plays a short advertising video before the game unlocks. That happens once per game. Spila asks for your choice about ads (see below) when you first reach the home screen.

What Google collects for an ad

The ads come from Google AdMob. To choose, show and measure an ad, and to fight ad fraud, Google's software in Spila collects, according to Google:

• the IP address of your phone, which can be used to estimate your general location;
• a device identifier: the advertising identifier of your phone (on iPhone only if you allow tracking, see below) or an identifier that is limited to this app or developer;
• which ads you were shown and how you interacted with them, such as whether a video was watched to the end;
• technical performance and crash information about the ad software.

This data goes to Google, not to us. We see only totals in our AdMob account, such as how many ads were shown; we cannot see who watched them.

You decide first

If you are in the European Economic Area, the United Kingdom or Switzerland, Google's consent message asks for your choice before any ad is requested. You can accept, refuse, or choose per purpose and per partner. Refusing is as easy as accepting. If you refuse, Google may still show non-personalised ads, which use little more than the app and your rough location. Where consent is required, the legal basis is your consent; elsewhere it is our legitimate interest in paying for a free app with advertising.

On iPhone, Apple's own question "Allow Spila to track your activity across other companies' apps and websites?" follows. If you choose Ask App Not to Track, Google does not receive your phone's advertising identifier. You can change that at any time in the iPhone Settings, under Privacy & Security, Tracking.

On Android you can reset or delete your advertising ID in the Android settings, under Privacy, Ads (the exact place differs per phone).

Google is responsible for its part

Google acts as an independent controller for the data it collects this way, so its own terms apply alongside ours:

• How Google uses information from sites or apps that use its services
• Google Privacy Policy
• My Ad Center, to manage ad personalisation directly

Google may process this data outside the European Economic Area. Google states that it relies on the European Commission's Standard Contractual Clauses and the EU-US Data Privacy Framework for such transfers.

The App Store and Google Play

You download Spila from Apple's App Store or Google Play. What those stores record about your account, your downloads and your payments is between you and Apple or Google, under their own privacy policies. From the stores we receive only anonymous totals, such as the number of downloads per country and crash reports that you allowed your phone to share with developers.

What we do not do

• There is no account. No sign-up, no login, no password, no email address.
• We do not run analytics of our own in Spila, and we do not build a profile of you.
• Spila sends nothing to a Stroetenga server. We have no copy of anything you do in the app.
• We do not sell or rent data to anyone.
• We do not use your location, camera, microphone, contacts, photos or files.
• We do not send newsletters or marketing email.
• We do not knowingly collect anything from children beyond what this statement describes.

How long we keep things

• Files on your phone: until you delete the app. We have no copy.
• Data Google collects for ads: as long as Google's own policy says; see the Google pages above.

Your rights

Under the GDPR you have the following rights. Because we hold very little that identifies you, some of them will have little to act on, but they are yours all the same.

Access

Ask what personal data we hold about you.

Rectification

Have inaccurate data corrected.

Erasure

Ask us to delete your data.

Restriction

Ask us to limit how we use it.

Objection

Object to processing based on our legitimate interest.

Portability

Receive your data in a machine-readable form.

Withdraw consent

Where we rely on your consent, withdraw it at any time, without giving a reason.

Write to privacy@stroetenga.nl to exercise any of these. We answer within one month. For data that Google or Apple hold about you, contact them directly: we cannot reach it on your behalf.

If you are unhappy with how we handle your request, you may lodge a complaint with the Dutch data protection authority, the Autoriteit Persoonsgegevens, or with the supervisory authority in your own country.

Changes to this statement

If what we do changes, this statement changes with it and gets a new "in force from" date at the top. The earlier version stays readable at its own address, listed under "Earlier versions" at the bottom of this page. There is no mailing list to notify, so the date is how you can tell.

Questions about Spila

For privacy questions write to privacy@stroetenga.nl. For anything else about the app, info@stroetenga.nl reaches us. Writing to us is ordinary email: we use your address and message only to answer you, and delete them once the conversation is finished.

The browser games

The browser games at games.stroetenga.nl are a separate website with their own privacy statement.