Fleon Labs

Data Controller

The data controller responsible for your personal information is:

Information We Collect

Hue Rings collects certain information to improve your gaming experience, provide analytics, and support app functionality. This information includes:

Device Information: Device ID and device model to identify unique installations
Game Center ID: Your Game Center identifier (which uses Apple's random identifier system separate from your Apple Account) to support leaderboards and achievements
Game Usage Data: Information about how you interact with the game, including levels played, progress, and gameplay patterns
Analytics Data: App performance metrics, session duration, and feature usage to help us improve the game
Crash Reports: Technical diagnostic information when the app crashes to help us fix bugs and improve stability

Legal Basis for Processing

Under GDPR, we process your personal data based on the following legal grounds:

Consent: For personalized advertising through Google AdMob, we collect your explicit consent through our consent management platform
Legitimate Interest: We process analytics data, crash reports, and game usage data based on our legitimate interest in improving app performance, fixing bugs, and enhancing user experience
Contractual Necessity: Processing game progress and Game Center data is necessary to provide the gaming services you have requested

How We Use Your Information

The information we collect is used solely to enhance your gaming experience. Specifically, we use this data to:

Analyze game performance and identify areas for improvement
Debug technical issues and fix crashes
Understand player behavior to design better puzzles and features
Track game progression and save your achievements
Improve overall app stability and performance

Google AdMob and Advertising

Hue Rings uses Google AdMob to display rewarded advertisements. When you choose to watch ads to earn rewards, Google AdMob may collect and process the following information:

Device Identifiers: Advertising ID and other device-specific identifiers for delivering personalized ads
IP Address: Used to estimate your general location (not precise location)
Ad Interactions: Information about ads you view, tap, or interact with
Performance Data: App launch time, battery usage, and other metrics to evaluate ad performance
Technical Information: Crash logs and diagnostic data related to ad serving

Consent Management: For users in the European Economic Area (EEA), United Kingdom, and Switzerland, we use a certified Consent Management Platform (CMP) that complies with the IAB Transparency and Consent Framework. You will be asked to provide consent for personalized advertising when you first launch the app. You can withdraw or modify your consent at any time through the app settings.

Google's use of advertising data is governed by Google's Privacy Policy. You can control ad personalization through your device settings or within the app.

Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected:

Game Progress and Settings: Stored locally on your device until you delete the app or clear app data
Analytics and Usage Data: Retained for up to 24 months, then automatically deleted or anonymized
Crash Reports: Retained for up to 12 months or until the issue is resolved, whichever is shorter
Advertising Data: Managed by Google AdMob according to their retention policies (typically 12-26 months)
Game Center Data: Managed by Apple according to their policies until you reset your Game Center identifier

If you request deletion of your data, we will delete or anonymize your information within 30 days, except where we are required to retain it for legal obligations.

International Data Transfers

Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA), including the United States, where our service providers (such as Google AdMob) operate.

When we transfer your data internationally, we ensure appropriate safeguards are in place:

Standard Contractual Clauses (SCCs): We use EU-approved Standard Contractual Clauses with our service providers to ensure your data is protected
Adequacy Decisions: We may transfer data to countries that the European Commission has determined provide adequate protection
Google AdMob: Google LLC complies with the EU-U.S. Data Privacy Framework and uses Standard Contractual Clauses

Data Storage and Security

Game progress, settings, and preferences are stored locally on your device. Analytics and usage data is transmitted securely to our servers and third-party service providers (Google AdMob). We take reasonable measures to protect your information from unauthorized access or disclosure.

Data Sharing

We do not sell your personal information. We only share data with:

Google AdMob: For advertising purposes as described above
Analytics Providers: To help us understand app usage and improve performance
Apple Game Center: To enable leaderboards and achievements functionality

Your Privacy Rights

Under GDPR and other privacy laws, you have the following rights regarding your personal data:

Right of Access: You can request a copy of the personal data we hold about you
Right to Rectification: You can request that we correct inaccurate or incomplete data
Right to Erasure ("Right to be Forgotten"): You can request deletion of your personal data
Right to Restrict Processing: You can request that we limit how we use your data
Right to Data Portability: You can request a copy of your data in a structured, machine-readable format
Right to Object: You can object to processing based on legitimate interests
Right to Withdraw Consent: You can withdraw your consent for advertising and data processing at any time through the app settings or by contacting us
Right to Lodge a Complaint: You can file a complaint with your local data protection authority if you believe your rights have been violated

To exercise any of these rights, please contact us at privacy@fleon.com. We will respond to your request within 30 days.

Additional Options:

Manage ad personalization through your device settings (iOS: Settings > Privacy > Tracking)
Reset your advertising identifier in your device settings
Reset your Game Center identifier in Settings > Game Center
Modify or withdraw consent for personalized ads through the app settings

Automated Decision-Making

We do not use automated decision-making or profiling that produces legal effects or similarly significantly affects you. Any analytics we perform are used solely for improving game design and user experience, and do not result in automated decisions about you.

Children's Privacy

Hue Rings is designed to be appropriate for all ages. However, if you are under 13 years of age (or the applicable age in your jurisdiction), please have a parent or guardian review this privacy policy with you. We do not knowingly collect personal information from children without parental consent where required by law.

Changes to This Policy

We may update this privacy policy from time to time to reflect changes in our practices or for legal, operational, or regulatory reasons. Any changes will be reflected on this page with an updated revision date. We encourage you to review this policy periodically.

Contact Us and Supervisory Authority

If you have any questions about this privacy policy, wish to exercise your privacy rights, or have concerns about how we handle your data, please contact us at privacy@fleon.com

If you are located in the EEA or UK and believe we have not adequately addressed your concerns, you have the right to lodge a complaint with your local data protection supervisory authority.

Last updated: February 15, 2026