Privacy Policy (GDPR / DSGVO)
Last updated: February 23, 2026
This Privacy Policy explains how Shelter Fall processes data when you use the iOS app. We aim to keep data processing minimal and transparent.
1. Controller (Verantwortlicher)
Controller for Shelter Fall:
Michel Nguyen
Email: mip@gmx.biz
2. What We Collect
Data we process directly
- Gameplay progress and settings stored on your device (for example UserDefaults and local save files).
- Optional iCloud sync data, if you use iCloud on your Apple device and sync is enabled.
Data we do not collect directly
We do not require account registration and we do not run our own analytics or profile database for Shelter Fall users.
In-app purchase processing
The optional "Remove Ads" purchase is processed by Apple (StoreKit/App Store). We do not receive your payment card or bank details.
3. Advertising, UMP Consent, ATT, and IDFA
If ads are enabled (no "Remove Ads" purchase), Shelter Fall uses Google AdMob.
- For users in the EEA, UK, and Switzerland, the app uses Google's User Messaging Platform (UMP) to show consent messages and collect/update privacy choices.
- On iOS, the app requests tracking permission via Apple's App Tracking Transparency (ATT) before accessing IDFA.
- If ATT is denied, the app does not access IDFA. Ads may still be shown in a non-personalized/contextual way.
- You can review consent choices in the app: Settings > Privacy & Ads > Review Ad Consent.
4. Categories of Data Processed by Ad Providers
When ads are shown, Google AdMob may process data such as:
- Identifiers (including IDFA only if ATT permission is granted)
- IP address and approximate location derived from IP
- Device and app information (model, OS, app version)
- Ad performance and interaction events (impressions, clicks)
5. Legal Bases under GDPR (Art. 6 DSGVO)
- Art. 6(1)(a) GDPR (consent): Personalized advertising and any tracking that requires consent.
- Art. 6(1)(b) GDPR (performance of contract): Core gameplay and local save functionality.
- Art. 6(1)(f) GDPR (legitimate interests): Basic app security/stability and non-personalized ad delivery where applicable.
You can withdraw consent at any time with effect for the future (see section 8).
6. Third-Party Recipients
7. International Transfers
Some processing by third-party providers (especially Google) may occur outside the EU/EEA, including the United States. Such providers state they use appropriate transfer mechanisms (for example Standard Contractual Clauses) where required by law.
8. Your Rights under GDPR / DSGVO
If GDPR applies to you, you may have rights to access, rectification, erasure, restriction, objection, and data portability, plus the right to withdraw consent at any time.
- Withdraw ad consent in-app: Settings > Privacy & Ads > Review Ad Consent
- Change ATT setting in iOS: Settings > Privacy & Security > Tracking
- For Google-processed ad data, rights can also be exercised via Google according to their policy.
You also have the right to lodge a complaint with your competent data protection supervisory authority.
9. Data Retention
- Local game data remains on your device until you delete the app or reset app data.
- Retention periods for ad-related data are determined by Google according to their policies.
10. Children's Privacy
Shelter Fall is not directed to children under 13. If you believe that personal data of a child has been processed via third-party services in connection with the app, contact us and we will review the request.
11. Changes to This Policy
We may update this policy to reflect legal, technical, or product changes. The "Last updated" date at the top shows the current version.
12. Contact
If you have privacy questions, contact: mip@gmx.biz