Privacy Policy — Sunless Grove
Version 1 · Last updated 17 September 2026 · Effective from the day it is published at owlnightstudio.com/privacy
Sunless Grove is a mobile game by Owlnight Studio — Oleksandr Shaniuk, an individual entrepreneur (FOP) registered in Ukraine (the "Studio", "we"). This policy explains which data the game and our website process, why, on what legal basis, who processes it for us, how long we keep it, and what choices and rights you have. It applies to the Sunless Grove app for iOS and Android and to owlnightstudio.com. Words like "personal data" and "processing" have the meaning given to them by the EU General Data Protection Regulation (GDPR).
Contact for anything about your data: privacy@owlnightstudio.com Postal address: Kyiv, Ukraine Player support: support@owlnightstudio.com
The short version
- No registration. The game creates an anonymous player ID on first launch. We do not ask for your name, e-mail address, phone number or postal address; we only receive an e-mail address if you write to us.
- Cloud save and leaderboards run on our own backend (Supabase, hosted in Ireland). Other players see only your nickname and your daily-challenge score.
- Play statistics and crash reports are optional. In the EEA, the United Kingdom and Switzerland we ask before collecting them; everywhere you can switch them off in Settings → Privacy. Statistics consist of event names and numbers, never free text you type.
- Ads (Google AdMob) fund the free game. Videos for rewards are always your choice. Personalised ads run only with your consent (the consent form in the EEA and the UK, the Allow Tracking prompt on iOS); you can change this at any time in Settings → Privacy.
- Purchases are made through Apple's App Store or Google Play. We do not receive your card or other payment details.
- Delete your profile with one tap: Settings → Profile → Delete profile. Section 6 lists the few records that are kept afterwards (for example anonymised purchase records required by tax law), and how to ask for the rest to be deleted by e-mail.
1. Who is responsible
The controller of the personal data described in this policy is Oleksandr Shaniuk, an individual entrepreneur (FOP) under the laws of Ukraine, trading as Owlnight Studio (contact details above and in section 11). We have not appointed a data protection officer, as the law does not require us to; every question about personal data goes to privacy@owlnightstudio.com. For advertising, Google is an independent controller (section 2.6); Apple and Google are independent controllers for the app stores and payments.
2. What we collect and why
Each table names the data, the purpose, the legal basis under the GDPR / UK GDPR (Article 6(1)) and how long the data is kept. "Contract" means Article 6(1)(b) (providing the game to you under our Terms of Service), "consent" means Article 6(1)(a), "legitimate interest" means Article 6(1)(f) (our interest in running, improving and protecting the game, balanced against your interests — you may object, see section 7), and "legal obligation" means Article 6(1)(c). Residents of Ukraine: the corresponding grounds of the Law of Ukraine "On Personal Data Protection" apply.
2.1 Anonymous account and cloud save
| Data | Why | Legal basis | Kept |
|---|---|---|---|
| Anonymous player ID — a random identifier created by our backend on first launch (no login, no password) | Links your cloud save, leaderboard entries and purchases without an account; also identifies you (pseudonymously) in statistics, crash reports and purchase validation | Contract | Until you delete your profile |
| Install token — a random code generated on your device and sent with every cloud save | Lets support tell which device wrote last when two devices conflict | Contract; legitimate interest (support) | Until you delete your profile |
| Game profile — heroes, souls and sun shards, run statistics, talents, mastery, depth tier, season progress, daily-quest state, offer counters, tutorial progress, and your in-game settings (language, sound, vibration, joystick mode) | Cloud save: continue on another device or after reinstalling; recovery after a crash | Contract | Until you delete your profile (a copy also lives on your device until you uninstall the game) |
The anonymous player ID is technically necessary for the game to work; without it cloud save, leaderboards and purchases cannot be provided. Everything else in this policy that is optional is marked as such.
2.2 Nickname and leaderboards
| Data | Why | Legal basis | Kept |
|---|---|---|---|
| Nickname — generated for you, or chosen by you (1–32 characters, checked against a word filter) | Shown to other players in the daily-challenge leaderboard | Contract | Until you rename it or delete your profile |
| Daily-challenge attempts — day, score, stages cleared, objectives, kills, level reached, time, win/loss, hero, modifier, and a compact log of the run used to verify the score on the server | Fair leaderboards (scores are validated server-side), cheat prevention | Contract; legitimate interest (anti-cheat) | Until you delete your profile |
Your nickname is visible to every player who opens the leaderboard, and other players may take screenshots of it. Treat it as public: do not use your real name or any contact details as a nickname.
2.3 Purchases
| Data | Why | Legal basis | Kept |
|---|---|---|---|
| Purchase records — store transaction ID, product, price, currency and store country, time, status (purchased / refunded), plus the unlocked items in your profile (No Ads, packs, heroes, season pass) | Grant what you bought, restore it on a new device, handle refunds, prevent double-granting, understand revenue | Contract; legal obligation (accounting and tax records); legitimate interest (fraud prevention) | Accounting records for the period required by Ukrainian accounting and tax law — currently 3 years from the end of the year of the purchase; when you delete your profile the records are anonymised (every identifier of your player is removed) |
| Payment details (card number, billing address, Apple ID / Google account) | Handled entirely by Apple or Google — we never receive them | — | See Apple's / Google's policies |
Purchase validation and restoration are performed for us by RevenueCat (section 4). RevenueCat receives your anonymous player ID and the store's signed receipt; it does not receive advertising identifiers from our app.
2.4 Play statistics (analytics) — optional
| Data | Why | Legal basis | Kept |
|---|---|---|---|
| Gameplay events — for example run started / ended, level-ups and cards picked, deaths, hero unlocked, screens opened, ad watched, purchase made — with numeric or category properties (hero, biome, stage, souls earned, duration) | Understand where players get stuck, tune balance and economy, measure features and A/B experiments | EEA / UK / Switzerland: consent (asked on first launch, changeable at any time). Elsewhere: legitimate interest, with an off switch in Settings → Privacy | Events up to 12 months; the player-level summary until you ask for it to be deleted; aggregated statistics that no longer identify anyone may be kept indefinitely |
| Player summary — days since install, runs, wins, heroes unlocked, wallet totals, streak, app language, whether crash reports are on | Same as above | Same as above | Same as above |
| Technical properties added by the analytics library — OS and version, device model, app version, language, time zone, screen size, network type | Compare behaviour across devices and versions | Same as above | Same as above |
| Approximate location (country / region / city) derived by the analytics server from your IP address at the moment an event is received | Regional balance and consent statistics | Same as above | Same as above |
Free text you type (such as a nickname) is never included in analytics. We have configured the analytics service to discard the IP address once the approximate location has been derived, and we do not use it for any other purpose. Analytics run on PostHog, hosted in the EU (Frankfurt). Where the consent question is asked, nothing is sent until you have answered it.
2.5 Crash reports — optional
| Data | Why | Legal basis | Kept |
|---|---|---|---|
| Crash and error reports — the technical stack trace, error type, device model and OS, app version, what the game was doing (hero, biome, stage, run seed), the last screens and event names before the crash, and your anonymous player ID. The report itself contains no IP address and no screenshots. | Find and fix crashes, freezes and errors | EEA / UK / Switzerland: consent; elsewhere: legitimate interest with an off switch | 90 days |
Crash reports run on Sentry, hosted in the EU (Frankfurt).
2.6 Advertising
Sunless Grove shows ads from Google AdMob (Google LLC; Google Ireland Limited for players in the EEA, the UK and Switzerland). Two kinds: rewarded videos that you choose to watch for an in-game benefit, and interstitials between runs with frequency limits. The No Ads purchase removes interstitials; rewarded videos stay optional.
Google's advertising software (the Google Mobile Ads SDK) runs inside the app and may collect:
- an advertising identifier — on iOS only if you allow tracking in the system prompt (IDFA); on Android the resettable Google Advertising ID;
- your IP address, from which Google estimates an approximate location, and technical details about your device (model, OS, app version, language);
- ad interactions — which ads were shown, clicked or watched to the end — and diagnostic data about the ad software itself;
- your consent choices (the TCF consent string) where the consent form applies.
Personalised ads only with consent. In the EEA, the UK and Switzerland a consent form is shown before any ad software starts; you can decline and still play (ads will then be non-personalised). On iOS, ads use the advertising identifier only if you tap Allow in the Allow Tracking prompt. You can revisit both decisions at any time (Settings → Privacy → Ads and your data → Ad privacy options, or iOS Settings → Privacy & Security → Tracking; on Android, reset or delete your advertising ID in Settings → Google → Ads). For advertising, Google acts as an independent controller: see Google's Privacy Policy and how Google uses information from sites or apps that use its services. We configure ads for a general (teen) audience and do not flag the game as child-directed.
2.7 Support and data requests
If you write to support@ or privacy@owlnightstudio.com we receive your e-mail address and whatever you send. We use it only to answer you and to carry out your request (legal basis: contract; legal obligation for privacy requests; otherwise legitimate interest). Support correspondence is kept for up to 2 years after the case is closed; a log of privacy requests (date, type of request, what was done) for 3 years.
2.8 Website
owlnightstudio.com is served by Cloudflare. Like any web server it records IP addresses and browser details for a short time to deliver pages and stop abuse. The site sets no cookies at all and runs no cross-site tracking, so browser signals such as Global Privacy Control require no action from us.
Visit statistics. The site counts page views and clicks on the store buttons with PostHog (EU servers) without cookies or any identifier stored in your browser: each page view gets a random number that is forgotten when you leave, and the IP address is discarded on arrival. We see aggregate numbers (pages, referring site, screen size, language), never a person. Browsers that send the "Do Not Track" signal are not counted at all.
"Tell me when it's out" form. If you leave your e-mail address on the front page, we store it — with the language and the place on the page you used, and the time — on our backend in the EU (Supabase) and use it for one e-mail on the day the game launches and, at most, one earlier one about a beta (legal basis: consent, which you give by sending the form). Nothing else is sent to it and the address is not shared. Every such e-mail carries an unsubscribe link; you can also write to privacy@owlnightstudio.com. The address is deleted when you unsubscribe or, if the launch e-mail bounces, after it; the list is emptied 12 months after launch at the latest.
Deletion request form (/delete-account). The form stores your Player ID, your e-mail address, your note and the time of the request so that we can find the profile, delete it and confirm to you. That entry is the log of privacy requests described in 2.7 (legal basis: legal obligation) and is kept for 3 years.
2.9 What stays on your device only
Your profile file, settings, reminder schedule, the tilt sensor used for the menu parallax, and sound are processed on your device and not collected. Reminders are local notifications; there are no push notifications and no push tokens.
2.10 What we do not collect
Name, e-mail address or phone number (unless you write to us), precise location, contacts, photos, camera or microphone, biometrics, health data, payment details, or — knowingly — any data from children under 13.
2.11 Automated decisions and experiments
We make no decisions about you that have legal or similarly significant effects. Some game rules and offers are shown by simple in-game conditions (for example an offer after a run, or a reroll price once free rerolls are used) and some are tested in A/B experiments, where players are assigned to a variant at random by their anonymous ID; the variants differ only in game rules, texts or prices of virtual items, and every price is shown before you buy.
3. Your choices
- Consent question (EEA, UK, Switzerland): on first launch you choose whether to allow play statistics and crash reports. Not now is a complete answer — nothing is sent, and no feature is withheld.
- Settings → Privacy: switches for Play statistics and Crash reports; Ads and your data → Ad privacy options reopens the ad consent form where it applies; Ad tracking shows the iOS tracking status with a shortcut to the system settings.
- Ads on iOS: the Allow Tracking prompt decides whether ads may use the advertising identifier.
- Ads on Android: reset or delete your advertising ID in the system settings; opt out of ad personalisation there too.
- Notifications: reminders are optional and controlled in Settings and in your system settings.
- Delete profile: Settings → Profile → Delete profile removes your cloud save, nickname, leaderboard entries and anonymous account and wipes the local profile (section 6).
4. Who processes data for us
| Provider | What for | Where | More |
|---|---|---|---|
| Supabase (Supabase Inc.) | Backend: anonymous accounts, cloud save, leaderboards, purchase ledger, remote configuration; the website's e-mail list and deletion requests | Ireland (AWS eu-west-1) | Privacy |
| PostHog (PostHog Inc.) | Play statistics and experiments (only with your consent / unless switched off); cookieless visit counts on the website | Germany (PostHog Cloud EU) | Privacy |
| Sentry (Functional Software Inc.) | Crash reports (only with your consent / unless switched off) | Germany (EU data residency) | Privacy |
| RevenueCat (RevenueCat Inc.) | Purchase validation and restoration | United States | Privacy |
| Google AdMob (Google LLC / Google Ireland Ltd.) | Advertising — independent controller | Global | Privacy |
| Apple / Google Play | App distribution and payments — independent controllers | Global | Apple · Google |
| Cloudflare (Cloudflare Inc.) | Website hosting and its forms, e-mail forwarding | Global network | Privacy |
We do not sell personal data and do not share it with data brokers. The providers marked as processors act only on our instructions under data-processing agreements; Apple, Google (including AdMob) and the app stores are independent controllers for their own services and are bound by their own policies. We may also disclose data where the law requires it (for example to a court or a regulator) or to protect the game and its players against fraud and abuse, and if the Studio's business is transferred the data may pass to the successor under this policy.
5. International transfers
Our backend, analytics and crash reporting are hosted in the European Union. Where data leaves the EEA or the UK — to RevenueCat, Google or Apple in the United States — the transfer relies on the EU–US Data Privacy Framework (where the recipient is certified) and otherwise on the European Commission's Standard Contractual Clauses (with the UK Addendum where applicable). Ukraine is not an EEA country; the Studio itself accesses the data from Ukraine under those same safeguards. You can ask us for a copy of the safeguards at privacy@owlnightstudio.com.
6. How long we keep data, and deletion
| Data | Retention |
|---|---|
| Account, cloud save, nickname, leaderboard attempts | Until you delete your profile |
| Play statistics | Events up to 12 months; the player summary until deleted on request; anonymous aggregates may be kept |
| Crash reports | 90 days |
| Purchase records | 3 years from the end of the year of the purchase (accounting and tax law); anonymised when you delete your profile |
| Support e-mails | Up to 2 years after the case is closed; privacy-request log 3 years |
| Consent choices | On your device while the app is installed |
Deleting your profile in the app (Settings → Profile → Delete profile) deletes your anonymous account, cloud save, nickname and leaderboard entries without delay and removes every identifier of your player from the purchase records; the local profile is wiped and the game starts over. Crash reports expire within 90 days. Play statistics remain pseudonymous under the old ID, which after deletion refers to no one; if you want them deleted as well, or if you can no longer open the game, e-mail privacy@owlnightstudio.com with your Player ID (shown in Settings → Profile) — we act within 30 days. Full details: owlnightstudio.com/delete-account.
7. Your rights
EEA and UK residents have the rights to access their data, to have it rectified or erased, to restrict or object to processing (including processing based on legitimate interest), to data portability, to withdraw consent at any time without affecting processing that took place before the withdrawal, not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects (we make none), and to lodge a complaint with a supervisory authority — in the EU, the authority of your country (list); in the UK, the Information Commissioner's Office. Where processing rests on consent, the switches described in section 3 withdraw it.
Residents of Ukraine have the rights set out in the Law of Ukraine "On Personal Data Protection", including the rights to know about the processing, to access, correct and delete their data, to object to processing, and to complain to the Ukrainian Parliament Commissioner for Human Rights or to a court.
Residents of California and of other US states with privacy laws, to the extent those laws apply to us, may request access to, deletion or correction of their personal information, may opt out of the "sale" or "sharing" of personal information for cross-context behavioural advertising, and will not be discriminated against for exercising these rights. We do not sell personal data. Personalised advertising through Google AdMob may count as "sharing": you can opt out in Ad privacy options and in your device's advertising settings (section 3). We do not use or disclose sensitive personal information for purposes that would require a right to limit. The categories of personal information we have collected in the preceding 12 months are those listed in section 2, from the sources listed there (you, your device, our providers), for the purposes listed there, and disclosed only to the providers listed in section 4.
To exercise any right, e-mail privacy@owlnightstudio.com and include your Player ID (Settings → Profile); because accounts are anonymous, that ID is the only way we can find your data, and we may ask you to confirm the request from within the game. We answer within 30 days (extendable by up to two further months for complex requests, where the law allows, in which case we tell you). Requests are free of charge unless they are manifestly unfounded or excessive. You may use an authorised agent where the law provides for it.
8. Children
Sunless Grove is intended for players aged 13 and over, and — where your country sets a higher age for consenting to data processing (up to 16 in parts of the EU) — for players of that age or with a parent's or guardian's consent. The game is not directed at children, and we do not knowingly collect personal data from children under 13. If you believe a child has given us personal data, write to privacy@owlnightstudio.com and we will delete it.
9. Security
All traffic between the game and our providers is encrypted (TLS). Your backend session is stored in the secure storage of your device (Keychain / encrypted preferences). Access to our backend and dashboards is limited to the Studio and protected by two-factor authentication. No system is perfectly secure; if a personal-data breach affects you, we will inform you and the competent authorities as the law requires.
10. Changes
We will update this policy when the game changes — for example when a service is added or removed. The version and date at the top show when it changed. We announce material changes in the game or on our website before they take effect, and where your consent is needed again the consent question is shown once more; continuing to play after the effective date means the updated policy applies. Earlier versions are available on request.
11. Contact
Owlnight Studio — Oleksandr Shaniuk, individual entrepreneur (FOP), Ukraine privacy@owlnightstudio.com · support@owlnightstudio.com Kyiv, Ukraine