Legal
Privacy Policy
Last updated: July 2, 2026
1. Data Controller
This Privacy Policy applies to the mobile applications and the website (www.orbitsparrowgames.com) operated by Orbit Sparrow Games("we", "us", "the company"). We act as the data controller under the EU General Data Protection Regulation (GDPR) and the Turkish Personal Data Protection Law (KVKK, Law No. 6698).
Location: Istanbul, Türkiye
Contact: hello@orbitsparrow.com
2. Data We Collect and Purposes
2.1 Automatically Collected Data (All Games)
| Data | Purpose | Processor |
|---|---|---|
| Advertising ID (IDFA / GAID) | Personalized ad delivery | Google AdMob |
| Device info (model, OS, language) | Debugging, analytics | Firebase Analytics |
| IP address (anonymized) | Regional content, security | Firebase |
| In-game behavior data | Game balancing, analytics | Firebase Analytics |
| Crash logs & diagnostics (linked to an anonymous user ID) | Stability and crash reporting | Firebase Crashlytics |
| Anonymous device token | Identifying your device for cloud save (see 2.2) | Firebase Authentication |
2.2 Cloud Save Data
Your game progress — including virtual currency balances, unlocked items and cosmetics, and season / battle pass progress — is stored in Google Firebase Cloud Firestore, linked to your anonymous user ID. This allows your progress to be restored after you reinstall the game or switch devices. This data is not linked to your name, email or any other directly identifying information. You can request deletion of your cloud save data at any time (see "Your Rights" below).
2.3 In-App Purchases
Our games offer optional in-app purchases (such as virtual currency packs and ad removal). Payments are processed entirely by Google Play (or the Apple App Store on iOS) under their own privacy policies — we never receive your payment card or billing details. We do receive purchase records (product ID and transaction status) so we can deliver the purchased items, restore them later, and measure purchases in aggregate through Firebase Analytics.
2.4 User Accounts
We currently use anonymous authentication only and do not collect any email address or username. If we introduce optional user accounts in the future, providing an email or username will be voluntary, and this policy will be updated accordingly.
2.5 Contact Form (Website)
| Data | Purpose | Processor |
|---|---|---|
| Name, email, message | Responding to your inquiry | Resend (email service) |
3. Legal Bases for Processing (GDPR)
For users in the European Economic Area (EEA), the UK and Switzerland, we rely on the following legal bases under Article 6 of the GDPR:
- Consent (Art. 6(1)(a)) — personalized advertising, optional analytics, and the use of cookies or local storage where consent is legally required.
- Performance of a contract (Art. 6(1)(b)) — providing the game and the account features you request.
- Legitimate interests (Art. 6(1)(f)) — security, fraud prevention, core functionality and aggregate analytics.
- Legal obligation (Art. 6(1)(c)) — retention required by applicable law.
4. Third-Party Services
The following third-party services may process data under their own privacy policies:
- Google AdMob — policies.google.com/privacy
- Google Firebase (Analytics, Crashlytics, Auth & Cloud Firestore) — firebase.google.com/support/privacy
- Google Play (in-app purchase payment processing) — policies.google.com/privacy
For more information on how Google uses data from apps that use its advertising services, see How Google uses information from sites or apps that use our services.
5. Children's Privacy
Our games are not directed to children under 13 (or under 16 in the EEA where a higher age applies). We do not knowingly collect personal data from children under these ages. If you believe a child has provided us with personal data, please contact us so we can delete it.
6. iOS — App Tracking Transparency (ATT)
On iOS devices, your explicit consent is requested through Apple's ATT framework before any ad personalization. If you choose not to allow tracking, non-personalized ads continue to be shown and game functionality is not affected.
7. Android — Resetting the Advertising ID
On Android devices, you can reset or disable your Google Advertising ID (GAID) at any time from Settings → Google → Ads.
8. EEA, UK and Switzerland — Consent and Withdrawal
For users in the European Economic Area (EEA), the UK and Switzerland, under Google's EU User Consent Policy our app obtains your explicit consenton first launch for the use of cookies/local storage and for the collection, sharing and use of personal data for ad personalization. This consent is requested through Google's User Messaging Platform (UMP / GDPR consent form) and a record of it is kept.
You can withdraw your consent at any time:
- Reopen the consent form from Settings → Privacy / Privacy options inside the game and change your choices.
- When you withdraw consent, personalized advertising stops; the game keeps working and non-personalized ads may be shown.
- You can also disable ad personalization at the device level (see the iOS ATT and Android Advertising ID sections above).
- You can review and control the ads Google shows you, and turn off ad personalization for your Google account, at adssettings.google.com.
The parties that may collect, receive or use your personal data as a result of your use of our products (Google and the ad networks below) are listed in the "Third-Party Services" section. For consent-related requests: hello@orbitsparrow.com
9. Your Rights
9.1 Under the GDPR (EEA, UK, Switzerland)
- Right of access to your personal data
- Right to rectification of inaccurate or incomplete data
- Right to erasure ("right to be forgotten")
- Right to restriction of processing
- Right to data portability
- Right to object to processing, including for direct marketing
- Right to withdraw consent at any time
- Right to lodge a complaint with a supervisory authority
9.2 Under the KVKK (Turkey, Law No. 6698, Art. 11)
- Learn whether your personal data is processed
- Request information about the processing
- Learn the purpose of processing and whether it is used accordingly
- Know the third parties to whom data is transferred, domestically or abroad
- Request correction of incomplete or inaccurate data
- Request deletion or destruction of your data
- Object to results produced against you solely by automated systems
- Claim compensation for damages arising from unlawful processing
9.3 How to Exercise Your Rights, Including Data Deletion
To exercise any of these rights, contact us at hello@orbitsparrow.com. To delete your cloud save data, email us from within the game's support option or include your request details, and we will delete the Cloud Firestore record linked to your anonymous user ID. We respond to deletion requests within 30 days. Note that because your data is linked only to an anonymous ID, deleting the app's data on your device (or reinstalling) may create a new anonymous ID, and we may need information from your device to locate the old record.
10. International Data Transfers
Some of our processors (such as Google) may process your data on servers located outside the EEA or Turkey. Where this happens, transfers are protected by appropriate safeguards such as the European Commission's Standard Contractual Clauses or an adequacy decision.
11. Data Retention Periods
| Data | Retention period |
|---|---|
| Event-level analytics data | 2 months |
| User- and identifier-level analytics data | 14 months |
| Advertising identifiers | Per ad network policy |
| Cloud save data (game progress) | Until you request deletion |
| Contact form messages | 1 year |
Analytics retention follows our Firebase / Google Analytics data-retention settings. Aggregated reports may be retained longer.
12. Changes to This Policy
Material changes to this policy will be published on this page and the update date will be revised. Please review this page periodically.