Icy Spire — Privacy Policy

1. Data Controller

The data controller for Icy Spire is AdShift Sp. z o.o., based in Poland. For any privacy-related inquiries, please contact us at:

2. Data We Collect

Icy Spire does not require user accounts or collect personal information such as your name or email. The app may collect the following data only if you provide consent (for example, through Apple's App Tracking Transparency prompt). If you decline, we do not collect advertising identifiers or share data with advertising partners.

• Device identifiers (e.g. IDFA, IDFV)
• In-app events and interactions (e.g. game progress, levels completed)
• App usage analytics (e.g. session duration, feature usage)
• Crash logs and diagnostic data
• Device information (model, OS version, language, country)

3. Purposes of Data Processing

We process the collected data for the following purposes:

• Ensuring proper app functionality and performance
• Testing and improving our Mobile Measurement Platform (MMP) system
• Analytics and quality improvement
• Crash reporting and bug fixing
• Attribution and measurement of advertising campaigns

4. Sharing with Advertising Partners

We may send in-app events and attribution data to advertising partners for campaign measurement and optimization. These partners may include, but are not limited to:

• Meta (Facebook/Instagram)
• Google Ads
• Other advertising networks and demand-side platforms

Data shared with these partners is used for attribution, measurement, and campaign optimization purposes. Each partner processes data according to their own privacy policies.

5. Legal Basis (GDPR)

If you are located in the European Economic Area (EEA), we process your data based on:

• Legitimate interest — for analytics, app improvement, and MMP system testing
• Consent — where required by applicable law (e.g. for tracking via IDFA under Apple's App Tracking Transparency framework)

6. Data Retention

We retain collected data only as long as necessary to fulfill the purposes described in this policy. Aggregated or anonymized data may be retained longer for analytical purposes.

7. Data Security

We implement industry-standard technical and organizational measures to protect the data we collect from unauthorized access, loss, or misuse.

8. Your Rights

Under applicable data protection laws (including GDPR), you have the right to:

• Access the data we hold about you
• Request correction of inaccurate data
• Request deletion of your data
• Object to data processing based on legitimate interest
• Withdraw consent at any time (where processing is based on consent)

To exercise any of these rights, contact us at:

9. Children's Privacy

Icy Spire is not directed at children under the age of 13. We do not knowingly collect personal data from children. If you believe a child has provided us with data, please contact us and we will delete it promptly.

10. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated effective date. We encourage you to review this policy periodically.