Privacy Policy

In short

• This website sets no cookies, uses no analytics or trackers and loads nothing from other servers.
• The app needs a little data to run the game: a random player ID, your game progress and some device facts.
• The app asks for your birth month and year once. It keeps only your age group, never the date.
• Players under 13 are not tracked and never get personalised ads. They can choose to watch a reward video, which is made for children: no advertising ID, no interest-based ads. Personalised ads are only for adults, who can turn them off at any time.
• Purchases go through Apple or Google. We never see your card details.
• You can delete your account in the app: Settings → Delete account.

Who is responsible

The controller for the website and the Hugstorm app is:

Managing director: Alexander Reiswich
Email: support@playhugstorm.com

For every privacy question or request, email support@playhugstorm.com.

This website

playhugstorm.com is a plain information page. It sets no cookies, stores nothing in your browser, has no analytics, no ads, no social media plug-ins and no embedded content from other servers. Fonts and images come from our own server.

The site is hosted by Cloudflare, Inc. (101 Townsend St., San Francisco, CA 94107, USA). To deliver the pages and keep them safe from attacks, Cloudflare processes technical data of every request: IP address, date and time, the page requested, browser and device type (user agent) and the referring page. We do not use this data to identify you. Cloudflare acts as our processor.

Legal basis: Art. 6(1)(f) GDPR — our interest in a secure, working website. Storing or reading information on your device (§ 25 TDDDG) does not take place.

The app: what we process and why

Your player ID and game data

When you first start Hugstorm, the app creates a random player ID. It is not linked to your real identity. Every player gets a generated player name (for example “Sunny Otter 42”) and can roll a new one; nobody types a name. With it the app keeps your progress: levels, the Grove, your Guardians and cards, coins, gems and other items, settings and your purchase history (so bought items are never lost). The app also reads technical facts about your phone — model, operating system version, app version, language and performance tier — to pick the right graphics quality and to fix problems.

Your progress is saved on your phone first. To back it up and to run online features (the weekly Garden League and the Pollen Race), the app creates an anonymous account at Google Firebase (Authentication, Cloud Firestore, Cloud Functions). Whenever you leave the app and your save has changed, the app uploads a copy of it — your levels, the Grove, your Guardians and cards, coins, gems and other items, settings and purchase history — at most every 15 minutes. This applies to every player, including children under 13: the backup is part of the game itself, never advertising, profiling or analytics, and it lets a reinstall on the same phone get progress and purchases back. The account has no name, email address or phone number; for a player under 13, any typed name is replaced with a generated one before the save leaves the device, and your birth date itself never leaves the device — only your age group is used. The first upload happens only once the app knows your age group, and the data is stored in Google’s data centre in Frankfurt, Germany (region europe-west3). Firebase App Check (on iPhone with Apple’s App Attest) confirms that requests come from the real Hugstorm app, to keep leagues fair and stop cheating. Other players never see your account ID. If the app finds a save from another device, it asks you to choose Keep device or Use cloud before changing anything on your phone; your purchases are kept either way. Deleting your account (Settings → Delete account) deletes this cloud copy too.

Legal basis: Art. 6(1)(b) GDPR — we need this data to provide the game you asked for.

Your age group

After the first few levels the app asks for your month and year of birth, with no pre-set answer. It keeps only your age group — under 13, 13 to 17, or 18 and over — and never stores the date. Where available, the app may also use the age range your phone shares (Apple Declared Age Range, Google Play Age Signals); the stricter result counts. We use the age group to protect younger players: no tracking for children and only child-directed, non-personalised reward videos, no personalised ads for teens, no pop-up offers or countdowns for children, and a grown-up check before a child follows a link out of the app.

Legal basis: Art. 6(1)(c) and (f) GDPR — protecting children and meeting our legal duties.

Renewed consent for under-18 players (Texas, Utah, Louisiana)

Some US states ask app stores to get a parent’s renewed consent, or to notify an adult, before an app makes a “significant” change. Where this applies, the app asks Apple to show its own consent or notice screen; we never see how a parent answers, only whether consent was given. Until a required consent is given, the app may hold back the affected features for that player.

For a player under 18, the app also reads (silently, through Apple’s StoreKit) the signed App Store transaction that names their Apple Account for this app, and sends it to our server once. We keep it only so that if a parent later withdraws consent for the app in Apple’s system, Apple can tell us (an App Store Server Notification, relayed through RevenueCat) and we delete that child’s account, save and league records straight away. It is never used for ads, profiling or analytics, and an adult account never keeps this identifier — it is removed if a player becomes an adult.

Legal basis: Art. 6(1)(c) GDPR — meeting these legal duties.

Purchases

In-app purchases and subscriptions are handled by the Apple App Store or Google Play under their terms. They process your payment; we never receive your card or bank details. To check that a purchase is real, to deliver it and to restore it on a new phone, we use RevenueCat (RevenueCat, Inc., USA) as our processor. RevenueCat receives your player ID, the store receipt (product, price, currency, date, transaction ID) and your platform.

Legal basis: Art. 6(1)(b) GDPR (delivering what you bought) and Art. 6(1)(c) GDPR (tax and accounting duties).

Ads

Hugstorm shows optional reward videos: you choose to watch one, for example to double a reward. Players who have not bought anything may also see a short ad between levels from level 10 on (for under-18s always non-personalised, see below). Ads are served by Google AdMob (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Google LLC, USA).

At the first start, before Level 1, the app does not know your age yet, so it asks everyone the same questions. Where the law requires it (the European Economic Area, the UK and Switzerland), Google’s consent form asks about ads. On iPhone and iPad, a short screen from us comes next, then Apple’s own request to allow tracking. To show the form, Google receives your IP address and basic device and app information. AdMob itself starts only after the age question. What your answers mean depends on your age group:

• Before the age question is answered: no ads. AdMob is not started.
• Under 13: reward videos the player chooses to watch and, for players who have not bought anything, possibly a short ad between levels. Every ad request is marked as child-directed (COPPA) and as coming from a user under the age of consent (GDPR), limited to content rated G (general audiences) and non-personalised. AdMob then sends no advertising ID, shows no interest-based ads and no remarketing, and uses only ad sources certified for Google Play’s Families program. No other ad network is used. This applies whatever was answered at the first start.
• 13 to 17: only reward videos, non-personalised, rated G and marked as coming from a user under the age of consent, whatever was answered at the first start.
• 18 and over: personalised ads only when all of these are true: “Personal ads” is on in your privacy choices (Settings → Privacy choices); where the law requires consent, you agreed in Google’s consent form; and on iPhone and iPad, you allowed tracking in Apple’s request. You can turn personalised ads off at any time in Settings → Privacy choices; in US states with privacy laws this is also how you opt out (see US state privacy rights).

For adults, AdMob may process your device’s advertising ID (IDFA on iPhone, only if you allow tracking; AAID on Android) and, on Android, the App Set ID. For every player it processes your IP address, which Google also uses to estimate your approximate location; device and app information; and how you interact with ads. Google also uses this to count views, limit repeats and prevent fraud. For players under 18, the ads are never personalised: Google uses this data to show the ad, count views, limit repeats and prevent fraud, not for interest-based ads or remarketing. For personalised ads Google acts as an independent controller; see how Google uses information from apps that use its services.

Legal basis: your consent, Art. 6(1)(a) GDPR and § 25(1) TDDDG, where the law requires consent; otherwise Art. 6(1)(f) GDPR (financing the free game). You can change your choice at any time in the app: Settings → Privacy choices.

Measuring our ads (Meta)

We advertise Hugstorm on Facebook and Instagram. To learn which ads bring players, the app uses Meta’s SDK (Meta Platforms Ireland Limited; Meta Platforms, Inc., USA), but only for players 18 and over, and only while “Personal ads” and “Game stats” are on in your privacy choices (Settings → Privacy choices: where the law requires consent, by your own choice; in US states with privacy laws this is also how you opt out) and, on iPhone and iPad, only if you allowed tracking in Apple’s request. Then the app tells Meta that it was installed and opened, when the tutorial is finished and when something is bought, together with device and app information, your IP address and the device’s advertising ID (IDFA on iPhone, AAID on Android). Meta uses this to measure our ads and to improve who sees them.

Before the age question, for players under 18, and whenever one of these choices is off, Meta’s SDK does not run and nothing is sent to Meta. If you turn a choice off later, the app stops sending to Meta at once and deletes on your device what Meta’s SDK had not sent yet. Deleting your account also deletes the identifiers Meta’s SDK kept on your device.

For collecting the data and passing it to Meta, we and Meta are jointly responsible (Art. 26 GDPR, Meta’s Controller Addendum); Meta alone is responsible for what it does with the data afterwards (Meta’s privacy policy). Legal basis: your consent, Art. 6(1)(a) GDPR and § 25(1) TDDDG, where the law requires consent; otherwise Art. 6(1)(f) GDPR (measuring our advertising); for US states, see US state privacy rights.

Measuring our ads (TikTok)

We also advertise Hugstorm on TikTok. To learn which ads bring players, the app uses TikTok’s SDK (TikTok Technology Limited, Ireland, and TikTok Information Technologies UK Limited; outside Europe, the TikTok company that runs TikTok’s advertising there), with the same limits as Meta’s: only for players 18 and over, only while “Personal ads” and “Game stats” are on in your privacy choices (Settings → Privacy choices: where the law requires consent, by your own choice; in US states with privacy laws this is also how you opt out) and, on iPhone and iPad, only if you allowed tracking in Apple’s request. Then the app tells TikTok that it was installed and opened, whether you came back the next day, when the tutorial is finished, when you win levels 5, 10, 15, 20, 30, 50 and 100 for the first time, what a watched ad earned us, when you start a purchase or a subscription, and when something is bought, together with device and app information (such as the model, system version, language and time zone), your IP address and the device’s advertising ID (IDFA on iPhone, AAID on Android). TikTok uses this to measure our ads and to improve who sees them.

Before the age question, for players under 18 and whenever one of these choices is off, TikTok’s SDK does not run and nothing is sent to TikTok. If you turn a choice off later, the app stops sending to TikTok at once and deletes on your device what TikTok’s SDK had not sent yet. Deleting your account also deletes the identifiers TikTok’s SDK kept on your device; only its note that the app was installed on this device stays, so that the device is not counted as a new install.

TikTok processes the data under its terms for business products, which set its role under data protection law, and under TikTok’s privacy policy. Legal basis: your consent, Art. 6(1)(a) GDPR and § 25(1) TDDDG, where the law requires consent; otherwise Art. 6(1)(f) GDPR (measuring our advertising); for US states, see US state privacy rights.

How the game is played and crash reports

To balance levels and fix what isn’t fun, the app records game events — for example level started or won, gates chosen, items earned or spent, shop visits, ad views, performance numbers and load times.

• Players 13 and over, after you agree where consent is needed: the events go to Google Analytics for Firebase (Google Ireland Limited / Google LLC), our processor, with a Firebase app-instance ID (on Android also the App Set ID). Google estimates your approximate location (country or region) from your IP address and does not store the IP address in Analytics. If you say no, no events are sent.
• Players under 13, before the age question and while a consent choice is still open: the app sends no usage statistics, or at most anonymous counts to our own server — the event name and small numbers such as the level, with no player ID, device ID or advertising ID and no third-party analytics.

If the app crashes for a player 13 or over who allowed game analytics (see above), Firebase Crashlytics (Google) receives a technical crash report (device model, OS version, app version, the part of the code that failed, a short error code). Crash reports contain no free text you typed. If you say no, no crash reports are sent. If you turn it off later, the app stops sending crash reports and deletes the ones it still holds; a report that was already being sent at that moment may still arrive. Players under 13 send no crash reports.

Legal basis: Art. 6(1)(f) GDPR — our interest in a working, well-balanced game; your consent under Art. 6(1)(a) GDPR and § 25(1) TDDDG where the law requires it.

Game settings, events and tests

The app downloads game settings and the event calendar from Google Firebase Remote Config. This uses a Firebase installation ID and your app version, country and language. The app also checks a small public settings file at playhugstorm.com/rc/live.json (safety switches such as a required update or a service notice); this is a plain request with no player ID, account ID or other identifier, and carries no player data. Legal basis: Art. 6(1)(b) GDPR.

Sometimes we try small changes with some of the players (A/B tests), for example the size of a reward or when a hint appears. Which version you get is worked out from your player ID. Players under 13 only take part in tests of the first tutorial levels, never in tests of prices, ads or offers, and their results stay anonymous counts. Legal basis: Art. 6(1)(f) GDPR — our interest in improving the game.

Game Center, Google Play Games and leagues

Players 13 and over can link their game to Apple Game Center or Google Play Games in Settings. Then we receive the player ID from that service to keep your progress across devices. Apple and Google are responsible for their own services. Players under 13 cannot link an account.

If you’re 13 or older and signed in, the app sends your highest level and your Bloom Stars (all-time and this week) to Game Center or Google Play Games leaderboards. Other players can see them there under your Game Center or Play Games name, according to Apple’s and Google’s settings. Players under 13 never send scores.

In the weekly Garden League and in Pollen Races, other players in your group see your player name, avatar, level and score. Every player name is generated by the game; our server accepts only such names. We check scores on our server to keep the league fair.

Legal basis: Art. 6(1)(b) GDPR.

Notifications

If you allow it, the app schedules reminders on your phone (for example “Your bakery is full”) — at most one a day and never at night. They are created on your phone; no push token is sent to us. You can turn them off in the app or in your phone’s settings.

Offers for adults

Adult players may see shop offers chosen from how they play (for example the level reached or items owned). This helps us show offers that fit. It has no legal or similarly significant effect on you. Children and teens don’t get these offers. Legal basis: Art. 6(1)(f) GDPR.

Store ratings

Now and then the app may ask your phone to show Apple’s or Google’s rating prompt. We never learn whether or how you rated.

When you contact us

If you email us, we use your email address, your message and any details you send (such as your player ID) to answer you. Settings → Send feedback opens your mail app with your app version, phone model and player ID filled in; you decide whether to send it. Our email is handled by Cloudflare, Inc. (receives and forwards the mail) and Google Ireland Limited (Gmail, stores the mail and sends the replies). Legal basis: Art. 6(1)(b) or (f) GDPR.

Children

Hugstorm is made for everyone, including children. For players who tell the app they are under 13:

• child-directed and non-personalised ads only: no advertising ID, no interest-based ads or remarketing, content rated G, and Google AdMob as the only ad network;
• no tracking: the tracking request at the first start comes before the app knows the age, and for a child it changes nothing;
• no crash reports and no link to Game Center or Google Play Games;
• only anonymous usage counts, without device IDs;
• no personalised offers, no pop-up offers, no countdowns, no purchase offers during a battle and no notifications about sales;
• a grown-up check (a parental gate) before any link out of the app. The app has no purchase check of its own: parents can require approval for purchases in Apple’s or Google’s family settings (how);
• a generated player name in leagues.

What we collect from children, and why

Only what the game needs to run: a random player ID, game progress and settings, the age group, technical facts about the phone (model, system and app version, language) and, if a purchase is made, the purchase record. We use this only for the internal operations of the game: saving and restoring progress, delivering purchases, keeping the game working and secure, and counting how the game is played without any ID. The player ID and the Firebase installation ID are persistent identifiers; we use them only for these internal operations — never for ads, profiling or contacting a child. Our service providers (Google Firebase, RevenueCat, and Apple and Google for the stores) process this data for us. We don’t sell or share it.

Reward videos for children

When a child chooses to watch a reward video, Google AdMob receives the IP address, device and app information and how the ad was used. This supports the internal operations of the app only: showing a contextual (not interest-based) ad, limiting how often it repeats, counting views and preventing fraud. Every such request is marked child-directed, so no advertising ID is sent and Google may not use the data for interest-based ads, remarketing or profiles. Closing a video early simply gives no reward.

How long we keep it

As long as the child plays. After the account is deleted, we delete the data as described under How long we keep data. An account that nobody has opened for 24 months is deleted from our servers. Purchase records are kept for tax law, apart from game data.

Parents

You can ask to see your child’s data, have it deleted, or stop any further collection (deleting the account stops it). Email support@playhugstorm.com with your child’s player ID (Settings → Player ID). We may ask a few questions to make sure the request comes from the child’s parent or guardian. We do not knowingly collect more from children than the game needs.

Service providers

We have data processing agreements with our processors. We do not sell your personal data for money. For the US, see US state privacy rights.

Data outside the EU

Some providers above are in the USA or may access data from there. Transfers rely on the EU–U.S. Data Privacy Framework where the recipient is certified under it (Art. 45 GDPR), and otherwise on the EU Standard Contractual Clauses (Art. 46(2)(c) GDPR).

How long we keep data

• Game account and saves: as long as you play. After you delete your account, we delete it from our servers within 30 days (usually at once); backup copies are gone within another 30 days.
• Accounts nobody opens: deleted from our servers after 24 months for players under 13 and players whose age is unknown, and after 36 months for players 13 and over.
• App Store transaction id (under-18 players): kept only as long as the account, removed when a player becomes an adult, and immediately if a parent withdraws consent for the app (their account and its data are then deleted straight away).
• Game analytics: up to 14 months, then deleted.
• Crash reports: 90 days.
• Purchase records: up to 10 years, because tax and commercial law requires it (§ 147 AO, § 257 HGB). They are kept apart from your game data.
• Emails: until your request is settled, unless the law requires us to keep them longer.
• Website request data at Cloudflare: only as long as Cloudflare needs it for delivery and security.

Your rights

You have the right to:

• get a copy of your data (Art. 15 GDPR);
• have wrong data corrected (Art. 16);
• have your data deleted (Art. 17);
• limit how we use it (Art. 18);
• receive your data in a common format (Art. 20);
• object to use based on our legitimate interests (Art. 21);
• withdraw consent at any time, for the future (Art. 7(3)).

To use a right, email support@playhugstorm.com and include your player ID (in the app: Settings → Player ID), so we can find your data. We answer within one month.

You can also complain to a data protection authority, for example where you live, or the one responsible for us: Berliner Beauftragte für Datenschutz und Informationsfreiheit (www.datenschutz-berlin.de).

Your right to object

Your choices in the app

• Ads and consent (also to opt out of selling or sharing in the US): Settings → Privacy choices.
• Tracking on iPhone: iPhone Settings → Privacy & Security → Tracking.
• Advertising ID on Android: Android Settings → Privacy → Ads (reset or delete the ID).
• Notifications: Settings → Notifications, or your phone’s settings.
• Delete everything: Settings → Delete account. How deleting works.

US state privacy rights

If you live in a US state with a consumer privacy law (for example California, Colorado, Connecticut, Virginia or Utah), this also applies:

• What we collect (in the last 12 months): identifiers (the player ID, Firebase IDs and, only for adults who allow it, the advertising ID); game activity and ad interactions; purchase records; device information; approximate location from the IP address; and what we infer for shop offers (adults only). We don’t collect sensitive personal information. Why we use it and how long we keep it is described above.
• Selling and sharing: we don’t sell personal information for money. When an adult allows personalised ads, Google AdMob uses data for ads based on activity across apps and websites. Some state laws call this “sharing” or “targeted advertising”. We never do this for players under 18.
• Your rights: to know what we collect and get a copy, to correct it, to delete it, to opt out of selling, sharing and targeted advertising, and not to be treated differently for using these rights. You can also ask through an authorised agent. If we turn a request down, you can appeal by replying to our answer.

Do Not Sell or Share My Personal Information

To opt out, open Settings → Privacy choices in the app and turn off personalised ads. On iPhone you can also turn off tracking in iPhone Settings → Privacy & Security → Tracking. Or email support@playhugstorm.com with the subject “Do not sell or share” and your player ID. This website collects nothing that could be sold or shared.

Security

This website is only served over encrypted connections (HTTPS). The app talks to our servers over encrypted connections too. Access to player data is limited to the people who need it to run the game.

Changes

If the app or the law changes, we update this policy and change the date at the top. For important changes we will also tell you in the app.