Privacy Policy

Last Updated: July 7, 2026

1. Who We Are

Data Controller: Stanisław Pawluczuk, operating as a sole proprietorship (Jednoosobowa Działalność Gospodarcza) under Polish law.

Address: ul. Świeradowska 47, 02-662 Warszawa, Poland

Contact: privacy [at] playmateria.xyz

Business Registration: NIP: 1231476789 | REGON: 387249521

2. Information We Collect

2.1 Information You Provide

Materia does not require you to provide any personal information to play. If you contact us for support, we receive your email address and the content of your message.

2.2 Automatically Collected Information

• Device Information: Device type, operating system, app version
• Approximate Location (service-derived): Materia does not request precise GPS location or iOS Location Services. If ads are shown, our advertising provider — Google AdMob — may derive an approximate, general location (such as region or country) from your IP address for ad delivery, fraud prevention, or security. This is coarse, service-derived location, not GPS.
• Local Game Data: Your best score and whether you've completed the tutorial are stored locally on your device. There is no account or username — this data is not tied to your identity, and is not stored on our servers. If iCloud sync is enabled, this same limited data (best score, tutorial status) may sync across your Apple devices via Apple's iCloud key-value storage.
• Transaction & Purchase Data (if in-app purchases are available in your version of Materia): We process your App Store purchase status and non-financial StoreKit transaction identifiers to deliver purchased content (such as removing ads) and support purchase restoration. We receive these details from Apple StoreKit and do not receive, process, or store your full payment card or financial account details.

2.3 Information from Third Parties

• Advertising Partners: Where ads are enabled, Google AdMob may process device and ad-related identifiers for ad delivery, fraud prevention, measurement, and — only where permitted — personalization. Personalized advertising and cross-app tracking are used only where required permissions are granted, including Apple App Tracking Transparency (ATT) on iOS.
• Apple iCloud: Your best score and tutorial-completion status, synced via Apple's iCloud key-value storage, if enabled.
• Apple StoreKit: Purchase status, if in-app purchases are available and used.

Materia does not currently use a third-party analytics service. If this changes, we will update this Privacy Policy to describe what is collected and why.

3. How We Use Your Information

Purpose	Legal Basis (GDPR)
Show optional advertisements (where enabled)	Consent (personalized) / Legitimate Interest (non-personalized)
Sync your best score and tutorial status via iCloud	Contract Performance / Consent
Deliver purchased content and support purchase restoration	Contract Performance
Respond to support requests	Contract Performance
Prevent fraud and abuse	Legitimate Interest
Schedule an optional local reminder notification on your device	Consent

4. Advertising & Tracking Consent

Where ads are enabled, Materia shows a neutral, in-app explanation before requesting the iOS App Tracking Transparency (ATT) permission. ATT controls whether Materia may ask permission to track your activity across other companies' apps and websites. If you decline or restrict ATT, we will not access the advertising identifier, and non-personalized/contextual ads will be served instead where ads are available.

You can change your ATT choice at any time in iOS Settings for Materia.

4.1 Cookies and App-Opened Web Pages

When you open our legal, support, or account pages from the Materia iOS app, those pages do not use cookies to track you across apps or websites, and are not used to personalize ads or track you across other companies' apps or websites. These pages exist only to provide information such as our Privacy Policy, Terms of Service, Support, and Delete Your Data instructions.

5. Notifications

Materia may schedule an occasional local reminder notification directly on your device — for example, a gentle nudge if you haven't played in a while. This is scheduled entirely on your device using Apple's local notification system; no personal data is sent to us or any third party to schedule or deliver it. We do not send marketing or promotional notifications.

How to disable notifications: Disable notifications for Materia in iOS Settings → Notifications → Materia. If a notifications toggle is shown in Materia's own Settings, you can also turn it off there.

Legal basis (GDPR): Consent. You may withdraw consent at any time using the method above without affecting the lawfulness of processing based on consent before its withdrawal.

6. Children's Privacy

Materia has no accounts, usernames, chat, or user-generated content, and does not require you to provide any personal information to use the game. Where ads are enabled, we rely on Apple's platform-level protections (including App Tracking Transparency) and configure our advertising partner in line with Materia's declared App Store age rating. Parents may contact us at privacy [at] playmateria.xyz with any questions about our data practices.

7. Your Rights

Depending on your location, you may have the following rights:

• Access: Request a copy of your data
• Correction: Request correction of inaccurate data
• Deletion: Request deletion of your data ("Right to be Forgotten")
• Portability: Receive your data in a machine-readable format
• Object: Object to processing based on legitimate interests
• Withdraw Consent: Withdraw consent at any time
• Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority. Our lead supervisory authority is the President of the Personal Data Protection Office (UODO) in Poland — uodo.gov.pl

Because Materia stores gameplay data locally on your device rather than in a server-side account, most of these rights are exercised directly through your device — see our Delete Your Data page. For anything else (such as support correspondence), contact us at privacy [at] playmateria.xyz. We will respond without undue delay, in accordance with applicable statutory timeframes (within 15 days under Brazil's LGPD, within 30 days under GDPR/UK GDPR, and within 45 days under CCPA/CPRA, extendable by a further 45 days where permitted).

7.1 United Kingdom

If you are located in the United Kingdom, your rights under the UK General Data Protection Regulation (UK GDPR) mirror those listed above. You may also lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.

7.2 California (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) provide you with the following rights:

• Right to Know: You may request the categories and specific pieces of personal information we have collected about you.
• Right to Delete: You may request deletion of your personal information.
• Right to Opt-Out: You may opt out of the "sale" or "sharing" of your personal information. Materia does not sell personal information. Where personalized advertising is enabled, AdMob may share device identifiers with advertising partners, which may constitute "sharing" under the CCPA. You can control this through App Tracking Transparency (iOS) or by contacting us.
• Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

To exercise these rights, contact us at privacy [at] playmateria.xyz.

7.3 Brazil (LGPD)

If you are located in Brazil, you have equivalent rights under the Lei Geral de Proteção de Dados (LGPD), including access, correction, deletion, and portability. To exercise these rights, contact us at privacy [at] playmateria.xyz.

8. Data Retention

• Local Game Data: Your best score and tutorial status are stored locally on your device, and in your personal iCloud if sync is enabled, until you clear this data or delete the app.
• Support Requests: Retained for 2 years for quality assurance.

9. International Data Transfers

Your data may be processed in countries outside your residence, including the United States, by our infrastructure and advertising providers (Apple, Google). Where required, we rely on appropriate safeguards including EU Standard Contractual Clauses, the UK International Data Transfer Agreement (IDTA) or UK Addendum, and Data Processing Agreements with service providers.

10. Third-Party Services

Service	Purpose	Privacy Policy
Google AdMob	Advertising (interstitial and rewarded video), where enabled	Link
Apple iCloud (key-value storage)	Sync of best score and tutorial status	Link
Apple StoreKit	In-app purchases, where available	Link

11. Security

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

• Encryption in transit (HTTPS/TLS)
• Secure infrastructure (Apple platform services)
• Minimal data collection principle

12. Changes to This Policy

We may update this Privacy Policy from time to time — for example, as we enable ads, in-app purchases, or other features described in this policy as optional. We will notify you of material changes via an in-app notification. Where required by applicable law, we will request your explicit consent to the updated policy before continuing to process your personal data under the new terms.

13. Contact Us

For privacy-related questions or to exercise your rights: