Privacy Policy
Last updated: 2026-11-14
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1. Who we are
Sunflip (the "Game") is published by LIMITED LIABILITY COMPANY "Lytvynov Production" (ТОВ «Литвинов Продакшн»), company code 43293825, Robocha Street 164A, apt. 58, 49000 Dnipro, Ukraine ("we", "us"). We are the controller of the personal data described here. Contact: alytvynov@lytvynov-production.com [TODO: mailbox not set up].
EU representative (Art. 27 GDPR): [TODO: appoint and name]. UK representative: [TODO].
2. The short version
- You can play without creating an account, giving your name or email.
- Your nickname is made from a list of words. There is no chat and no free text you can type to other players.
- We ask for an age range, not your birth date. Players under 13 (or under the age of digital consent in their EU country) get only non-personalized ads and cannot link a Google or Apple account.
- We never sell your personal data.
- You can delete your account and data at any time, in the Game or via this page.
3. What we collect and why
| Data | Why | Legal basis (GDPR) | Kept |
|---|---|---|---|
| Random player ID created by the Game, install ID | Save progress, leaderboards, purchases | Contract (Art. 6(1)(b)) | Until you delete the account; inactive accounts after 24 months [TODO confirm] |
| Nickname (from word list), country you pick, cosmetic items | Shown on leaderboards and with your ghost | Contract | Same as above |
| Age range (child / teen / adult) | Apply child protections | Legal obligation (Art. 6(1)(c)), legitimate interest | Same as above |
| Game runs: button inputs over time, finish time, level, game version | Leaderboards, ghosts of your runs, cheat checks | Contract, legitimate interest (fair leaderboards) | Best runs while the leaderboard exists; other runs up to 30 days |
| Purchase records (product, store transaction ID, date) | Deliver and restore purchases, refunds, accounting | Contract, legal obligation | As required by tax law (up to 5 years) [TODO confirm] |
| Gameplay events (level started / finished, crashes in the game, menu actions), device model, OS, language | Improve levels and difficulty, fix bugs | Legitimate interest (Art. 6(1)(f)) | 60 days in our database; vendor retention see section 5 |
| Crash reports (stack trace, device model, OS, game version) | Fix crashes | Legitimate interest | 90 days |
| Advertising ID and ad interaction data (only if you are not in the child group and you allowed it where consent is required) | Show ads that pay for the free game | Consent (EEA, UK) / legitimate interest elsewhere | Handled by ad partners, see section 5 |
| If you choose to link Apple or Google: the account identifier and possibly an email the provider gives us | Restore progress on a new device | Contract | Until you unlink or delete |
| Emails you send to support | Answer you | Legitimate interest | 24 months |
We do not store your IP address in our game database. Our hosting providers process IP addresses in server logs for security for a short period.
Content you create: track designs and track titles chosen from word lists (when the track editor is released) are public when you publish them.
4. Children
Sunflip is a general-audience game that children may also play. We ask a neutral age question before features where age matters. If you are under 13 (in the US) or under the age of digital consent in your country (13-16 in the EU):
- ads are contextual only (no personalization, no advertising ID);
- you cannot link an Apple or Google account; you can move progress with a transfer code made of words;
- analytics run without advertising identifiers [TODO: confirm analytics vendor child mode];
- there is no chat, no free text, and no way to share personal information with other players.
We only collect what is needed to run the game for a child (COPPA "support for internal operations"). Parents can ask us to review or delete a child's data at alytvynov@lytvynov-production.com [TODO: mailbox not set up]; please include the player ID shown in Settings.
5. Service providers we use
| Provider | What for | Where |
|---|---|---|
| Supabase Inc. | Game database, accounts | EU (Frankfurt, Germany) |
| Cloudflare Inc. | Website, content delivery, file storage | Global network |
| Hetzner Online GmbH | Run verification and error tracking servers | Germany / Finland |
| GameAnalytics ApS | Game analytics | [TODO confirm] |
| Apple, Google | App stores, payments, optional sign-in | Global |
| Advertising partners | Ads in the mobile game | [TODO: list networks, e.g. Google AdMob / AppLovin MAX, after selection] |
| Web game portals | If you play on a portal (e.g. Poki, CrazyGames), the portal's own privacy policy applies to its ads and analytics | [TODO] |
Transfers outside the EEA rely on the EU-US Data Privacy Framework where the provider is certified, or on Standard Contractual Clauses. We are based in Ukraine; data we access from Ukraine is protected by the same measures.
6. Your rights
You can ask to access, correct, delete or export your data, object to processing based on legitimate interest, and withdraw consent at any time (ads consent: Settings in the Game). EEA/UK residents can complain to their data protection authority; in Ukraine - the Ukrainian Parliament Commissioner for Human Rights. California residents: we do not sell or share personal information as defined by the CCPA/CPRA.
Most requests can be done in the Game (Settings -> Account). Otherwise write to alytvynov@lytvynov-production.com [TODO: mailbox not set up] with your player ID. We answer within 30 days.
7. Security
Data is encrypted in transit (HTTPS). Access to databases is limited to the two people running the game. Leaderboards show only nickname, country, time and ghost.
8. Website
This website sets no cookies and uses no tracking by default. [TODO: if Cloudflare Web Analytics is enabled, mention it here - it is cookieless.]
9. Changes
We will post changes here and, for important changes, tell you in the Game.