This Privacy Policy explains how Individual Entrepreneur Afinogenov Sergei Olegovich (“we”, “us”, the “Developer”), the publisher of the mobile game Vials: ASMR Sand Sort Puzzle (the “Game”), handles information in connection with your use of the Game.
Short version: the Game is a single-player puzzle. We do not require an account, and we never ask for your name, email address, or precise location. Your game progress is stored on your device and, if you enable cloud backup, in your own Apple or Google account. To run the Game we use a small number of third-party services for purchases, basic usage analytics, optional rewarded advertising, and crash reporting, described in detail below.
The data controller is the Developer named above (an individual entrepreneur registered in the Republic of Armenia, registration / taxpayer No. 2408000572). For any privacy question or request you can contact us at vialsgame.play@gmail.com.
We are established outside the European Economic Area (EEA). The Game does not require an account and collects no special-category data; any processing of EEA users’ data is occasional and limited in scale. On that basis we rely on the exemption in Article 27(2) GDPR and have not appointed an EU/UK representative. If this changes, we will update this policy and appoint one as required.
| Category | What | Why | Where it goes |
|---|---|---|---|
| Game progress & settings | Solved levels, coins, helper counts, sound/music and language preferences | To save your progress and let you continue playing | Stored only on your device (local storage). Not transmitted to us. |
| In-app purchases | An anonymous purchase/transaction identifier and the product you bought. We never see your card number, name, or billing address. | To deliver the item you bought, restore non-consumable purchases, and handle refunds | Processed by Apple App Store / Google Play and by our purchase processor RevenueCat, Inc. See section 4. |
| Local notifications | Reminder notifications are scheduled and shown entirely on your device. We do not use push tokens or a server, and we send nothing to ourselves. | To remind you about hearts/daily rewards (you can turn these off) | Stays on your device. |
| Connectivity status | Whether the device is currently online or offline (a yes/no signal) | To adapt features that need a connection | Used in-app only; not transmitted or stored by us. |
| Usage analytics & crash reports | Anonymous, aggregated events about how the Game is used (e.g. levels started/completed, screens viewed), plus app version, device model, operating-system version, language, and crash diagnostics. A service-assigned identifier is used; this is not tied to your name or email. | To understand which levels are too hard or easy, fix crashes, and improve the Game | Processed by Google Firebase (Analytics, Crashlytics, Remote Config). |
| Advertising | If you choose to watch an optional rewarded ad (e.g. for hearts/coins), our advertising partners may process your device’s advertising identifier (IDFA on iOS, where you have granted permission via the App Tracking Transparency prompt; Advertising ID on Android), coarse device and ad- interaction data. | To show rewarded ads and measure that they were delivered | Processed by Google AdMob and its mediation partners (AppLovin, Meta Audience Network, Mintegral). Ads are optional — you are never required to watch one to play. |
| Cloud save (optional) | A copy of your game progress | To back up and restore your progress across your own devices | Stored in your own iCloud account (iOS) or Google Play Games Saved Games (Android). We do not run our own server; the data lives in your platform account. |
We rely on these third parties only for the purposes above. Where required by law, we ask for your consent before processing analytics or advertising identifiers (for example, the App Tracking Transparency prompt on iOS and a consent dialog in applicable regions).
Where the GDPR applies, we process your data on the following legal bases:
The Game relies on these providers for the functions described above:
We are based in the Republic of Armenia, and the third-party providers above (Google, RevenueCat, AppLovin, Meta, Mintegral) are located mainly in the United States and other countries outside your own. Using the Game therefore involves transferring data internationally, including outside the European Economic Area. Where such transfers occur, they are protected by appropriate safeguards — for EEA/UK data, the European Commission’s Standard Contractual Clauses (or the UK equivalent) as implemented by those providers, alongside their own data-transfer frameworks. You can request more detail about these safeguards using the contact below.
The Game is suitable for a general audience but is not directed to children under the age of 13 (or the equivalent minimum age in your country). In parts of the EEA the digital age of consent is higher — up to 16 — and where it applies, the relevant local minimum age governs. We do not knowingly collect personal information from children, and we do not serve personalized (interest-based) advertising. If you believe a child has provided us with information, contact us and we will delete it.
Depending on where you live (e.g. the EEA/UK under GDPR, or California under the CCPA/CPRA), you may have rights to access, correct, or delete personal information, to object to or restrict certain processing, and to data portability. Because your game data lives on your device, you can exercise the simplest form of this right at any time by deleting the Game, which removes all locally stored data. For purchase records held by the app stores or RevenueCat, contact us at vialsgame.play@gmail.com and we will assist.
EEA/UK: you also have the right to lodge a complaint with your local data protection authority (in the UK, the Information Commissioner’s Office) if you believe we have not handled your data lawfully.
California (CCPA/CPRA): we do not “sell” your personal information, and we do not “share” it for cross-context behavioral advertising as those terms are defined under the CCPA/CPRA. We honor opt-out preference signals (such as Global Privacy Control) where required.
Local game data is kept on your device until you delete it or uninstall the Game. Purchase records are retained by the app stores and RevenueCat for as long as required to provide and support the purchase and to meet legal obligations — in particular, tax and accounting records are kept for the period required by applicable law (typically several years). Analytics and crash data are retained only in aggregated or short-lived form by the relevant provider.
We may update this Privacy Policy as the Game evolves — for example, if we change a third-party provider or add a new feature. When we do, we will revise the “Last updated” date above and, for material changes, surface a notice in the Game. Continued use after an update means you accept the revised policy.
Questions or requests: vialsgame.play@gmail.com.