Privacy Policy

Data Controller

The data controller responsible for your personal information is:

Fleon Labs
Email: privacy@fleon.com

Information We Collect

Our data practices differ by platform:

• iOS: We collect data only as needed to operate the game's multiplayer functionality, including maintaining your player profile, matchmaking, game progress, and leaderboards. We do not use Google AdMob or collect data for advertising on iOS.
• Android: We collect information to provide multiplayer functionality, prevent fraud, serve advertisements, and improve the game. This includes the information described below and the Google AdMob data described in the advertising section.

Depending on your platform and the features you use, this information may include:

• 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 multiplayer matchmaking, leaderboards, achievements, and to maintain your profile across sessions
• Purchase Information: Records of in-game purchases to verify transactions, prevent fraud, and provide purchased content
• Game Usage Data: Information about how you interact with the game, including matches played, game 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 (Android only): For personalized advertising through Google AdMob, we collect your explicit consent through our consent management platform
• Contractual Necessity: Processing your Game Center ID, game progress, and multiplayer functionality is necessary to provide the gaming services you have requested
• Legitimate Interest: We process analytics data, crash reports, and purchase verification based on our legitimate interest in improving app performance, fixing bugs, preventing fraud, and enhancing user experience
• Legal Obligation: We may process purchase data to comply with financial record-keeping and tax requirements

How We Use Your Information

The information we collect is used solely to provide multiplayer functionality, prevent fraud, and enhance your gaming experience. Specifically, we use this data to:

• Enable multiplayer matchmaking and connect you with other players
• Process and verify in-game purchases
• Detect and prevent fraudulent transactions and abuse
• Track game progression and save your achievements
• Maintain leaderboards and competitive rankings
• Analyze game performance and identify areas for improvement
• Debug technical issues and fix crashes
• Understand player behavior to design better gameplay and features
• Improve overall app stability and performance

Google AdMob and Advertising (Android Only)

The Android version of Sheeping Around uses Google AdMob to display advertisements. Google AdMob may collect and process the following information on Android:

• 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 Android 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 and on our servers until you delete your account or request data deletion
• Purchase Records: Retained for up to 7 years to comply with financial record-keeping requirements and for fraud prevention
• 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 (Android only): 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 (such as purchase records for tax compliance).

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 servers and, for Android, 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 both locally on your device and on our secure servers to enable multiplayer functionality. User data and purchase information are transmitted securely using encryption to our servers. On Android, analytics and advertising-related data may also be transmitted to third-party service providers, including Google AdMob. We implement industry-standard security measures to protect your information from unauthorized access, disclosure, alteration, or destruction.

Data Sharing

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

• Google AdMob (Android only): For advertising purposes as described above
• Apple Game Center: To enable multiplayer matchmaking, leaderboards, and achievements functionality
• Apple App Store: To process and verify in-game purchases
• Analytics Providers: To help us understand app usage and improve performance (data is anonymized where possible)
• Cloud Service Providers: To host game servers and store data securely
• Legal Authorities: When required by law or to protect our rights and prevent fraud

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 (subject to legal record-keeping requirements for purchases)
• 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:

• On Android, manage ad personalization through your device settings
• On Android, reset your advertising identifier in your device settings
• Delete your account through the app settings to remove your game progress and profile
• Reset your Game Center identifier in Settings > Game Center
• Request purchase history through the App Store
• On Android, modify or withdraw consent for personalized ads through the app settings

Multiplayer and User Interactions

Sheeping Around is a multiplayer game. When you play matches, other players may see:

• Your Game Center username and avatar
• Your game statistics and ranking
• Your in-game level and progression

This information is necessary for multiplayer functionality and cannot be hidden while playing online matches. You can control your Game Center profile settings through your iOS device settings.

Fraud Prevention

We take fraud prevention seriously. We monitor purchase patterns, user behavior, and gameplay to detect and prevent:

• Fraudulent transactions and chargebacks
• Account sharing and unauthorized access
• Cheating and exploitation of game mechanics
• Abuse of in-game currency or purchased items

If we detect suspicious activity, we may temporarily suspend access to your account while we investigate. We process this data based on our legitimate interest in preventing fraud and maintaining a fair gaming environment.

Automated Decision-Making

We use automated systems for the following purposes:

• Matchmaking: Automated algorithms match you with other players based on skill level and availability
• Fraud Detection: Automated systems flag suspicious transactions or behavior for review

These automated decisions do not produce legal effects. If you believe an automated decision was made in error (such as an incorrect fraud flag), you can contact us for manual review.

Children's Privacy

Sheeping Around 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.

Parents and guardians should be aware that multiplayer games involve interaction with other players online. We recommend supervising children's gameplay and configuring appropriate Game Center restrictions through iOS parental controls.

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.