1. Summary
| What | Default | Only if… |
|---|---|---|
| Game progress & settings | Stored on your device only | — |
| Account / sign-in | None | — |
| Play statistics (analytics) | Off | you switch them on in Settings |
| Video ads | Never shown on their own | you tap the in-game offer (e.g. the owl) |
| Personalized ads | Off | you consent in the consent screen |
| Purchases | Handled by Apple / Google | you buy something |
| Selling your data | Never. | |
2. Who is responsible
Sergiu Cetulean, operating as Cetulean Games
Via Franco Zorzi 27, 6900 Paradiso, Switzerland
Email: support@cetulean.com
We follow the Swiss Federal Act on Data Protection (FADP/nDSG) and, for players in the EU/EEA and UK, the General Data Protection Regulation (GDPR).
3. Data in our games
3.1 Stored on your device
Your progress, soft currency, collections and settings are saved locally on your phone. We cannot see them. They're deleted when you uninstall the game.
3.2 Purchases
Payments are processed entirely by Apple (App Store) or Google (Google Play). We never see your name, payment card or address. To unlock what you bought and to restore it on a new device, we receive a purchase record from the store (product, date, country, price, and a random app user ID), handled through our purchase service provider (see section 5). Legal basis: performance of a contract (GDPR art. 6(1)(b)).
3.3 Optional rewarded videos
Some games offer an optional short video in exchange for an in-game gift. Videos are provided by Google AdMob and are only requested when you choose to watch one. When a video loads, Google processes device and usage data such as IP address, device type, OS version and, only if you allow it, an advertising identifier.
- In the EU/EEA, UK and Switzerland, we ask for your choice through Google's consent screen before any ad is shown. You can change your choice anytime in the game's settings.
- On iPhone, we only use the advertising identifier if you allow tracking in Apple's prompt. If you decline, the game still works fully and ads are non-personalized.
Legal basis: your consent (GDPR art. 6(1)(a)) for personalized ads and identifiers; legitimate interest (art. 6(1)(f)) for serving a non-personalized video you asked for.
3.4 Optional play statistics
Switched off by default. If you switch them on (Settings → "Share anonymous play data"), the game sends pseudonymous gameplay events, such as "level 12 completed in 80 seconds using 1 hint", to Google Analytics for Firebase, together with a random app-instance ID, device model, OS version, app version and approximate country. We use this only to find levels that are too hard and to fix bugs. We set data retention to the shortest available period (2 months). Legal basis: your consent (GDPR art. 6(1)(a)). Switching it off stops collection immediately.
3.5 Support emails
If you email us, we use your email address and message to answer you. We delete support conversations 12 months after they're resolved. Legal basis: legitimate interest (art. 6(1)(f)).
4. Starthread: game-specific details
| Feature | Data | Shared with |
|---|---|---|
| Progress, Stardust, constellations, settings | On device only | Nobody |
| Owl gift (rewarded video, optional) | See 3.3 | Google AdMob |
| Supporter Pack & lantern tips | See 3.2 | Apple / Google, RevenueCat |
| "Share anonymous play data" (off by default) | See 3.4 | Google Analytics for Firebase |
| Daily Sky | Generated on your phone from the date. Nothing is sent | Nobody |
Other games will be listed here before they're released, with the same level of detail.
5. Service providers
- Apple Inc. and Google LLC / Google Ireland Ltd.: app distribution and payments (their own privacy policies apply).
- RevenueCat, Inc. (USA): purchase validation and restore. Privacy policy
- Google AdMob: optional rewarded videos. How Google uses data in ads
- Google Analytics for Firebase: optional, opt-in play statistics. Firebase privacy
They act as our processors or as independent controllers for their own services. We don't use any other trackers.
6. International transfers
Some providers process data in the USA. Transfers rely on the EU–US and Swiss–US Data Privacy Framework where the provider is certified, or on the European Commission's Standard Contractual Clauses (recognized by the Swiss FDPIC) otherwise.
7. Children
Our games are made for all ages but are not directed specifically at children. We don't knowingly collect personal data from children under 13 (or under the age set by your country). Analytics is off and ads are non-personalized unless consent is given. If you believe a child has shared personal data with us, email us and we'll delete it.
8. Your rights
You can ask us for access to, correction of, or deletion of your personal data. You can also object to processing, ask for a copy in a portable format, and withdraw consent at any time (in-game settings or by email). Write to support@cetulean.com. Because we don't run accounts, please tell us which game and, if possible, the approximate date of a purchase or message so we can find the right data.
You may also complain to a supervisory authority: in Switzerland the Federal Data Protection and Information Commissioner (FDPIC), or the data protection authority in your EU country.
9. This website
games.cetulean.com uses no cookies, no analytics and no third-party content. Fonts are hosted on our own server. Like every web server, ours briefly keeps technical logs (IP address, date, page, browser) for security. These logs are deleted after 14 days.
10. Changes
If we change how our games handle data, we'll update this page and the date at the top before the change takes effect. Important changes will also be noted in the game's update notes.