01Controller
The controller within the meaning of the General Data Protection Regulation (GDPR) for the processing of personal data in connection with the iOS app "OnPoy Cars" is:
Onur Sitar
Bayernstraße 33
30855 Langenhagen
Germany
Email: onpoy.studios@gmail.com
This privacy policy explains which data is processed when you use the app, for what purposes, and what rights you have.
02General Information About the App and Data Processing
OnPoy Cars is a toy-style car racing game for iPhone and iPad. You race against computer-controlled opponents, collect stars, unlock levels and customize your cars in the workshop. No registration and no user account are required. We do not operate a backend or server of our own for game progress.
The app itself does not collect, in particular:
- Names
- Email addresses
- Phone numbers
- Photos or videos
- Voice recordings
The app does not use the camera or microphone and does not ask for your precise location.
Because the app is free and funded by advertising, Google AdMob is integrated. Google may process certain technical and personal data in this context (see Sections 5 to 9).
03Data Stored Locally on Your Device
The following data is stored exclusively on your device (via the iOS feature UserDefaults):
- Collected stars and the best star rating per level
- Unlocked levels
- Last selected car and level
- Workshop customizations per car (paint, tires, stickers, exhaust)
- Settings: music, music volume, sounds, haptics, graphics, opponent difficulty and language
- Whether the introduction has already been shown on first launch
- A counter of finished races that controls when the next ad appears
This data stays on your device. It is not transmitted to us and not shared with third parties. We do not keep a copy on any server.
In addition, the Google consent form (see Section 7) stores your advertising consent locally on the device so that it is respected the next time you open the app.
You can remove all of this data by deleting the app.
04Language and Region Settings
The app reads the language set on your device to choose a suitable language automatically: German if your device language is German, otherwise English. No access to GPS or your precise location is required.
You can change the language in the app's settings at any time. Your choice is stored locally on the device (see Section 3).
05Google AdMob and Advertising
The app shows advertising via Google AdMob (Google Mobile Ads SDK). For users in the European Economic Area and Switzerland, the provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
How advertising is used in OnPoy Cars:
- As a rule, a full-screen video ad (interstitial) appears after every second finished race.
- No ads are shown during a race.
- There are no banner ads.
- Ads are limited to content that Google rates as suitable for teens aged 13 and over (Google rating "T").
In connection with the Google Mobile Ads SDK, the following data in particular may be processed:
- IP address, from which an approximate location may be derived
- Device identifiers, including the advertising identifier (IDFA) where available and permitted (see Section 9)
- Information about ads shown and your interactions with them
- Technical device, operating system and app information
- Performance, crash and diagnostic data
Google processes this data to deliver, select and measure ads, to control ad frequency, to prevent fraud and abuse and – only with your consent – to personalize ads. Google publishes the current list of data categories in the documentation for the Google Mobile Ads SDK.
06Personalized and Non-Personalized Advertising
Where required by law, we ask for your consent before processing data for advertising purposes. You decide whether you agree to personalized advertising.
If you do not agree, non-personalized or limited ads may be shown. Certain data may still be processed where necessary to deliver, secure or measure ads. You can use the game in full either way.
07Google User Messaging Platform (UMP)
The app uses the Google User Messaging Platform (UMP) to manage your consent. In particular in the European Economic Area, the United Kingdom and Switzerland, a Google consent form appears on first launch that informs you about the data processing and lets you make your choice.
Your choice is stored locally (see Section 3) and, where technically and legally necessary, passed on to the advertising services.
08Changing and Withdrawing Advertising Consent
You can change or withdraw your consent at any time with effect for the future. The app provides permanent access to the Google consent form under "Settings → Ad Settings". This entry appears if such an option is required for your region.
Withdrawal only takes effect for the future and does not affect the lawfulness of processing carried out before the withdrawal.
09App Tracking Transparency (ATT) and IDFA
Your device's advertising identifier (IDFA) may only be used for tracking with your permission. For this, iOS shows a one-time system prompt ("Allow OnPoy Cars to track your activity …?").
If you decline, you can still use the game without restriction; only ads without tracking will be shown. You can change your decision at any time in the iOS settings under "Privacy & Security → Tracking".
10No In-App Purchases
OnPoy Cars contains no in-app purchases and no subscriptions. All cars, tracks and workshop customizations are free to play.
The app is funded exclusively by advertising (see Section 5). The app does not process any payment data.
11No User Accounts and No Online Features
You do not need a user account to use the app. In particular, there is:
- No login
- No public profiles
- No chat
- No messages between players
- No way to upload photos or videos
- No online multiplayer mode
The opponents in a race are controlled entirely by the game on your device. There is no connection to other players.
12Disclosure of Personal Data
We do not sell personal data. Processing by third parties only takes place in connection with the integrated services:
- Google – in connection with Google AdMob and the Google UMP
- Apple – in connection with the App Store and iOS
Beyond this, we do not disclose personal data to third parties unless we are legally obliged to do so.
13International Data Transfers
Google and Apple are internationally operating companies. When their services are used, personal data may also be processed outside Germany and the European Economic Area, in particular in the USA.
Such transfers are based on the mechanisms provided by law, for example an adequacy decision of the European Commission (such as the EU-US Data Privacy Framework) or appropriate safeguards under Art. 46 GDPR such as standard contractual clauses. You can find more information in the privacy notices of Google and Apple (see Section 21).
14Legal Bases for Processing
Section 25 of the German Telecommunications Digital Services Data Protection Act (TDDDG) additionally applies to storing information on your device and accessing it. Where such storage or access is not strictly necessary, it only takes place with your prior consent.
Depending on the purpose, processing is based on the following legal bases under the GDPR:
- Art. 6(1)(a) GDPR and Section 25(1) TDDDG (consent) – in particular for personalized advertising and tracking
- Art. 6(1)(f) GDPR (legitimate interests) – for the technically necessary provision of the app and of non-personalized advertising, as well as for security and the prevention of fraud and abuse. Our legitimate interest lies in the secure, stable and economical provision of the free app.
- Art. 6(1)(c) GDPR (legal obligation) – where we are legally obliged to process data
The game and settings data stored only locally (Section 3) is strictly necessary for the game to work and does not leave your device.
15Retention Period and Deletion
Your stars, unlocked levels, workshop customizations and settings remain on your device until you delete the app. Since we do not store them on our own servers, we have no copy of them.
Data processed by Google or Apple is subject to their own retention and deletion rules.
16Minors and Children
OnPoy Cars is rated 13+ on the App Store because the app shows advertising. We do not knowingly collect personal data from children. There are no user accounts, no public profiles, no chat and no way to share your own content.
Advertising is limited to ads suitable for teens aged 13 and over (see Section 5). Where a minor cannot validly give consent under applicable law – in Germany generally until their 16th birthday (Art. 8 GDPR) – consent from parents or guardians is required for personalized advertising.
We recommend that parents set up the device's privacy, advertising, Screen Time and purchase settings in an age-appropriate way. More information can be found in the "Guide for Parents" in the app.
17No Use of Camera, Microphone or Precise Location
OnPoy Cars does not need access to the following for the game:
- Camera
- Microphone
- Photos
- Contacts
- Precise GPS location
This is distinct from technical information that Google may process in connection with advertising, for example an approximate location based on the IP address (see Section 5).
18Your Rights
Where the GDPR applies, you have the following rights in particular:
- Access (Art. 15 GDPR)
- Rectification (Art. 16 GDPR)
- Erasure (Art. 17 GDPR)
- Restriction of processing (Art. 18 GDPR)
- Data portability (Art. 20 GDPR)
- Objection (Art. 21 GDPR)
- Withdrawal of consent (Art. 7(3) GDPR)
Since game progress and settings are stored only locally on your device and we do not maintain user accounts, we cannot attribute this data to a person or delete it remotely. You can remove it yourself at any time by deleting the app. For advertising data processed by Google, you can also exercise your rights directly with Google.
19Right to Lodge a Complaint with a Supervisory Authority
You have the right to lodge a complaint with a data protection supervisory authority if you believe that the processing of your personal data infringes the GDPR (Art. 77 GDPR). The authority responsible for us is the State Commissioner for Data Protection of Lower Saxony (Die Landesbeauftragte für den Datenschutz Niedersachsen). You may also contact the supervisory authority where you live.
This right exists without prejudice to any other administrative or judicial remedy.
20Security
We rely on data minimization: there are deliberately no user accounts and no server-side storage of game progress.
The integrated services of Google (AdMob, UMP) and Apple apply their own technical and organizational security measures.
21Privacy Information from Google and Apple
The privacy notices of the integrated providers apply in addition:
- Google Privacy Policy: policies.google.com/privacy
- How Google uses information from sites or apps that use its services: policies.google.com/technologies/partner-sites
- Apple Privacy Policy: apple.com/legal/privacy
22Changes to This Privacy Policy
We update this privacy policy when the app's features, integrated services, technical processes or legal requirements change.
You can always find the current version in the app under "Settings → Privacy Policy".
23Contact for Privacy Inquiries
If you have any questions about privacy, you can contact us at any time:
Onur Sitar
Bayernstraße 33
30855 Langenhagen
Germany
Email: onpoy.studios@gmail.com