Privacy Policy for the App “LocoGames”
Last updated: [Insert Date]
This Privacy Policy explains how we process personal data when you use the mobile application “LocoGames”. We process personal data only in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection laws.
1. Controller
The controller responsible for data processing within this app is:
PM Applications
Owner: Philipp Michelis
Im Schadlohn 54
77933 Lahr, Germany
Email: info@pm-applications.com
2. General Information on Data Processing
(1) We process personal data only to the extent necessary for the functionality, stability and further development of the app.
(2) The app can generally be used without providing data that identifies you personally. Some processing operations, however, are required for the proper functioning of the app or are based on your explicit consent.
(3) When we use third-party services (e.g., Google Firebase, Google AdMob), these services process data on our behalf or as independent controllers. Such processing only takes place based on consent (Art. 6(1)(a) GDPR) or on legitimate interests (Art. 6(1)(f) GDPR) when permissible.
3. Data We Process, Purposes and Legal Bases
a) User-generated content (stored locally on your device only)
Data types:
– Words, categories, tasks or other content you create within certain games (e.g., “Impostor”).
Storage:
– Local storage on your device only (e.g., SharedPreferences).
– We do not access or transmit these contents.
Purpose:
– Functionality of features within the app.
Legal basis:
– Art. 6(1)(b) GDPR (performance of a contract).
b) Consent logging (Firebase Realtime Database)
We store a record of your acceptance of the Terms & Conditions and this Privacy Policy.
Data types:
– Randomly generated installation ID (pseudonymous)
– Timestamp of your consent
Purpose:
– Legal documentation of user consent as required by law.
Legal basis:
– Art. 6(1)(c) GDPR (legal obligation)
or
– Art. 6(1)(f) GDPR (legitimate interest in compliance and documentation)
The installation ID does not allow identification of you or your device.
c) Firebase Analytics (performance & usage analysis – only with your consent)
We use Google Firebase Analytics to better understand how our app is used and to improve functionality.
Data types:
– App usage events (e.g., which screens are used)
– Device information (e.g., model, OS version)
– App version
– Performance metrics
Purpose:
– Improving functionality and user experience
– Understanding errors, interactions and feature usage
Legal basis:
– Your explicit consent (Art. 6(1)(a) GDPR)
Firebase Analytics is not activated unless you agree.
d) Firebase Crashlytics (crash diagnostics)
Crashlytics helps us identify and fix app crashes.
Data types:
– Error messages
– Device model
– OS version
– Technical state of the app at the time of the crash
– No direct personal identifiers
Purpose:
– Debugging and ensuring app stability
Legal basis:
– Art. 6(1)(f) GDPR (legitimate interest in providing a stable and functional app)
e) Google AdMob (advertising)
We use Google AdMob to finance the free version of the app.
Depending on your consent:
Without consent:
– Only non-personalized ads are displayed
– No use of Advertising ID for profiling
– Minimal technical data may be processed by Google (legitimate interest)
Legal basis: Art. 6(1)(f) GDPR
With consent:
– Advertising ID may be used for personalization
– Google may use device and behavioral signals to deliver personalized ads
Legal basis: Art. 6(1)(a) GDPR (consent)
You may withdraw consent at any time.
Opt-out / controls:
- Android: Settings → Google → Ads → Reset advertising ID
- Device-wide tracking controls
4. Data Transfers to Third Countries (including the United States)
Services provided by Google Ireland Ltd. may transfer data to Google LLC (USA).
Google participates in the:
✓ EU–US Data Privacy Framework (DPF)
If data is processed outside the DPF scope, Google applies:
– Standard Contractual Clauses (SCCs) under Art. 46 GDPR
Further information: https://policies.google.com/privacy
5. Retention Periods
- Consent logs: retained until you request deletion
- Analytics data: usually up to 14 months (Google default)
- Crash reports: up to 180 days
- AdMob data: according to Google’s retention policy
- Locally stored content: remains until you delete it or uninstall the app
6. Your Rights Under the GDPR
You have the following rights at any time:
- Right of access (Art. 15 GDPR)
- Right to rectification (Art. 16 GDPR)
- Right to erasure (Art. 17 GDPR)
- Right to restriction of processing (Art. 18 GDPR)
- Right to data portability (Art. 20 GDPR)
- Right to object to processing based on legitimate interests (Art. 21 GDPR)
- Right to withdraw consent with effect for the future (Art. 7(3) GDPR)
To exercise your rights, simply contact:
7. Withdrawal of Consent (especially Ads & Analytics)
You can withdraw your consent at any time:
- via the app’s privacy settings
- via device settings (reset advertising ID, disable tracking)
- by contacting us directly
Withdrawal does not affect the lawfulness of processing before the withdrawal.
8. Right to Lodge a Complaint
You may lodge a complaint with any data protection authority.
The supervisory authority responsible for us is:
State Commissioner for Data Protection and Freedom of Information Baden-Württemberg
https://www.baden-wuerttemberg.datenschutz.de/
9. Changes to This Privacy Policy
We may update this Privacy Policy if legal, technical or functional changes occur.
The latest version will always be available within the app.