Privacy Policy

1. Who we are

Holey: Swallow It All ("Holey", "the game") is developed and published by Digitalsynn Ltd, a company registered in England and Wales ("we", "us", "our"). We are the controller of the personal data described in this policy.

Company number: 11765997

Registered office: Unit A 82 James Carter Road, Mildenhall, Bury St. Edmunds, England, IP28 7DE

Contact for anything about privacy: info@digitalaynn.co.uk

2. What this policy covers

This policy covers the Holey app on iPhone, iPad and Android, and this website (holeygame.com). The website does not use cookies, analytics, advertising or any third-party scripts or fonts. The server that hosts it keeps standard access logs (IP address, date and time, page requested and browser type) for security and to keep the site running.

3. Data we process and why

3.1 Game data on your device

The game saves your progress, coins, items, settings and a record of what you have bought in the app's private storage on your device. We do not receive this data and it is not linked to your name or to any account.

Your device's own backup can include the save, so your progress can survive a reinstall or a new phone. On Android this is Android Auto Backup to your Google account. On iPhone and iPad it is your iCloud or computer backup. These backups are run by Google or Apple under your own account and settings, and we cannot see them. Uninstalling the game deletes this data from the device.

3.2 Support log on your device

The game keeps a small, rolling text log of recent app events and errors (holey-support.log) on your device only. It contains technical information such as screens opened and error messages, not your name or contact details. It is excluded from device backups. It only reaches us if you choose to email us from the game (see 3.8).

3.3 Your privacy choices

The choices you make in the consent messages and in Settings are stored on your device so the game and its partners can respect them. The game may also send a record of the choice (for example "analytics on, tracking denied") as an analytics event, if analytics is allowed.

3.4 Rewarded video ads (Google AdMob)

Holey only shows an ad when you tap a button to watch one for a reward, such as a continue, double coins, a free chest or a free booster. There are no banner ads and no forced full-screen ads.

So that a video is ready when you tap, the game starts the Google Mobile Ads SDK and loads rewarded videos in the background once your consent choices allow ad requests (and, on iPhone and iPad, after the tracking prompt). Loading an ad sends an ad request to Google even if you never watch it. When ads are requested, shown or interacted with, Google AdMob (Google LLC, and Google Ireland Limited for users in the EEA, UK and Switzerland) collects:

• your device's advertising ID: the Android Advertising ID, or on iPhone and iPad the IDFA, but only if you allow tracking;
• your IP address, which Google uses to estimate approximate location (for example country or city);
• device and app information, such as device model, operating system, language, app version and network type;
• ad interactions and diagnostics, such as which ads were loaded and shown, whether you watched or tapped them, and performance data.

Google uses this data to deliver and measure ads, limit how often you see the same ad, and prevent fraud and abuse. Ads are personalised only if you consent (in the UK, EEA and Switzerland) or have not opted out (in US states with privacy laws). Otherwise Google serves non-personalised or limited ads, which can still use data such as approximate location and device information for delivery, measurement and fraud prevention.

The game tells Google it is not directed at children and caps ad content at a rating suitable for teenagers (Google's "T" rating). To learn more, see How Google uses information from sites or apps that use its services, the Google Privacy Policy and Google's business data responsibility pages.

3.5 Play statistics (Unity Analytics)

The game can send gameplay statistics to Unity Gaming Services Analytics, run by Unity Technologies. We use them to find bugs, see which levels are too hard or too easy, and improve the game. In the UK, EEA and Switzerland, statistics stay off unless you agree in the consent message. Elsewhere they are on by default and you can switch them off at any time in Settings > Privacy > Options. Your opt-out always wins.

The data sent is:

• gameplay events: level start, win, loss, quit and continue (with level number, world, time taken and hole size); tutorial steps; Zen, Battle and event sessions; boosters used or bought; settings changed; rewarded ads offered and watched; purchases started, completed, failed and restored (with the product ID and price); your privacy choices;
• session start and length, and save-file health checks;
• app version, device model, operating system and language;
• country or region, which Unity works out from your IP address;
• a random installation ID created by Unity. This is not your advertising ID and is not linked to your name.

We do not send your name, email address or any contact details to Unity.

3.6 Crash and error reports (through Unity Analytics)

Under the same choice as 3.5, the game sends short error reports to Unity Analytics so we can fix bugs: the error message and where in the game's code it happened, whether the previous session ended unexpectedly or the game froze, and a short trail of your most recent in-game actions (for example "level_start", "ad"). If statistics are off, these reports stay on your device in the support log.

3.7 In-app purchases

In-app purchases and the VIP subscription are sold and paid for through Apple's App Store or Google Play. We never see your card or payment details. When you buy something, the store gives the game a signed transaction record (product ID, transaction or order ID, and for subscriptions the renewal status and period). The game checks it on your device using the Unity In-App Purchasing library (Google Play Billing on Android, StoreKit 2 on Apple devices) and then unlocks what you bought. We do not run a server that receives your receipts. Apple and Google process your payment under their own privacy policies. If statistics are allowed, the purchase event in 3.5 is also recorded.

3.8 When you contact us

In Settings > Support > Email us, the game opens your own email app with a message to us that already contains the game version, platform, operating system, device model and the last lines of the support log. Nothing is sent until you press send, and you can edit or delete any of it first. When you email us, we receive your email address, your message and anything included or attached. We use it only to answer you and deal with your request.

3.9 What we do not collect

• No accounts, names, logins or passwords.
• No precise location. The game does not ask for location permission.
• No camera, microphone, contacts, photos or files.
• No chat, messaging or user-generated content. Battle rivals are computer-controlled.
• No payment card details.
• No push notifications and no Game Center or Google Play Games sign-in.

4. Your choices and consent

On first launch the game runs its privacy steps before any ad is requested:

1. UK, EEA and Switzerland: Google's consent message (Google User Messaging Platform, using the IAB Transparency and Consent Framework) appears. You can accept, reject, or choose by purpose and by partner. Your answer controls personalised ads and whether play statistics are collected.
2. US states with privacy laws (such as California, Colorado, Connecticut, Virginia, Utah, Texas and Oregon): where Google's US state regulations message is shown, you can opt out of the "sale" or "sharing" of personal information and of targeted advertising. You can also opt out by emailing us.
3. iPhone and iPad: the game shows a short explanation, then Apple's App Tracking Transparency prompt. The IDFA is only used if you tap Allow. You can change this at any time in iOS Settings > Privacy & Security > Tracking.

Changing your mind: in the game, open Settings (the gear icon on the home screen) > Privacy > Options. You can switch play statistics off or on, ask Unity to delete the statistics already sent from your device, and, where your region has them, reopen Google's ad choices to change or withdraw consent.

Your advertising ID: on Android you can reset or delete it in your device's Settings > Privacy > Ads (wording varies by device). On iPhone and iPad, turning off "Allow Apps to Request to Track" stops apps from using the IDFA.

5. Legal bases (UK GDPR and EU GDPR)

Withdrawing consent does not affect processing that took place before you withdrew it.

6. Who receives data

• Google (AdMob and the Google consent message): Google LLC and Google Ireland Limited. For ads, Google acts as an independent controller for some purposes and as our processor for others, as set out in Google's ads data protection terms.
• Unity Technologies (Analytics, including crash and error reports, and the In-App Purchasing library): our processor for statistics and crash reports. See the Unity Game Player and App User Privacy Policy.
• Apple and Google as app stores, for app distribution, purchases and subscriptions, under the Apple Privacy Policy and the Google Privacy Policy.
• Our email and website hosting providers, who store support emails and website logs for us.
• Authorities, only if the law requires us to share data.

We do not sell personal data for money and we do not share it with data brokers.

7. International transfers

Google and Unity may process data in the United States and other countries outside the UK and EEA. Where they do, they rely on the safeguards in their own terms: the EU Standard Contractual Clauses, the UK International Data Transfer Addendum, and, where they are certified, the EU-US Data Privacy Framework and its UK Extension. You can ask us for more information about these safeguards.

8. How long data is kept

• Game data and support log on your device: until you uninstall the game. The support log rolls over and only keeps recent entries.
• Play statistics and crash reports: kept by Unity in line with its retention policy, and deleted earlier when you ask for deletion in the game or by email.
• Advertising data: kept by Google in line with Google's retention policy.
• Support emails: for as long as we need to answer you and keep a record of your request, then deleted.
• Website access logs: kept by the hosting provider for a limited period for security, then deleted or overwritten.

9. Your rights (UK and EU)

Under the UK GDPR and the EU GDPR you have the right to be informed (this policy), to access the personal data we hold about you, to have it corrected, to have it deleted, to restrict or object to processing (including processing based on legitimate interests), to data portability, and to withdraw consent at any time.

Because there are no accounts, we usually cannot link data to you by name. The fastest way to act on statistics data is the in-game Settings > Privacy > Options screen, which sends a deletion request to Unity for this installation. For anything else, email us. We may ask for details that help us find your data, such as your device model and roughly when you played. We reply within one month. See also our data deletion page.

10. US state privacy rights (including California)

If you live in California or another US state with a consumer privacy law, you have the right to know what personal information we process, to access it, to correct it, to delete it, to opt out of its "sale" or "sharing" and of targeted advertising, and not to be treated differently for using these rights.

In the last 12 months, the categories of personal information processed through the game were:

• Identifiers: advertising ID, Unity installation ID, IP address.
• Commercial information: products bought, as a product ID and price.
• Internet or other electronic network activity: gameplay events, ad requests and ad interactions.
• Geolocation data: approximate (country, region or city) only, derived from IP address.

They come from your device and are used for the purposes in section 3, and disclosed only to the recipients in section 6. We do not sell personal information for money. Letting Google use data for personalised ads may count as "selling" or "sharing" under some state laws. You can opt out in the game's privacy options where Google's US message is shown, or by emailing us with "Do not sell or share" in the subject. We do not collect sensitive personal information, and we do not knowingly sell or share the personal information of anyone under 16.

To make a request, email us. You can use an authorised agent. We respond within 45 days. If we refuse a request, you can appeal by replying to our answer with "Appeal" in the subject line.

11. Children

Holey is intended for players aged 13 and over. It is not directed at children, it is not part of Google Play's Designed for Families programme or Apple's Kids category, and its store listings target ages 13 and over. We do not knowingly collect personal data from children under 13. The game tells Google that its ad requests are not child-directed and limits ad content to a teen rating. In EEA countries that set a higher age for consenting online (up to 16), younger players should ask a parent or guardian before giving consent. If you believe a child under 13 has used the game and data was collected, contact us and we will help delete it.

12. Security

All data the game sends to Google and Unity is encrypted in transit using HTTPS (TLS). Data on your device is kept in the app's private storage, which other apps cannot read. This website is served over HTTPS only. No system is completely secure, but we keep the data we handle to a minimum.

13. Google Play: Data safety summary

AndroidThis section lines up with the Data safety section of Holey's Google Play listing. It summarises sections 3 to 12; the full details above apply.

• Data collected: yes, as listed below. Data shared: yes, with Google for advertising (Unity acts as our service provider, so data sent to Unity is collected, not shared).
• Encrypted in transit: yes, all of it.
• Accounts: the app has no accounts and no sign-in.
• Deletion: you can ask for your data to be deleted. See the data deletion page, or use Settings > Privacy > Options in the game for statistics data.
• Target audience: ages 13 and over. Not in the Designed for Families programme.
• Ads: yes, rewarded videos only, from Google AdMob.

Data types collected by the Android app

Data type	Shared with a third party	Required or optional	Purposes	Source
Location: approximate location	Yes (Google)	Required while ads are enabled	Advertising; analytics; fraud prevention and security	AdMob and Unity, derived from IP address
Device or other IDs	Yes (Google)	Required while ads are enabled	Advertising; analytics; fraud prevention and security	Android Advertising ID (AdMob); random Unity installation ID
App activity: app interactions	Yes (Google)	Required while ads are enabled	Analytics; advertising; fraud prevention and security	Ad interactions (AdMob); gameplay events (Unity, optional)
App info and performance: diagnostics	Yes (Google)	Required while ads are enabled	Analytics; advertising; fraud prevention and security	Ad performance (AdMob); device, OS, app version, session length (Unity, optional)
App info and performance: crash logs	No	Optional	Analytics; app functionality	Unity Analytics error events
Financial info: purchase history	No	Optional	Analytics	Unity Analytics (product ID and price)

"Required while ads are enabled" means: once your consent choices allow ad requests, the game loads rewarded videos in the background, so Google receives this data even if you never watch an ad. Statistics data sent to Unity is always optional and can be switched off in the game.

Not collected: name, email address, user IDs, phone number, address, precise location, contacts, messages, photos, videos, audio, files, calendar, health and fitness, web browsing or search history, installed apps, payment information.

14. Apple App Store: App Privacy summary

iPhone and iPadThis section lines up with the App Privacy details ("privacy nutrition label") on Holey's App Store page. It summarises sections 3 to 12; the full details above apply.

Data used to track you

Only if you allow it in Apple's App Tracking Transparency prompt, Google AdMob uses your device's advertising identifier (IDFA) and advertising data to show and measure ads across apps and websites owned by other companies. If you tap "Ask App Not to Track", the IDFA is not available to the game or to Google, and Google serves ads without it.

App Privacy categories for the iOS and iPadOS app

Data type	Linked to you	Used to track you	Purposes
Identifiers: device ID	Yes (device identifiers only, no account)	Yes, IDFA only with your permission	Third-party advertising; analytics
Usage data: advertising data	Yes	Yes, only with your permission	Third-party advertising
Usage data: product interaction	Yes	No	Analytics
Location: coarse location (from IP address)	Yes	No	Third-party advertising; analytics
Purchases: purchase history	Yes	No	Analytics
Diagnostics: crash data	No	No	App functionality; analytics
Diagnostics: performance and other diagnostic data	No	No	Analytics; third-party advertising

"Linked to you" here means linked to a device identifier. Holey has no accounts and never collects your name, email address or contact details. Not collected: contact info, health and fitness, financial info other than purchase history, precise location, sensitive info, contacts, user content, browsing history, search history.

Tracking and consent on Apple devices

• In the UK, EEA and Switzerland, Google's consent message comes first. In US states with privacy laws, Google's US state message may be shown. Then the game shows a short explanation followed by Apple's tracking prompt.
• You can change tracking at any time in iOS Settings > Privacy & Security > Tracking, and your ad and statistics choices in the game under Settings > Privacy > Options.
• The Google and Unity components in the app ship with the privacy manifests Apple requires, describing the data they use.

In-app purchases on Apple devices

Purchases and the VIP subscription are handled by Apple through StoreKit. Apple processes the payment; we never see your payment details or Apple ID. The game verifies Apple's signed transaction on your device. Manage or cancel subscriptions in iOS Settings > your name > Subscriptions, and request refunds at reportaproblem.apple.com.

15. Changes to this policy

We may update this policy when the game or the law changes. The effective date at the top shows the current version. If a change is significant, we will tell you in the game and ask for consent again where needed.

16. Contact and complaints

Email: info@digitalaynn.co.uk

Digitalsynn Ltd, Unit A 82 James Carter Road, Mildenhall, Bury St. Edmunds, England, IP28 7DE

If you are not happy with how we handle your data, you can complain to the UK Information Commissioner's Office (ICO) at ico.org.uk/make-a-complaint or on 0303 123 1113. If you live in the EEA, you can also complain to your local data protection authority. We would appreciate the chance to help first, so please contact us.