Privacy Policy

Last updated: July 24, 2025

Important Notice: This Privacy Policy applies to users worldwide and complies with the EU General Data Protection Regulation (GDPR), UK Data Protection Act 2018, Swiss Federal Data Protection Act (FADP), California Consumer Privacy Act (CCPA), and Apple App Store requirements.

This Privacy Policy describes how Witch Odyssey ("we," "our," or "us") collects, uses, stores, and shares personal and non-personal data from users of our mobile application in compliance with applicable data protection laws.

1. Data Controller Information

Data Controller: ACM Interactive

Contact: contact@acm-interactive

EU Representative: Not applicable (we are established in European Union).

2. Information We Collect

2.1 Automatically Collected Data

Data Category	Specific Data	Purpose	Legal Basis
Advertising Identifiers	Google Advertising ID (Android), Identifier for Advertisers - IDFA (iOS)	Personalized advertising via Google AdMob	Consent (GDPR), Legitimate Interest (other jurisdictions)
Device Information	Device type, OS version, language, timezone, unique device identifiers	App functionality, analytics, crash reporting	Legitimate Interest
Usage Analytics	App interactions, session duration, feature usage, performance metrics	App improvement, bug fixes	Legitimate Interest
Technical Data	IP address (anonymized), app version, crash logs, performance data	Technical support, security	Legitimate Interest

2.2 Cookies and Similar Technologies

We use cookies, web beacons, and SDKs to collect information about your browsing behavior and ad interactions. This includes:

Session cookies for app functionality
Analytics cookies for usage measurement
Advertising cookies for personalized ads (with consent)

3. Third-Party Services

3.1 Google AdMob

Purpose: Monetization through targeted advertising

Data Shared: Advertising ID, device information, location data (if permitted), ad interaction data

Privacy Policy: Google Privacy Policy

Data Processing: Google may process data in the US and other countries

User Controls: You can limit ad tracking in device settings or visit Google Ads Settings

3.2 Google Analytics for Firebase

Purpose: Anonymous usage analytics and app improvement

Data Collected: App events, user interactions, crash reports, performance metrics

Data Anonymization: All data is aggregated and anonymized - no personally identifiable information is collected

Privacy Policy: Google Privacy Policy

Opt-out: iOS users can disable analytics sharing in: Settings > Privacy & Security > Analytics & Improvements > Share iPhone Analytics

3.3 Firebase (Google)

Purpose: App infrastructure, crash reporting, performance monitoring

Data Processing: Technical data for app stability and performance

Data Anonymization: Personal identifiers are not collected or stored

Privacy Policy: Firebase Privacy Policy

4. Legal Basis for Processing

4.1 European Union (GDPR)

Consent: For advertising cookies and personalized ads (obtained via Google UMP)
Legitimate Interest: For analytics, app improvement, fraud prevention, and technical functionality
Contractual Necessity: For core app functionality

4.2 United Kingdom (UK GDPR/DPA 2018)

Same legal bases as EU GDPR apply.

4.3 Switzerland (FADP)

Consent: For advertising and marketing purposes
Overriding Legitimate Interest: For analytics and app improvement

4.4 United States

California (CCPA/CPRA): Processing based on business purposes and user consent for advertising.
Other States: Processing based on legitimate business interests and user consent where required.

Notice under California Consumer Privacy Act (CCPA): We do not sell personal information collected through this app to third parties.

5. Data Sharing and International Transfers

5.1 Third-Party Sharing

We share data with the following categories of recipients:

Google Services: AdMob, Analytics, Firebase (as described above)
Advertising Partners: Aggregated, anonymized data for advertising optimization
Legal Authorities: When required by law or to protect our rights

5.2 International Data Transfers

Important: Your data may be transferred to and processed in countries outside your jurisdiction, including the United States. These transfers are protected by:

Google's compliance with EU-US Data Privacy Framework
Standard Contractual Clauses (SCCs)
Adequacy decisions where applicable

6. Data Retention

Data Type	Retention Period	Rationale
Advertising Data	As per Google AdMob policies (typically 18 months)	Ad performance optimization
Analytics Data	14 months maximum (Google Analytics default)	App improvement and performance analysis
Technical/Crash Data	90 days	Bug fixes and technical support
User Consent Records	3 years	Legal compliance and proof of consent

7. Your Rights

7.1 European Users (GDPR/UK GDPR/Swiss FADP)

You have the following rights regarding your personal data:

Right of Access: Obtain a copy of personal data we hold about you
Right to Rectification: Correct inaccurate or incomplete data
Right to Erasure: Request deletion of your personal data
Right to Restrict Processing: Limit how we process your data
Right to Object: Object to processing based on legitimate interests
Right to Data Portability: Receive your data in a structured format
Right to Withdraw Consent: Withdraw consent for advertising at any time
Right to Lodge a Complaint: File a complaint with your local data protection authority

7.2 California Users (CCPA/CPRA)

Right to Know: Know what personal information is collected and how it's used
Right to Delete: Request deletion of personal information
Right to Opt-Out: Opt-out of the sale of personal information
Right to Non-Discrimination: Not be discriminated against for exercising your rights

7.3 How to Exercise Your Rights

To exercise any of these rights, contact us at: contact@acm-interactive

We will respond to your request within 30 days (EU/UK) or 45 days (California).

8. Children's Privacy

Age Restrictions: Our app is not intended for children under 13 (US) or 16 (EU). We do not knowingly collect personal data from children under these ages. If you believe we have collected data from a child, please contact us immediately.

COPPA Compliance (U.S.): Our app fully complies with the U.S. Children’s Online Privacy Protection Act (COPPA). We do not knowingly collect personal data from children under the age of 13.

9. Security Measures

We implement appropriate technical and organizational security measures to protect your data, including:

Data encryption in transit and at rest
Access controls and authentication
Regular security assessments
Incident response procedures
Employee training on data protection

10. Apple App Store Compliance

Apple Privacy Requirements: This app complies with Apple's App Store privacy requirements, including:

Accurate privacy nutrition labels in the App Store
Proper disclosure of data collection practices
User consent for tracking (iOS 14.5+)
No sale of personal data to data brokers

11. Updates to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices or applicable laws. The "Last Updated" date at the top indicates when the policy was last revised. Material changes will be communicated through:

In-app notifications
Email notifications (where applicable)
Prominent notice on our app

12. Contact Information

Data Controller: ACM Interactive

Email: contact@acm-interactive

Response Time: We will respond to privacy inquiries within 30 days

Data Protection Authorities

If you're not satisfied with our response, you can lodge a complaint with:

EU: Your local data protection authority
UK: Information Commissioner's Office (ICO)
Switzerland: Federal Data Protection and Information Commissioner (FDPIC)
California: California Attorney General's Office

Multi-Jurisdictional Compliance Statement: This Privacy Policy is designed to comply with data protection laws in the European Union, United Kingdom, Switzerland, United States, and other jurisdictions where our app is available. Where specific local requirements apply, the most protective standard will govern.