This Privacy Policy explains how the Formula Swim iPhone app (the "App") handles information. The App is developed and published by Eric Doroshenko, an individual developer based in Washington, USA ("I", "me", "my"). I am responsible for the App. Google acts as an independent controller of the data it collects when it serves ads, and its own privacy policy applies to that data.
Summary
- The App has no accounts of its own and does not ask for your name, email or other personal information. Signing in to Apple's Game Center is optional (see below).
- I do not run a server for the App. Your scores and settings are stored on your device. If you choose to sign in to Game Center, your distances and achievements, including ones you earned before signing in, are also sent to Apple (see below).
- Ads are provided by Google AdMob, which may collect certain device and usage data as described below. Ads are limited to Google's PG content rating or lower.
- Your advertising identifier is only used for tracking if you allow it through Apple's App Tracking Transparency prompt.
- In the UK, Switzerland, Norway, Iceland and Liechtenstein, the App asks for your consent using Google's consent message before any ads are requested. In US states with privacy laws, you can opt out of targeted advertising in the App. You can change your choice at any time in the App under Settings → Privacy choices.
- The optional Remove Ads purchase is processed entirely by Apple. I never see your payment information.
- The App is rated 13+ and is not directed at children under 13.
Information stored on your device
I do not collect, store or receive any personal information through the App. There is no sign-up, no Formula Swim login and no server operated by me that the App sends your data to.
Your high scores, recent runs, car colour, unlocks and settings (such as units and sound volume) are saved locally on your device. They are not transmitted to me, and they are deleted if you delete the App. If you are signed in to Game Center, your distances from runs finished while signed in and your achievements, including ones already earned on this device, are also sent to Apple's Game Center. Deleting the App does not remove them from Game Center.
Game Center (optional)
Formula Swim works fully without Game Center. The App offers Game Center sign-in once on the main menu, and you can also sign in from Settings; you can skip it and keep playing. If you sign in, the App sends Apple your distance in Chill, Normal and Extreme (in metres) for runs you finish while signed in, and your achievements. The first time you sign in, achievements you already earned on this device, including the Silver, Gold and Diamond awards for cars you already own, are sent to Game Center once; after that, new achievements are sent as you earn them. These can then appear on Game Center leaderboards and your Game Center profile. Depending on your Game Center settings, other players may see your Game Center nickname, scores and achievements. The App receives your Game Center player identifier and nickname from Apple and uses them only for Game Center features (and keeps your identifier on your device so an award isn't sent twice). When you open the Global leaderboard, the App also loads the top Game Center scores and the nicknames of the players who posted them from Apple, only to show them on that screen, and does not save them. None of this is sent to me, to Google AdMob or to any advertiser. Apple handles Game Center information under its own privacy policy: https://www.apple.com/legal/privacy/data/en/game-center/. You can sign out, or change who can see your Game Center activity, in the Settings app under Game Center. To have Game Center data deleted, contact Apple through its privacy page.
Advertising (Google AdMob)
The App shows ads served by Google AdMob, a service of Google LLC, through the Google Mobile Ads SDK. Ads are limited to Google's PG maximum ad content rating. No ads are requested until Google's consent message (where required) and then Apple's App Tracking Transparency prompt have both been answered. Google acts as an independent controller of the data it collects through its ads. When ads are requested and displayed, Google and its advertising partners may automatically collect information such as:
- Advertising identifier (IDFA), only if you tap "Allow" on Apple's App Tracking Transparency prompt. If you do not allow tracking, the IDFA is not shared.
- IP address, and an approximate (coarse) location derived from it.
- Device information, such as device model, operating system version, language and screen size.
- Usage and ad interaction data, such as which ads were shown, whether they were viewed or tapped, and in-app activity related to ads.
- Diagnostics, such as crash, performance and ad-loading data.
Google uses this information for advertising (including personalized ads where you allow them), ad measurement and analytics, and fraud and abuse prevention. I do not receive this information in a form that identifies you. I only see aggregated reports, such as the number of ads shown.
Google's handling of this data is governed by Google's own policies:
App Tracking Transparency and your advertising identifier
Your iPhone has an advertising identifier (IDFA). Apps may only use it to track you across other companies' apps and websites if you give permission through Apple's App Tracking Transparency (ATT) prompt.
- On first launch, after Google's consent message (if one is required where you are), the App shows a short screen explaining that it is free thanks to ads. When you tap Continue, Apple's tracking prompt appears.
- Tap Allow to let the IDFA be used for more relevant ads, or tap Ask App Not to Track to decline. If you decline, the IDFA is not shared, and you will still see ads that are not personalized using it.
- You can change this at any time in iOS under Settings → Privacy & Security → Tracking. Turn off Formula Swim there, or turn off "Allow Apps to Request to Track" for all apps.
In-app purchase (Remove Ads)
The App offers an optional one-time "Remove Ads" purchase. It removes all ads and includes 3 free revives that recharge one at a time, 30 minutes each. Purchases and restores are handled entirely by Apple through the App Store using StoreKit. I never receive your name, Apple ID, payment card or billing details. The App only receives confirmation from Apple that the purchase is active, so it can turn off ads on your device. After you buy Remove Ads, the App makes no further ad requests, does not start Google's ads software and does not show the consent message or tracking prompt automatically. Privacy choices in Settings still works.
Notifications
If you own Remove Ads, the App may ask for permission to send a local notification when all your free revives have recharged. This permission is only requested after you use a free revive. These notifications are scheduled on your device, and no data is sent to me.
Users in the UK, Switzerland, Norway, Iceland and Liechtenstein
The App is not offered on the App Store in the European Union. This section applies to users in the United Kingdom and Switzerland, and in Norway, Iceland and Liechtenstein (European Economic Area countries outside the EU).
How consent is collected
The App uses Google's User Messaging Platform (UMP), a separate Google software development kit (SDK) for consent that works alongside the Google Mobile Ads SDK. Each time the App starts, it first checks with Google whether a consent message is needed in your region. If you are in one of the regions above, the App shows Google's consent message before the tracking prompt and before any ads are requested. You can consent to personalized ads, consent to non-personalized ads only, or decline. If you decline, you may still see Google's "limited ads", which do not use cookies or identifiers for personalization. Your choice is stored on your device and passed to Google and its ad partners so they can respect it.
How to withdraw or change consent
You can review, change or withdraw your consent at any time. Open Settings in the App and tap Privacy choices in the Privacy section. This option appears whenever a consent choice applies to you, or while the App hasn't yet been able to check with Google. Withdrawing consent does not affect processing that happened before you withdrew it.
Legal bases
- Consent (UK GDPR / GDPR Art. 6(1)(a), Swiss data protection law, and the rules on storing or reading information on your device): personalized ads and non-personalized ads, and the related storage or access of cookies or identifiers on your device, given through Google's consent message.
- Legitimate interests (Art. 6(1)(f)): only Google's "limited ads", which are shown without consent and without cookies or identifiers for personalization, together with the related invalid-traffic and fraud prevention, to keep the App free.
- Contract (Art. 6(1)(b)) and legitimate interests: processing the Remove Ads purchase and restores. Apple handles this processing as the App Store operator.
Your rights
Under the UK GDPR, the GDPR as it applies in Norway, Iceland and Liechtenstein, and Swiss data protection law, you have the right to:
- Access the personal data held about you.
- Rectification of inaccurate data.
- Erasure of your data.
- Restriction of processing.
- Object to processing based on legitimate interests.
- Data portability.
- Withdraw consent at any time.
- Complain to a supervisory authority, such as the data protection authority where you live or work. In the UK this is the Information Commissioner's Office (ICO), and in Switzerland the Federal Data Protection and Information Commissioner (FDPIC).
I do not hold personal data about you, because the App has no accounts or server. Data collected for ads is held by Google, and you can exercise your rights directly with Google at policies.google.com/privacy. Purchase data is held by Apple. You can also email me and I will help where I can. Data collected by Google may be transferred to and processed in the United States and other countries under the safeguards described in Google's Privacy Policy.
US state privacy rights
Residents of California and other US states with consumer privacy laws (for example, Virginia, Colorado, Connecticut, Utah, Texas and Oregon) may have the right to:
- Know what personal information is collected, used and disclosed.
- Delete personal information.
- Correct inaccurate personal information.
- Opt out of the "sale" or "sharing" of personal information for targeted (cross-context behavioral) advertising.
- Not be discriminated against for exercising these rights.
I do not sell personal information for money. However, allowing Google AdMob to use device identifiers for personalized ads may count as "sharing" or "targeted advertising" under some state laws. To opt out, open Settings in the App and tap Privacy choices, then follow Google's US state privacy options. You can also tap Ask App Not to Track on the ATT prompt, or turn off tracking for Formula Swim in iOS under Settings → Privacy & Security → Tracking.
Because I do not hold personal information about you, most requests to know, delete or correct are fulfilled by Google for ad data, or by deleting the App for data stored on your device. You can still email me with a request and I will respond within the time required by law. If I decline your request, you can appeal by replying to my response at formulaswimapp@gmail.com; I'll respond within 45 days. If your appeal is denied, you can contact your state's Attorney General. If you exercise any of these rights, you will not be treated differently. The App and all its features keep working the same way.
Children's privacy (under 13)
The App is rated 13+ on the App Store. It is not directed at children under 13, and I do not knowingly collect personal information from children under 13. If I learn that personal information from a child under 13 has been collected in connection with the App, I will delete it, and I will ask Google to delete any such data it holds. If you believe a child under 13 has provided personal information, please email formulaswimapp@gmail.com.
Data retention
Because I do not collect personal information, I do not retain any. Data stored on your device remains there until you delete the App. Scores and achievements sent to Game Center are kept by Apple under its Game Center privacy policy. Data collected by Google AdMob is retained according to Google's Privacy Policy.
Security
Your game data stays on your device and is protected by iOS, except the scores and achievements sent to Game Center if you choose to sign in. Communication between the App and Google's ad servers uses encrypted connections provided by Google's software.
Changes to this policy
I may update this Privacy Policy from time to time, for example if the App's features or advertising partners change. The updated version will be posted on this page with a new effective date.
Contact
If you have questions or want to make a privacy request, email formulaswimapp@gmail.com.
Eric Doroshenko, Washington, USA