App Privacy Policy

This policy applies exclusively to the Cosmo Cleaner app. Information about our website is provided in the separate website privacy policy.

Controller

The controller for data processing in the “Cosmo Cleaner” app is:

1. Overview

Cosmo Cleaner is an arcade game for iOS. We operate no user account and no server of our own. Game progress and settings are stored locally on your device and – if you are signed in to iCloud – additionally synchronised between your devices via Apple iCloud (section 6). Personal data is processed only to the extent described here – essentially through the services used from Google (advertising) and Apple (app distribution, in-app purchases, Game Center, iCloud).

2. Advertising: Google AdMob

To finance the free app we show advertising via Google AdMob, a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. To deliver and measure ads, AdMob may process data including advertising identifiers (e.g. Apple IDFA), IP address, device and usage information and approximate location data.

The Google Mobile Ads SDK may additionally collect technical diagnostic information. This includes non-user-related crash logs concerning SDK-related errors and performance data such as app launch time, hang rate, or energy usage. Google may use this information to diagnose issues, analyse and improve the SDK and advertising performance, and support advertising features. We do not use a separate analytics or crash-reporting SDK.

Ad requests are aligned with your choice in Google UMP and the consent signals made available by Google. Personalised ads are shown only with your consent. If legally required consent for storing or accessing information on your device or for advertising data processing has not been given, the app requests only the form of advertising permitted by those signals – which may be limited ads – or does not request an ad.

According to Google, even non-personalised ads may use cookies or mobile identifiers for purposes such as frequency capping and aggregated reporting. They are therefore not automatically exempt from consent requirements.

Where consent is required, the legal bases are Art. 6 (1) (a) GDPR and section 25 (1) TDDDG. A required consent is not replaced by a legitimate-interest assessment. Access to or storage of information that is strictly necessary may fall under section 25 (2) TDDDG; any further processing additionally requires its own legal basis under the GDPR.

3. Consent management (Google UMP)

To obtain and manage your advertising consent we use the Google User Messaging Platform (UMP). On first launch – and for users in the EEA, the United Kingdom and Switzerland – you are offered a choice to consent to or decline data processing by us and our advertising partners. You can change your decision at any time via the privacy/advertising settings in the app.

4. App Tracking Transparency (IDFA)

On iOS we additionally ask you via Apple’s App Tracking Transparency (ATT) whether the advertising identifier (IDFA) may be used for cross-device personalisation. If you decline, the IDFA is not read; ad measurement then takes place in aggregated, privacy-friendly form via Apple’s SKAdNetwork. You can revoke this permission at any time in the iOS settings under “Privacy & Security → Tracking”.

5. Apple services

5.1 App distribution

The app is distributed via the Apple App Store (Apple Inc. and Apple Distribution International Ltd., Ireland). When you download and use the app, Apple processes data under its own responsibility.

5.2 In-app purchases

Purchases (e.g. “ad-free”, credits) are handled entirely through Apple’s in-app purchase system (StoreKit). Payment data is processed exclusively by Apple – we receive no card or bank details, only the information whether a purchase was made or restored. Legal basis: Art. 6 (1) (b) GDPR.

5.3 Game Center

If you use Game Center, leaderboards and achievements are managed through Apple’s GameKit. Apple thereby processes your Game Center player ID and, where applicable, your alias. Use is optional and is based on your consent (Art. 6 (1) (a) GDPR) and Apple’s own responsibility.

6. Local storage and iCloud

Game progress, settings and your chosen consent status are stored locally on the device – essentially via Apple UserDefaults and, for the abuse lock on creator codes, additionally in your device’s Keychain. We operate no server of our own and do not receive this data.

If your device is signed in to iCloud, the app additionally synchronises a small part of this data between your devices via Apple’s iCloud key-value store, so that progress and purchases survive a change of device. Only the following is synchronised: credits earned and spent, unlocked ships and level unlocks. To prevent several devices from overwriting one another, the app assigns each device a randomly generated technical identifier; it is created on the device and allows no conclusions about your person.

This data resides in your own iCloud account with Apple; we have no access to it. If you are not signed in to iCloud, no synchronisation takes place and storage remains purely local. Legal basis: Art. 6 (1) (b) GDPR.

Locally stored data is removed when you delete the app. Values held in iCloud and Keychain entries may outlast uninstallation; you can remove them via the iCloud or device settings of your Apple account.

7. Recipients and third-country transfers

Recipients of personal data are the Google and Apple services named above and – within AdMob – the advertising partners you have approved. Depending on the service, Google and Apple act under their own responsibility. Their privacy information is available in the Google Privacy Policy and the Apple Privacy Policy. This may involve transfers to third countries, in particular the USA. Google and Apple state that they rely on applicable transfer mechanisms, including adequacy decisions such as the EU-US Data Privacy Framework where applicable and EU standard contractual clauses. Details of the safeguards and data-protection commitments are available through the linked privacy information. The named partners are expected to protect personal data in accordance with applicable data-protection law and the privacy commitments applicable to their services.

8. Retention

We ourselves store no personal data in an app backend. Game values held in your iCloud remain there until you remove them via your Apple account or device settings. Google determines retention periods according to the purpose and type of data; details are provided in Google’s retention policy. Apple retains personal data for as long as necessary for the purposes described or as required by law; details are provided in Apple’s Privacy Policy.

9. Withdrawing consent

• Advertising consent: in the app via the privacy/advertising settings.
• Tracking (IDFA): in the iOS settings under “Privacy & Security → Tracking”.

10. Your rights

You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and objection to processing based on legitimate interests (Art. 21). Consent once given can be withdrawn at any time with future effect (Art. 7 (3)).

You may also lodge a complaint with a data protection supervisory authority (Art. 77 GDPR). The authority competent for us is the State Commissioner for Data Protection and Freedom of Information of North Rhine-Westphalia (ldi.nrw.de); you may equally contact the authority of your country of residence.

For all privacy matters: info@cosmocleaner.de

11. Changes

We adapt this app privacy policy when the app or the legal situation changes. The version published at this address applies.

Die deutsche Fassung ist maßgeblich. The German version prevails.