Business Name: NotionIQ s. r. o.
Registered Office: 878 Veľký Lapáš 951 04
ID No.: 56 813 376
Registered in: The Commercial Register of the District Court Nitra, Section: Sro, Insert No.: 65434/N
E-mail: stellarhazard@gmail.com
(hereinafter referred to as the “Controller”).
This Personal Data Processing Policy (hereinafter the "Policy") governs the terms of personal data processing in connection with the use of the mobile application Orcborn: The Great Flight (hereinafter the “Application”).
The Application does not require registration or account creation. We do not require your name, e-mail, or other identifying information. Nevertheless, when using the Application, certain technical data may be processed, which is collected by the integrated advertising network, Google AdMob. This data is used exclusively for the technical provision of non-personalized ads and does not include user profiling. This data may include, for example:
The Device Advertising ID is not transmitted or used in this case, as the Application is designated as suitable for children and implements special protection modes (tagForChildDirectedTreatment = true, tagForUnderAgeOfConsent = true). These settings ensure that ads are not personalized and that user profiling does not occur.
We do not link any of this data to your identity, we do not attempt to identify you directly, and we do not create any personal profile of you. All your game statistics (such as scores) are stored only locally on your device.
We process personal data for the following purposes:
tagForChildDirectedTreatment = true). As a result of this setting, the Advertising ID is not transmitted, and user profiles are not created. Only technical data (e.g., IP address, operating system, device model) is used.The Application does not require access to contacts, location, camera, microphone, or other sensitive components of the device. It also does not request data that would allow for the direct identification of the user (e.g., name, e-mail, or login).
Personal data is processed on the basis of our legitimate interest in accordance with Article 6(1)(f) of the GDPR.
This legitimate interest consists mainly of:
The processed data serves exclusively to ensure the basic functionality of the Application and to display non-personalized ads as part of a free information society service that the user has explicitly requested. The processed data is not used for profiling or for direct marketing by the Controller. Where technical data is processed (e.g., IP address, device type, system version), this is a necessary part of the communication between the Application and the third-party advertising system (Google Ireland Ltd.). Due to their technical necessity, the user's prior consent is not required for their processing.
Our Application does not use traditional cookies. However, in the context of displaying non-personalized ads through the Google AdMob service, technologies similar to cookies may be used, such as an IP address, device information (OS type and version), and other technical identifiers, which, however, do not include the Device Advertising ID. Given that this is technically necessary data, separate consent for the processing of this data is not required. Should we begin to use personalized ads or analytical tools in the future, an appropriate consent management mechanism will be added to the Application in accordance with legislative requirements.
Our Application displays ads through the Google AdMob service. Google Ireland Limited (hereinafter in this section referred to as “Google”) and its partner advertising companies may collect certain data from users during this process, particularly technical parameters and anonymous usage metrics for the purpose of providing ads.
The manner in which Google handles personal data through its official information channels is regulated here: https://policies.google.com/privacy.
In addition to Google itself, other advertising companies, so-called Google Certified Ad Technology Providers, may be involved in the process of displaying ads, processing personal data to the extent necessary to deliver non-personalized ads. The Application Controller has not made its own selection of advertising partners within the AdMob account. In accordance with the Google EU User Consent Policy, the default list of partners ("commonly used set") is therefore applied, which Google makes available on the following page: https://support.google.com/admob/answer/9012903
All partners on this list are contractually bound by Google's terms and have committed to complying with data protection rules under the GDPR.
To ensure compliance with legal and contractual requirements, a Consent Management Platform (CMP), specifically the Google User Messaging Platform (UMP) SDK, is implemented in the Application. This mechanism typically displays an initial dialog box requesting consent for data processing. In our case, however, we have used special parameters to designate the Application as intended for children, which in practice means that the standard consent dialog is not activated by default, as personalized ads are not displayed. The child-directed mode already precludes the display of ads based on interests or profiling. The user can view privacy information at any time in the Application's settings.
Our Application does not create any user profiles or carry out the processing of personal data for the purpose of ad targeting. All ads are non-personalized, which means they are not tailored based on the user's previous behaviour, interests, or other individual characteristics.
We do not use any automated decision-making mechanisms within the meaning of Article 22 of the GDPR that would have legal effects or similarly significant effects on the user's rights.
We process the provided personal data exclusively within the territory of the European Union. The Application as such does not transfer data outside the EU, and as the Controller, we do not transfer any personal data to third countries.
The display of non-personalized ads in the Application is provided by the Google AdMob service, operated by Google Ireland Limited, with its registered office at Gordon House, Barrow Street, Dublin 4, Ireland. Within this service, a technical transfer of some data (e.g., IP address) may occur to the servers of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, or to other entities operating in so-called third countries outside the European Economic Area (EEA).
These transfers are secured in accordance with Chapter V of the GDPR, primarily on the basis of Standard Contractual Clauses (SCC) approved by the European Commission, which Google Ireland Limited has implemented as part of its data protection commitments. Further information on these transfers can be found on the Google Ireland Limited website.
The visual and game content of the Application is also suitable for younger age groups and can therefore be used by children without age restriction.
In light of this fact, the Application has been implemented in accordance with the rules for protecting children's privacy in the digital environment. For the purpose of displaying ads, we have activated special modes within the Google AdMob service (tagForChildDirectedTreatment = true, tagForUnderAgeOfConsent = true), which ensure an increased level of protection.
These settings ensure that:
The Application does not require registration and does not support functionalities that would allow for the direct identification of the user (e.g., name, e-mail, comments, content uploading). For this reason, there is no active processing of children's personal data.
We process personal data only for the period necessary to fulfill the purpose for which it was collected. Since the Application does not store any data outside the user's device and all ads are non-personalized, no personal data is retained by the Controller. Data processed through the Google AdMob service is retained exclusively by Google Ireland Limited and its partners for a necessarily short period (typically several days to months), primarily for the purposes of ad display, statistical evaluation, and fraud prevention. More detailed information on data retention periods by Google is available in Google's privacy policy: https://policies.google.com/privacy.
This section of the document is dedicated to the specific purpose of processing, which is the recording of exercised rights of data subjects and the recording of personal data breaches, which we, as the Controller, are obliged to maintain in accordance with applicable legislation.
Recording of exercised rights of data subjects and data breaches according to Act No. 18/2018 Coll. on the Protection of Personal Data and on amending and supplementing certain acts; recording of exercised rights of data subjects according to Chapter III and notifications according to Articles 33 and 34 of Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.
Legitimate interest in accordance with Art. 6(1)(f) of the GDPR. The main legitimate interest is the recording of exercised rights and notifications of personal data breaches.
Data subjects to whom the request to exercise a right pertains; data subjects affected by a personal data breach.
Data related to the exercise of the right; data provided by the notifier when reporting a data breach.
Authorized persons in a contractual relationship with the Controller; entities to which the Controller is legally obliged to provide personal data.
Within 6 months after the expiration of 5 years from the exercise of the right or the occurrence of the data breach.
Although the Application does not require registration and does not collect personal data such as name, e-mail, or telephone number, its use may involve the processing of certain technical data (e.g., IP address) through integrated third-party tools like Google AdMob. In this context, as a data subject, you have rights under Chapter III of the GDPR, which you can exercise against the Controller. These rights include, in particular:
| Right under the GDPR | Content of the Right | How to Exercise |
|---|---|---|
| 1. Right to access (Art. 15) | To obtain confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, access to the personal data and further information (purpose, categories, recipients, etc.). | Send a request by e-mail to stellarhazard@gmail.com, stating the application name, device type, operating system, and advertising identifier (GAID/IDFA). |
| 2. Right to rectification (Art. 16) | To obtain the rectification of inaccurate personal data or the completion of incomplete data. | Given that the Application does not store identifying data, this right can only be exercised in relation to technical data processed by a third party. Contact us via stellarhazard@gmail.com, where we will provide assistance. |
| 3. Right to erasure (“right to be forgotten”) (Art. 17) | To obtain the erasure of data if it is no longer necessary for the purpose, is being processed unlawfully, etc. | Exercise by e-mail to stellarhazard@gmail.com with the relevant identifiers. If the data is processed exclusively by Google AdMob, the request will be forwarded, or the data subject will be referred to the correct Google interface. |
| 4. Right to restriction of processing (Art. 18) | To request that the processing be temporarily restricted. | Given the minimal processing by the Application, a request can be addressed to stellarhazard@gmail.com. Restriction can only be applied in cooperation with third parties (e.g., Google). |
| 5. Right to object (Art. 21) | To object to the processing of personal data that is carried out on the basis of a legitimate interest. | An objection can be filed by e-mail to stellarhazard@gmail.com with clear identification of the device. If the processing is carried out exclusively on behalf of Google, the right will need to be exercised through their systems. |
| 6. Right to data portability (Art. 20) | To receive personal data in a machine-readable format and transmit it to another controller. | This right is practically inapplicable in the Application, as we do not collect data directly. In relation to Google AdMob, a request can be submitted through their tools (e.g., Google Privacy Tools). |
| 7. Right to withdraw consent (Art. 7(3)) | If the legal basis for processing is consent, you have the right to withdraw it at any time. | Non-personalized ads are displayed in the Application, and therefore active consent is not required. |
| 8. Right to lodge a complaint with a supervisory authority (Art. 77) | To lodge a complaint with the Office for Personal Data Protection of the Slovak Republic. | The data subject can lodge a complaint directly with: Office for Personal Data Protection of the Slovak Republic, dataprotection.gov.sk |
In the event of an objection concerning the processing of your personal data, you have the right to submit a suggestion or request to the e-mail: stellarhazard@gmail.com.
The provision of technical data, such as an IP address or device data, is technically necessary for the proper functioning of the Application and the display of non-personalized ads. This data is collected automatically when using the Application and does not constitute a statutory or contractual requirement within the meaning of Article 13(2)(e) of the GDPR. However, not providing this data may affect the availability of the Application's basic functions.
We may amend this Privacy Policy from time to time (for example, due to changes in legislation, the introduction of new technologies, or adjustments to the way the Application functions). In such a case, we will update the date of the last change. We, therefore, recommend that you regularly check this page to stay informed about the current version of the Personal Data Processing Policy.
Last updated: July 10, 2025