Privacy Policy for Life Empire
This translation is for information; the German version is authoritative.
1. Controller
ECLE - Emerv Creveo Life Empire
Owner: Fabian Hartmann
c/o flexdienst – #21189
Kurt-Schumacher-Straße 74
67663 Kaiserslautern, Germany
Email: support@life-empire.de
No data protection officer has been appointed.
2. What this is about
Life Empire is a game for iPhone. Your own game world runs on your device, even without internet. For the online features (account, friends, chat, groups, voice chat, leaderboard, online races, cloud saves, purchases) we run our own server.
Ads only come as optional videos: if you want, you watch a short ad video and get an in-game reward for it. The videos are provided by Google AdMob. We show no banners and no interstitial ads. Personalised ads and tracking across apps and websites of other companies only happen with your consent (section 6). Beyond that, we use no third-party analytics services.
3. Which data we process
a) Account. Email address and an irreversible fingerprint of your password (we never store the password itself). With Sign in with Apple, an identifier from Apple and, if you share it, your email address; with Apple possibly an anonymous relay address. For Sign in with Apple we also keep a key that we use to revoke the connection when you delete your account. For guest accounts, a random identifier the game creates on your device at first start (not a device or advertising identifier from Apple). The time you agreed to the terms of use.
b) Profile. Player name, profile picture (a character or a photo you pick from your library yourself; we convert it to 256 × 256 pixels and remove metadata such as location and device), motto, friend code.
c) Friends. Your friends list, requests, blocked players, your privacy settings (e.g. whether others see that you are online).
d) Messages. We pass chat messages (world, area, friends, group) on to the recipients and keep them briefly in the history. We store whisper messages between two players (the last 100 per conversation) so they arrive even if the other player is offline. Messages pass through an automatic filter against insults, links and contact details.
e) Voice chat. The microphone is only active when you switch it on yourself and your device has allowed it. While it is on, the game detects on your device whether you are speaking; only then is your voice transmitted, and only to the other participants of your voice room (group, online race, call). We do not record or store voice chat.
f) Game progress and content. Saves you store in the cloud (up to three slots), leaderboard (points, net worth, sales), season ranks, daily bonus, construction orders (building, level, start, end), the settlement of your offline earnings and your gem balance with every credit and spending (time, amount, reason) as well as running times of purchased offers.
g) Purchases. For in-game purchases the transaction number, the product and the time. Apple handles the payment itself; we receive no payment data. We verify every purchase with Apple (App Store Server API).
h) Online races. During a race we forward your position and speed to the other participants without storing it; we keep your finishing time and rank for the result.
i) Reports and support. If you report someone or are reported, we store the report as a case with a number: reason, text and context (the reported message with the lines before and after, the profile at the time of the report, for races the mode, track and position). If you contact support, we store your request and our replies; for technical errors the game version, device type and settings, for purchase problems the transaction numbers of your purchases – never passwords or payment data. If you email us at support@life-empire.de, we use your sender address and the content to handle your request. The email is received by the mail server of our domain provider checkdomain and forwarded to our support mailbox at a German email provider. We delete emails once the request has been dealt with, unless statutory retention periods apply. We record moderation actions (warning, chat ban, suspension) with the reason and which team member took them.
j) Technical data. We need your IP address for the connection and to protect against abuse (e.g. blocking after too many failed sign-in attempts). We keep it only in the server's memory and do not write it to files or logs. We also process the game version and platform.
k) On your device. Your save, a session (so you stay signed in) and a technical log are stored on your device. We do not send the log; it stays on the device. For the ad videos, the Google Mobile Ads SDK also stores your consent choice and, where applicable, identifiers on your device (section 6).
4. Purposes and legal bases
- Providing the game, your account and the online features, processing purchases: Art. 6(1)(b) GDPR (contract).
- Security, protection against fraud and abuse, moderation of chat and profiles, handling reports, enforcing the terms of use: Art. 6(1)(f) GDPR (legitimate interest in a safe and fair game).
- Retention of purchase records: Art. 6(1)(c) GDPR (statutory retention) and (f) (no double crediting).
- Microphone: only when you switch it on yourself (Art. 6(1)(b) GDPR; access to the microphone itself only after your permission in the system).
- Storage on your device (save, session): strictly necessary for the game (Section 25(2) no. 2 TDDDG).
- Ad videos, consent and rewards: see section 6.
5. Recipients and service providers
- Hosting: OVH GmbH, Oskar-Jäger-Straße 173/K6, 50825 Köln, Germany, operates our server in a data centre in Warsaw, Poland (EU), on our behalf (processing under Art. 28 GDPR).
- Apple (Apple Distribution International Ltd., Ireland): App Store, processing and verification of purchases, Sign in with Apple – if you use them. Apple's privacy policy also applies.
- Google (Google Ireland Limited, Ireland, or Google LLC, USA): ad videos via Google AdMob, see section 6.
- Email: checkdomain GmbH, Große Burgstraße 27/29, 23552 Lübeck, Germany, operates the mail servers for life-empire.de as our domain provider and, on our behalf, forwards emails sent to support@life-empire.de to our support mailbox at a German email provider, which stores them for us (processing under Art. 28 GDPR). We do not use an email sending service, so we do not send password reset codes. If you have forgotten your password, our support will help you.
- Other players see your profile (name, picture, motto, reputation level), your chat messages in the channels you write in, your leaderboard ranks and – if you allow it – whether you are online.
We do not sell data. Data for advertising is collected only by Google through the SDK in the app, as described in section 6.
6. Advertising with Google AdMob
What you see. Ads in Life Empire appear in one place only and only voluntarily: instead of gems, you can get the offline bonus by watching ad videos (4 hours: one video, 8 hours: two videos, at most one bonus a day). You start every video yourself. There are no banners and no interstitial ads.
Provider. The videos are provided by Google AdMob through the Google Mobile Ads SDK and Google's consent dialog (User Messaging Platform) in the app. On first launch, the game asks for your consent through Google's consent management platform (UMP); in the process, technical data (e.g. IP address, device and app information) is transmitted to Google. The advertising SDK is only started and loads a video when you open the offer for the offline bonus. For users in the European Economic Area and Switzerland, the responsible company is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; otherwise Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google").
Which data Google processes. According to Google (the SDK's privacy manifest and https://developers.google.com/admob/ios/privacy/data-disclosure):
- Device identifiers: your iPhone's advertising identifier (IDFA) only if you allow it in Apple's "App Tracking Transparency" prompt; otherwise identifiers tied to this app or to us as the developer. Purposes: third-party advertising, developer's advertising, analytics. Tracking across apps and websites of other companies only happens with your permission.
- IP address and your approximate location derived from it (advertising, analytics).
- Advertising data: which ads were shown or tapped.
- App usage: app launches, taps, videos watched.
- Diagnostics not linked to you: crashes, performance and other errors (error analysis, advertising, analytics).
- The consent dialog processes approximate location, performance and interaction data only for the dialog itself and without reference to you. Your choice is stored on your device (TCF string under the IAB Transparency & Consent Framework).
What reaches us. From Google we receive aggregated reports (e.g. number of videos shown), but no advertising identifier and no advertising profile of you. To credit your reward, Google reports to our server for each video watched to the end: your account ID (only for accounts on our server), the ad placement, a random identifier, the transaction number, the reward, the ad unit and the time (server-side verification). We keep at most 40 such records for at most 3 days with your account, only so that the bonus is credited exactly once. If this verification is not switched on, our server only learns that the bonus was obtained via video.
Consent. On first launch, after choosing the language, the game uses Google's consent dialog to ask whether Google and its advertising partners may store or read information on your device and show personalised ads (in the European Economic Area, the United Kingdom and Switzerland). After that, iOS asks with App Tracking Transparency: "So the optional reward videos can show you more relevant ads. If you decline, you still get the videos, just less tailored to you."
- If you agree, Google may show personalised ads.
- If you decline in Google's dialog, Google only shows limited, non-personalised ads. If you decline in Apple's prompt, the app sends no IDFA. The videos remain available in both cases.
- You can change or withdraw your choice at any time with effect for the future: in the game in the pause menu under "Privacy settings (ads)" (the entry appears where Google requires consent), and the tracking permission in the iPhone settings under Privacy & Security › Tracking.
- Playing without ads: simply don't watch any videos; the offline bonus is also available for gems.
Legal bases. Storing and reading information on your device and personalised ads: your consent (Section 25(1) TDDDG, Art. 6(1)(a) GDPR). Playing a video you started and crediting the reward: Art. 6(1)(b) GDPR; billing and fraud prevention: Art. 6(1)(f) GDPR.
Transfers to third countries. Google may also process data in the USA. Google LLC is certified under the EU-US Data Privacy Framework. Further advertising partners are listed in the list of ad technology providers in the consent dialog.
Children and young people. Ad content is limited to the "T" rating (teen, 13 and over).
More from Google:
- Google's privacy policy: https://policies.google.com/privacy
- How Google uses information from sites or apps that use its services: https://policies.google.com/technologies/partner-sites
- Advertising at Google: https://policies.google.com/technologies/ads
- How long Google keeps data: https://policies.google.com/technologies/retention
- Your ad settings at Google: https://myadcenter.google.com
- Consent at AdMob: https://support.google.com/admob/answer/9012903
- Privacy for Google's business partners: https://business.safety.google/privacy/
7. Retention
- We store account data as long as your account exists.
- Deleting your account: in the game under Main menu or Pause menu › Account & privacy › Delete account for good. We then immediately remove account, profile, profile picture, friends list, message histories, cloud saves, gem records and construction orders – on our server and on your device.
- After deletion we keep purchase records (transaction number, product, time) without reference to your account so the same purchase is never credited twice and as far as the law requires.
- If you signed in with Apple, we also revoke the connection to Apple on deletion; if that fails at first, we retry for up to 14 days and only keep a technical key without reference to your account.
- We delete reports, support requests and moderation actions no later than 12 months after the last change; if you delete your account, we delete them immediately along with it.
- Unused sessions expire after 60 days.
- Server logs contain no IP or email addresses and are deleted after 14 days.
- Your ad consent stays stored on your device until you change it or delete the app. How long Google stores data is described in Google's privacy policy.
8. Your rights
You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and to object to processing based on legitimate interests (Art. 21). Write to us at support@life-empire.de or use Phone › Help in the game. You can delete your account yourself in the game at any time.
You can lodge a complaint with a data protection supervisory authority, in particular in the member state of your habitual residence, your place of work or the place of the alleged infringement (Art. 77 GDPR).
9. Children and young people
The online features are intended for players aged 16 and over. Younger players may use them only with parental consent.
10. Security
The connection to the server is encrypted (TLS). We store passwords only as a salted PBKDF2 fingerprint and session keys only as a checksum.
11. This website
When you visit life-empire.de, the server processes, as technically necessary, your IP address, the time, the requested address and information about your browser in order to deliver the pages and protect them against attacks (Art. 6(1)(f) GDPR). We do not write access logs. The website sets no cookies, uses no analytics or advertising services and loads no fonts, scripts or images from third-party servers. Links to Apple, Google and other providers only open their pages when you tap them. The website is hosted by OVH GmbH on the same server in Warsaw (section 5).
12. Changes
We update this policy when the game or the law changes. The current version is in the game and at https://life-empire.de/en/datenschutz.html.