This Privacy Policy explains how OSCA Studios collects, uses, and protects personal data of users of its mobile games and applications, in accordance with Regulation (EU) 2016/679 of April 27, 2016 (the "GDPR") and applicable French data protection law (Law No. 78-17 of January 6, 1978, as amended).
This policy applies to all games and applications published under the OSCA Studios brand on Google Play, the App Store, and any other distribution platform, unless a specific game states otherwise.
Contents
1. Data Controller
Nicolas Ungern-Sternberg, sole trader ("entrepreneur individuel") operating under the trade name OSCA Studios
Country: France
Contact email: contact@oscastudios.com
OSCA Studios is a brand operated by an individual sole trader: the data controller within the meaning of the GDPR is the natural person named above.
2. Data We Collect
OSCA Studios games are designed to keep personal data collection to the strict minimum. Depending on the game and the features you use, the following categories of data may be processed:
| Category | Examples | Source |
|---|---|---|
| Technical and usage data | device model, OS version, language, gameplay statistics, progression, in-game events | Firebase Analytics |
| Technical identifiers | advertising identifier (AAID/IDFA), install identifier | AdMob, Firebase, internal cross-promotion system (Firestore) |
| Crash data | error logs, app state at the time of the crash | Firebase Crashlytics |
| Transaction data | purchase history, purchased item, transaction status (no payment card data) | Google Play Billing (in-app purchases) |
| Advertising data | ad interactions, promotional content displayed | AdMob, internal house-ads / cross-promotion system |
OSCA Studios never collects your payment details: in-app purchases are processed directly by Google Play Billing, whose own privacy policy applies to that step.
3. Purposes and Legal Bases
- Running the game and saving your progress — performance of a contract / legitimate interest.
- Audience measurement and game improvement (Firebase Analytics) — consent.
- Crash diagnostics and technical stability (Crashlytics) — legitimate interest (strictly technical data, never used for commercial purposes).
- Displaying ads (AdMob, personalized or non-personalized) — consent for personalized ads; legitimate interest for non-personalized ads strictly necessary to sustain the free-to-play model.
- Cross-promotion between OSCA Studios games (house ads) — legitimate interest, limited to promoting other games from the same publisher, with no third-party ad profiling.
- In-app purchases — performance of a contract.
4. Recipients and Processors
Data is processed by the following technical service providers, acting as processors or joint controllers as applicable:
- Google LLC — Firebase Analytics, Firebase Crashlytics, Cloud Firestore, Google Play Billing
- Google AdMob — advertising network embedded in the games
This data is never sold, rented, or shared for commercial purposes with any third party beyond these technical providers necessary for the game to function.
5. International Transfers
Some providers (notably Google) may process data outside the European Economic Area, including in the United States. These transfers rely on the European Commission's Standard Contractual Clauses and/or the EU-U.S. Data Privacy Framework, ensuring an adequate level of protection.
6. Data Retention
- Progression and save data: for as long as you use the game, then deleted after an extended period of inactivity.
- Analytics and advertising data: as defined by Google's own retention periods (generally 14 to 26 months depending on the service).
- Transaction data: retained for the legally required accounting and tax period.
- Crash logs: retained only as long as needed to resolve technical issues.
7. Children's Privacy
OSCA Studios games are designed for a general audience, with no age restriction, and may be used by children under 13.
In this context, OSCA Studios is committed to:
- never serving personalized ads in games that may be used by children, in line with Google Play's Families Policy;
- limiting data collection to what is strictly necessary for the game to function when the user is identified as a minor;
- never asking children directly for personal information (name, address, email);
- recommending that parents or legal guardians supervise use of the games by children under 15, the age below which, under French law, consent from a holder of parental authority is required for any processing based on consent.
Any parent or legal guardian wishing to exercise a child's rights may contact contact@oscastudios.com.
8. Consent Management
The first time you launch an OSCA Studios game, a consent banner (powered by Google's User Messaging Platform) lets you accept or decline non-essential trackers (personalized advertising, audience measurement). Trackers strictly necessary for the game to function (save data, security, crash diagnostics) do not require prior consent but are listed in this policy. You can change your choice at any time from the game's "Privacy" menu, where available, or from your device's advertising settings.
9. Data Security
OSCA Studios implements reasonable technical and organizational measures to protect processed data against unauthorized access, loss, or alteration, relying in particular on Google Firebase's secure infrastructure.
10. Your Rights
Under the GDPR, you have the following rights over your personal data:
- right of access and rectification;
- right to erasure ("right to be forgotten");
- right to restriction of processing;
- right to object;
- right to data portability.
To exercise these rights, contact contact@oscastudios.com. You will receive a response within one month at the latest.
11. Filing a Complaint
If you believe your rights are not being respected, you may lodge a complaint with the French data protection authority, the CNIL (Commission Nationale de l'Informatique et des Libertés): www.cnil.fr. You may also contact the data protection authority in your own EU country of residence.
12. Changes to This Policy
This policy may be updated to reflect legal, technical, or functional changes. The "last updated" date at the top of this page indicates the current version. We encourage you to review it periodically.
13. Contact
For any question regarding this Privacy Policy or the processing of your data:
OSCA Studios
Email: contact@oscastudios.com