Micinka Tower Privacy Policy
Version 1.1 · effective {{EFFECTIVE_DATE}}
Working draft for the non-production test website. Before release, verify the actual behaviour of every version and advertising SDK, complete the contact details and date, and obtain a privacy review. This page alone does not prove that the app collects only the data described here.
This policy describes data processing when you play Micinka Tower (the “Game”) or visit https://micinkagames.party.
In brief: The current version has no user accounts, does not sync progress to our server and does not offer real-money purchases. Progress, in-game cash and settings are stored locally on your device. The mobile Game is free and may display Google AdMob ads. The test website itself has no analytics or advertising scripts; its hosting provider may process technical request data.
1. Controller and contact
The controller is Samir Jahjefendič, a Czech sole trader (OSVČ), company ID (IČO) 03187951, business address Nová ulice 716/51, 664 47 Střelice, Czech Republic, e-mail {{EMAIL}}, phone {{PHONE}}, website https://micinkagames.party (“we”). The contact details in placeholders must be completed before public release.
Google processes data for its services, such as AdMob and Google Play distribution, under its own rules. Cloudflare hosts this test website. The current Game version has no user accounts or active server-side progress synchronisation operated by us.
2. Data we process
2.1 Data stored on your device
The Game stores locally, among other things: sound, vibration and language settings; game progress; in-game cash; skills; daily missions; local scores and any nickname entered for the local leaderboard; a random installation ID; age band; and privacy/ad choices.
In the current test version, these data are not sent to our game server. Delete them using Settings → Delete my data → Everything, if available in that version, or by uninstalling the Game or clearing its data in your device settings. Uninstalling may also remove your cash and progress.
We use these data to save local progress and settings. We do not maintain an online profile for them and cannot restore them after they are deleted from your device.
2.2 Accounts and online services
The current test version does not let you create a user account, synchronise progress to our server or use an active online leaderboard. Nicknames and scores stay on the device. If a future version enables server-side leaderboards, accounts or progress storage, we will update this policy, provide in-app information and establish the required legal basis and controls before the new processing begins.
2.3 Advertising (Google AdMob and UMP)
The mobile Game is free and may display ads. Planned formats are optional rewarded video and ads between runs; exact formats depend on the actual version. A test build may use test ad units. The web test demo does not itself display ads.
When an ad loads, Google’s advertising SDK may process information such as your IP address, device advertising identifier (if available and enabled), device and app information, diagnostics and ad interactions to serve ads, measure performance and prevent fraud. The precise scope depends on Android version, device settings, age and consent choices. See Google – AdMob data disclosure and Google – technologies used on partner sites and apps.
Google UMP may display a consent form and pass your choices to advertising partners. In the EEA and other regions where required, ad choices depend on consent and in-app settings. We apply age-appropriate ad restrictions where required by the player’s age and Google Play rules. You can change choices in Settings → Privacy settings where that option is available in the version.
Google may act as an independent controller or in another role depending on the advertising function and legal regime. Google’s processing is governed by its policies; advertising partners generally receive the ad request and settings passed by the app. We verify the precise behaviour for each production version.
2.4 Purchases and payments
The current version offers no real-money purchases, coin purchases, ad removal or subscriptions. We do not use Google Play Billing/Unity IAP to accept payments and do not create purchase order, receipt or payment records. In this version, you earn in-game cash only through gameplay and in-game rewards; only the in-game balance is stored on your device.
Google Play distributes the app and may process data needed for its store and user account under its own policies. Google Play does not currently provide us with data about purchases in this Game because no purchases are offered.
2.5 Messages you send us
If you write to {{EMAIL}}, we process your address and message to respond and handle your request. We keep messages while needed to resolve the request and, where necessary, to establish or defend legal claims; the precise period depends on the request.
2.6 Website visits
The test website uses no first-party analytics, advertising pixels or tracking cookies. When serving the page, Cloudflare as hosting provider may process technical request data needed for delivery and security, such as an IP address, request time, URL, browser type and technical logs, under its own terms. We do not use these data to profile visitors.
2.7 What we do not process in the current version
The Game does not require an account, in-app e-mail, precise location, contacts, photos, camera or microphone. We do not operate our own server for accounts, progress storage or online leaderboards. We do not process payments for game content because purchases are unavailable. Advertising and hosting providers may still process technical data as described in sections 2.3 and 2.6.
3. Recipients and providers
| Recipient | Role | Purpose |
|---|---|---|
| Google (AdMob, UMP) | advertising services; role depends on processing | serving ads, consent choices and measurement |
| Google Play | platform and app distribution provider | downloading and updating the app |
| Cloudflare Pages | hosting provider | delivering the website and securing requests |
| Public authorities | recipient required by law | compliance with legal obligations |
In this version, we do not send game progress, cash balances or scores to our own server. We will identify new recipients before enabling a new service.
4. Transfers outside the European Economic Area
Depending on the service, Google and Cloudflare may process data outside the EEA, including in the United States. These providers describe their international transfer mechanisms in their own terms and policies. We will verify the specific mechanism and safeguards for the services actually used before production release. You may request information about applicable safeguards at {{EMAIL}}.
5. Children and age
5.1 The Game is not intended for children under 13. The app may ask for an age band on first launch; it does not store the exact year of birth unless a specific version expressly says otherwise.
5.2 Ad and content settings depend on the player’s age, consent and Google Play rules. Players under 16 are not shown personalised ads; child-directed treatment and age-appropriate advertising are used for children.
5.3 If you learn that a child has provided personal data directly to us, contact {{EMAIL}} so we can assess the request and remove any relevant data. The current version does not require account creation.
6. Retention
| Data | Where and how long |
|---|---|
| Local progress, in-game cash and settings | on your device until app data is deleted or the Game is uninstalled |
| Age and ad choices | on your device while using the app or until its data is deleted |
| Technical website request data | by the hosting provider under its operational and security rules |
| E-mail messages | while resolving the request and only as long as necessary for legal claims or obligations |
| Advertising data | according to your device settings and Google policies |
7. Your rights
Depending on the circumstances, you may request access, rectification or erasure, restriction of processing, portability, object to processing or withdraw consent. The applicable right depends on who processes the data and on what legal basis.
- Local game data: delete it in the app using Settings → Delete my data → Everything, if available, or in device settings / by uninstalling the Game. We cannot restore data after deletion.
- Ads: change advertising preferences in the Game’s privacy settings, Android settings or directly with Google. Google handles requests relating to data it processes as an independent controller.
- Requests to us: e-mail {{EMAIL}} and describe your request. We will respond within the period required by law.
- Complaint: you may complain to the Czech Data Protection Authority, Pplk. Sochora 27, 170 00 Prague 7, uoou.gov.cz, or to the supervisory authority where you live.
8. Security
We use appropriate technical and organisational measures. The website is served over HTTPS. No security measure is absolute; we will notify you of a personal-data breach where required by law.
9. Changes to this policy
We may update this policy when the Game, advertising services or legal requirements change. We will publish the current version at https://micinkagames.party and notify you of material changes as required by law. This general statement alone will not activate new server accounts, progress synchronisation or payments; before enabling them, we will provide specific information and required settings.
10. Contact
Samir Jahjefendič (sole trader / OSVČ), company ID (IČO) 03187951, Nová ulice 716/51, 664 47 Střelice, Czech Republic, e-mail {{EMAIL}}, phone {{PHONE}}, website https://micinkagames.party.