1. Who We Are (Data Controller)

Data Controller: Cyberbit Genesis LLC Address: 16192 Coastal Hwy, Lewes, DE 19958, United States Email for privacy requests: info@cyberbitgenesis.com

2. Information We Collect

We collect the following categories of data (consistent with the Google Play Data Safety declaration and actual usage):

Data we collect / process

• Device or other IDs (installation ID, advertising ID where applicable, etc.).
• Personal info – User IDs (Unity Player ID / UAS ID, linked external IDs from Google Play Games, Apple Game Center, Meta, etc.).
• App activity – App interactions, other user-generated content (pet name, customisations, progress, actions performed).
• App info and performance – Crash logs, diagnostics, other app performance data.
• Financial info – Purchase history (Holocoins and Digital Content purchases).
• Device information (model, OS version, etc.).
• IP address (often anonymised or pseudonymised).
• Optional contact information only if you email us for support.

 

We do not collect sensitive personal data (racial/ethnic origin, political opinions, health data, precise real-time location for tracking, etc.) beyond what is strictly necessary for the AR/MR experience on the device.

Data processed by Unity Gaming Services (Unity Technologies acts as independent controller or processor depending on the service):

• Unity Authentication (Player ID and linked external identities).
• Unity Cloud Save (progress, pet data, customisations).
• Unity Analytics / Economy (usage events, purchase events, crash data, etc.).

Please also read Unity’s Game Player and App User Privacy Policy: https://unity.com/legal/game-player-and-app-user-privacy-policy

Platform providers (Meta, Google, Samsung, Apple) collect and process data according to their own privacy policies when you use their sign-in or billing systems.

3. How We Use Your Information and Legal Bases (GDPR)

• Provide and operate the Game, synchronise cloud saves, manage accounts and Holocoins → performance of contract.
• Analytics, crash reporting, product improvement → legitimate interest (or consent where required).
• Fraud prevention, security, compliance → legitimate interest / legal obligation.
• Advertising or marketing purposes (as declared in Data Safety) → consent or legitimate interest where permitted.
• Respond to support requests → legitimate interest / performance of contract.
• Comply with legal obligations → legal obligation.

4. Sharing of Information

We share data with:

• Unity Technologies (Authentication, Cloud Save, Analytics, Economy).
• Platform operators (Meta, Google, Apple) for authentication, billing and platform requirements.
• Technical service providers strictly necessary for hosting, security and operations.
• Competent authorities when legally required.

 

Advertising

We share certain personal data (including device identifiers, advertising IDs, approximate location derived from IP address, app activity and, where applicable, purchase history) with Unity Technologies through the Unity Ads service for the purposes of displaying advertisements, personalizing ads, measuring ad performance, fraud prevention and analytics.

Under the California Consumer Privacy Act (CCPA/CPRA), this sharing of data for cross-context behavioral advertising may constitute a “sale” or “sharing” of personal information.

We do not sell personal data in exchange for money. We do not share personal data with third parties for their independent direct marketing purposes outside the advertising services described above.

You can control personalized advertising through:

• the privacy options offered by Unity Ads (in-ad privacy icon / consent flow),
• your device settings (Limit Ad Tracking / App Tracking Transparency on iOS, opt-out of ads personalization on Android),
• and by contacting us at info@cyberbitgenesis.com.

5. International Data Transfers

Data may be transferred to the United States and other countries. We use appropriate safeguards (Standard Contractual Clauses or equivalent mechanisms approved under GDPR).

6. Data Retention

• Account and game-progress data: retained for as long as the account is active or until you request deletion.
• Analytics data: generally retained according to Unity’s retention periods (typically up to 13 months or as updated by Unity).
• Purchase records: retained as required by tax and accounting laws.
• After deletion request we delete or anonymise data within the legal timeframes (normally ≤ 30 days, subject to technical constraints of third-party services).

7. Your Rights

Depending on your location (especially if you are in the EU/EEA, UK or California) you have the right to:

• Access, rectification, erasure (“right to be forgotten”), restriction, objection, data portability.
• Withdraw consent at any time (where processing is based on consent).
• Lodge a complaint with a supervisory authority (e.g. Garante per la Protezione dei Dati Personali in Italy, or your local authority).

To exercise these rights, or to request account/data deletion, contact us at info@cyberbitgenesis.com.

For data controlled solely by Unity you may also use Unity’s own mechanisms (including the player account deletion page where applicable).

8. Account and Data Deletion – Practical Instructions

See Section 9 of the Terms of Service for the detailed procedure.

In short:

• Email us with sufficient identifiers so we can locate and delete your Unity Authentication account + all associated Cloud Save, Economy and Analytics data under our control.
• Platform accounts (Google Play Games, Apple Game Center, Meta) are not deleted by us.

You can also request deletion via the Google Play Data Safety section or Apple’s privacy tools where available.

9. Security

Data is encrypted in transit. We implement appropriate technical and organisational measures. No system is 100% secure.

10. Children’s Privacy

The Game is not directed at children under 13. We do not knowingly collect personal data from children under 13. If we become aware of such data we will delete it.

11. Changes to This Privacy Policy

We may update this Policy. Material changes will be notified via the Game or other reasonable means. The “Last Updated” date will be revised.

12. Contact

Cyberbit Genesis LLC

16192 Coastal Hwy, Lewes, DE 19958, USA

Email: info@cyberbitgenesis.com

Website: https://cyberbitgenesis.com