Prywatność — Grey Seas: Submarines

Plain-language summary

Grey Seas: Submarines is a fast-paced arcade game in which you command a submarine, launch torpedoes at enemy warships, and evade depth charges. The App is free to download, contains no ads, and offers an optional purchase that unlocks the full version. This Privacy Policy explains what information is - and is not - processed when you use the App.

Advertising

None. The App contains no advertisements or advertising SDKs.

Business model

Free download with an optional one-time in-app purchase that unlocks the full version.

Accounts

No SpiroNet account or profile is required for normal gameplay.

Tracking

No analytics, behavioral profiling, cross-app tracking, or sale of personal data.

1. Who we are

The developer and data controller is Bartosz Czmuchowski, trading as SpiroNet, NIP 5782491634, REGON 363128990 ("SpiroNet", "we", "us" or "our").

Privacy enquiries may be sent to privacy@spironet.pl. Technical support enquiries may be sent to support@spironet.pl.

2. Scope of this policy

This policy applies to the Android game Grey Seas: Submarines (the "App") and to personal data that you voluntarily provide when contacting SpiroNet about the App. It does not replace the privacy terms of Google Play, Android, your device manufacturer, mobile network operator, or other independent third parties.

3. Information processed during normal gameplay

During normal gameplay, the App does not ask you to provide your name, email address, telephone number, postal address, precise location, contacts, photos, microphone recordings, camera data, health data, or similar personal or sensitive information.

The App does not create a SpiroNet user account, does not display advertising, and does not use personal data for analytics, profiling, personalized advertising, or cross-app tracking. We do not sell or rent personal data.

Game progress, preferences, settings, or entitlement information may be stored locally on your device. Information that remains only on your device is not received by SpiroNet. It may be removed if you clear the App data, reset the device, or uninstall the App, subject to any purchase restoration mechanisms provided by Google Play.

4. In-app purchase and Google Play Billing

The free version of the App may offer a one-time purchase that unlocks access to the full version. The purchase is initiated and processed using Google Play billing services. Google acts independently in relation to your Google account, payment method, transaction processing, fraud prevention, refunds, and related legal obligations.

SpiroNet does not receive your complete payment card number, bank account details, or Google account password. To unlock or restore the full version, the App may receive or process limited purchase information made available by Google Play, such as the product identifier, purchase status, order or transaction reference, and a technical purchase token. This information is used only to verify and provide the purchased entitlement, prevent unauthorized access, restore purchases, and handle support or legal obligations.

Google's processing is governed by its own terms and policies.

• Google's Privacy Policy (otwiera się w nowej karcie)
• Google Play Terms (otwiera się w nowej karcie)

5. Contacting support or privacy services

If you contact us by email, we process the information contained in your message. Depending on what you send, this may include your email address, name, device model, Android version, App version, screenshots, purchase reference, and details of the issue.

We use this information to respond to your request, diagnose technical problems, confirm a purchase or entitlement, protect the App and users against abuse, and maintain necessary business records. The legal basis is our legitimate interest in providing support and protecting our services, steps necessary to perform or manage the purchase-related service, and compliance with legal obligations where applicable.

Please do not include passwords, full payment card details, identity documents, health information, or other sensitive personal data in a support message unless we specifically and lawfully request it.

6. Sharing and recipients

We do not sell personal data and we do not share it for advertising. Personal data may be disclosed only where necessary to:

• use Google Play distribution and billing services;
• operate email, hosting, security, or technical support services through processors acting on our instructions;
• comply with applicable law, a binding request from a competent authority, or establish, exercise, or defend legal claims; or
• complete a business reorganization or transfer with appropriate legal safeguards and notice where required.

Service providers are required to handle data only for the agreed purpose and with appropriate confidentiality and security measures.

7. International data transfers

Some independent providers, including Google, may process information in countries outside Poland or the European Economic Area. Where GDPR rules apply, such transfers must rely on a lawful transfer mechanism and appropriate safeguards. Please consult the relevant provider's privacy documentation for details of its locations and safeguards.

8. Retention and deletion

We retain personal data only for as long as necessary for the purpose for which it was processed:

• local game data remains on your device until removed through the App, device settings, a reset, or uninstallation;
• purchase or entitlement information, if retained by SpiroNet, is kept only as long as needed to provide and restore the full version, prevent fraud, resolve disputes, and meet legal or accounting obligations;
• support correspondence is kept until the request is resolved and thereafter only for a period justified by security, record-keeping, limitation periods, or other legal requirements.

Google determines the retention of information that it processes as an independent provider under its own policies. To request deletion of data held by SpiroNet, contact privacy@spironet.pl. We may need limited information to verify the request.

9. Security

We use reasonable technical and organizational measures appropriate to the limited nature of the data processed. These measures are intended to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. No method of electronic transmission or storage can be guaranteed to be completely secure.

10. Children

The App is a general-audience game and is not designed to collect personal data from children. In-app purchases are handled through Google Play and may be subject to Google Play family, parental approval, and device controls. If a parent or guardian believes that a child has sent personal data to SpiroNet, please contact us so that we can review and, where appropriate, delete it.

11. Your data protection rights

Where the GDPR or similar law applies, and subject to its conditions and exceptions, you may have the right to request access to your personal data, correction, deletion, restriction of processing, data portability, or to object to processing. Where processing is based on consent, you may withdraw that consent without affecting earlier lawful processing.

You also have the right to lodge a complaint with a competent supervisory authority. In Poland, this is the President of the Personal Data Protection Office (UODO). We encourage you to contact us first at privacy@spironet.pl so that we can address your concern.

12. Automated decisions and profiling

SpiroNet does not use personal data from the App for automated decision-making that produces legal or similarly significant effects, and does not create advertising or behavioral profiles.

13. Changes to this policy

We may update this Privacy Policy when the App, its services, applicable law, or Google Play requirements change. The revised version will show a new effective date and will be published at https://spironet.pl/en/privacy/pl_spironet_games_submarine. Material changes will be communicated in an appropriate manner where required by law.

14. Contact

Data controller

Bartosz Czmuchowski, trading as SpiroNet

Privacy email

privacy@spironet.pl

Support email

support@spironet.pl

Website

https://spironet.pl/en