Privacy policy

Provisional version. This text is not yet the final, validated version: passages still to be completed are highlighted. It will be replaced before the app is published.

This policy explains what data the UMARE mobile app ("Umare", store name: "UMARE: Born Elsewhere"), available on Apple's App Store, processes, what never leaves your device, and what choices you have. It also covers the app's website. We wrote it to be read: if anything is unclear, write to us (§ 19).

1. Who is responsible

The publisher of Umare, who is responsible for the processing described here, is:

[TO FILL IN: publisher's name or company name], [TO FILL IN: postal address, possibly a business domiciliation address], France. Privacy contact: [email protected].

No Data Protection Officer has been appointed [TO CONFIRM: not mandatory for an organization of this size].

2. In short

• You can play without an account. In that case the publisher receives no personal data: your games stay on your device.
• An account is optional. If you create one (Apple, Google or e-mail), your current life and your completed lives are saved in the cloud, in the European Union, so you can pick them up on another device. You can delete your account and this data inside the app (Settings → Account).
• No usage analytics and no crash reporting from the publisher in the app [TO CONFIRM: no analytics or crash-reporting SDK is added].
• Purchases and subscriptions are handled by Apple. The publisher sees neither your payment method nor your Apple identity.
• Advertising (a full-screen ad after some lives) is provided by Google AdMob. It is personalized only with your permission (Google's consent form and iOS's tracking prompt). Club subscribers see none [TO CONFIRM: and people who bought the extension?].
• We do not sell any data and we do not build player profiles.
• The stories are fictional: the characters do not refer to any real person and are not linked to you.

3. What the app does without an account

To work, the game stores the following locally, in the app's private space on your device:

• your games: the current life, its choices and memories, and completed lives (fictional character name, fictional country and city of birth, summary);
• your settings: language, light or dark mode, music, sound effects, haptics, reduced motion;
• technical counters related to advertising (for example, when the last ad was shown) and the state of your advertising consent;
• the fact that you have seen the introduction, and the state of your purchase entitlements (last known entitlement).

This data stays on your device because of the game. It is deleted when you uninstall the app. Depending on your iOS settings, your device's iCloud backup may contain a copy: that is up to Apple and your settings, not the publisher.

The game works offline. It does not ask for access to your location, contacts, camera, microphone, photo library or health data.

4. Optional account and cloud save

An account is never required: the "Continue without an account" button gives access to the whole game. No feature is reserved for people with an account, other than cloud save itself.

Services used. If you create an account, the app uses Firebase Authentication (sign-in), Cloud Firestore (storage of your games, in a database located in Paris, France, region "europe-west9", i.e. within the European Union) and Firebase App Check (protection against abuse). These are Google services; Google acts as the publisher's processor.

Sign-in methods.

• Sign in with Apple: Apple may send us your e-mail address (or a "Hide My Email" relay address) and, the first time, your name, depending on your choice.
• Sign in with Google: Google sends us your e-mail address and your Google account name [TO CONFIRM: whether the name and profile picture are kept by the sign-in service].
• E-mail address: with a password, or with a sign-in link sent by e-mail (no password). We process the address you enter; the password is protected by the sign-in service and can never be read by the publisher. Sign-in e-mails are sent on our behalf by Google's Firebase service.

Data processed with an account.

Legal basis. Performance of the service you request (saving and syncing, GDPR art. 6(1)(b)); our legitimate interest in protecting the service against abuse (art. 6(1)(f)).

Retention. As long as the account exists. When you delete your account, your account and saved games are erased; technical copies held by Google's services are purged within [TO CONFIRM: 30 days, depending on configuration]. Games on your device are not erased by deleting the account. [TO CONFIRM: automatic deletion of inactive accounts after 24 months?]

Deleting your account. Settings → Account → Delete account. Deletion is permanent. If you have a subscription, deleting the account does not cancel it: the App Store keeps billing until you cancel it (see the subscription terms). If you signed in with Apple, the app's access to your Apple ID is revoked.

Minors and accounts. See § 15.

5. Purchases and subscriptions

In-app purchases and subscriptions are processed by Apple. We receive neither your name, nor your payment method, nor your Apple ID: only, on your device, confirmation that the purchase is valid. The publisher may view aggregated sales reports supplied by Apple. Processing of your payment data is governed by Apple's privacy policy. The purchase is tied to your Apple account, not to your Umare account.

6. Advertising (Google AdMob)

The base game is free and may show a full-screen ad when you return home after some lives. Never during a game. Ads are provided by Google AdMob (Google Ireland Limited for the European Economic Area, the United Kingdom and Switzerland; Google LLC elsewhere).

What Google's SDK may process, on your device and at Google: your advertising identifier (IDFA, only if you allow tracking), your IP address and the approximate location derived from it, device and system information, the ads seen and your interactions with them, and diagnostic data (performance, crashes). Google is the controller of this data for advertising; the publisher does not receive it in individual form. See How Google uses information from sites or apps that use our services.

Your choices.

• European Economic Area, United Kingdom, Switzerland: a consent form (Google User Messaging Platform) is shown before any ad. You can review your choice at any time in the app under Settings → Ads → Privacy choices.
• iOS: an Apple prompt (App Tracking Transparency) asks whether to allow "tracking". Declining does not stop you from playing; ads are then non-personalized. You can change your mind in iOS Settings → Privacy & Security → Tracking.
• California and other US states: see § 16.
• The ad content level requested from Google is "teen" (T). You can report an inappropriate ad from Settings → Ads → Report an ad or by e-mail to support.

Legal basis. Your consent (GDPR art. 6(1)(a) and access to information on your device, art. 82 of the French Data Protection Act). You can withdraw it at any time, without affecting what was done before.

Retention. Set by Google (see its policies).

7. Support and contact

If you write to us (support, exercising rights, reporting an ad), we process your e-mail address, your message and the technical information you include (app version, device model) to reply to you. Legal basis: our legitimate interest in answering requests (art. 6(1)(f)) or, if you ask to exercise a right, a legal obligation (art. 6(1)(c)). Retention: [TO CONFIRM: 12 months] after the last exchange. We do not share these messages with anyone, apart from our e-mail provider [TO FILL IN: provider].

8. Website

The app's website is hosted by [TO FILL IN: host], which may keep technical logs (IP address, date, requested page) for service security, for [TO FILL IN: duration]. The website uses no audience-measurement cookies and no advertising trackers [TO CONFIRM when the website goes live]. Links to the App Store or other sites are governed by those sites' policies.

9. Sharing a card

The game can create an image card of your completed life. It is shared only if you decide to: it is passed to the app you pick in the iOS share sheet. The publisher receives nothing and has no access to this card.

10. What we do not do

We do not sell data, we do not build player profiles, we do not use usage-analytics tools or social networks, we do not track your location, and we do not ask for access to your contacts, camera, microphone or photo library. There is no automated decision-making with legal effects on you.

11. Legal bases, in a table

12. Retention periods, in a table

13. Who receives data

14. Transfers outside the European Union

Saved games are stored in the European Union. Some Google processing (sign-in, security, advertising) may involve transfers to the United States or other countries. They rely on the safeguards provided by the GDPR, notably the European Commission's standard contractual clauses and, for Google LLC, the EU–US Data Privacy Framework [TO CONFIRM: check Google LLC's certification and the clauses in force at publication]. The publisher itself makes no transfers outside the Union.

15. Minors

Umare is not intended for children under 13 and is not offered to them. We do not knowingly collect data from children under 13; if we learn that an account was created by a child that age, we delete it. In France the age of digital consent is 15 (13 to 16 depending on EU country): if you are under 15, ask a parent or legal guardian for permission before creating an account or accepting personalized advertising. [TO CONFIRM: owner's decision, for example restricting accounts to people aged 15 and over.] Parents can write to us (§ 19) to ask for an account to be deleted.

16. Your rights

In the European Union, the United Kingdom and Switzerland (GDPR). You have the right to access your data, to have it corrected, to have it erased, to restrict its processing, to object to it, to receive the data you provided in a common format (portability), and to withdraw your consent at any time. To erase your account data, the simplest way is to delete your account in the app. For any other right, write to [email protected]: we reply within one month (extendable by two months if the request is complex) and may ask you to confirm your identity from your account's e-mail address. For data processed by Google or Apple as separate controllers, contact them (your Google account settings, the app's consent form, iOS tracking settings). You may also lodge a complaint with a data protection authority: in France, the CNIL (cnil.fr/fr/plaintes); elsewhere, the authority of your country.

California and other US states (CCPA/CPRA and similar laws). We do not sell personal data. Showing personalized ads through Google may count as "sharing" under California law; you can decline it in iOS Settings → Privacy & Security → Tracking and, where offered, in the app's Privacy choices. You have the right to know what data is collected, to request its deletion or correction, and not to be discriminated against for exercising your rights. [TO CONFIRM: CCPA applicability thresholds are probably not met; this is provided out of caution.]

Japan (Act on the Protection of Personal Information). See the Japanese version of this policy and the "External transmission of information" page.

17. Security

Local data is kept in the app's private space, protected by iOS. Exchanges with the account and advertising services are encrypted (HTTPS). Access to cloud data is limited to your account and to the publisher for service maintenance. No system is infallible; in the event of a data breach that poses a risk to you, we will notify the CNIL and you as required by law.

18. Changes

This policy may change (new feature, new provider). The update date is at the top of the page; for any important change, the app will inform you before it applies.

19. Contact

[email protected] · [TO FILL IN: postal address] General support: see the "Support and contact" page.

This website

This site uses no cookies, no audience-measurement tool and no third-party service: no request is sent to any server other than its own. The fonts, images and scripts are hosted here. That’s why there is no consent banner.

The only storage is local and optional: your browser may remember your choice of theme (light or dark) and language. It is never sent anywhere.

The host may keep technical logs (IP address, date, requested page) for security and proper operation. [HOST AND RETENTION PERIOD TO BE FILLED IN]