SeaBloom

1. Controller and scope

This policy applies to the game SeaBloom (the "Game"). The controller of the processing described here is Sylvain KOPECNY, a French sole trader (entrepreneur individuel) trading as KopPlay Games ("we"). Our service providers process some data on our behalf (analytics, crash reports, in-app purchases). Google and the ad networks also process some data on their own behalf, under their own policies. Questions and requests: kopplaygame@gmail.com.

The Game is released step by step: during testing, some of the services described below (advertising, analytics, reminders) may not yet be active in the version you have installed. This policy describes everything the Game may do; it never does more.

2. Data kept on your device

The Game keeps in its private storage on your device: your progress (places unlocked, fish, eggs, decorations, sanctuary level, levels and the Beach board), your resources (coins, gems, energy and its timer), the state of events and gifts, the names you give your fish and the first name you may choose for your profile, your settings (language, music, sounds, vibration, reminders), the result of the age question (section 4), your privacy choices, purchase delivery receipts, a game code shown in Settings, and a small local log of game events used for troubleshooting.

The names you choose and the local log are never sent: they stay on your device and are visible only to you. The game code is sent only if you choose to give it to us (for example in a support email). The Game has no chat and no way to exchange content with other players.

This data remains until you clear the app's data or uninstall the Game. The Game does not yet offer an online save: if you uninstall it, your progress is lost.

3. Internet connection

Most of the Game can be played offline. An Internet connection is used by the store, advertising, consent, crash-report and, if you accept them, analytics services described below. We run no game server of our own.

4. The age question and protections under 16

The question. Before any advertising or analytics service is started, the Game asks, on a neutral screen, whether you are under 16 or 16 and over. Nothing is preselected and nothing suggests which answer unlocks more. We do not ask for and do not keep your date of birth or your exact age: only your answer is kept, on your device.

• Under 16 — you can play the whole Game. Advertising: non-personalized only, tagged "under the age of consent", without the advertising identifier, with an opt-out of sale and sharing signaled to ad networks. Analytics: off, the question is not asked.
• 16 and over — advertising: the choices presented by Google UMP for your region (section 5); analytics: asked separately, optional (section 7).

You can answer again from the Game's Settings. The age question is not an identity check and is not consent to personalized advertising. SeaBloom is not intended for children under 13 and we do not knowingly collect their data; if you believe a child under 13 has used the Game, write to us and we will delete what we can link to them (section 15).

5. Advertising and consent

Advertising funds SeaBloom. Rewarded videos are always optional: you choose to watch one in exchange for an in-game bonus (for example energy or a faster-hatching egg), and declining never blocks the Game. Interstitial ads may appear only at natural breaks, never at launch and never in the middle of a level. The length of a video is set by the ad network that serves it.

For players aged 16 and over, the Game asks Google UMP (User Messaging Platform) to update your choices before any ad; where a consent message is required (for example in the European Economic Area, the United Kingdom and Switzerland), no ad is requested until you answer. If you decline personalized ads, ads remain non-personalized and the rewards stay the same. You can change these choices at any time in the Game's Settings.

6. Advertising data

When advertising is shown, Unity LevelPlay (mediation) and the ad networks it works with — ironSource Ads, Unity Ads, Google AdMob and Liftoff Monetize (Vungle) — as well as Google UMP, may process the data needed to request, deliver, limit, secure and measure ads:

• device and app information (operating system, language, version, device model), approximate location derived from the IP address;
• the device's advertising identifier, only where available, legally allowed and not blocked by the protections in section 4 or by your device settings;
• ad requests, impressions, clicks, completed rewarded videos and other interactions;
• IP address, network, diagnostics, performance and fraud-prevention signals.

These networks act as independent controllers for their own processing. If the list of networks changes, this policy is updated first.

7. Optional analytics (GameAnalytics)

GameAnalytics (GameAnalytics ApS, Denmark) starts only for players aged 16 and over who accepted it in a dedicated choice, asked before the service is started. Declining or withdrawing does not block the Game or change anything in it.

This data is pseudonymous: it uses a random identifier created for the installation, never the advertising identifier, and contains no name or contact details. It may include: device model, operating system, Game version, country derived from the IP address, sessions, progress (levels, places, eggs, fish discovered), in-game economy movements, purchases (product and price, never payment details), ads offered and watched, and events about how features are used. GameAnalytics may also deliver remote settings and A/B tests to adjust the Game's balance; they apply to randomly chosen groups and never target an individual.

You can withdraw your consent at any time in the Game's Settings; nothing more is sent after that. To have past analytics data deleted, write to us with your game code (section 15).

8. Crash reports

To fix crashes, the Game uses Unity's diagnostics service (Unity Technologies): when a crash or serious error occurs, a technical report (error trace, device model, operating system and Game versions, an installation identifier) is sent to Unity, which processes it on our behalf. These reports are never used for advertising or profiling. Google Play also receives its own reports (Android vitals).

9. In-app purchases

Purchases (gems, offers, season pass) go through Unity IAP and Google Play Billing. Google handles payment: we never receive your bank or card details. Unity IAP and Google may process the product identifier, purchase token, order identifier, app version, dates and purchase state to show local prices, deliver each purchase once and provide support. Purchases are checked on the device and local receipts prevent double delivery. Google sends us sales reports for our accounts. Parents can require approval for purchases with Google Family Link or in Google Play settings.

10. Reminders (local notifications)

The Game can schedule optional reminders on the device (for example: an egg is ready to hatch, energy is full again). They are asked for separately, can be refused or turned off at any time in the Game or the system settings, are limited to two a day, are never sent between 9 p.m. and 9 a.m., and are produced by the device itself: no notification server is involved and no data leaves the device for them.

11. Services used

Depending on the version and on your answers: Unity LevelPlay and ironSource Ads; Unity Ads; Google AdMob and Google UMP; Liftoff Monetize (Vungle); GameAnalytics (optional); Unity diagnostics; Unity IAP and Google Play Billing; Android local notifications. The Game does not use Firebase, a mobile measurement partner, server-sent notifications or a social login.

More information: the privacy policies of Unity (https://unity.com/legal/privacy-policy), Google (https://policies.google.com/privacy), GameAnalytics (https://gameanalytics.com/privacy) and Liftoff (https://liftoff.io/privacy-policy/).

12. Purposes and legal bases

• Running the Game, saving on the device, delivering purchases, reminders you asked for — legal basis: performance of the contract.
• Age-based protections, handling rights requests, accounting obligations — legal basis: legal obligation.
• Crash reports, security and fraud prevention — legal basis: legitimate interest: a stable and safe game; you can object by writing to us.
• Non-personalized advertising — legal basis: legitimate interest: funding a free game, within the choices made in Google UMP.
• Personalized advertising — legal basis: consent (Google UMP).
• Analytics, remote settings and A/B tests — legal basis: consent.

Where processing relies on legitimate interest, you can object to it on grounds relating to your particular situation by writing to us.

13. Sharing and "sale" of data

We do not sell personal data for money. Data may be disclosed to the providers listed, only for their services, security, fraud prevention, legal compliance or support, or where the law requires it. Some U.S. laws treat certain advertising disclosures as a "sale" or "sharing". For players under 16, the Game itself signals an opt-out of sale and sharing to the ad networks. For other players, the choices Google UMP presents for your region apply; you can also delete or reset your advertising ID in your Android settings, or write to us.

14. Retention periods

• Progress, resources, names, settings, choices, age answer, delivery receipts, local log — where: device; period: until you clear the app's data or uninstall the Game (the local log is capped and overwrites itself).
• Analytics data — where: GameAnalytics; period: GameAnalytics' retention periods; deletion on request.
• Crash reports — where: Unity, Google; period: these providers' periods.
• Advertising data — where: ad networks; period: their policies.
• Purchase history — where: Google; period: Google's policy (we only keep sales reports, as long as accounting law requires).
• Support correspondence and rights requests — where: kopplaygame@gmail.com mailbox; period: 3 years after the last exchange.

15. Deleting your data and exercising your rights

On your device: clearing the app's data or uninstalling the Game erases everything it stored on the device. Your purchases remain attached to your Google account.

Data held by providers: write to kopplaygame@gmail.com, subject "SeaBloom privacy". Because the Game has no account, give us your game code (shown in Settings) so that we can find your analytics data; we then ask GameAnalytics to delete it. Without this code, we may be unable to link pseudonymous data to a person, and we will tell you so.

Your rights: access, rectification, erasure, restriction, objection, portability, withdrawal of consent at any time (without affecting what was done before), and instructions on what happens to your data after your death. We reply within one month; for complex requests this can be extended by two months, and we will tell you. A request made on behalf of a child is handled without asking for more information than necessary.

16. Transfers outside the European Union

Some providers (Unity, Google and ad networks) process data outside your country, notably in the United States. These transfers rely on the safeguards provided by data-protection law: an adequacy decision (including the EU-U.S. Data Privacy Framework for certified companies) or the European Commission's standard contractual clauses.

17. Security

We take reasonable technical and organizational measures to protect data under our control: encrypted transport (HTTPS), no payment details held by the Game, access to service consoles limited to the publisher and protected by strong authentication. No method is 100% secure.

18. Regional rights and complaints

You may have additional rights under the law of where you live (GDPR, UK GDPR, U.S. state laws, Brazil's LGPD). You can complain to the data-protection authority of your country; in France, the Commission nationale de l'informatique et des libertés (CNIL, www.cnil.fr).

19. Changes to this policy

This policy may change with the Game, its providers or the law. The effective date at the top is updated with each version. A material change is announced in the Game before it takes effect, and your consent is asked again where the law requires it.

20. Contact

Sylvain KOPECNY, entrepreneur individuel (KopPlay Games) — 173 rue de Courcelles, 75017 Paris, France — kopplaygame@gmail.com.