Privacy Policy
1. Who we are
This Privacy Policy is issued by Klim Sarakeev IE, trading as Somnaut Entertainment ("Somnaut", "we", "us"), an individual entrepreneur registered in the Republic of Armenia, 41 Zoravar Andranik St., Dilijan 3903, Tavush, Armenia. We are the data controller for the processing described here.
Privacy questions, requests and copyright complaints: legal@somnaut.org.
2. What this policy covers
This policy applies to the mobile games published by Somnaut (the "Games") and to the website at somnaut.org (the "Site"). It does not cover third-party services that you reach through our Games or Site, which have their own policies.
3. This website collects nothing
The Site is a set of static pages. It sets no cookies, runs no analytics, embeds no trackers and loads no third-party fonts or scripts. Our hosting provider processes standard server request data, including IP address, transiently in order to deliver pages and mitigate abuse.
4. What our Games collect
We do not ask you to create an account. We do not collect your name, email address, phone number, contacts, photos, precise location, or the contents of your device.
Our Games include third-party software development kits ("SDKs") for advertising, analytics and crash reporting. Through those SDKs the following data is collected automatically:
- Advertising identifier — the resettable Google Advertising ID (GAID) of your device.
- Device and technical information — device manufacturer and model, operating system and version, screen size, device language, coarse country or region derived from IP address, network connection type, app version.
- Crash and diagnostic data — stack traces, error logs, the state of the app at the time of a crash, session duration, and device state such as available memory.
- Gameplay events — in-app actions such as levels started and completed, progression milestones, session length, ad impressions and, where applicable, in-app purchase events.
- IP address — processed by our SDK providers for fraud prevention, coarse geolocation and ad delivery. We do not store IP addresses ourselves.
We have no access to your Google Play account details or payment card data. In-app purchases, where offered, are processed entirely by Google Play; we receive only anonymised transaction confirmations.
5. Why we process this data
| Purpose | GDPR legal basis |
|---|---|
| Showing advertising, including personalised advertising | Your consent (Art. 6(1)(a)) |
| Product analytics — understanding how the Games are played so we can improve them | Your consent (Art. 6(1)(a)) |
| Crash reporting and stability, fraud and abuse prevention | Our legitimate interest in a working, secure product (Art. 6(1)(f)) |
| Responding to your support or privacy requests | Legitimate interest, and legal obligation where the request is a statutory one (Art. 6(1)(f), 6(1)(c)) |
Where we rely on consent, you may withdraw it at any time — see section 9. Withdrawal does not affect processing that took place before withdrawal.
6. Third-party services we use
These providers act as independent controllers or as our processors, depending on the service. They receive the data described in section 4.
| Provider | Purpose | Data received | Policy |
|---|---|---|---|
| AppLovin MAX (AppLovin Corporation) | Advertising mediation and delivery | Advertising ID, device and technical information, IP address, ad interaction events | applovin.com/privacy |
| Unity Ads (Unity Technologies) | Advertising delivery | Advertising ID, device and technical information, IP address, ad interaction events | unity.com/legal |
| GameAnalytics (GameAnalytics ApS) | Product analytics | Device and technical information, gameplay events, coarse region, pseudonymous user identifier | gameanalytics.com/privacy |
| Firebase Crashlytics (Google LLC) | Crash reporting and stability monitoring | Crash logs and stack traces, device and technical information, Firebase installation ID | firebase.google.com/support/privacy |
| Google Play (Google LLC) | Distribution and in-app billing | Handled by Google under its own policy; we receive no payment details | policies.google.com/privacy |
7. Sharing and disclosure
We do not sell your personal data for money. We share data only with the providers listed in section 6, and where we are legally required to do so — for example in response to a valid legal request, or to establish or defend legal claims.
Note for California residents: sharing an advertising identifier with advertising networks for the purpose of cross-context behavioural advertising is treated as a "sale" or "sharing" of personal information under the CCPA as amended by the CPRA, even though no money changes hands. See section 10 for how to opt out.
8. Retention and international transfers
We retain crash reports for up to 90 days and aggregated analytics for up to 24 months. Our SDK providers apply their own retention periods, set out in their policies.
Our providers are established in the United States and the European Union, so your data may be transferred outside your country of residence. Transfers out of the European Economic Area and the United Kingdom rely on the European Commission's Standard Contractual Clauses or on an applicable adequacy decision.
9. Advertising choices
You can limit or reset advertising tracking at any time:
- On your device: Settings → Google → Ads → Delete advertising ID or Opt out of Ads Personalization. Once deleted, apps can no longer read your advertising ID.
- In the Game: where required by law we show a consent prompt on first launch. You can change or withdraw that choice from the Game's privacy or settings screen.
Opting out does not remove advertising — it makes the advertising you see non-personalised.
10. Your rights
If you are in the EEA, the UK or Switzerland (GDPR)
You have the right to access your personal data, to have inaccurate data corrected, to have your data erased, to restrict or object to processing, to data portability, and to withdraw consent at any time. You also have the right to lodge a complaint with your national data protection authority.
If you are in California (CCPA/CPRA)
You have the right to know what personal information we collect and how it is used and disclosed, the right to delete it, the right to correct it, the right to opt out of its sale or sharing, and the right not to be discriminated against for exercising these rights.
How to exercise your rights
Email legal@somnaut.org. Because our Games have no accounts, we may ask you for your advertising ID and the approximate date and time of play so that we can locate the relevant records. We respond within 30 days. There is no charge, and you may use an authorised agent.
11. Children
Our Games are intended for players aged 13 and over. They are not directed to children, and we do not knowingly collect personal data from anyone under 13. If you believe a child under 13 has provided us with personal data, write to legal@somnaut.org and we will delete it.
12. Security
We keep the data we hold to a minimum, use reputable providers, and access their consoles over accounts protected by two-factor authentication. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
13. Changes to this policy
If we change this policy we will update the effective date above and, for material changes, give notice in the Game before the change takes effect. Continued use after a change means you accept the updated policy.
14. Contact
Somnaut Entertainment
Klim Sarakeev IE
41 Zoravar Andranik St., Dilijan 3903, Tavush, Armenia
legal@somnaut.org