Privacy Policy
This Privacy Policy explains how Onni Lab SL ("Onni Lab", "we", "us") collects, uses and shares information about you when you play our mobile games, use our applications or visit our website onnilab.com (together, the "Services"). It applies to all games and applications published by Onni Lab (the "Games").
Data controller:
Onni Lab SL
Pl. Universitat 3, Planta 6, 08007 Barcelona, Spain
VAT: ESB56430531
E-mail: contact@onnilab.com
Contents
- Information we collect
- How we use information and legal bases
- Advertising and your choices
- Third-party partners
- How we share information
- International data transfers
- Data retention
- Your rights (EEA, UK and similar jurisdictions)
- Privacy rights for US residents
- Children
- Security
- Third-party links and services
- Changes to this Privacy Policy
- Contact us
1. Information we collect
1.1. Information collected automatically
When you play our Games, we and our third-party partners (see section 4) collect certain information automatically from your device:
- Device and advertising identifiers - such as the Google Advertising ID (GAID), and similar app- or vendor-scoped identifiers (for example the Firebase app instance ID or a push notification token).
- Device information - device model and manufacturer, operating system and version, language and region settings, screen size, mobile network or carrier, and general technical properties of the device.
- IP address.
- Gameplay and usage data - for example levels started and completed, game progress, session length and frequency, in-game events, features used, and general interaction with the Games.
- Advertising interaction data - which ads were shown, viewed or clicked, and related measurement data (for example estimated ad revenue per impression).
- Crash and diagnostics data - crash traces, device state at the time of a crash and performance diagnostics, used to find and fix technical problems.
1.2. Information you provide to us
- Feedback and support - if you contact us by e-mail or fill in one of our feedback forms (hosted by Google Forms), we receive the information you choose to provide, such as your message, game version and, if you include it, your contact details.
1.3. Purchases (where offered)
If you make in-app purchases, payments are processed entirely by the store platform (Google Play) - we never receive your payment card details; we only receive confirmation of the purchase (a receipt and transaction identifier) so that we can deliver the purchased content.
2. How we use information and legal bases
Where the EU/UK General Data Protection Regulation ("GDPR") applies, we rely on the legal bases shown below.
| Purpose | Data used | Legal basis |
|---|---|---|
| Providing and operating the Games (core gameplay, remote configuration of game features and difficulty, delivering purchased content) | Device information, gameplay data, technical identifiers | Performance of a contract (our Terms of Service); legitimate interest in operating our Services |
| Personalized advertising (ads selected using your data, including interests inferred from your activity in other apps) | Advertising ID, IP address, device information, advertising interaction data | Consent (in the EEA, UK, Switzerland and other regions where required), collected through the consent flow at first launch; where consent is not required by law, our and our partners' legitimate interests, with the opt-out options described in section 3 |
| Non-personalized (contextual) advertising, ad delivery, frequency capping, ad measurement and fraud prevention | Advertising ID or other device identifiers, IP address, device information | Legitimate interest in funding our free Games and protecting them against fraud |
| Analytics and product improvement (understanding how the Games are played, improving levels, balancing difficulty, A/B testing of game features) | Pseudonymous usage events, device information | Legitimate interest in improving our Games |
| Crash reporting and diagnostics | Crash and diagnostics data | Legitimate interest in keeping the Games stable and secure |
| Push notifications (where offered) | Push notification token | Consent (you can disable notifications at any time in your device settings) |
| In-app purchases (where offered) | Purchase receipts and transaction identifiers (no payment card data) | Performance of a contract; legal obligations (tax and accounting) |
| Responding to your messages and feedback | The information you send us | Legitimate interest in supporting our players; consent |
| Compliance with law, establishing or defending legal claims | Any of the above, as relevant | Legal obligation; legitimate interest |
3. Advertising and your choices
Our Games are funded by advertising. We use AppLovin MAX as our advertising mediation platform: when an ad slot is available, AppLovin and the ad networks listed in section 4 compete to fill it. For this purpose these partners receive data from your device (such as your advertising ID, IP address and device information) and act, in most cases, as independent data controllers of that data under their own privacy policies.
3.1. Consent in the EEA, UK and Switzerland
If you are in the European Economic Area, the United Kingdom or Switzerland, a consent dialog (a "consent management platform" operating under the IAB Transparency and Consent Framework) is shown when you first launch a Game. There you can accept or refuse personalized advertising and see the full, current list of advertising vendors. If you refuse, you will still see ads, but they will not be personalized.
You can change or withdraw your consent at any time, with effect for the future: disable personalized advertising using the device-level controls described in section 3.2, or contact us at contact@onnilab.com. If you reinstall a Game, the consent dialog is shown again at first launch.
3.2. Your choices on your device
- Android - you can reset or delete your advertising ID and opt out of ads personalization under Settings > Google > Ads (naming varies by device).
4. Third-party partners
The table below lists the advertising and analytics partners currently used in our Games. The exact set of partners can vary slightly per Game and over time; where the consent dialog is shown, it always contains the current full vendor list for that Game. Each partner processes personal data under its own privacy policy:
| Partner | Purpose | Privacy policy |
|---|---|---|
| AppLovin (MAX mediation and AppLovin's ad network) | Ad mediation, ad serving, measurement | legal.applovin.com/privacy |
| Google AdMob and Google Ads (Google LLC) | Ad serving, measurement | policies.google.com/privacy |
| Meta Audience Network (Meta Platforms) | Ad serving, measurement | facebook.com/privacy/policy |
| Unity Ads / ironSource (Unity Technologies) | Ad serving, measurement, ad quality | unity.com/legal/game-player-and-app-user-privacy-policy |
| Mintegral | Ad serving, measurement | mintegral.com/en/privacy |
| Liftoff Monetize (Vungle) | Ad serving, measurement | liftoff.ai/privacy-policy |
| InMobi | Ad serving, measurement | advertising.inmobi.com/privacy-policy |
| DT Exchange (Digital Turbine / Fyber) | Ad serving, measurement | digitalturbine.com/privacy-policy |
| Pangle (ByteDance) | Ad serving, measurement | pangleglobal.com/privacy/enduser-en |
| Moloco | Ad serving, measurement | moloco.com/privacy-policy |
| BidMachine | Ad serving, measurement | bidmachine.com/privacy-policy |
| Google Firebase (Analytics, Crashlytics, Remote Config, Cloud Messaging) | Analytics, crash reporting, remote configuration, push notifications | firebase.google.com/support/privacy |
| Unity engine (Unity Technologies) | Game engine runtime services | unity.com/legal/game-player-and-app-user-privacy-policy |
| Google Forms (Google LLC) | Optional player feedback forms | policies.google.com/privacy |
5. How we share information
We share information only:
- with the advertising and analytics partners listed in section 4, for the purposes described in this policy;
- with service providers that help us operate the Services (for example cloud and configuration infrastructure), acting on our behalf;
- with platform providers (Google Play) when you install our Games or make purchases through them, under their own terms and privacy policies;
- with authorities or other parties where required by law, or to establish, exercise or defend legal claims, or to protect the rights, safety and property of Onni Lab, our players or others;
- in connection with a business transaction (merger, acquisition or sale of assets), in which case the data described in this policy may be transferred to the acquiring entity; any material changes to this policy would be announced as described in section 13.
6. International data transfers
The partners listed in section 4 may process personal data in countries outside the European Economic Area, including the United States. Where personal data is transferred from the EEA, the UK or Switzerland to a country without an adequacy decision, we and our partners rely on appropriate safeguards, in particular the European Commission's Standard Contractual Clauses, the UK Addendum where applicable, and - for partners certified under it - the EU-US Data Privacy Framework. You can request more information about these safeguards using the contact details in section 14.
7. Data retention
We keep personal data only for as long as necessary for the purposes described in this policy, and then delete or anonymize it. In particular:
| Data | Retention |
|---|---|
| Analytics data (Firebase Analytics) | User-level data is retained in Google Analytics for up to 14 months. Raw analytics events are additionally retained in our own analytics warehouse (Google BigQuery) for up to 3 years from collection, then deleted or anonymized. Aggregated statistics that no longer identify you may be kept longer |
| Crash and diagnostics data (Firebase Crashlytics) | Up to 90 days |
| Feedback and correspondence | Up to 3 years after the matter is resolved (art. 72 of the Spanish LOPDGDD) |
| Purchase records (where purchases are offered) | 6 years (art. 30 of the Spanish Commercial Code) |
| Game progress | Stored locally on your device; removed when you uninstall the Game |
| Data held by advertising partners | Retained under each partner's own privacy policy (see the links in section 4) |
8. Your rights (EEA, UK and similar jurisdictions)
Where the GDPR or similar laws apply, you have the right to:
- access the personal data we hold about you and receive a copy;
- rectify inaccurate personal data;
- erase your personal data ("right to be forgotten");
- restrict processing in the cases provided by law;
- data portability - receive data you provided in a structured, machine-readable format;
- object to processing based on legitimate interests, including profiling;
- withdraw consent at any time, without affecting processing carried out before the withdrawal - for advertising consent, see section 3.
To exercise these rights, contact us at contact@onnilab.com. The data we hold is pseudonymous: it is linked to technical identifiers (such as the advertising ID or an app instance identifier), not to your name or e-mail address. We may therefore ask you for additional information (such as your device's advertising ID) so that we can locate the data concerned and confirm that it relates to you. If we are unable to do so, we may not be able to fulfil your request; in that case we will inform you of the reasons. For data processed by our advertising partners as independent controllers, you can also exercise your rights directly with them via the links in section 4.
You also have the right to lodge a complaint with a supervisory authority, in particular in the EU member state of your residence or workplace. The authority for Onni Lab is the Spanish Data Protection Agency (Agencia Espanola de Proteccion de Datos, AEPD), www.aepd.es.
9. Privacy rights for US residents
Depending on your state of residence (for example under the California Consumer Privacy Act, as amended), you may have rights to know, access, correct and delete personal information, and the right not to be discriminated against for exercising them. Over the past 12 months we have collected the categories of information described in section 1 (identifiers, device information and internet or app activity information) from the sources and for the purposes described in this policy; our advertising partners may derive inferences from this data for advertising purposes.
We do not sell personal information for money. However, sharing identifiers and device information with advertising partners for personalized advertising may be considered a "sale", "sharing" or "targeted advertising" under some US state laws. You can opt out of this:
- on Android, by deleting or resetting your advertising ID and turning off ads personalization in device settings;
- or by contacting us at contact@onnilab.com.
10. Children
Our Games are directed at a general audience and are not directed at children. We do not knowingly collect personal data from children under 13 years of age (or under the higher minimum age for consent to data processing in your jurisdiction, such as 14 in Spain and up to 16 in some EEA countries). If you are under that age, please do not use the Games or provide any personal data to us. If we learn that we have collected personal data from a child contrary to this policy, we will delete it.
11. Security
We use appropriate technical and organizational measures to protect personal data, appropriate to the risk (such as encryption in transit and access controls). However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.
12. Third-party links and services
The Games and our website may contain advertisements and links that lead to third-party websites, apps or services (including app stores and our feedback forms). We are not responsible for the content or privacy practices of those third parties. This Privacy Policy does not apply to them; please review their privacy policies.
13. Changes to this Privacy Policy
We may update this Privacy Policy from time to time, for example when we add features or integrate a new partner. The current version is always available at onnilab.com/privacy_policy.html, with the "Last updated" date at the top. If the changes are material, we will inform you in a more prominent way (for example in the Games or in the store listing).
14. Contact us
If you have any questions about this Privacy Policy or how we handle your data, contact us at:
Onni Lab SL
Pl. Universitat 3, Planta 6, 08007 Barcelona, Spain
E-mail: contact@onnilab.com