Lucky Eggs Privacy Policy

This policy explains what data is collected when you play Lucky Eggs: Sand Puzzle (“Lucky Eggs” or “the game”) on iPhone, iPad or Android, why, who receives it, and what you can do about it. The game is published by ALBERT TEKNOLOJİ A.Ş. (“Albert”, “we”, “us”).

Contents

1. Who we are
2. What we collect
3. How we use it
4. Legal bases
5. Who receives data
6. Your choices
7. How long we keep data
8. International transfers
9. Your rights and requests
10. Children
11. US state privacy rights
12. Security
13. Changes to this policy
14. Contact us
15. Türkçe özet

1. Who we are

The data controller for Lucky Eggs is:

ALBERT TEKNOLOJİ A.Ş.
Asmalı Mescit Mah. Kallavi Sk. No:1-1
Beyoğlu/İstanbul 34430, Türkiye
Email: albertteknoloji@gmail.com

Use the same email address for any privacy question or request, including requests about your data (see section 9).

2. What we collect

Lucky Eggs has no sign-up and no text fields, so we never ask you to type in personal details. The data below is collected automatically by the game and by the partner software development kits (SDKs) built into it, listed in section 5.

Device and advertising identifiers

• Your device’s advertising identifier: the IDFA on iPhone and iPad (only if you allow tracking) or the Google advertising ID on Android (unless you have deleted it in your device settings).
• The IDFV (an identifier Apple gives each app publisher on iPhone and iPad).
• The Firebase installation ID and the Google Analytics app instance ID, which identify this installation of the game.
• The AppsFlyer ID, a random ID AppsFlyer creates when the game is installed.
• Identifiers that our ad partners create or read for your device or installation (for example, on Android some ad partners may read the Android ID).

Gameplay and app activity

Events such as the game being opened, levels started, completed, failed, restarted or skipped, stars earned, how much sand was left, undo and hint use, cosmetic items bought or equipped with in-game stars, the shop and Remove Ads screens being opened, and whether you accepted or declined in-game prompts. We also record whether reminder notifications were allowed, scheduled or opened, and which game settings were applied remotely.

Ad data

Which ads were requested, loaded, shown or clicked, the ad format (banner, interstitial or rewarded video) and placement, the ad network that served it, ad loading errors, and the revenue an ad earned.

Purchase records

If you buy Remove Ads, we record the product, price, currency, the store’s transaction ID and the level you were on. Payment is handled entirely by Apple (App Store) or Google (Google Play): we never receive your card number, bank details or billing address.

Approximate location

Like any internet service, our partners receive your device’s IP address when the game connects to them, and use it to estimate an approximate location (such as country, region or city). The game does not ask for location permission and does not use GPS or other precise location.

Crash and diagnostic data

Crash reports and error messages, app performance data (for example load times and failures), and technical information such as device make and model, operating system version, language, time zone, screen size, network type and app version.

Your privacy choices

Whether you allowed tracking on iPhone or iPad, whether you are in a region where we ask for consent, and the consent choices you made there, so the game and our partners can respect them.

What we do not collect

• Your name, email address, phone number or postal address (unless you email us yourself).
• Your contacts, photos, videos, files, messages or anything you create.
• Your precise location.
• Payment card or bank details.

Data that stays on your device

Your level progress, stars, cosmetics, sound settings and whether you own Remove Ads are stored on your device. They are not sent to us. If you delete the game, this data is deleted from your device and we cannot restore it for you (on Android, your device’s own Google backup may restore it if you have backups turned on). Remove Ads itself can always be restored from the store (Settings → Restore purchases). Reminder notifications are scheduled on your device; we do not collect a push notification token.

3. How we use data

• To run the game and its features, including delivering and restoring your Remove Ads purchase and applying game settings we change remotely (for example, how often ads appear).
• To show ads that keep the game free, including optional reward videos, to limit how often you see them, and, where you allow it, to personalise them.
• To measure and attribute (through AppsFlyer): to know which ads or campaigns led to an install, and to measure how our own ads for the game perform.
• To understand and improve the game, for example which levels are too hard, where players stop, and how changes affect play.
• To find and fix crashes and bugs.
• To prevent fraud and keep things secure, for example detecting fake installs, fake ad clicks and purchase abuse.
• To comply with the law and respond to lawful requests.

We do not make decisions about you based solely on automated processing that have legal or similarly significant effects. Our ad partners may use automated systems to choose which ad to show you.

4. Legal bases

If you are in the European Economic Area (EEA), the United Kingdom or Switzerland, we rely on these legal bases under the GDPR (and the UK GDPR or Swiss law where they apply):

• Consent for personalised advertising, for tracking across apps and websites owned by other companies for advertising, and for using your advertising identifier for these purposes. You give or refuse it on the consent screen and, on iPhone and iPad, through the tracking permission. You can withdraw it at any time (see section 6). Install attribution is handled separately, as explained below.
• Legitimate interests for game analytics, crash reporting, remote settings, ad frequency limits, non-personalised advertising, install attribution and measuring our own advertising, and fraud prevention. Our interests are to keep the game working, improve it, know which of our ad campaigns bring players to the game, pay our advertising partners correctly and keep the game free and secure. You can object to this processing (see section 9).
• Performance of a contract for providing the game and delivering and restoring the Remove Ads purchase.
• Legal obligation where we must keep or disclose information by law.

Install attribution if you do not consent

AppsFlyer measures installs and in-game events (such as completed levels and purchases) for every player, including players in the EEA, the UK and Switzerland who do not consent on the consent screen. For those players we rely on the legitimate interests described above. AppsFlyer then still receives the identifiers described in section 2: on Android, this includes your advertising ID unless you have deleted it; on iPhone and iPad, it includes the IDFV, and the IDFA only if you allowed tracking. We tell AppsFlyer that you did not consent, and AppsFlyer can pass this choice on to advertising platforms that support it, but this does not stop AppsFlyer from receiving these identifiers. You can object at any time by emailing us (see section 9). To stop your advertising ID being sent from then on, delete it in your device settings (see section 6) or uninstall the game.

Türkiye

If you are in Türkiye, we process your personal data in line with the Law on the Protection of Personal Data No. 6698 (KVKK). We rely on the grounds in Article 5 of the KVKK, in particular processing that is necessary to perform a contract with you and for our legitimate interests, provided it does not harm your fundamental rights and freedoms, and on your explicit consent where the law requires it (for example, the tracking permission on iPhone and iPad). Transfers of data abroad are carried out in line with Article 9 of the KVKK.

5. Who receives data

We do not sell your data for money. We share it only with the service providers and partners below, whose SDKs are built into the game, and each of them handles data under its own privacy policy. Some act on our behalf (for example Firebase and AppsFlyer); the ad networks also use the data for their own advertising purposes.

• Google (Firebase, Google Analytics, AdMob, User Messaging Platform, Google Cloud) Google Analytics for Firebase (game analytics), Firebase Crashlytics (crash reports), Firebase Remote Config (remote game settings), Google AdMob (one of the ad networks we use), Google’s User Messaging Platform (the consent screen in the EEA, UK and Switzerland), and Google Cloud, where we keep a copy of our analytics data for our own analysis. Google Privacy Policy · How Google uses data from apps · Firebase privacy
• AppLovin (AppLovin MAX) Our main ad platform. It runs the auction between ad networks, serves ads itself, and shows the consent flow and the iOS tracking permission when you first open the game. AppLovin Privacy Policy
• Unity Ads (Unity Technologies) Ad network, through AppLovin MAX. Unity Game Player and App User Privacy Policy
• Mintegral Ad network, through AppLovin MAX. Mintegral Privacy Policy
• Pangle (TikTok Ad Network / ByteDance) Ad network, through AppLovin MAX. Pangle is run by ByteDance and TikTok group companies, and the company responsible for your data depends on where you live: TikTok Technology Limited (Ireland) and TikTok Information Technologies UK Limited for people in the EEA, the UK and Switzerland; TikTok USDS Joint Venture LLC in the United States; and TikTok Pte. Ltd. (Singapore) in most other regions. Pangle’s software in the game also includes parts of the TikTok Business SDK. EEA, UK and Switzerland: TikTok Ad Network Privacy Policy · United States · Other regions · Pangle’s list of regional policies
• AppsFlyer Install attribution and measurement. When we promote Lucky Eggs through advertising platforms, AppsFlyer may tell those platforms that an install or an in-game event (such as a completed level or a purchase) happened, so they can measure their ads. AppsFlyer Services Privacy Policy
• Apple (App Store) Distributes the game, processes Remove Ads purchases on iPhone and iPad, and provides the tracking permission. Apple Privacy Policy
• Google Play Distributes the game and processes Remove Ads purchases on Android. It also tells the game how it was installed (install referrer), which is used for attribution. Google Privacy Policy

To avoid showing you ads for apps you already have, an ad network may check on your device whether the advertised app is already installed. On Android, Google’s ad services may also use Android’s Privacy Sandbox features (such as Topics) where available.

We may also disclose data if the law requires it, to protect our rights or the safety of others, or to a buyer or successor if our business or the game is transferred.

How our partners must protect your data

Each partner receives data under an agreement with us that includes data protection terms, such as a data processing agreement and, for transfers out of the EEA, the UK or Switzerland, Standard Contractual Clauses. These terms require the partner to keep the data secure and to process it only as the agreement and applicable data protection law allow. We share data only with partners that are bound in this way to protect it to the same or an equal standard as described in this policy and as required by the App Store and Google Play rules.

6. Your choices

Tracking permission (iPhone and iPad)

When you first open the game, iOS asks whether Lucky Eggs may track your activity across other companies’ apps and websites. The whole game works either way. If you do not allow it, the game and our partners cannot access your IDFA. You can change this at any time in Settings → Privacy & Security → Tracking. Apple explains this in If an app asks to track your activity.

Consent screen (EEA, UK and Switzerland)

If you are in the EEA, the UK or Switzerland, a consent screen asks for your choice when you first open the game. If you do not consent, we do not use your data for personalised advertising, and you may see fewer ads or none. Some processing continues on the basis of our legitimate interests (see section 4):

• Game analytics and crash reports through Google Analytics for Firebase and Firebase Crashlytics. We tell Google Analytics that you did not consent so that it limits its processing.
• Install attribution through AppsFlyer, which still receives device identifiers, including your advertising ID on Android unless you have deleted it (see Install attribution if you do not consent).

The game does not currently have its own privacy settings screen. To change or withdraw your consent, you can:

• delete and reinstall the game so that the consent screen appears again. On Android, if your device restores app data from a backup, clear the game’s storage instead (Settings → Apps → Lucky Eggs → Storage → Clear storage). Either way, this also deletes your progress, which is stored on your device; or
• email us with the identifier described in section 9. We will record your withdrawal or objection and ask AppsFlyer and our ad partners to delete data linked to that identifier where they offer a way to do so. This does not change what the game on your device sends from then on, so also reinstall the game as described above, or turn off tracking or delete your advertising ID as described below.

Turning off tracking on iPhone or iPad, or deleting your advertising ID on Android (see below), stops the game and our partners from using that identifier from then on. It does not change the choice stored from the consent screen, and the other identifiers and the IP-based processing described in section 2 continue.

Advertising ID on Android

You can reset or delete your advertising ID in your device settings (usually Settings → Google → Ads, or Settings → Privacy → Ads). Resetting only replaces it with a new ID, which breaks the link to your past activity; the new ID is still used. Deleting it means apps receive only zeros instead of an ID, so ads can no longer be personalised with it and it can no longer be used for attribution.

Notifications

Reminder notifications are sent only if you allow them, and you can turn them off at any time in your device’s notification settings.

Stopping all collection

Uninstalling the game stops all further collection by the game and its SDKs. Data already sent to us and our partners is kept as described in section 7 unless you ask us to delete it.

Remove Ads and your data

Buying Remove Ads turns off banner and interstitial ads. It does not turn off analytics or crash reporting, and the ad SDKs stay in the game so that optional reward videos remain available.

7. How long we keep data

We keep data only as long as we need it for the purposes in section 3, and then delete or anonymise it:

• Game progress stays on your device until you delete the game.
• Crash reports are kept by Firebase Crashlytics for 90 days.
• Analytics data: Google Analytics keeps event-level data linked to an installation’s identifiers for at most 14 months after your last activity in the game (14 months is the longest retention setting available for our type of Google Analytics account). Aggregated reports that do not identify you may be kept longer.
• Our copy in Google Cloud: Google Analytics also exports each day’s game events to our Google Cloud (BigQuery) account for our own analysis. Each day’s export is deleted automatically 60 days after it is created. Totals we calculate from it do not identify anyone and may be kept longer.
• Firebase installation IDs used for remote settings are kept until they are deleted, for example after a deletion request.
• AppsFlyer and our ad partners keep data for the periods set out in their own privacy policies (for example, AppLovin says it typically keeps data for up to two years).
• Emails you send us are kept for as long as needed to answer you and to keep a record that we handled your request.

8. International transfers

We are based in Türkiye, and our partners process data in other countries, including the United States, the European Union, Israel, Singapore and other countries where they or their service providers operate. When data from the EEA, the UK or Switzerland is transferred to a country that does not have an adequacy decision, the transfer is protected by safeguards such as the European Commission’s Standard Contractual Clauses or, where a partner is certified, the EU-U.S. Data Privacy Framework, as provided in our partners’ data protection terms. Transfers from Türkiye are carried out in line with Article 9 of the KVKK. You can contact us for more information about these safeguards.

9. Your rights and how to make a request

Depending on where you live, you may have the right to:

• access your data and get a copy of it;
• have inaccurate data corrected;
• have your data deleted;
• restrict or object to processing, including processing based on legitimate interests and for advertising;
• receive your data in a portable format;
• withdraw consent at any time, without affecting processing that happened before;
• complain to a data protection authority, such as the authority in your EU country, the UK Information Commissioner’s Office, or in Türkiye the Personal Data Protection Board (KVKK). Under Article 11 of the KVKK you also have the rights listed there, including learning whether your data is processed, who it is transferred to, and requesting correction or deletion.

How to ask

Email albertteknoloji@gmail.com with the subject “Lucky Eggs privacy request”. Please tell us what you want (for example, a copy or deletion), whether you play on iPhone, iPad or Android, and include an identifier so we can find data linked to your device, because we do not know your name or email:

• Android: your advertising ID, found in Settings → Google → Ads (or Settings → Privacy → Ads). Send it before you reset or delete it. If you bought Remove Ads, your Google Play order number (it starts with “GPA.”) also helps.
• iPhone and iPad: iOS does not show your advertising identifier in Settings, and if you did not allow tracking we never received it. Tell us your device model, your country and roughly when you installed and played the game, and we will look for matching data and explain what we can do.

When we receive a deletion request, we delete the data we control that we can link to the details you give us, and ask AppsFlyer and our ad partners to delete data they received from the game where they offer a way to do so. Analytics data we cannot link to you is still deleted automatically at the end of the periods in section 7. We may ask you to confirm details before acting on a request. We reply within 30 days. If a request is complex and the law allows more time, we will tell you within those 30 days why we need longer. Making a request is free.

You can also contact our partners directly using the links in section 5.

10. Children

Lucky Eggs is not directed to children under 13, and we do not knowingly collect personal data from children under 13. If you believe a child under 13 has played the game and data about them was collected, please contact us and we will take steps to delete it. In some countries, people under 16 need a parent’s permission to agree to personalised advertising; if that applies to you, please ask a parent before giving consent, or simply choose not to consent.

11. US state privacy rights

If you live in a US state with a consumer privacy law, such as California, you may have the right to know what personal information we collect and share, to access, correct and delete it, and to opt out of the “sale” or “sharing” of personal information and of targeted advertising. We will not treat you differently for using these rights.

The game collects the categories described in section 2: identifiers (device and advertising IDs, IP address), internet or other electronic activity (gameplay and ad interactions), commercial information (Remove Ads purchase records), approximate geolocation, and inferences our ad partners may draw about your interests. We do not collect sensitive personal information. We do not sell personal information for money, but making device identifiers and ad data available to ad networks for targeted advertising may count as “selling” or “sharing” under some state laws.

The game does not currently have an in-game “Do Not Sell or Share” setting. To opt out:

• on iPhone or iPad, turn off tracking for Lucky Eggs (Settings → Privacy & Security → Tracking), so that the game and our partners can no longer access your IDFA;
• on Android, delete your advertising ID (see section 6). Resetting it is not enough, because it only replaces the ID with a new one; and
• email us with the subject “Do Not Sell or Share” and include the details described in section 9 (on Android, your advertising ID, copied before you delete it), so that we can identify data linked to your device. We will pass your request on to AppsFlyer and our ad partners where they offer a way to do so.

After you opt out, the other identifiers and IP-based data described in section 2 may still be used for non-personalised ads, measurement, analytics and fraud prevention. To make any other request, follow section 9. If we decline your request, you can appeal by replying to our answer.

Consumers under 16. The game does not ask for your age, so we do not know whether a player is under 16, and we do not knowingly sell or share the personal information of consumers under 16. If you are under 16, or the parent of a player under 16, please turn off tracking or delete the advertising ID as described above, and email us. We will then treat that device as opted out and pass the request on to our partners where they offer a way to do so.

12. Security

We protect the data we can access with access controls on our accounts with Google, AppsFlyer and our ad partners, and we rely on the security measures of those partners and of Apple and Google. The game only allows encrypted connections: on iPhone and iPad it keeps Apple’s App Transport Security in place, and on Android it blocks unencrypted (plain HTTP) connections on every supported Android version. This also applies to our partners’ software inside the game, so data sent from the game travels over encrypted (HTTPS) connections. No method of transmission or storage is completely secure, but we work to protect your data and will act promptly if we learn of a security issue.

13. Changes to this policy

We may update this policy, for example when we add or remove a partner. We will post the new version on this page and change the effective date at the top. If a change is significant, we will take reasonable steps to let you know, for example in the game’s store listing.

14. Contact us

ALBERT TEKNOLOJİ A.Ş., Asmalı Mescit Mah. Kallavi Sk. No:1-1, Beyoğlu/İstanbul 34430, Türkiye
Email: albertteknoloji@gmail.com

Help with the game, Remove Ads and restoring purchases: Lucky Eggs Support. Terms: Terms and Conditions.