Privacy Policy
smuttlewerk interactive UG ("smuttlewerk", "we", "us", "our") is committed to protecting the privacy of its users ("users", "you", "your") with regard to the processing of personal data. We observe all applicable data protection requirements.
This Privacy Policy applies to all services offered on our websites (in particular smuttlewerk.de), our mobile applications, and the games offered for download via the Apple App Store and Google Play Store ("games", "apps").
If you have any questions about how we handle your personal data, or if you would like to exercise any of your rights described below, please contact us at: contact[at]smuttlewerk.de
Last updated: April 2026
1. General Information on Data Processing
1.1 Legal Bases
We process personal data under the following legal bases of the EU General Data Protection Regulation (GDPR):
- Consent (Art. 6(1)(a) GDPR) — where you have given us your consent for a specific processing purpose.
- Contract performance (Art. 6(1)(b) GDPR) — where processing is necessary to perform a contract with you or to carry out pre-contractual measures at your request.
- Legal obligation (Art. 6(1)(c) GDPR) — where processing is required to comply with a legal obligation.
- Legitimate interest (Art. 6(1)(f) GDPR) — where processing is necessary for our legitimate interests or those of a third party, provided your fundamental rights and freedoms do not override those interests.
1.2 Data Retention
We delete or anonymize your personal data as soon as the purpose of storage has been fulfilled, unless a longer retention period is required by European or national law. Where statutory retention obligations apply, data is blocked or deleted at the end of the prescribed retention period.
1.3 Data Security
We implement reasonable technical and organizational measures to protect your personal data against unauthorized access, misuse, or manipulation. All employees are bound by data secrecy obligations and have been instructed accordingly. Payment data is transmitted using SSL/TLS encryption.
No system is absolutely secure. The provision of personal data — whether in person, by phone, or via the internet — is inevitably associated with certain risks.
2. Data Collection via Our Website and Apps
2.1 Website Visits (Without Registration)
When you visit our website, the following data is automatically collected and stored in server log files:
- IP address
- Date and time of access
- URL of the referring website
- Pages visited
- Browser type and operating system
- Data volume transferred
- Access status (e.g., file transferred, file not found)
This data is necessary for delivering the website to your device and for ensuring the security and stability of our systems. It is not combined with other personal data. The legal basis is our legitimate interest (Art. 6(1)(f) GDPR). Log files are deleted after a maximum of seven days, unless retention is required for investigation of misuse or by statutory obligation.
2.2 Use of Our Games
When you use our games, we collect the following data to operate the game, provide online features, and improve our services:
- Device type, operating system, and language setting
- Internet protocol and shortened IP address
- Game app version
- Duration and frequency of use
- Game-related data (scores, levels achieved, ranks, match results, leaderboard positions)
- Avatar / player name
- Download source and advertising identifiers (where applicable)
- Amounts or tokens invested in in-app features
This data may be used to generate pseudonymized statistics to help us improve the games, fix bugs, and enhance our services. The data is not used to identify you personally beyond what is necessary for game operation.
Google Play IDs and Game Center IDs may be stored to allow login from multiple devices.
The legal basis for this processing is contract performance (Art. 6(1)(b) GDPR) and our legitimate interest in improving our services (Art. 6(1)(f) GDPR).
2.3 App Store Data
The download and installation of our games through the Apple App Store or Google Play Store involves data collection by those platforms. smuttlewerk has no control over this data collection. Please refer to the privacy policies of the respective store operators for details. We process data provided by the stores only to the extent necessary for delivering and operating the game.
2.4 In-App Purchases
If you make in-app purchases, additional data may be processed for the purpose of fulfilling the transaction and performing the license agreement. smuttlewerk does not collect or process payment data (bank account numbers, credit card data, etc.) — all payment processing is handled by the respective app store.
3. Third-Party Services and SDKs
Our games use third-party services for networking, analytics, attribution, player account management, and advertising. These services may process personal data as described below.
3.1 Game Networking and Backend
- Photon (Exit Games) — Provides real-time multiplayer networking. Processes connection data, player session data, and match-related information. Privacy policy: https://www.photonengine.com/privacy
- BrainCloud (bitHeads) — Provides backend services including player accounts, statistics, leaderboards, and virtual currency management. Processes player profile data, game statistics, and account credentials. Privacy policy: https://getbraincloud.com/privacy-policy/
3.2 Analytics and Attribution
- Firebase (Google) — Provides analytics and crash reporting. Processes device information, app usage data, and performance metrics. Privacy policy: https://firebase.google.com/support/privacy
- Singular — Provides mobile measurement and attribution. Processes device identifiers, install attribution data, and campaign performance data. Privacy policy: https://www.singular.net/privacy-policy/
3.3 Advertising
Our games display advertisements to support free-to-play availability. We use LevelPlay (Unity/ironSource) as our ad mediation platform, which works with the following ad networks:
- ironSource
- AdMob (Google)
- Meta Audience Network
- AppLovin
- Unity Ads
- Digital Turbine
- Vungle (Liftoff)
- Pangle (TikTok/ByteDance)
- InMobi
- Ad4Game
These ad networks may collect device identifiers, IP addresses, and usage data to serve and measure advertisements. Some networks may use this data for interest-based advertising, subject to your consent where required.
You can manage your ad preferences:
- iOS: Settings → Privacy & Security → Tracking. You can also enable "Limit Ad Tracking" under Settings → Privacy & Security → Apple Advertising.
- Android: Settings → Google → Ads. You can opt out of ad personalization or reset your advertising ID.
The legal basis for ad-related data processing is your consent (Art. 6(1)(a) GDPR) where required, or our legitimate interest in financing the free-to-play service (Art. 6(1)(f) GDPR).
4. Login via Third-Party Platforms
If you log into our games using a third-party account (such as a Google account or Apple Game Center), you consent to us accessing certain account or profile information held by that provider. We process this data solely for the purpose of authenticating your identity and enabling cross-device play.
You can change your login settings at any time to prevent further data exchange with the respective platform.
5. Cookies
Our website uses cookies — small text files stored by your browser on your device.
- Session cookies are technically necessary for website functionality and are deleted when you close your browser. The legal basis is our legitimate interest (Art. 6(1)(f) GDPR).
- Persistent cookies remain on your device after your session ends and may be used to make the website more user-friendly and effective. These are set only with your consent (Art. 6(1)(a) GDPR).
You have full control over cookies. You can deactivate or restrict cookies in your browser settings and delete stored cookies at any time. Some website functions may not be available if cookies are deactivated.
6. Push Notifications
You can configure your device to allow us to send push notifications for game updates and other relevant information. You can manage push notification settings in the game's options menu or in your device settings at any time.
The legal basis is contract performance (Art. 6(1)(b) GDPR).
7. Children and Minors
Fleet Battle is not specifically directed at children under the age of 16. We do not knowingly collect personal data from children under 16 without parental consent.
Fleet Battle includes a parental control feature that allows the in-game chat to be locked with a password or restricted to pre-defined phrases only.
If we become aware that we have collected personal data from a child under 16 without appropriate consent, we will take steps to delete that data promptly. If you believe a child under 16 has provided us with personal data, please contact us at contact[at]smuttlewerk.de.
8. Data Retention Periods
| Data Type | Retention Period |
|---|---|
| Server log files (website) | Maximum 7 days |
| Player accounts and game data | Until account deletion by the user or upon request |
| Match history and leaderboard data | For the duration of the active account |
| Purchase records | As required by tax and commercial law (typically up to 10 years) |
| Analytics data | Stored in pseudonymized/aggregated form; raw data deleted within 14 months |
| Ad interaction data | As determined by the respective ad network's retention policy |
We may retain data longer where required by statutory retention obligations or for the investigation of misuse.
9. Disclosure of Data to Third Parties
Your personal data is treated confidentially. We disclose data to third parties only:
- With your express consent, or
- Where necessary to perform a contract, respond to inquiries, or provide customer support, or
- Where required by law (e.g., disclosure to investigating authorities).
We work with external service providers for statistical analysis, IT infrastructure (hosting, databases, backups), and the third-party services listed in Section 3. These providers are contractually obligated to treat data confidentially and to process it only as necessary to perform their duties, in accordance with data processing agreements under Art. 28 GDPR.
10. Links to Other Websites
Our website and games may contain links to external websites. smuttlewerk has no control over the content, design, or data protection practices of linked third-party websites. The respective operators are solely responsible for their own compliance with data protection requirements.
11. Your Rights Under the GDPR
As a data subject under the GDPR, you have the following rights:
11.1 Right of Access (Art. 15 GDPR)
You may request confirmation of whether we process your personal data, and if so, request details about the purposes, categories, recipients, retention periods, and sources of that data.
11.2 Right to Rectification (Art. 16 GDPR)
You have the right to request the correction of inaccurate personal data or the completion of incomplete data without undue delay.
11.3 Right to Restriction of Processing (Art. 18 GDPR)
You may request restriction of processing where you contest the accuracy of your data, the processing is unlawful, we no longer need the data but you require it for legal claims, or you have objected to processing under Art. 21(1) GDPR.
11.4 Right to Erasure (Art. 17 GDPR)
You may request deletion of your personal data where the data is no longer necessary for its original purpose, you withdraw consent, you object to processing, or the processing is unlawful.
You can delete your account directly in the game (Options, page 2, "Delete Account"), or by contacting us at support[at]smuttlewerk.de with your in-game username and/or associated email address.
Erasure may be refused where retention is required for compliance with legal obligations, the exercise of legal claims, or archiving purposes in the public interest.
11.5 Right to Data Portability (Art. 20 GDPR)
You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transfer it to another controller where technically feasible.
11.6 Right to Object (Art. 21 GDPR)
You have the right to object to the processing of your personal data based on our legitimate interests (Art. 6(1)(f) GDPR) at any time, for reasons relating to your particular situation. Where your data is processed for direct marketing purposes, you may object at any time without giving reasons.
11.7 Right to Withdraw Consent (Art. 7(3) GDPR)
You may withdraw any previously granted consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.
11.8 Right to Lodge a Complaint
You have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your residence, place of work, or the place of the alleged infringement, if you believe your personal data is being processed in violation of the GDPR.
11.9 Automated Decision-Making (Art. 22 GDPR)
You have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning you or similarly significantly affects you. smuttlewerk does not currently use automated individual decision-making of this nature.
12. Information for California Residents (CCPA/CPRA)
If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), provides you with additional rights regarding your personal information.
Categories of Personal Information Collected
We may collect: identifiers (device IDs, IP addresses, player names), internet activity information (game usage, browsing data), and commercial information (purchase history).
Your Rights
- Right to Know: You may request disclosure of the categories and specific pieces of personal information we have collected about you.
- Right to Delete: You may request deletion of your personal information, subject to certain exceptions.
- Right to Opt-Out of Sale/Sharing: smuttlewerk does not sell personal information. However, some ad-related data sharing with third-party ad networks may constitute "sharing" under the CPRA. You can opt out of personalized advertising through your device settings (see Section 3.3).
- Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.
To exercise these rights, contact us at contact[at]smuttlewerk.de. We will verify your identity before processing your request.
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated revision date. We encourage you to review this page periodically.
14. Contact
smuttlewerk interactive UG
Email: contact[at]smuttlewerk.de
Website: www.smuttlewerk.de