Owlyfit Privacy Policy
Effective Date: 22.04.2026
Welcome, and thank you for playing Owlyfit (the “Game”). This policy explains how we collect, use, share, and protect your information when you install or play the Game on Android or iOS devices, and how you can exercise your privacy rights.
1. Who We Are
At Vasilev Labs UG (“we”, “us”, “our”) we value your privacy and are committed to lawful, fair, and transparent processing of personal data. We are the data controller responsible for your personal data under applicable privacy laws. We are based at Theresienstr. 56, 80333 Munich, Germany. You can contact us at [email protected] and find more information about us here.
2. Data we collect ourselves
We do not collect any data ourselves.
No device identifiers, IP addresses, user IDs, or any other personal information or personal data are ever captured.
3. Data Collected by Our Partners
We use the following external services to provide advertising, game progress sync and in-app purchases. Below is a summary of the categories of data they collect, the purposes for which they collect it, and links to their privacy policies for more detail.
| Service | Data Categories Collected | Purpose | Privacy Policy |
| Google Play Games Services Apple iCloud |
• Game-progress records | Progress sync across devices | Play Games
Privacy Apple Privacy Policy |
|
Google Play Billing Apple StoreKit |
• Purchase tokens (Google) or receipts (Apple) • Product IDs & order details |
Purchase processing |
Google
Privacy
Policy Apple Privacy Policy |
4. Legal Bases, Purposes & Consent Mechanisms
We process personal data in accordance with the EU General Data Protection Regulation (GDPR) for users in the EU/EEA and UK. For users outside these regions, we rely on legitimate interests and contractual necessity as described below.
GDPR Legal Bases (EU/EEA & UK):
For game progress sync (Play Games, iCloud) and in-app purchases, we
rely on contractual necessity.
Purposes of Processing: As summarized in Section 3, data are used for game progress synchronization, and purchase processing.
5. Data Retention
We do not store any personal data ourselves. Third-party services retain your data as follows (please
see their privacy policies for full details):
• Game progress: as long as your account exists
• Purchase receipts: per platform policy
6. Data Subject Rights
If you are in the EU/EEA, UK, or California, you have the right to:
- Access, correct, delete, or port your personal information
- Restrict or object to our processing
- Withdraw your consent at any time
To exercise these rights, please see the relevant instructions below:
-
In-App Purchase records
We do not retain your purchase history ourselves.
• On Android, view/download your orders at play.google.com/store/account/orderhistory.
• On iOS, manage your purchases at reportaproblem.apple.com. -
Game progress (Play Games & iCloud)
You can instantly delete all your synced game data in-app via the “Delete My Progress” option in Settings.
You may also always submit a general request to [email protected]. We will respond within 30 days. You also have the right to lodge a complaint with a supervisory authority (e.g. the Berlin Data Protection Authority at https://www.datenschutz-berlin.de).
7. Children's Privacy
We do not target or knowingly collect personal data from children under 16. If we learn we have inadvertently collected personal data from a child under 16 without verified parental consent, we will delete it immediately. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us at [email protected] so that we will be able to take the necessary actions.
8. Security Measures
All third-party services we use implement industry-standard safeguards, including HTTPS/TLS in
transit, encryption at rest, access controls, and regular security audits.
We have implemented procedures to detect, contain, and investigate any suspected personal data
breach. In the event of a
breach, we will notify both the relevant supervisory authority and affected users
in accordance with GDPR Articles and any applicable locallaw.
9. International Transfers
We do not process personal data ourselves. Data collection and processing are carried out by our third-party providers in various locations, including within the EU, the United States, and other jurisdictions. We rely on EU Standard Contractual Clauses and applicable adequacy decisions to safeguard any transfer of data outside the European Economic Area.
10. Changes to This Policy
We may update this policy to reflect changes in our practices or applicable law. Any changes will be posted on this page with the updated effective date.