Privacy Policy

Black Hornet Game Studio

Open Terms of Service
Last updated: August 1, 2020

1. Introduction

Please read this Privacy Policy and our Terms of Service carefully before using our Services.

This Privacy Policy applies to all of the games, applications, software, products, features and services (together "Games" or "Services") of Black Hornet Game Studio and is made available to any end Users directly by us or with a usage of all platforms and systems.

"Black Hornet Game Studio", "BHGS", "We", "Us" or "Our" refers to the indie game developer community Black Hornet Game Studio with official representative Siarhei Kavaleuski and We refer to You as "You", "Your", "User" and "Users" in this Privacy Policy.

We are compliant with all applicable regulations regarding privacy and its protection. The purpose of this Privacy Policy is to provide our Users with comprehensive and easy to understand overview of what we do with Your data.

We wish to remind You that this Privacy Policy applies to the data that we control and process when You use the Services. It does not apply to any external services or third party applications and websites or any other third parties which You may encounter using our Services.

By installing, using, registering to or otherwise accessing the Services, you are expressing Your agreement to this Privacy Policy and the processing of Your data, including Your personal information, in the manner provided in this Policy. If you do not agree to these terms, please do not use the Services.

We may update our Privacy Policy from time to time. Thus, you are advised to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately after they are posted on this page.

If You have any questions regarding this Privacy Policy, contact us using the details at "How to contact us" section below.

2. Who we are

Black Hornet Game Studio is a software developer and a publisher. In order to provide our Services, we collect, store and use Your data as a data controller and processor. The data we are in control of is provided by Users to our Services, collected automatically by our Services and provided to us by any third-parties (see "Third parties" section below).

3. What information is being collected

We collect the information with either Your explicit consent in accordance with GDPR article 6(1)(a) or as part of our legitimate interest in accordance with GDPR article 6 (1)(f), including:

3.1 Information that you provide voluntarily

Certain parts of our Services may ask you to provide personal information voluntarily. For example, we may ask for certain information in order to register an account with us, to begin playing Games, to subscribe to marketing communications from us, and/or to submit enquiries to us, such as:

The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be explained to you when we ask you to provide Your personal information.

If you wish to delete your information that we received when you contacted us, please contact us using the information in the "How to contact us" section below.

BHGS has implemented age-gate to its Games to verify players age. We do not store Your age but we use this information to set the maximum content rating. Please see "Children's Privacy" section below for more information.

3.2 Information that we collect automatically

When you use our Services, we may also collect certain information automatically from you and/or Your device which may be considered personal information under applicable data protection laws, such as:

Advertising ID means Apple Identifier for Advertisers ("IDFA") on Apple and Google Advertising Identity ("GAID"). These are unique identifiers for mobile device that advertisers use for personalized advertising. They are consistent across all mobile applications and thus allow cross-app tracking. On Apple, you can opt out of it by choosing "limit ad tracking" option in Your privacy settings. On Google Android, you can opt out of these ads by choosing "Opt-out of personalized ads". Advertising IDs are non-permanent, non-personal identifiers, which are uniquely associated with Your device. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognize Your device when you use websites and applications.

Device ID or information means device type, device model, device maker, device operating system and its language or other technical data like screen size or processor, or a combination of this data available from a device for a developer for checking the device compatibility with a particular application.

For more information on mobile privacy settings, You may refer to Google's privacy policy:

Please note that we do not currently provide any Services working on Apple's iOS.

3.3 Advertising

We use advertising in our Services so we can continue to offer many of our Services for free or at low cost. When You use our Services we rely on our legitimate interest to show contextual advertisements to You. Before sharing any information with our advertising partners for the purposes of interest-based advertising, we will always ask for Your consent.

When advertisers or ad networks place ads in our Services, they may collect the following types of information from within our Services:

Our advertisers need to collect this data in order to find appropriate ads to serve You in our Services. Black Hornet Game Studio does not control which specific ads are shown in the Services (this is controlled by ad networks), but we do prohibit certain types of ads.

Advertising IDs are used by ad networks for a number of purposes (please refer to the Privacy Policies of our advertising partners listed at "Third parties" section below) including, for example:

Ad networks track which games You have used to market You similar kind of games.

Your IP address is typically used by advertisers to identify Your general geographic location, for example, Your country, state and, sometimes, Your city).

The foregoing data may be used and disclosed in accordance with this Privacy Policy and the privacy policy of the company providing the ad serving technology.

Our advertising partners may combine this information with information which they have collected about You when You use their services (or the websites or services of third parties) in order to serve You more relevant ads in our Games or to improve the accuracy of their targeting and measurement systems.

This Privacy Policy does not apply to the collection of Your information by our advertising partners.

For the list of all the current data controllers and processors see "Third parties" section below.

Your privacy is important to us, so we follow not only applicable legislation, but also accepted market practices, such as respecting Your privacy preferences on your device. You can choose to opt out of interest-based advertising via "Opt Out of Interest-Based Ads" on Your Android device and all advertising providers are bound to comply with such setting, but we cannot provide any guarantees on their behalf. If You choose to withdraw your consent available via our Services, we will not share your advertising ID with advertisers for the purposes of interest-based advertising.

Should you decide to opt out of advertising altogether, you may make an in-app purchase "Remove ads" to do so, or you can stop using the Services.

3.4 Information we obtain from third party sources

We may receive personal information about you from third-party sources. We may get Your personal information for example when you installed our Game and prior to installing you have clicked on an advertisement for the same Game.

From time to time, we may also receive personal information about you from other third-party sources. For example, if you clicked on an advertisement to direct you to one of our Services (such as an advert of one of our Games in other publisher's game), we will be provided with information from which ad network and advertising campaign the install originated from.

Please see "Third parties" section below to get full information about our partners.

3.5 No special categories of information

We do not request or intend to collect any "special categories of information" such as any information on health, race, religion, political opinions or philosophical beliefs, sexual preferences or orientation. Please, be cautious when sharing this information about Yourself (or others) using our Services.

4. Why we collect the data

We may use Your data for the following purposes:

5. What we do with the information we collect

We use the information we collect to provide the Service to You. Our goal is to make our Services the most enjoyable and without the information about Your playstyle we cannot conclude about why Users prefer certain things among the others. It's necessary for us to use Your information:

We have a legitimate interest in both improving User experience and learning from our past products in order to gain knowledge on how to develop better Services. In short, it's necessary for us to collect this data and You may often find that without allowing us to automatically collect this anonymized data the Service won't work as expected or may not work at all.

Information collected automatically will be used only for general statistics in order to improve the Services' functionality and correctness. The way You interact with our Services may affect Your gameplay and we may target You with certain offers more often than others. For example, we may recommend You playing more difficult levels if our algorithm noted that You completed certain levels distinctly faster than other Users. That way both we and Users benefit from sharing Your information to:

We also may analyze and use the information that we collect on an anonymized or aggregated basis for product development, to analyze the performance of our games, to troubleshoot and to improve and optimize the games to ensure the best player experience for our players as a whole.

6. Who will the data we collect be shared with

We may disclose Information to third-parties when it is required by law or by law enforcement entity in accordance with binding regulations.

We, as a data controller, make sure that the data processing carried out on our behalf always meets regulatory requirements and ensure the protection of the rights of the data subject. Third party companies or individuals that we employ to process information work on our behalf based on our instructions and in compliance with this Privacy Policy.

We contract with third parties to provide certain services to facilitate the operations of our Services, such as to manage the analytics information about the usage of our Services. Our service providers will be given access to Your information as reasonably necessary to provide the services for which they are contracted. Current data controllers and processors are listed in the "Third parties" section below.

We may share information that can be used to personally identify your device (e.g. persistent identifiers such as advertising ID and IP address) for the purposes of delivering our services, displaying advertisements, conducting analysis and research and for measuring our and our partners's advertising campaign performance. We may share such information to:

7. For how long will we retain Your information

We collect Your data for as long as You use our Services. How long we retain this information depends on why we collected it and how we use it. We retain the collected data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

When information is no longer needed, we shall delete it using reasonable measures to protect the information from unauthorized access or use.

8. Payment Information

Some of our Games enable in-app purchases. We do not process payments for in-app purchases and do not have access to Your credit card information.

Payment transactions for in-app purchases are completed through the app store via Your Google Play account. Any post-purchase processes are controlled by the Google Play store and are subject to specific terms of Google Play store. Please review the privacy policy and terms of service of Google Play store.

9. Children's Privacy

Protecting children's privacy online is very important to us. Generally, our Services are not directed to children under 13 (or other age as required by local law), and the Services do not knowingly collect personal data from children, except as described in the following paragraph.

BHGS has implemented age-gate to its Games to verify players age. Even if You are below the age needed for providing a valid consent for targeted advertising and profiling, You can continue accessing our Services. However, there will be no profiling and targeted advertising, Our Services will then only contain contextual advertising. We will only collect data, on players under 13 (or the applicable age in their territory) years of age, when it is needed to provide the Services and ensure that they are protected in accordance with the applicable privacy laws.

We do not store age of users who have identified themselves as a child in our Services, the information that their device did not pass the age gate will be saved into these devices.

If we discover that we hold personal data relating to a child, we will take appropriate measures to ensure that we process that data according to the requirements of applicable laws and regulations or promptly delete the data from our records. If You are a parent or legal guardian of a child under the age of 13 (or other age as required by local law) who uses our Services, please contact us using the information in the "How to contact us" section below, if You have any questions or comments. On Your request we will delete Your child's personal information if we are able to identify Your child, unless You provide us with Your verifiable consent for Your child to continue to use our Services.

10. Disclosure for California residents

The following section applies to only to residents of California.

If you are a California resident, please be aware that under the California Consumer Privacy Act of 2018, as amended (“CCPA”), you are entitled to receive specific information on how we process your data. You also have specific rights to your data, including the right to opt out of the sale of your personal information. Your rights under California law are described in the section "Your data protection rights" below. If you have any questions or you wish to exercise your rights please contact us using the information in the "How to contact us" section below.

The categories of personal data we have collected in the preceding 12 months, and the sources of said data, are described in the section "What information is being collected" in the section above with exception that we do not collect any personal information of the California residents with purpose of selling. Specifically for AdMob we use Restricted data processing setting for California residents, so Google restricts how it uses certain unique identifiers and other data. Google only shows non-personalized ads from Google demand to eligible users in California. Non-personalized ads are based on contextual information, such as the content of the application.

11. Security of Your Information

We use appropriate technical and organizational measures designed to protect the personal information that we collect about You and process. The measures we adopt are designed to provide a level of security appropriate for the degree of risk involved with processing Your personal information.

While we take precautions against possible security breaches of our Services and our databases, no transmission is completely secure. We cannot guarantee that data loss or security breaches will never occur. We have a legal obligation to notify You when a security breach occurs.

12. International data transfers

Your personal information may be transferred to and processed in, countries other than the country of which You are a resident. These countries may have data protection laws that are different from the laws of Your country.

Specifically, our headquarters are located in Poland and our third-party service providers and partners operate around the world. This means that when we collect Your personal information we may process it in different countries. However, we ensure appropriate safeguards are in place so that Your personal information will remain protected in accordance with this Privacy Policy.

13. Your data protection rights

You have the following data protection rights:

You can control and limit the type of personal information we collect and process about you in a number of ways. For example, you can reset Your mobile Advertising ID or limit ad tracking altogether using the settings on Your phone (see definition of "Advertising ID" in the section "What information is being collected" above).

We will respond to all requests we receive from Users wishing to exercise their data protection rights in accordance with applicable data protection laws.

14. Links to Other Sites

The Services may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, We strongly advise you to review the Privacy Policy of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

15. Third parties

We contract with third parties to provide certain services to facilitate the operations of our Services. Current data controllers and processors are listed in this section.

Third party data controllers

Party Function Link to Privacy Policy
Google Play Transaction handler Privacy Policy
Google Play Game Services Leaderboards, achievements and cloud save of user progress Privacy Policy
Google AdMob Advertising and analytics Privacy Policy

Third party data processors

Party Function
Google Analytics for Firebase Service to collect and verify analytics information
Firebase Crashlytics Service to measure application crash events
Firebase Remote Config Service to provide configuration for application remotely

Firebase by Google

We use the Firebase service from Google LLC in order to derive application behavioral analytics. We use that information to see how users interact with our website and app.

Firebase is part of the Google Cloud Platform and offers numerous services for developers. Some Firebase services process personal data. In most cases, the personal data is limited to so-called "Instance IDs", which are provided with a time stamp. These "Instance IDs" assigned by Firebase are unique and thus allow the linking of different events or processes. This data does not represent personally identifiable information for us, nor do we make any efforts to personalize it subsequently. We process these aggregated data to analyze and optimize usage behavior, for example by evaluating crash reports.

Currently, we use the following Firebase services:

The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter f GDPR. Google is certified under the Privacy Shield Agreement and thus guarantees compliance with European data protection legislation

16. How to contact us

If, for any reason, You are concerned with the way that We may be using Your personal information, You have questions about the privacy aspects of the Services please contact us at

Please note that other third parties (our data partners) may be data controllers of Your information. More information regarding the third parties We work can be found in the "Third parties" section above.