Aberwla

• Who We Are: ATXR Ltd, located at Np-105, Icentre Howard Way, Interchange Park, Newport Pagnell, MK16 9PY, United Kingdom.
• Applicability: This Privacy Policy applies to your use of Aberwla on Meta and Pico platforms.

GDPR Note

For users in jurisdictions like the European Union (EU) or United Kingdom (UK), we may rely on:

Legitimate Interest for data necessary to maintain and improve the App (e.g., mandatory crash/error reporting).

Consent for optional analytics features (e.g., Unity Analytics).

Because we do not store or directly handle personal data (e.g., IP addresses) ourselves, we typically do not fall under full GDPR registration requirements (e.g., with the ICO) or need to appoint a Data Protection Officer. However, users should be aware that third-party services like Unity or Meta may process some personal data under their own privacy frameworks.

2.1 Meta’s Age Category API

• Data Processed: User ID and Age Group.
• Purpose: Required by Meta to verify users’ age category.
• Storage: We do not store or log the User ID or Age Group. Meta shares this data solely for compliance with platform requirements.

2.2 Unity Engine (General Data Collection)

Because Aberwla is built on the Unity platform, Unity may collect certain device and application data (on Unity’s own behalf), including:

• IP Address(used by Unity to infer approximate location).
• Device Information(model, OS version, CPU/GPU details).
• Unity Editor & Player Version.
• App or Bundle Identification(unique ID for the app).

We do not access or store these details. Refer to the Unity Privacy Policyfor more information.

2.3 Unity Cloud Diagnostics (Crash & Error Reporting)

• Always On:We use Unity Cloud Diagnostics continuously to identify and fix crashes, errors, and performance issues. This is based on our legitimate interest in ensuring the App functions properly and securely.
• Data Collected:Crash logs, error messages, stack traces, and possibly device metrics (e.g., OS, CPU/GPU info, IP address).
• No Direct Identification:We do not combine crash logs with any other data that identifies you personally. Unity encrypts and stores these logs according to its policies.

2.4 Unity Analytics (User Consent)

If you opt in, we use Unity Analytics to understand user engagement and improve gameplay features.

• Automatically Collected Data
  
  - Standard Events (e.g., gameStarted, gameEnded): Session frequency, session length, etc.
  -Device Information: Similar hardware/OS details as in Section 2.2, potentially including IP address.
• Game-Specific Events
  
  - Custom Events(e.g., levels completed, achievements).
  - User Attributes: Non-personal demographics or user preferences, if tracked.
• Opt-In Consent
  
  - When you launch the App for the first time, a popupasks whether you agree to enable analytics. No analytics data is sent until you explicitly consent.

• Age Verification: Relying on Meta’s Age Category API for platform compliance.
• Crash & Error Analysis: Using Unity Cloud Diagnostics (always on) to fix critical errors and enhance performance (legitimate interest).
• App Analytics: If enabled, Unity Analytics helps us refine user engagement and game design (consent-based).
• Legal & Regulatory: We may use limited data (where available) to comply with laws, resolve disputes, or protect our rights.

4.1 Meta & Pico Platforms

Our App is distributed on Meta and Pico, each governed by its own privacy policy:

- Meta Privacy Policy
- Pico Privacy Policy

4.2 Unity

We rely on the Unity engine, Cloud Diagnostics, and (optionally) Analytics:

- Unity Privacy Policy

We do not control nor are we responsible for how Meta, Pico, or Unity handle data beyond our direct usage.

No Personal Data Storage: We do not store personal data ourselves.

Unity Retention: Unity retains crash logs, analytics data, and any associated user information in line with Unity’s own policies.

Security: Unity encrypts data in transit and at rest. We rely on Unity’s security measures to protect crash logs and analytics data.

Access, Correction & Deletion

- No Direct Access: Since we do not handle or store personal data (e.g., IP addresses), we cannot directly modify or delete it.

- Unity Analytics Deletion: If you opt in to Analytics, there is a “Delete My Data” button in-app. When you use this button, we will forward a data-deletion request to Unity on your behalf. Unity ultimately determines how and when data is removed under their own privacy policies.

Consent Management

- Opt-In / Opt-Out: Unity Analytics is entirely optional. If you do not consent initially, no analytics data is sent. You can opt in or out later through the App’s settings.

- Always-On Crash Reporting: Unity Cloud Diagnostics is mandatory for error and crash reports because we have a legitimate interest in maintaining a functional, secure app. This cannot be disabled.

Children

- Aberwla is labeled as a “mixed age group” app on Meta. We do not knowingly collect or store personal data from children. If you believe a child has provided personal data, contact us at privacy@atxr.co.uk so we can address the issue.

We may revise this Privacy Policy from time to time to reflect changes in our practices or the App’s functionality. We will update the “Effective Date” above and, where appropriate, notify you in-App or on our website.

If you have any questions about this policy, you can contact us at:

ATXR Ltd
Np-105, Icentre Howard Way, Interchange Park
Newport Pagnell, MK16 9PY
United Kingdom
privacy@atxr.co.uk
www.atxr.co.uk