Privacy Policy
The short version
We never ask you for your name, your email address or an account. The game carries no advertising and no sign-in. What we do collect is anonymous gameplay statistics — which levels people reach, which ones they give up on — so that we know what to fix. Nothing about you is sold to anybody.
Who we are
Muchos Mineros is made and published by Freddie Honohan, based in Ireland. For the purposes of the EU General Data Protection Regulation, Freddie Honohan is the data controller for everything described here. You can get in touch at info@boltassociation.com.
The game
Gameplay analytics
The game uses GameAnalytics (GameAnalytics A/S, Denmark) to understand how it is actually played. Each event is a fact about the game rather than about you — the app was opened, level 7 was started, level 7 was failed, the tutorial was finished, a screenshot was shared. Alongside those events the SDK sends:
- device model, manufacturer, operating system and version, and the build number of the game;
- your device language, its memory as a broad band, and which graphics preset the game is running — the three details that tell us whether a problem is ours or the hardware's;
- the country your connection appears to come from, derived from your IP address by GameAnalytics and then discarded — we never see or store the address itself;
- a device identifier: on Android the advertising ID and the app-set ID supplied by Google Play services, and on iOS the vendor identifier, which is specific to this app and is reset when you delete it;
- automatic error and exception reports when something in the game goes wrong.
On iOS the game does not track you. It never asks for App Tracking Transparency permission and never collects the IDFA advertising identifier, so nothing it sends can be tied to you across other companies' apps or websites.
Checking the copy of the game
Roughly once a fortnight the game asks the platform to confirm that this copy came from the App Store or Google Play, and sends that signed confirmation to our own server on Cloudflare to be checked. On Android it is a Google Play Integrity token; on iOS it is an App Store app transaction. Neither carries your name, your account or your device identifier, and we keep only the answer, for as long as it takes to give it.
Your progress
Levels completed, miners rescued and your settings are stored on your device alone. They are never uploaded to us. If Android backup is switched on, your device backs that file up to your own Google account, which we cannot read. Deleting the game deletes the data with it.
Sharing a screenshot
When you share, the game hands a picture to your phone's own share sheet and stops there. We do not see what you send or who you send it to. On iOS, choosing "Save Image" asks permission to add to your photo library — the game can add a picture, it can never read one.
What the game never does
- No advertising, and no advertising networks in the app at all.
- No account, no sign-in, no name, no email address.
- No location, contacts, microphone, camera or file access — the only permissions it asks for are internet and network state.
- No selling or sharing of personal information for anyone else's marketing.
The website
This site sets two cookies. Both are strictly functional, and neither is used to identify you or to follow you anywhere:
mm_lang— remembers the language you picked from the flag menu, so the site stops guessing. One year.mm_stay— remembers that you chose to stay on the website rather than be sent to an app store. One year.
Page-view statistics come from Cloudflare Web Analytics, which is measured at the server rather than in your browser: no cookies, no fingerprinting, no profile, and nothing that follows you to other sites. Cloudflare also hosts and delivers the site, and handles IP addresses briefly in order to route traffic and block attacks.
The trailer is a YouTube embed that loads only if you press play. Until you do, nothing is requested from Google and no Google cookie is set. Once you do, YouTube's own terms and Google's privacy policy apply to that player.
Why we are allowed to do this
Under the GDPR we rely on legitimate interests (Article 6(1)(f)) for the gameplay analytics, the error reports and the check on the copy of the game: we need to know whether the game works, where players get stuck, and whether a copy is genuine. That interest is a narrow one — everything above is about the device or about the game, and none of it is used to make a decision about a person. The two website cookies are strictly necessary for a preference you chose yourself, so they do not require consent.
Who else sees it
GameAnalytics and Cloudflare process data on our behalf under contract, and neither may use it for its own purposes. Apple and Google run the stores and tell us how many people installed the game and how it was rated; whatever they collect as part of running those stores is covered by their privacy policies rather than this one. We disclose nothing else, except where the law requires it of us.
Where it goes, and how long it stays
GameAnalytics stores data in the EU. Cloudflare is a US company running a global network, and relies on the European Commission's Standard Contractual Clauses and the EU–US Data Privacy Framework for any transfer out of the EU. Analytics data is kept in aggregate for as long as the game is supported and it remains useful to us; the licence answer is kept for days rather than months; your progress stays on your device until you delete the game.
Children
Muchos Mineros is rated for a general audience of 13 and over. It is not directed at children under 13, and we do not knowingly collect anything from them. If you believe a child under 13 has sent us something, write to us and we will delete it.
Your rights
If you are in the EU or the UK you can ask us for a copy of anything we hold about you, ask us to correct or erase it, object to our processing it, or ask us to restrict that processing. Because we deliberately hold nothing that names you, we normally need the device identifier in order to find any of it — email us and we will explain how to read it off your device. We answer within one month.
To stop the analytics at the source: on Android, delete or reset the advertising ID under Settings → Privacy → Ads; on iOS, delete and reinstall the game to reset its vendor identifier. Uninstalling ends collection altogether.
You also have the right to complain to a supervisory authority. Ours is the Irish Data Protection Commission, dataprotection.ie, and you may equally complain to the authority where you live.
Changes
If this policy changes in a way that matters, we will update the date at the top, and for anything substantial say so in the release notes of the game. This page is always the current version.
Contact
Freddie Honohan, Ireland — info@boltassociation.com