Privacy Policy for the game “Tiefenriff”

1. Summary

• You don't need an account. We never ask for your real name, e-mail address, phone number or location.
• On first launch the game creates a random player ID. It links your cloud save, purchases, leaderboards, friends and mail to your game.
• Our own server is located in the EU (Frankfurt am Main, Germany).
• Ads are only optional rewarded videos (Google AdMob). You decide in the consent form whether Google may show personalised ads, and you can change your choice in the settings at any time.
• Gameplay statistics and error reports sent to our server can be switched off in the settings (“Send statistics”).
• Reminders are local notifications on your device – there are no server push notifications.
• Other players only see your player name (a random name by default) and game-related values (see section 5).

2. Controller

Mario Horvath
Ahorngasse 12/19
2231 Strasshof an der Nordbahn, Austria
E-mail:
Web: https://mariodev.at

No data protection officer has been appointed (not legally required). Please send all privacy questions to the e-mail address above.

3. No account – player ID, recovery code, friend code

Player ID: On first launch the game generates a random string (32 characters) on your device. It contains no device, advertising or hardware identifier and does not reveal who you are. It is sent with every request to our server so the server knows which game the data belongs to. Because data is linked to a game through this ID, we still treat it as (pseudonymous) personal data.

Recovery code: When your save is uploaded for the first time, the server issues an 8-character code (Settings → “Transfer progress”). With this code you can move your save to another device. Treat it like a password: anyone who knows it can load your save.

Friend code: When you open the friends window, the server issues a permanent 6-character friend code that you can give to friends.

We also need your recovery code or friend code to identify you when you make a data request (section 9) – we have no other way of recognising you.

4. What data we process and why

Legal bases (GDPR): Art. 6(1)(b) = performance of the contract of use (providing the game features you use) · (f) = legitimate interests (stated in brackets) · (a) = consent.

4.1 Every connection to our server

The game connects to reef-api.mariodev.at (encrypted via HTTPS) at start-up, regularly while you play and when you close it.

• Data: your IP address is only processed to establish the connection and is not logged. Server logs contain only date and time, requested path (without player ID), status code, amount of data, processing time and the app/system identifier of the request (user agent).
• Purpose: delivering responses, operation, security and troubleshooting.
• Legal basis: (f) (secure and stable server operation).
• Retention: server logs 14 days. IP addresses are neither logged nor stored in our database (exception: salted hash when restoring, see 4.2).

4.2 Cloud save, sync between devices and restore

• Data: player ID, your full save (progress, inventory, currencies, in-game settings such as language, player name and recovery code), time of saving, revision number, recovery code. On restore: old and new player ID, time and a salted hash of your IP address (not the IP itself). For wrong codes: salted IP hash and time (protection against guessing, at most 10 failed attempts per hour).
• Purpose: backing up your progress, moving it to a new device, syncing between several devices.
• Legal basis: (b); protection against code guessing: (f) (security of saves).
• When: automatically about every 5 minutes while playing and when the app is closed.
• Retention: only the current and the immediately previous save are kept. Stored until you ask us to delete it; without any game activity, all data linked to your player ID is deleted automatically after 24 months. Failed attempts (IP hash): about 24 hours. Log of successful restores: 30 days.

4.3 Gameplay statistics (can be switched off)

• Data: player ID; level, current and unlocked zones, stars/shells/pearls balance, maximum energy, completed rooms, whether the tutorial is finished, counters (merges, orders, generator taps, pearls/shells spent, videos watched), whether the save was modified outside the game, app version, platform (Android/iOS), language setting (e.g. de_AT); also game progress milestones with the time each was first reached (e.g. first start, tutorial steps, first order, rooms, zones, levels, first purchase, joining a Reef Race, first friend). From this we record per day that the game was used, how often it was started and how many pearls were spent that day, as well as the day of first use.
• Purpose: improving the game (e.g. “where do players stop?”, balancing), counting daily active players, fair leaderboards.
• Legal basis: (f) (development and fairness of the game).
• When: when the app starts, when you return to the app after a longer break and when you leave the app.
• Objection: switch off Settings → “Send statistics”. No statistics and no error reports are sent after that.
• Retention: only the latest state per player is kept (overwritten); milestones and the day of first use once each. Daily entries: 24 months. Analyses are only carried out in aggregated form.

4.4 Error reports (can be switched off)

• Data: player ID, error message and technical trace (code location), app version, platform, current zone. No content from other apps, no photos, no contacts.
• Purpose: finding and fixing bugs.
• Legal basis: (f) (a bug-free game).
• Scope: at most 10 reports per session; identical errors are grouped.
• Objection: as in 4.3 via “Send statistics”.
• Retention: per-player daily counter: 7 days. Error groups (with the ID of the player last affected): 12 months.

4.5 In-app purchases and purchase verification

Purchases are handled exclusively by Google Play or the Apple App Store. We do not receive payment details (card, name, address, e-mail).

• Data: player ID, product, platform, purchase receipt (Android: order data signed by Google incl. order ID, purchase token, purchase time; iOS: transaction ID), verification result and time.
• Purpose: checking that a purchase is genuine, crediting it exactly once, restoring the starter pack, preventing fake purchases. For iOS our server queries Apple (App Store Server API) with the transaction ID.
• “Reef Club” subscription: for a subscription our server also asks Google (Google Play Developer API) or Apple (App Store Server API) whether and until when it is active (expiry date, status such as active/cancelled/refunded) and stores expiry date and status with your player ID, so that the benefits (daily pearls, faster energy, badge) apply for exactly that long. Your save game contains the expiry date, the day you last claimed daily pearls and the date of first activation. Cancellation and payment details are managed solely with Google or Apple.
• Legal basis: (b) (delivering the purchased content); fraud prevention: (f).
• Retention: receipts are kept for as long as the game is operated, because this is the only way to prevent the same receipt from being credited twice, but at least 7 years (tax retention duty, § 132 BAO). On a deletion request the link to your player ID is removed.

4.6 Mail and coupons

• Data: player ID, time of last retrieval, messages addressed to you, redeemed coupon codes with time.
• Purpose: delivering messages and rewards (e.g. compensation, event prizes, gifts from friends), redeeming coupons exactly once.
• Legal basis: (b).
• When: at start-up, every 10 minutes and when you return to the app.
• Retention: messages until they expire (gifts and help from friends: 30 days); redemptions and last retrieval time: until your data is deleted or 24 months after your last game activity.

4.7 Reef Race (events with leaderboards)

• Data: player ID, player name, score, group, rank, time of joining and of the last update.
• Purpose: running time-limited competitions in groups of about 30 players and handing out prizes.
• Participation: while a race is running, the game reports your score automatically (every 2 minutes and when closing); the first report places you in a group. Taking part is part of the game. If you do not want to appear under your name, you can choose another name at any time (Settings → Name) or delete your data.
• Visible to others: player name, score and rank – only to the players in your group.
• Fairness: the server automatically checks whether scores are plausible and whether a save was modified. Suspicious entries are ranked separately. This has no legal or similarly significant effect on you (not a case of Art. 22 GDPR); you can keep playing normally.
• Legal basis: (b); plausibility checks: (f) (fair competitions).
• Retention: the final standings remain visible for 48 hours after the race ends. Entries are deleted 90 days after the race is closed.

4.8 Friends, gifts and help

Only if you open the friends window.

• Data: player ID, friend code, player name, level, time you last used the friends feature, your friends list, gifts sent (sender, recipient, day, sender's name); for help requests the requested item, time and expiry of the request, who helped whom (with both player names) and the thank-you reward.
• Purpose: adding friends by code, sending one gift per friend per day, asking friends for an item and helping friends.
• Visible to your friends: player name, friend code, level, when you last used the friends feature; your player name as sender of gifts and help; your open help request (which item).
• Legal basis: (b).
• Retention: friendships until you remove them (removes both directions) or ask for deletion. Gift records and help requests: 90 days. If you delete your data, help you gave to a friend stays with them without your ID and name, so they can still collect their item.

4.9 Player name

On first launch you get a random name (e.g. “Octopus 42”). You can change it in Settings → Name (2–16 characters). Please don't use your real name. We may change inappropriate names; a name changed by us is locked afterwards.

4.10 Server time, app settings, game content

At start-up the game fetches the server time, app settings (e.g. maintenance, minimum version, balancing adjustments) and current events. Apart from connection data (4.1) and – for events – the player ID, nothing is transmitted. Legal basis: (b) and (f) (protection against manipulating the device clock).

4.11 Advertising (Google AdMob) and consent (Google UMP, Apple ATT)

The game only shows rewarded videos that you start yourself. The provider is Google (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland).

• Consent: before the first video is loaded, Google's consent platform (UMP) shows a consent form in the EEA, the UK and Switzerland. On iPhone/iPad the system also asks whether the app may track you across other companies' apps and websites (App Tracking Transparency). Without this permission Google does not receive the advertising ID (IDFA).
• Data processed by Google: advertising ID (Android advertising ID or IDFA, only with permission), IP address and approximate location derived from it, device and app information, interactions with ads, diagnostic data of the ads SDK.
• Purpose: serving and billing ads, measurement, fraud prevention; personalised ads only with your consent, otherwise non-personalised or limited ads.
• Legal basis: (a) (consent, also for access to your device under the ePrivacy rules); non-personalised ads: (f) (funding the free game).
• Withdrawal: at any time via Settings → “Ad consent” (UMP) or in iOS Settings → Privacy → Tracking. You can reset or delete the Android advertising ID in the Android settings.
• Google processes this data as an independent controller: https://policies.google.com/privacy and https://policies.google.com/technologies/partner-sites.
• We never receive the advertising ID; our server only learns how many videos were watched in your game (counter in the statistics, 4.3).

4.12 Achievements via Google Play Games / Game Center

Achievements you reach are reported to Google Play Games (Android) or Apple Game Center (iOS) if you are signed in there. If you are already signed in on the device, the game signs in silently at start-up. Google or Apple process your profile there as independent controllers (https://policies.google.com/privacy, https://www.apple.com/legal/privacy/). We do not receive any data from your Google or Apple account. Legal basis: (b).

4.13 Local notifications

Reminders (e.g. “energy is full”) are scheduled on your device. There is no push service and no data is sent to us or to third parties for this. They can be switched off in the game settings and in your device settings.

4.14 Sharing

When you share a picture of your station, the game creates the picture on your device and opens your system's share menu. You decide what you share and where; we receive nothing. On iOS, “Save image” requires permission to add images to your photo library – we never read your photos.

4.15 Data stored only on your device

Save, settings, player ID, sync status and a technical error log are stored in the app's storage on your device. They are deleted when you uninstall the app. Write down your recovery code first if you want to keep your progress.

5. What other players see

Your player ID and recovery code are never shown to other players.

6. Recipients and processors

• Hosting: OVH GmbH, Christophstraße 19, 50670 Cologne, Germany, server location data centre in Frankfurt am Main, Germany (EU). OVH operates the server running our backend as a processor (Art. 28 GDPR, data processing agreement under OVH's terms).
• Google (Google Ireland Limited; Google LLC, USA): AdMob/UMP (ads, consent), Google Play Billing (purchases), Google Play Games (achievements) – each as an independent controller.
• Apple (Apple Distribution International Ltd., Ireland; Apple Inc., USA): App Store / StoreKit (purchases), App Store Server API (purchase verification: our server sends the transaction ID), Game Center (achievements) – as an independent controller.
• Authorities only where we are legally obliged.

We do not sell data and do not pass data from our backend to advertising partners.

7. International transfers

Our backend stores data exclusively in the EU. Google and Apple may transfer data to the USA. Both are certified under the EU-US Data Privacy Framework (adequacy decision of the European Commission of 10 July 2023, Art. 45 GDPR) and additionally use standard contractual clauses (Art. 46 GDPR).

8. Retention overview

9. Your rights

You have the right of access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and to object to processing based on legitimate interests (Art. 21). You can withdraw any consent at any time with effect for the future (Art. 7(3)).

Delete directly in the game: Settings → “Delete my data” immediately deletes all data linked to your player ID on our server (purchases are kept without the ID for bookkeeping, § 132 BAO) and resets the game on this device.

Otherwise: write to and include your recovery code (Settings → “Transfer progress”) and/or your friend code (friends window). Without one of these codes we cannot find your data, because we store no names or e-mail addresses. As the recovery code works like a password, please share it only with us. On deletion we remove all data linked to your player ID from our backend within one month; it disappears from backups after at most 14 days.

You can control ads and statistics directly in the game (Settings → “Ad consent” and “Send statistics”).

10. Right to lodge a complaint

You may lodge a complaint with a data protection supervisory authority, in Austria with the
Österreichische Datenschutzbehörde (Austrian Data Protection Authority), Barichgasse 40–42, 1030 Vienna, phone +43 1 52 152-0, e-mail dsb@dsb.gv.at, https://www.dsb.gv.at.

11. Children

The game is not directed at children under 13. In Austria, persons aged 14 and over can consent to the processing of their data themselves (§ 4(4) DSG); for younger users, consent to personalised advertising requires a parent's approval (the age may differ in other countries). If you are under 14, please decline personalised ads or ask your parents. If we learn that a child's data was processed without the required consent, we delete it.

12. Security

All connections to our server are encrypted via HTTPS. The server can only be administered through a secured access, the database is not publicly reachable, and IP addresses are only stored in the database as a salted hash.

13. Changes

We will update this policy if the game or the law changes. The version published here applies.