Privacy Policy for Lido Simulator
Last updated: 8 October 2026
1. Controller and contact
The controller responsible for processing personal data in connection with the Lido Simulator iPhone app is:
Arno Littmann · Happy Game Design
Friedrich-Ebert-Str. 66
42719 Solingen
Germany
Email: info@happygamedesign.info
2. Scope and overview
This policy describes data processing in Lido Simulator, including Google AdMob for non-personalized advertising and Google's User Messaging Platform (UMP) for privacy choices. Advertising-related processing depends on whether advertising is active in your app version, your privacy choices and ad availability.
No user account is required. Game saves are stored locally. We do not operate a server for your game saves or send them to Google. Advertising services may nevertheless process technical personal data separately. No additional advertising network SDKs through AdMob mediation or separate analytics tools such as Firebase Analytics are integrated.
3. Game saves, settings and audio
Your device stores game progress, beach and town layouts, inventory, game day, economic data, unlocks, language and audio settings. It may also store whether a rating prompt has already been shown. These data support gameplay and preserve your preferences.
Where personal data are involved, the legal basis is Article 6(1)(b) GDPR. Storage on and access to your device that are strictly necessary for these functions are based on section 25(2), no. 2 of Germany's TDDDG.
You can remove game saves by resetting the game; settings may remain until you delete the app. Device backups may retain data after local deletion. You manage those backups through your device or Apple; we cannot access them. Bundled music and ambient sounds play locally without sending data to us for playback.
4. Advertising before the beach search
When advertising is active, a Google AdMob rewarded video may be offered before the beach search. You start it using the relevant button. The reward is access to the beach search after the reward event; ending the video early does not grant this reward. If no ad is available or no permissible ad can be loaded, the app uses its provided access to the search without a video.
The app requests only non-personalized ads and disables publisher personalization and Google's publisher first-party ID. It does not request Apple's App Tracking Transparency permission and does not provide for IDFA use for cross-app advertising personalization. These settings do not eliminate all technical identifier or data processing by the advertising service.
5. Data and purposes in Google AdMob
Depending on consent and serving mode, processing may include IP address and approximate region, device/app information and identifiers, ad interactions, and diagnostic and performance data.
Purposes include delivering contextual advertising, limiting repetition, measuring and billing ads, troubleshooting, and preventing fraud and abuse. Non-personalized ads are not selected using a historical cross-app interest profile; app context and approximate region may, for example, be considered.
Non-personalized does not mean data-free: device storage and identifiers may still be required for technical advertising purposes. Refusing consent therefore does not automatically permit ordinary non-personalized ads. Depending on your choice, Google may use a limited serving mode or no ad is loaded. Limited ads may still involve technical connection and security data.
6. Consent, privacy options and legal bases
We use Google UMP to manage your choice. It processes consent status and technical information needed to provide the appropriate message; your selection is stored on your device and considered in later ad requests. Where required, the message appears before the first ad request. You can consent, refuse or select the available settings. Starting a video does not replace this privacy decision.
Advertising processing requiring consent is based on Article 6(1)(a) GDPR; device storage or access requiring consent is based on section 25(1) TDDDG. Processing strictly necessary to implement and document your privacy choice serves our legal data protection obligations under Article 6(1)(c), together with Articles 5(2) and 7(1) GDPR. Strictly necessary device storage is based on section 25(2), no. 2 TDDDG.
Any limited technical processing for secure delivery, fraud prevention or permissible measurement without consent requires its own legal basis. Where Article 6(1)(f) GDPR applies, legitimate interests are secure operation, prevention of abusive ad requests and reliable billing. This does not replace required consent for device access. The privacy message explains the specific purposes, providers and available choices.
When UMP requires an entry point to revisit the message, the app settings provide privacy options (labelled “Datenschutzoptionen” in German). You can change your choices and withdraw consent at any time with effect for the future. You can also contact us. Withdrawal does not affect the lawfulness of earlier processing. Advertising consent is not mandatory; refusal may affect ad availability but does not prevent the rest of the game. Changing your choice discards preloaded ads, and subsequent requests take the new choice into account.
7. Recipients and Google's role
For users in the European Economic Area and Switzerland, the Google service provider is generally Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, may also be involved.
Google also processes advertising data as an independent controller within its advertising services and is not solely our processor. Depending on the ad and privacy choice, other advertising technology providers or ad buyers may be involved. The privacy message identifies the applicable providers and purposes. Not integrating additional mediation SDKs does not exclude these participants in Google's advertising system.
Further information:
Google privacy: https://policies.google.com/privacy?hl=en
Processing in partner apps: https://policies.google.com/technologies/partner-sites?hl=en
8. Processing outside the EEA
Google and participating providers may process data outside the European Economic Area, particularly in the USA. Transfers to appropriately certified US recipients may rely on the adequacy decision for the EU-US Data Privacy Framework. Google LLC is certified under this framework. Where no adequacy decision applies, Google identifies standard contractual clauses as a transfer mechanism, with supplementary safeguards where appropriate. Further information about safeguards and how to obtain copies:
https://policies.google.com/privacy/frameworks?hl=en
9. Retention
Local game data remain until you remove them as described above. Privacy choices are retained as necessary to implement them and, where applicable, demonstrate them; a new request may be needed, for example when the message changes.
There is no single deletion period set by us for data processed by Google and other providers. Retention depends on data type and purpose, your settings, security and billing needs, and statutory retention obligations. Google's retention and deletion criteria are explained here:
https://policies.google.com/technologies/retention?hl=en
Withdrawing consent or deleting the app does not automatically delete all data already held by Google.
10. Apple and existing entitlements
Apple processes data relating to the App Store, TestFlight, device backups and, where applicable, purchases under its own policies. The app may check existing purchase entitlements through StoreKit to respect valid ad-free entitlements. The full version is currently not offered for purchase. We do not receive full payment or credit card details in this process.
The app may display Apple's rating prompt. Apple processes ratings; the app does not learn which rating you submit.
https://www.apple.com/legal/privacy/
11. Device access, support and linked websites
The app does not request access to your precise device location, contacts, photos, camera, microphone, health data, calendar, Bluetooth, or motion and fitness data. An advertising service's inference of approximate location from an IP address is a separate matter.
If you contact us, we process your email address, your name where provided, your message and any details you voluntarily include to handle your enquiry. The legal basis is Article 6(1)(b) GDPR for contractual matters, otherwise Article 6(1)(f) GDPR based on our interest in answering enquiries. We retain correspondence as necessary to handle the matter and, where applicable, meet legal obligations or resolve claims. Our email service provider is STRATO GmbH, Germany, acting as a processor.
When opening website or support links, the website privacy information additionally applies to the visit and any contact form there:
https://happygamedesign.info/hgd-datenschutz/
12. Your rights
Subject to the legal conditions, you have rights of access, rectification, erasure, restriction of processing and data portability, and the right to withdraw consent. For processing under Article 6(1)(f) GDPR, you may object on grounds relating to your particular situation; you may object to direct marketing at any time.
You can complain to a data protection supervisory authority, particularly in the country of your habitual residence, place of work or suspected infringement. The authority for our location is the State Commissioner for Data Protection and Freedom of Information North Rhine-Westphalia, Germany: https://www.ldi.nrw.de
To exercise your rights, contact info@happygamedesign.info. For data processed independently by Google or Apple, you may also contact those providers directly. As we do not maintain central game-save accounts, we cannot access your local saves. We do not use solely automated decisions producing legal or similarly significant effects on you.
13. Security and changes
We use appropriate technical and organisational safeguards. Please also keep your device and operating system up to date and protect device access. We update this policy when functions, services or legal requirements change. Any required new consent will be requested separately.