Privacy Policy

This Privacy Policy explains how Odd Circuit Games ("we", "us") handles information in connection with oddcircuitgames.com (the "Site") and the mobile games we publish (each a "Game"), including Aero: Arrow Puzzle Escape and any other game we release under the Odd Circuit Games name. A current list of our Games is available on our Games page.

We are based in India and publish worldwide. This policy is written to meet our obligations under India's Digital Personal Data Protection Act, 2023 and the Information Technology Act, 2000, and to give you the rights you are entitled to under the law of your own country, wherever you live.

We have written this document to describe what our Site and Games actually do. In short:

• We hold no account for you, and we run no game servers. Your progress and settings are saved on your device.
• Signing in is optional. Our Games are fully playable without signing in to anything.
• Three Google services built into our Games do send information off your device:advertising (section 4), analytics and crash reporting(section 5), and Google Play Games, only if you choose to use it (section 6).
• We never receive your name, email address, or payment details from any of them.

Contact:support@oddcircuitgames.com
Data controller / Data Fiduciary: Odd Circuit Games, India
Grievance Officer: see section 12

1. Who this policy applies to

This policy applies to the Site and to our mobile games distributed through Google Play. Our Games are intended for a general audience aged 13 and over, subject to the higher ages that apply in some countries. They are not directed to children. See section 14.

2. The website

oddcircuitgames.com is a static informational site. It sets no cookies, runs no analytics or tracking scripts, and builds no profile of you. Our hosting provider may keep short-lived server logs (such as IP addresses and requested pages) for security and reliability, as is standard for any website; we do not use those logs to identify you.

The Site includes a contact form. If you send us a message, we will hold what you typed - your name, email address and message - only for as long as it takes to respond to you. You can also simply email us instead, which we prefer.

3. Information stored on your device by our Games

Our Games save your progress and preferences locally, in your device's private app storage. This information is not transmitted to us and we cannot see it. Exactly what is saved varies from Game to Game, but typically includes:

Game progress (stored in a save file, plus one backup copy):

• Level, stage or match progress and results - such as scores, stars earned, best times or move counts, hints used, mistakes made, and whether a level was completed
• In-game currency balance, hints or lives remaining, and any cosmetic items you own or have equipped
• Streaks and records, and the calendar dates those records were set
• Awards or achievements unlocked, and the dates they were unlocked
• Whether you have completed the tutorial and accepted these documents

Preferences (stored using Android's standard preference storage):

• Dark mode, sound, vibration, refresh-rate and control-scheme settings
• Your chosen language
• Whether you have chosen to connect the Game to Google Play Games (see section 6)
• A temporary snapshot of an in-progress level or match, so you can resume it

None of this identifies you. It contains no name, email address, phone number, account identifier, contact list, photos, files, or location data.

This information leaves your device only if you choose to back it up using Android's own device-backup feature, which is controlled by your Google account settings and not by us.

Removing it: you can erase all of it at any time from Settings → Delete My Data inside the Game, or by uninstalling the Game. Both are immediate and permanent.

4. Advertising

Our Games display advertisements provided by Google AdMob. To serve, measure and protect the integrity of those ads, Google collects information directly from your device. This happens through Google's software inside the Game, not through us - we never receive or see this information.

Google's advertising services may collect and process:

• Your device's advertising identifier (Advertising ID / AAID)
• Your IP address, from which an approximate location may be derived
• Device and app information - device model, operating system version, and the app you are using
• Ad interaction data - which ads were shown, viewed, or clicked, and whether a rewarded ad was completed

How Google uses this information is described in:

• Google Privacy Policy
• How Google uses information from sites or apps that use our services

Your advertising choices

• In the European Economic Area, the United Kingdom and Switzerland, we ask for your consent before personalised ads are used. You can change or withdraw that consent at any time from Settings → Privacy options inside the Game. If you decline, you will still see ads, but they will not be personalised.
• On any device, you can reset or delete your advertising identifier, and opt out of ads personalisation, in your Android settings under Settings → Privacy → Ads.

5. Analytics and crash reporting

Our Games use Google Firebase Analytics and Firebase Crashlytics to understand how a Game is played and to find out when it crashes. This is Google's software running inside the Game.

What is collected:

• A Firebase app instance identifier - a random ID generated for your installation of the Game. It is not your name, your Google account, or your advertising ID, and it is reset if you reinstall the Game or clear its data.
• Gameplay events - for example that a level was started, completed or failed, that a hint was used, or that an ad was shown. These describe what happened in the Game, not who you are.
• Device and app information - device model, operating system version, language, approximate region, and the version of the Game.
• Crash diagnostics - if the Game crashes, a technical report describing where in the code it happened and the state of the device at the time.

What is not collected: we do not send your name, email address, contacts, photos, files, precise location, or the contents of your save file.

We use this only to fix bugs and to decide which parts of a Game to improve. Google processes it as our service provider. See the Google Privacy Policy and Firebase privacy information.

6. Google Play Games (optional)

Our Games can connect to Google Play Games, Google's gaming service, so that features such as leaderboards can work. This is optional and a Game is fully playable without it.

If you sign in, Google provides the Game with your Play Games player ID and display name (gamer tag). We show your gamer tag in the Game's settings screen so you can see which account is connected. We do not store it on any server of ours, and we never receive your Google account email address or password - the sign-in is handled entirely by Google.

Turning it off: use the Play Games switch in Settings inside the Game. This stops the Game signing in and stops it sending anything to Play Games.

Please note that this switch controls the Game's use of Play Games - it does not sign you out of Google Play Games itself, which Google manages for your device. To manage or delete your Play Games profile and data, use the Google Play Games app or your Google account settings.

Google's handling of Play Games data is described in the Google Privacy Policy.

7. Purchases

Some of our Games offer optional purchases made with real money - for example, an ad-removal purchase, or a bundle of in-game currency. Not every Game offers every kind of purchase; each Game's store listing and in-game shop describe what is actually on offer. Optional rewarded ads, which you may choose to watch in exchange for a hint or another in-game benefit, are separate from these purchases and remain available either way.

Purchases are processed entirely by Google Play. We do not see, receive, or store your payment card, billing address, or any other payment information. Google tells our app only whether a purchase succeeded.

The only thing recorded on your device as a result is a small entitlement flag or balance - for example, that ads are removed, or how much in-game currency you hold. Your entitlement itself is held by Google against your Play account, which is howRestore Purchases works if you reinstall a Game or move to a new device.

Google's handling of your purchase is governed by the Google Play Terms of Service and the Google Privacy Policy.

Note: using Delete My Data erases the local record of a purchase, but does not cancel the purchase itself - tap Restore Purchases to bring it back.

8. Who receives information about you

We do not sell your information, and we do not pass it to anyone for their own marketing. Because we hold almost nothing, there is very little that could be passed on. The complete list of recipients is:

• Google, as our advertising provider (section 4)
• Google, as our analytics and crash-reporting processor (section 5)
• Google, as the operator of Play Games, and only if you choose to sign in (section 6)
• Google Play, as the seller and payment processor for any optional purchases (section 7)

We use no other advertising networks, no marketing partners, no data brokers, no social-media SDKs, and no third-party login providers.

If we were legally required to disclose information - under a court order, or a lawful demand from a government authority in India or elsewhere - we could only provide what we actually hold, which is nothing that identifies you. Requests for advertising, analytics, hosting or Play Games data would have to be directed to Google, because Google holds that data and we do not.

9. What we do not do

To be explicit, our Site and Games do not:

• Require an account, login, or profile in order to play
• Collect your name, email address, phone number, or postal address, except if you choose to write to us
• Store your data on our servers - we run none
• Use analytics to identify you personally, or link analytics data to your real-world identity (see section 5 for what analytics does collect)
• Process or receive payment details. Optional purchases (see section 7) are handled entirely by Google Play, and we never see your card, billing address, or any payment information
• Access your contacts, photos, camera, microphone, files, or precise location
• Track you across other apps or websites
• Sell or share your personal information as those terms are defined under California law

Our Games request only the INTERNET network permission, together with the network-state and advertising-ID permissions added by Google's advertising software. These are used solely to load advertisements.

10. Legal bases for processing (GDPR Article 6)

Where the GDPR applies, we rely on:

11. Your rights

Depending on where you live, you have some or all of the following rights: to access your data, to have it corrected, to have it erased, to restrict or object to its processing, to data portability, and to withdraw consent at any time.

We hold no account or personal profile for you, so most of these rights are exercised directly on your device or with Google:

We will respond to any request sent to the address above within 30 days. We do not charge for this, and we will not treat you differently for asking.

Automated decisions. We do not make decisions about you by automated means that produce legal effects or similarly significantly affect you, and we do not profile you for such purposes. The personalisation of advertising is carried out by Google and can be switched off at any time (section 4).

If you are in the EEA or UK, you also have the right to lodge a complaint with your local data protection supervisory authority. If you are in the EEA, you can find yours via the European Data Protection Board; in the UK, the Information Commissioner's Office.

12. Grievance redressal

If you are unhappy with how we have handled your information, or with our answer to a request, you can raise a grievance with us directly. Indian law requires us to publish this route and to deal with your complaint promptly, and we offer it to everyone, wherever you live.

Grievance Officer, Odd Circuit Games, India
Email: support@oddcircuitgames.com

We will acknowledge your grievance and resolve it within 30 days, in line with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.

If we do not resolve your grievance to your satisfaction, you may escalate it. In India, you may complain to the Data Protection Board of India under the Digital Personal Data Protection Act, 2023. Elsewhere, you may complain to the data protection authority for your country.

13. Data retention

Information stored on your device is kept until you delete it, either through Settings → Delete My Data or by uninstalling the Game. We have no copy of it and therefore retain nothing ourselves.

Messages you send us are kept only as long as needed to deal with your enquiry, and no longer than 24 months after our last exchange. Information collected by Google for advertising, analytics, crash reporting and Play Games is retained according to Google's own policies, linked in sections 4, 5 and 6. Firebase Analytics data associated with an app instance identifier is retained for a limited period set in our Firebase configuration, after which Google deletes it.

14. Children

Our Games are intended for a general audience and are not directed to children. The age at which a person counts as a child differs by country, and we respect the higher standard wherever it applies:

• India: the Digital Personal Data Protection Act, 2023 treats everyone under 18 as a child. We do not knowingly process the personal data of a child in India, and we do not carry out behavioural advertising or tracking directed at children.
• European Economic Area: the age of consent for data processing is between 13 and 16 depending on the country. Below it, a parent or guardian must consent.
• United States and elsewhere: under 13, or the minimum age set by your local law.

We do not knowingly collect personal information from children. If you are a parent or guardian and believe a child has provided information through a Game, contact us at support@oddcircuitgames.com and we will assist. We will not ask you to send identity documents to make such a request.

In practice, deleting the app removes everything stored on the device, and Settings → Delete My Data does the same without uninstalling. To remove analytics or Play Games information held by Google, use the contacts in sections 5 and 6.

15. International data transfers

We are based in India and our Games are available worldwide, so information necessarily crosses borders. Google may process advertising, analytics, crash reporting and Play Games data on servers outside your country, including in the United States. Google states that it relies on Standard Contractual Clauses approved by the European Commission, and equivalent safeguards for the UK, for such transfers. See Google's privacy policy for details.

India's Digital Personal Data Protection Act, 2023 permits transfers outside India except to countries the Government of India restricts. We comply with any such restriction that applies to us.

16. Security

Data saved by a Game is held in your device's private, app-sandboxed storage, which other apps cannot read on a non-rooted device. It is stored unencrypted, because it contains only game progress and no sensitive information. Communication between our Games and Google's services uses encrypted HTTPS connections, as does this website.

We follow reasonable security practices appropriate to the very small amount of information involved, as required by section 43A of the Information Technology Act, 2000. No method of storage or transmission is ever completely secure, and we cannot promise absolute security - but it is worth saying plainly that there is no account of yours for anyone to break into, and nothing of yours sitting on a server of ours.

17. Changes to this policy

We may update this policy as our Site and Games change. The "Last updated" date at the top will always reflect the current version, and material changes will be announced in the Game or its Google Play listing. Continuing to use our Site or Games after a change means you accept the updated policy.

Regional information

India (DPDP Act 2023 and IT Act 2000)

We are a Data Fiduciary established in India, and you are a Data Principal. Under the Digital Personal Data Protection Act, 2023 you have the right to a summary of the personal data we process and how, the right to correction and erasure, the right to grievance redressal, and the right to nominate another person to exercise your rights if you die or become incapable of doing so yourself.

Because we hold no account or personal profile for you, a request for a summary has nothing to return beyond what this policy already describes. Erasure is immediate and in your own hands (section 11). To raise a grievance, or to make a nomination, use the Grievance Officer route in section 12; if we do not resolve it, you may complain to theData Protection Board of India.

European Economic Area & United Kingdom (GDPR / UK GDPR)

The data controller is Odd Circuit Games (support@oddcircuitgames.com). We have not appointed a Data Protection Officer, as we are not required to, and we have not appointed an EU or UK representative under Article 27, as our processing is occasional and low-risk. Your rights and the legal bases we rely on are set out in sections 10 and 11. Advertising personalisation is consent-based and can be withdrawn at any time from Settings → Privacy options.

California (CCPA / CPRA)

We do not hold an account or personal profile for you, we do not sell your personal information, and we have not done so in the preceding 12 months. Sharing an advertising identifier with Google for personalised advertising may constitute "sharing" for cross-context behavioural advertising under the CPRA. You can prevent it via Settings → Privacy options or by opting out of ads personalisation in Android settings. We will not discriminate against you for exercising any privacy right.

Other United States states

Several other states - including Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana - give residents rights comparable to California's: to confirm whether we process their data, to access, correct and delete it, and to opt out of targeted advertising and of any sale of personal information. We hold no account or profile, so access and correction requests have nothing to return; the opt-out for targeted advertising is Settings → Privacy options in the Game, or Android's own ads settings. We do not sell personal information, and we do not process sensitive personal data.

Brazil (LGPD)

You have the rights of confirmation, access, correction, anonymisation, portability, deletion, and information about data sharing under Articles 17-22. Exercise them using the mechanisms in section 11, or contact us at support@oddcircuitgames.com.

Canada (PIPEDA)

You may request access to, or correction of, personal information held about you. We hold no account or personal profile for you. Advertising, analytics, crash reporting and Play Games data are handled by Google.

Other jurisdictions

If your local law grants you rights not listed here, contact us at support@oddcircuitgames.com and we will honour them to the extent the law requires.

Contact

Odd Circuit Games, India
Email: support@oddcircuitgames.com
Grievance Officer: see section 12

If you have a concern we have not resolved, you may contact the Data Protection Board of India or your local data protection authority.