1. Controller
Philip Grabner
Widerinstraße 18B/26
3100 St. Pölten
Austria
Email: grabner.labs@gmail.com
Natural person, not registered in the Austrian Commercial Register. Privacy requests may be sent to the stated email address. Do not send passwords, complete payment details, or Apple or Google Account credentials.
2. Scope
This notice applies to the iOS and Android app Trenchfront: Flashpoint, this privacy website, and voluntary contact by email. It describes services actually used in version 1.0.
3. Processing overview
| Activity | Data, purpose, and source | Recipient, retention, and choice |
|---|---|---|
| Local game | Progress, settings, statistics, battle reports, doctrine levels, unlocks, command points, and local purchase status generated by use. | Primarily on the device. Delete by removing the app; Flashpoint normally has no direct access. |
| Apple/Google services | Product, transaction, and entitlement status used to deliver and restore purchases. | Apple or Google under their terms; managed through the platform account. |
| Advertising | Depending on choices, device, usage, advertising, diagnostic, and security data for ad delivery and fraud prevention. | Google and participating ad partners under their policies; Remove Ads stops new ad requests. |
| Optional analytics and diagnostics | After separate activation, aggregated gameplay events and crash and diagnostic data. | Google Firebase; both features are off by default and can be withdrawn independently. |
| Support | Email address, name, message, and voluntary technical details used to handle a request. | Philip Grabner and Gmail/Google; only as needed for handling, documentation, or claims. |
| Website | IP address, time, requested resource, browser/device data, and referrer where transmitted. | Netlify; technical delivery, security, and diagnostics under its rules. |
4. Local game data
Game save, audio and gameplay settings, statistics, battle reports, doctrine levels, unlocks, command points, progress, and local purchase status are stored in system storage on the device. The developer normally has no direct access to this purely local data.
Version 1.0 has no complete in-app delete-data control and no enabled cloud-save service. Local data can be removed by deleting the app. Without cloud storage, reinstalling does not automatically restore local progress; restorable purchases are separate.
5. App Store, Google Play, and in-app purchases
Purchases are processed through Apple StoreKit on iOS and Google Play Billing on Android. Flashpoint does not process card or bank data. The app checks product, transaction, and entitlement status to unlock content and restore eligible purchases.
Apple or Google may process data for payment, tax, fraud prevention, and legal duties. Flashpoint does not determine their retention. See Apple Privacy, Google Privacy Policy, and Report an Apple purchase problem.
6. Platform services
Version 1.0 does not use Apple Game Center or Google Play Games for sign-in, leaderboards, achievements, or cloud saves. The game requires no platform gaming service and therefore sends no related player names or identifiers to AdMob or Firebase.
7. Google AdMob
Free use supports interstitial ads at natural breaks and voluntary rewarded ads for the displayed in-game reward. There are no banner ads and no ads during an active battle.
Depending on consent, region, and SDK configuration, Google and participating ad partners may process IP address, approximate region derived from it, device identifiers, the advertising identifier where available and permitted, ads displayed, advertising and product interactions, diagnostics, crash and performance data, and security and fraud-prevention information. Purposes include ad delivery, measurement, security, fraud prevention, and technical optimization. The current partner list may be available in a displayed UMP message.
Google Privacy Policy · How Google uses information from partner services · Google My Ad Center
8. Optional Firebase analytics and error diagnostics
Anonymous usage analytics and technical error reports can be enabled separately in the game settings. Both features are disabled by default. Analytics then processes only numeric gameplay events and technical categories transmitted by the app. When enabled, Crashlytics processes crash and diagnostic data to resolve technical issues.
Flashpoint does not send names, email addresses, telephone numbers, postal addresses, free-form text, payment details, or proprietary persistent player identifiers as analytics events to Firebase. The app does not grant Firebase Analytics advertising storage, ad user data, or ad personalization. Either consent can be withdrawn at any time in Settings.
10. UMP and privacy options
On every normal app launch, after the campaign map is visible and before the first ad request, the app updates UMP consent information, loads required messages, and checks canRequestAds. No ad is requested while UMP does not permit it. Errors do not interrupt gameplay.
Open AdMob privacy options is always available in the app privacy center. Choices available for the region and status can be reopened there. Refusing personalized advertising does not block purchased content; advertising may be limited or non-personalized.
11. Advertising identifier and App Tracking Transparency
Version 1.0 does not integrate a proprietary ATT prompt and does not independently request the iOS advertising identifier. Depending on platform, SDK, consent, and system status, Google services may process technically permitted identifiers. Refusal or restriction in system settings does not limit gameplay or purchased content.
12. United States privacy rights
To the extent applicable law provides, US users may request access, correction, deletion, portability, non-discrimination, and an opt-out of sale, sharing, or targeted advertising. An authorized agent and appeal of a denial may be available where applicable.
Flashpoint does not sell personal data for money. Advertising flows may nevertheless be treated as a sale, sharing, or targeted advertising under individual laws. The published US UMP message is assigned to both Flashpoint apps; additional requests may be sent to grabner.labs@gmail.com.
13. Support communications
An email may process address, sender name, subject, content, time, and voluntarily supplied app version, device model, operating-system version, language, game mode, issue description, screenshots, or attachments. Purposes are replying, diagnostics, purchase assistance, security, and stability improvement.
Legal bases are Article 6(1)(b) GDPR for use- or purchase-related requests, otherwise Article 6(1)(f) for support, security, and troubleshooting, and where applicable Article 6(1)(c) for legal duties. Email is handled through Gmail/Google and retained only as needed for handling, documentation, abuse prevention, legal duties, or claims.
14. Website and Netlify
The static website is delivered by Netlify. For delivery, security, diagnostics, and attack detection, Netlify may process IP address, date and time, requested resource, browser/device information, and a technically transmitted referrer in server and security logs. Processing outside the EEA may occur under lawful mechanisms such as adequacy decisions or standard contractual clauses.
The website uses no first-party analytics, ad trackers, marketing cookies, social pixels, forms, or user accounts. See the Netlify Privacy Statement.
15. Recipients and international transfers
Depending on the activity, recipients may include Apple, Google and ad partners, Gmail/Google, Netlify, and legally authorized public authorities. Providers may act in different privacy roles depending on the processing. Transfers outside the EU/EEA may rely on adequacy decisions, the EU-US Data Privacy Framework where applicable, standard contractual clauses, or other lawful safeguards.
16. Legal bases
Local game delivery, purchases, and purchase-related support generally rely on Article 6(1)(b) GDPR. Consent-required personalized advertising and tracking rely on Article 6(1)(a). Security, fraud prevention, general support, and technical website logs rely on Article 6(1)(f). Legally required processing relies on Article 6(1)(c). The applicable basis depends on the activity and law.
17. Retention and deletion
Local game data remains until the app is deleted. Apple, Google Play, purchase, and Google advertising data follow the providers' rules and legal duties. Consent choices are managed by UMP on the device and through supported standards. Support emails and Netlify logs are retained only under the described purposes and provider rules.
Deleting the app does not automatically delete data processed by Apple, Google, or Netlify under their own legal bases. Purchases can be restored in the app and privacy requests sent by email.
18. GDPR rights
Where requirements are met, individuals have rights of access, correction, deletion, restriction, portability, objection, and withdrawal of consent for future processing. A complaint may be lodged with the Austrian Data Protection Authority or another competent authority.
The developer may have no access to device-only data; it must be removed by deleting the app.
19. Children and young people
Flashpoint is not directed to children under 13 and is not intended for Apple's Kids Category or a comparable child-directed program. The developer does not knowingly ask children under 13 to submit personal data directly. Parents or guardians may contact support with concerns. Advertising and age settings must match the relevant store age ratings.
20. Automated decisions
Flashpoint itself makes no solely automated decisions with legal or similarly significant effects. Depending on consent and law, advertising providers may use data for ad selection and measurement.
21. Changes
This notice is updated for material new features, SDKs, providers, or legal requirements. A new version receives a new manually maintained effective date. Individual email notice is not provided because Flashpoint has no account or mailing list.