PRIVACY POLICY
Last Updated: October 3, 2026
1. Who we are
This Privacy Policy explains how Procedural Games processes personal data when you play our mobile games, including Startup Empire Tycoon, and use related services (the “Games”).
The data controller is Procedural Games, S.L. (Sociedad Unipersonal), NIF B70777016, with registered address at C/ dels Arquets, 19, 46870 Ontinyent (Valencia), Spain. You can contact us at games@proceduralgames.com.
This policy informs you about how we use your data. It is not a contract, and using the Games does not by itself mean you consent to anything. Where we rely on your consent, we ask for it separately inside the Game.
2. Information we collect
Our Games do not require an account, and we do not ask for your name, email or phone number to play.
When you play, we automatically collect technical data about your device (model, operating system and version, language, time zone, app version, crash and performance logs) and gameplay data (progress, session times, in-game events and achievements).
We also collect device identifiers: the advertising ID (IDFA on iOS, only if you allow tracking; GAID on Android), the IDFV or Android app set ID, and identifiers generated by our partners’ SDKs. From your IP address we derive your approximate country or region. We do not collect precise GPS location.
For advertising, we record which ads were shown, clicked or completed, and your consent choices. For attribution, we record which campaign or ad led you to install the Game.
In-app purchases: payments are processed by Apple (App Store) or Google (Google Play). We never receive your card or bank details. We receive a purchase confirmation with the product, price, currency, date and a transaction ID, which we use to deliver your purchase and prevent fraud.
If you contact us: we receive your email address and the content of your message.
3. Why we use your data and on what legal basis
Each use of your data has a specific legal basis under Article 6 of the EU General Data Protection Regulation (GDPR).
| Purpose | Data used | Legal basis |
|---|---|---|
| Running the Game, saving progress, fixing crashes | Device and technical data, gameplay data | ContractProviding the Game you downloaded |
| Delivering and verifying in-app purchases | Purchase confirmation, device identifiers | Contract |
| Showing ads that fund the Game (non-personalized) | Device and technical data, IP address, approximate location, ad data | Legitimate interestFunding a free game |
| Showing personalized ads | Advertising ID, IP address, ad and gameplay data | |
| Measuring which ad campaigns lead to installs (attribution) | Advertising ID, IP address, attribution data | |
| Custom and lookalike audiences for our own ad campaigns | Advertising ID | |
| Analytics to improve game design and balance | Gameplay data, device data | Legitimate interestImproving the Game |
| Preventing fraud and cheating | Purchase data, identifiers, gameplay data | Legitimate interestProtecting the Game and its players |
| Answering support requests | Email, message content | Contract Legitimate interest |
| Complying with tax, accounting and legal obligations | Purchase records | Legal obligation |
Where we rely on legitimate interest, you can object at any time (see section 9). We do not make decisions that produce legal or similarly significant effects about you based solely on automated processing.
4. Advertising and your consent choices
Our Games are free and funded by ads. We use Unity LevelPlay (ironSource) to choose which ad network shows each ad, and Adjust to measure our marketing campaigns.
In the EEA, UK and Switzerland: the first time you open the Game, a consent window from our consent management platform asks whether you agree to personalized ads and ad measurement. If you decline, you will still see ads, but they will not be based on your advertising ID or profile.
On iOS: we only access your IDFA if you tap “Allow” on Apple’s App Tracking Transparency prompt. You can change this in iOS Settings > Privacy & Security > Tracking.
On Android: you can reset or delete your advertising ID in your device settings (on most devices, Settings > Privacy > Ads, or Settings > Google > Ads).
Changing your choice: open the Game and go to Settings > Privacy to review or withdraw your consent at any time. Withdrawing consent does not affect processing carried out before you withdrew it.
5. Who we share your data with
We do not sell your data for money. We share it only with the partners below, each of which processes it under its own privacy policy.
| Partner | Role | Headquarters | Privacy policy |
|---|---|---|---|
| Unity Technologies (LevelPlay / ironSource, Unity Ads) | Ad mediation, ad network | United States | Link |
| AppLovin | Ad network | United States | Link |
| Google (AdMob) | Ad network | United States | Link |
| Meta Platforms (Audience Network, Meta Ads) | Ad network, custom and lookalike audiences | United States | Link |
| InMobi | Ad network | India / Singapore | Link |
| Liftoff | Ad network | United States | Link |
| Chartboost | Ad network | United States | Link |
| Adjust | Install attribution and campaign measurement | Germany | Link |
| Apple, Google | App stores and in-app payment processing | United States | Apple / Google |
We may also disclose data to public authorities when required by law, to protect our rights or our players’ safety, or to a buyer or successor if our company is involved in a merger, acquisition or sale of assets.
6. International transfers
Most of our partners are based outside the European Economic Area, mainly in the United States. These transfers are protected by the EU-US Data Privacy Framework for certified partners, by Standard Contractual Clauses approved by the European Commission, or by an adequacy decision for the destination country.
You can ask us for a copy of the relevant safeguards at games@proceduralgames.com.
7. How long we keep your data
| Data | Retention period |
|---|---|
| Gameplay and analytics data | Up to 24 months after your last session |
| Advertising and attribution data held by our partners | Under each partner’s own retention policy (see section 5) |
| Consent records | For as long as needed to prove your choice, up to 3 years after you withdraw it |
| Purchase records | 6 years, as required by Spanish commercial and tax law |
| Support emails | Up to 2 years after your request is closed |
When these periods end, we delete or anonymize the data.
8. Children
Our Games are not directed at children and are intended for players aged 13 and over. We do not knowingly collect personal data from children under 13.
In the EEA, the age at which you can consent to personalized ads yourself depends on your country (for example, 14 in Spain and 16 in Germany). If you are below that age in your country, you will only see non-personalized ads, and we will not use your advertising ID for personalized ads or attribution.
If you believe a child under 13 has given us personal data, write to games@proceduralgames.com and we will delete it.
9. Your rights
Under the GDPR and Spanish data protection law, you can access, correct or delete your personal data, restrict or object to its processing, and receive it in a portable format. You can also withdraw your consent at any time in the Game under Settings > Privacy.
How to exercise them: email games@proceduralgames.com. Because the Games have no accounts, include the user ID shown in Settings > Privacy so we can find your data. We reply within one month.
Complaints: you can file a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos, aepd.es) or with the authority in your country.
10. California residents
If you live in California, you have the right to know what personal information we collect, to request its deletion, to correct it, and not to be discriminated against for exercising these rights. Sharing your advertising ID with ad partners for personalized ads may count as “sharing” under the CCPA/CPRA. To opt out, turn off personalized ads in Settings > Privacy or email games@proceduralgames.com with the subject “Do Not Sell or Share”.
11. Security
We use encrypted connections and limit access to personal data to what each partner needs. No system is completely secure, but we will notify you and the authorities of any data breach as the law requires.
12. Changes to this policy
We will post any changes on this page and update the date at the top. If a change affects how we use your data based on consent, we will ask for your consent again in the Game.
13. Contact
Procedural Games, S.L. (Sociedad Unipersonal), NIF B70777016, C/ dels Arquets, 19, 46870 Ontinyent (Valencia), Spain. Email: games@proceduralgames.com
