Privacy Policy

The data controller within the meaning of the EU General Data Protection Regulation (GDPR) is:

Leiter Sales und Invest GmbH Kefedergrundgasse 5E/4 1210 Vienna, Austria Email: support@flyingpengu.com Managing Director: Luca Leiter

This Privacy Policy applies to the mobile game Flying Pengu (the “App”), this website and all related services. By using the App or this website you acknowledge this policy.

We process the following categories of data:

• Game data: high scores, progress, purchased and unlocked items, settings — stored locally on your device only.
• Technical data: device type, operating system version, language, screen resolution — for stability and compatibility.
• Crash & diagnostics: Firebase Crashlytics — to ensure App stability (legitimate interest).
• Usage analytics: Firebase Analytics — only with your consent, pseudonymous events such as session length and levels reached.
• Advertising: Google AdMob identifiers and ad measurement — only with your consent. On iOS additionally subject to App Tracking Transparency (ATT).
• Purchases: RevenueCat / App Store / Google Play — pseudonymous buyer ID, purchase status and product ID for managing and restoring in-app purchases.

• Art. 6(1)(a) GDPR — your consent (analytics, advertising).
• Art. 6(1)(b) GDPR — performance of contract (providing the App, in-app purchases).
• Art. 6(1)(f) GDPR — legitimate interest (stability, security, fraud prevention, crash reports).

• Google AdMob (Google Ireland Ltd., Dublin) — advertising, only with consent; on iOS subject to ATT.
• Google Firebase Analytics (Google Ireland Ltd.) — usage analytics, only with consent.
• Google Firebase Crashlytics (Google Ireland Ltd.) — crash and stability reports.
• RevenueCat, Inc. (USA) — management and restoration of in-app purchases.
• Apple App Store / Google Play — App distribution and billing under their own privacy policies.

Some providers (e.g. Google, RevenueCat) may transfer data to the USA or other third countries. Such transfers rely on the EU Standard Contractual Clauses (Art. 46(2)(c) GDPR) and, where applicable, the EU-US Data Privacy Framework. Appropriate safeguards ensure an equivalent level of data protection.

The App offers optional paid digital content (e.g. “No Ads”, coin packs, cosmetic skins). Payments are processed exclusively by Apple App Store or Google Play. We receive only a pseudonymous purchase confirmation via RevenueCat — never your payment details.

We retain personal data only as long as necessary for the stated purposes or as required by law. Local game data remains on your device until you delete it or uninstall the App. Advertising and analytics data are processed in accordance with the providers' retention periods (typically up to 14 months).

• Right of access (Art. 15 GDPR)
• Right to rectification (Art. 16 GDPR)
• Right to erasure (Art. 17 GDPR)
• Right to restriction of processing (Art. 18 GDPR)
• Right to data portability (Art. 20 GDPR)
• Right to object (Art. 21 GDPR)
• Right to withdraw consent at any time (Art. 7(3) GDPR)

To exercise your rights, contact us at support@flyingpengu.com.

You can change or withdraw your consent for analytics and advertising at any time within the App under Settings → Manage Consent. The withdrawal applies to the future and does not affect prior lawful processing.

You may lodge a complaint with the competent supervisory authority. In Austria: Austrian Data Protection Authority (Datenschutzbehörde) Barichgasse 40–42, 1030 Vienna Phone: +43 1 52 152-0 Email: dsb@dsb.gv.at Web: www.dsb.gv.at

Flying Pengu is intended for users aged 13 and older. We do not knowingly collect personal data from children under 13. If we learn that such data has been collected, we will delete it without undue delay. Parents who believe their child has provided us with data may contact us at support@flyingpengu.com.

We reserve the right to update this Privacy Policy to reflect legal changes or changes to our service. The current version is always available at this URL.