# Privacy Policy — Golden Harvest Slots (DRAFT)

> **DRAFT — requires legal review before publication.** Last updated: 27 September 2026.
> Replace `goldenharvest.app`, `[EMAIL]` and `[POSTAL ADDRESS]` with real details before launch.

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## 1. Who we are (Data Controller)

Golden Harvest Slots ("the App") is operated by **[LEGAL NAME]**, [registered address], United Kingdom ("we", "us"). Contact: **[EMAIL]**.

## 2. What we collect and why

| Data | Purpose | Legal basis (UK GDPR / EU GDPR) |
|---|---|---|
| Account data (e-mail address, sign-in provider, user ID) | Creating and securing your account, syncing progress | Performance of contract |
| Gameplay data (coins, spins, machines unlocked, daily bonus state) | Running the game and saving your progress | Performance of contract |
| Device and technical data (device model, OS version, app version, IP address, crash logs) | Security, fraud prevention, debugging, statistics | Legitimate interests |
| Advertising ID (Android Advertising ID) and ad interaction data | Showing and measuring advertisements | **Consent** (EEA/UK) — see section 4 |
| Purchase history | **Not collected — the App has no in-app purchases at this time.** | — |
| Support messages you send us | Answering your request | Legitimate interests |

**We do not collect:** precise location, contacts, financial data, health data.
**We do not pay out money.** There is no cash, prize, redemption, withdrawal or transfer of virtual coins to real-world value of any kind.

## 3. Why we process it

- To provide the game (contractual necessity)
- To show advertisements, including personalised ads in the UK/EEA **only if you consent**
- To prevent fraud, cheating and invalid ad traffic (legitimate interests)
- To comply with legal obligations (e.g. tax/accounting)

## 4. Advertising and consent (UMP)

We use **Google AdMob** to display ads. In the UK and EEA, personalised advertising is only enabled after you give consent through the consent dialog shown on first launch. You can change your choice at any time in **Settings → Personalised ads**.

- With consent: personalised ads (your advertising ID may be shared with Google and its partners).
- Without consent: non-personalised ads (contextual only, limited ad measurement).

Google's processing: [Google Privacy Policy](https://policies.google.com/privacy) and [AdMob UK GDPR additions](https://policies.google.com/technologies/ads).

## 5. Processors and transfers

| Provider | Service | Location |
|---|---|---|
| Google Firebase (Auth, Analytics, Crashlytics) | Authentication, analytics, crash reports | USA (Google Cloud) — EU/UK data covered by EU/UK–US Data Privacy Framework and Standard Contractual Clauses |
| Google AdMob | Advertising | USA / global |
| Cloudflare, Inc. | Hosting and API (game server) | USA / global — Standard Contractual Clauses |

A current list of sub-processors is available on request at **[EMAIL]**.

## 6. Retention

- Account and gameplay data: until you delete your account, then deleted or anonymised within **30 days**.
- Crash logs: **90 days**.
- Ad event logs (aggregated, no identifiers): **13 months**.
- Support messages: **24 months**.

## 7. Your rights

You have the right to: access, rectify, erase ("right to be forgotten"), restrict processing, object to processing, data portability, and to withdraw consent at any time (without affecting prior processing).

**To exercise your rights, or to delete your account and all associated data, use Settings → Delete my account, or e-mail [EMAIL].**

You may also lodge a complaint with the UK Information Commissioner's Office (ico.org.uk) or your local supervisory authority.

## 8. Children

The App is intended for persons aged **18 and over**. We do not knowingly collect data from minors. If you believe a minor has provided us data, contact **[EMAIL]** and we will delete it.

## 9. Cookies and similar technologies

The App itself does not use cookies. Advertising SDKs may use identifiers (e.g. the Android Advertising ID) for measurement — controlled by your device settings and your consent choice.

## 10. Changes

We will post any changes here with an updated date. Material changes will be notified in the App.

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**MAGYAR FORDÍTÁS:** `privacy_policy_hu.md` — informatív, nem hivatalos; a hatályos változat az angol nyelvű.