Privacy Policy
WHO WE ARE
SUBPIXELS is a games brand that develops and publishes games for Apple devices (iPhone, iPad, Mac) and Android, such as SPHAZE (“Games”). The SUBPIXELS brand and this Website are owned and operated by Mateusz Janczewski, a private individual, who is the controller of your personal data (“we”, “us”). Contact: support@subpixels.pl.
This Policy explains what personal data we process when you play our Games and when you visit subpixels.pl, why we do it, who helps us, how long the data is kept and what your rights are under the EU General Data Protection Regulation (“GDPR”). All our Games use the same technology and the same service providers, so this Policy applies to each of them.
In short.
- Our Games have no accounts, no registration and no ads.
- Analytics, crash reports and install attribution run only if you choose “Allow” when a Game starts for the first time. The Game works the same if you choose “Don’t allow”, and you can change your choice at any time in the Game’s Settings → Analytics.
- Your progress is saved on your device and, if you use Game Center or Google Play Games, in your own Apple or Google account.
- Our Website counts visits with Jetpack Stats only if you accept statistics in the cookie banner, and we only see aggregated numbers.
- We do not sell personal data.
AT A GLANCE
The table summarises what we process, why, for how long and who receives the data. Details are in the sections below.
| What | Legal basis | How long | Who receives it |
|---|---|---|---|
| Game progress and settings | Contract (Art. 6(1)(b)) | On your device until you delete the Game; in your Apple or Google account until you delete it there | Apple, Google (their own services) |
| In-app purchases and sales records | Contract; legal obligation (Art. 6(1)(b), (c)) | Sales records: as long as tax and accounting law requires | Apple, Google; Unity Technologies (purchase diagnostics) |
| Licence check (Android) | Legitimate interest (Art. 6(1)(f)) | Not stored by us | |
| Support requests | Legitimate interest (Art. 6(1)(f)) | As long as needed to handle your request | Our e-mail provider |
| Gameplay statistics (Google Analytics for Firebase) | Consent (Art. 6(1)(a)) | Up to 14 months | Google (processor) |
| Crash reports (Firebase Crashlytics) | Consent (Art. 6(1)(a)) | 90 days | Google (processor) |
| Install attribution (AppsFlyer) | Consent (Art. 6(1)(a)) | Up to 24 months | AppsFlyer (processor); advertising networks (independent controllers) |
| Performance statistics (Android Performance Tuner) | Consent (Art. 6(1)(a)) | As set by Google Play (Android vitals) | |
| Website server logs | Legitimate interest (Art. 6(1)(f)) | About 30 days | cyber_Folks S.A. (Zenbox), hosting (processor) |
| Website visit statistics (Jetpack Stats) | Consent, given in the cookie banner (Art. 6(1)(a)) | Logs with IP addresses: 28 days; we keep only aggregated statistics | Automattic Inc. (processor) |
| Your cookie banner choice | Legal obligation to respect and record consent (Art. 6(1)(c)) | Up to 12 months, on your device | Nobody, stored only on your device |
| Website fonts (Bunny Fonts) | Legitimate interest (Art. 6(1)(f)) | Not stored by us | BunnyWay d.o.o. |
| Website trailer (YouTube) | Consent, by clicking play (Art. 6(1)(a)) | As set by Google |
WHAT THE GAMES NEED TO WORK
The following happens whether or not you allow analytics, because it is needed to provide the Game you downloaded (Article 6(1)(b) GDPR) or, where stated, because of our legitimate interests (Article 6(1)(f) GDPR).
Progress and settings. Your progress and settings are stored on your device. If you are signed in to Game Center (Apple) or Google Play Games (Google), the Game also saves your progress in your account’s saved-games storage (iCloud or Google Drive) and records your achievements there, so you can continue on another device. Apple and Google run these services under their own privacy policies. We do not receive your player name or ID.
In-app purchases. Purchases are made through the App Store or Google Play, which handle the payment. Apple and Google give us sales reports and transaction confirmations (for example the item, price, country, date and order number), but never your payment card details. Our Games use Unity In-App Purchasing, a library from Unity Technologies, which sends Unity technical diagnostics about the purchase process. We keep sales records for as long as tax and accounting law requires (Article 6(1)(c) GDPR).
Licence check (Android). To protect our Games against piracy, Google Play checks on your device whether your copy is licensed. This is based on our legitimate interest in protecting the Games.
Reminders. If you allow notifications, a Game may schedule occasional reminders on your device. They are created on the device and nothing is sent to us. You can turn them off in your device settings.
Support. If you write to us, for example with the Support button in a Game, we use your e-mail address, your message and anything you attach to answer you. This is based on our legitimate interest in handling your request. The Support button pre-fills technical details about your device (model, operating system, graphics, processor and memory); you can remove them before sending. We keep the correspondence for as long as needed to handle your request and any follow-up questions.
Links. Our Games link to our Website and this Policy, to our pages on social networks such as Facebook and X, to review sites such as Metacritic, and to the app stores. These links open in your browser, and the privacy policies of those sites apply.
WHAT HAPPENS ONLY IF YOU CHOOSE “ALLOW”
When you start a Game for the first time, we ask whether we may collect gameplay statistics and crash reports and measure where your install came from. None of the services below starts until you choose, and none of them starts if you choose “Don’t allow”. If you choose “Allow”, we process the data below on the basis of your consent (Article 6(1)(a) GDPR), which also covers storing and reading identifiers on your device.
You can withdraw consent at any time in the Game’s Settings → Analytics. Collection stops at once (crash reporting stops completely from the next launch), and analytics data stored on your device is deleted. Withdrawing consent does not affect processing that took place before.
Google Analytics for Firebase (iPhone, iPad, Android). The service automatically records usage statistics: first launch, sessions and their length, app version, device model, operating-system version, language, approximate country (derived from your IP address), in-app purchases and a random app-instance identifier. It does not collect advertising identifiers (Google Advertising ID, IDFA) or the iOS vendor identifier, and the data is not used for advertising. We use it to understand how our Games are played and to improve them.
Firebase Crashlytics (iPhone, iPad, Android). When a Game crashes or hits an error, Crashlytics sends a crash report (where in the code it happened), the device model, operating-system and app version, free memory and storage, technical logs and error codes recorded by the Game, and a random installation identifier. We use it to find and fix bugs.
AppsFlyer (iPhone, iPad, Mac, Android). AppsFlyer measures install attribution: whether your install came from the store directly or from one of our campaigns. It also records a few game milestones, such as levels started and completed (with score, time and number of attempts). The data used is your IP address, device and operating-system details, an AppsFlyer identifier, install-referrer information (from Google Play and, if present on your device, Meta, Samsung or Huawei services) and the device advertising identifier. On Android that is the Google Advertising ID. On iPhone and iPad it is the IDFA, and only if you also choose “Allow” in Apple’s tracking prompt, which appears after our question. If an advertising campaign brought you to a Game, AppsFlyer confirms the install to the network that ran it. We use AppsFlyer to measure which of our campaigns work.
Android Performance Tuner (Android). It sends frame-rate and loading-time statistics, together with your device model and the Game’s quality settings, to Google Play (Android vitals). We use it to make our Games run smoothly on more devices.
WHO RECEIVES DATA
We share personal data only with the providers named in this Policy and only for the purposes described:
- Google (Google Ireland Limited and Google LLC): Firebase Analytics, Firebase Crashlytics and Android Performance Tuner, acting as our processors;
- AppsFlyer Ltd. (Israel): install attribution, acting as our processor;
- advertising networks that ran a campaign which brought you to a Game: they receive a confirmation of your install from AppsFlyer and act as independent controllers;
- Unity Technologies: diagnostics of the in-app purchase library;
- Apple and Google as operators of the App Store, Game Center, iCloud, Google Play and Google Play Games, which they provide to you under their own terms and privacy policies;
- Automattic Inc. (USA): visit statistics for our Website (Jetpack Stats), acting as our processor;
- our hosting and e-mail providers, and public authorities where the law requires us to share data.
Some of these providers process data outside the European Economic Area, mainly in the United States and Israel. Such transfers rely on an adequacy decision of the European Commission (Israel, and companies certified under the EU–U.S. Data Privacy Framework) or on standard contractual clauses approved by the European Commission. You can ask us for a copy of these safeguards at support@subpixels.pl.
We do not sell personal data, we do not show ads, and we do not make automated decisions or create profiles that affect you.
HOW LONG DATA IS KEPT
- Data stored on your device: until you delete the Game. Switching Settings → Analytics off deletes the analytics data stored on the device.
- Saved games and achievements: in your Apple or Google account until you delete them there.
- Google Analytics for Firebase: up to 14 months.
- Firebase Crashlytics: 90 days.
- AppsFlyer: up to 24 months.
- Support correspondence: as long as needed to handle your request and any follow-up.
- Sales records: as long as tax and accounting law requires.
- Website visit statistics (Jetpack Stats): logs with IP addresses 28 days; aggregated statistics are kept.
- Cookie banner choice: up to 12 months, on your device.
- Website server logs: about 30 days (see “Our Website” below).
OUR WEBSITE
This section describes how personal data are processed when you visit our Website at subpixels.pl. The Website uses no advertising tools and does not offer contact forms, comments or user accounts. Cookies are used only to remember your choice in the cookie banner, and visits are counted with Jetpack Stats only if you agree, as described below.
Hosting and server logs. The Website is hosted by cyber_Folks S.A. (Zenbox), Poland, which acts as our processor. When you visit the Website, the server automatically records technical data: your IP address, the date and time of the request, the address of the requested page, and information about your browser and operating system. We use these data to operate the Website and to protect it against attacks and abuse, on the basis of our legitimate interest (Article 6(1)(f) GDPR). Server logs are kept for approximately 30 days and then deleted.
Your cookie choice. The cookie banner is provided by the Complianz plugin, which runs on our own server. It stores your choice in small cookies on your device (their names start with “cmplz_”) for up to 12 months, so that we do not ask you again on every visit. These cookies are necessary to respect and record your choice and are not shared with anyone.
Visit statistics (Jetpack Stats). We use Jetpack Stats, a service of Automattic Inc. (USA), to count visits to the Website. When you open a page, a script from stats.wp.com sends Automattic your IP address, browser and device information (user agent), the address of the page you visit, the referring page, the time of the visit, your browser language and your country. We only see aggregated numbers, such as views per page, referring sites and countries. We cannot see which person visited which page. Automattic keeps the logs containing IP addresses for 28 days and uses them only to provide this service. Jetpack Stats does not set cookies on your device, and visits by people signed in to our administration panel are not counted. The script loads only if you choose “Accept” in the cookie banner, so we process these data on the basis of your consent (Article 6(1)(a) GDPR). You can withdraw your consent at any time via “Cookie settings” at the bottom of every page. If your browser sends a Do Not Track or Global Privacy Control signal, we treat it as a refusal. Automattic may process the data in the United States (see “Who receives data”).
Security. To protect the Website’s administration panel, we record the IP addresses of failed login attempts and temporarily block repeated attempts, on the basis of our legitimate interest. This does not affect regular visitors.
Fonts. The Website loads its fonts from Bunny Fonts, a service provided by BunnyWay d.o.o. (Slovenia, EU). To deliver the fonts, your browser connects to Bunny’s servers, which receive your IP address. Bunny Fonts does not use cookies. We use this service on the basis of our legitimate interest in presenting the Website consistently.
Videos (YouTube). The game trailer on the Website is hosted on YouTube, a service provided by Google Ireland Limited. The YouTube player is loaded only after you click the play button, in YouTube’s privacy-enhanced mode (youtube-nocookie.com). After you click, Google receives your IP address and information about your device and viewing activity, and may store cookies or similar data on your device. By clicking the play button you request this content, and the data are processed on the basis of your consent (Article 6(1)(a) GDPR). You can withdraw this consent at any time by not starting the video again and deleting YouTube’s cookies in your browser settings. Google may transfer data to Google LLC in the United States, which is certified under the EU–U.S. Data Privacy Framework. More information: Google Privacy Policy.
Links to app stores. The Website contains links to the Apple App Store, the Mac App Store and Google Play. These services receive data about you only if you follow a link, and their own privacy policies apply.
CHILDREN
Our Games are suitable for all ages, but we do not knowingly collect personal data from children beyond what the Games need to work. If you are under 16, please ask a parent or guardian before choosing “Allow”; the Game works fully if you choose “Don’t allow”. If you believe a child has allowed analytics without a parent’s consent, contact us and we will delete the data we can identify.
YOUR RIGHTS
You have the following rights:
| Right | When you can use it |
|---|---|
| Access | At any time: you can ask whether we process your data and receive a copy of it. |
| Rectification | If your data is inaccurate or incomplete. |
| Erasure | If the data is no longer needed, you withdraw your consent and there is no other legal basis, your objection is upheld, the data was processed unlawfully, or erasure is required by law. |
| Restriction of processing | While we check whether your data is accurate; if processing is unlawful but you prefer restriction to erasure; if we no longer need the data but you need it for legal claims; or while we consider your objection. |
| Data portability | If we process data you provided on the basis of your consent or a contract, by automated means. You can receive it in a structured, commonly used, machine-readable format. |
| Objection | If we process your data on the basis of our legitimate interests (for example support requests or Website server logs), on grounds relating to your particular situation. |
| Withdrawal of consent | At any time: in the Game’s Settings → Analytics, or via “Cookie settings” at the bottom of every page of our Website. This does not affect processing carried out before the withdrawal. |
To use these rights, write to support@subpixels.pl. Our Games have no accounts, so the data held by our providers is linked to random identifiers of your device rather than to your name. We may therefore ask for details that help us find it, such as the Game, your platform and roughly when you installed it.
We will respond without undue delay and in any case within one month of receiving your request. If a request is complex, we may extend this period by up to two further months; if so, we will let you know within the first month and explain why. Exercising your rights is free of charge.
You can also lodge a complaint with a data protection supervisory authority, in particular in the EU country where you live or work or where you think the infringement took place. In Poland this is the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, ul. Moniuszki 1A, 00-014 Warszawa, uodo.gov.pl).
SECURITY
We do not run our own game servers. The providers we use transmit data in encrypted form and protect it with appropriate technical and organisational measures. Where they act as our processors, they do so under data processing agreements with us.
CHANGES TO THIS POLICY
We update this Policy when our Games, our providers or the law change. The date at the top shows when the current version took effect. We announce important changes on this page and, where appropriate, in the Games.
CONTACT
Questions about this Policy or your data: support@subpixels.pl.