Pilot Donut Privacy Policy

Effective date: 12 October 2026

This policy explains how the game Pilot Donut — the Android app and the web version at iceberg-holding.github.io/river-game-play (together, “the game”) — handles information. The game is designed for children aged about 10–13 and for families. We wrote this policy to be readable by parents and by older children.

1. Who we are

The game is developed and published by:

For any personal data that could be processed in connection with the game, UAB Vebsana is the data controller under the EU General Data Protection Regulation (GDPR).

2. Designed for children

Pilot Donut is made for children and complies with the Google Play Families Policy. We follow the principles of the GDPR (including its special protections for children, Article 8) and the U.S. Children’s Online Privacy Protection Act (COPPA). Because the game does not collect personal information from anyone, we do not ask for a child’s age, name or any other details, and no parental consent is needed to play.

3. Information we do not collect

We do not collect, store, sell or share personal data. In particular, the game:

• has no user accounts, log-in or registration;
• has no chat, messaging, friend lists, leaderboards or user-generated content;
• does not use analytics, crash-reporting or tracking tools;
• does not use cookies;
• does not collect advertising IDs, location, contacts, photos, audio or other device data;
• contains no links to social networks.

4. Data saved on your device

To remember your game, Pilot Donut saves a small amount of data only on your device (in the browser’s or app’s local storage, “localStorage”):

• settings: language, sound and music volume, vibration on/off, control sensitivity;
• progress: best score, total score, unlocked worlds, achievements, and whether the tutorial and hints have been shown.

This data never leaves your device and is never sent to us or anyone else. We cannot see it. You can delete it at any time by clearing the app’s data or uninstalling the app (Android), or by clearing site data for the game in your browser (web).

5. Device permissions

The game does not ask for access to your camera, microphone, location, contacts, photos or files. It may use:

• Vibration — for short haptic effects during play. You can switch this off in the game’s settings.
• Internet access — the web version is loaded over the internet; the Android app may use the network only to load game content and, in the future, ads (see section 7).

6. Web version and hosting

The web version of the game is served by GitHub Pages (GitHub, Inc.). Like any web server, the hosting provider may process technical information such as your IP address in server logs in order to deliver the page and keep the service secure. We do not receive or use these logs. See the GitHub Privacy Statement. The Android app is distributed through Google Play, which is governed by Google’s Privacy Policy.

7. Advertising (planned — not active yet)

In the future, the Android app may show ads provided by Google AdMob (Google Ireland Limited / Google LLC). If and when we do:

• all ad requests will be tagged as child-directed (tagForChildDirectedTreatment), in line with COPPA and the Google Play Families Policy;
• only non-personalised (contextual) ads will be shown — no interest-based advertising, remarketing or profiling;
• the maximum ad content rating will be set to G (suitable for general audiences);
• we will use only ad networks that are certified for the Google Play Families programme.

Even with these settings, to deliver an ad, limit how often it is shown, and prevent fraud, AdMob may process limited technical information such as device identifiers (e.g. the advertising ID, where available), the IP address (used for approximate location only), device type, operating system and app version. Google processes this information under its own policies; see How Google uses information from sites or apps that use its services and the Google Privacy Policy. We do not receive any personal data from Google about players.

If a paid “remove ads” option is offered in the future, payment will be handled entirely by Google Play. We will not receive any payment details.

8. Your rights and parents’ rights

Because we do not collect personal data, there is normally nothing for us to access, correct or delete. Nevertheless, under the GDPR you (or, for a child, a parent or guardian) have the right to ask whether we process any personal data, and to request access, correction, deletion, restriction of processing, data portability, or to object to processing.

Under COPPA, parents may ask us to review or delete any personal information collected from their child and to refuse further collection. We do not knowingly collect such information; if you believe a child has sent us personal information (for example, by email), contact us and we will delete it promptly.

If you email us, we will use your email address and message only to answer you, and we will delete them when they are no longer needed.

9. Complaints

If you have concerns, please contact us first at info@vebsana.lt. You also have the right to lodge a complaint with a data protection supervisory authority. In Lithuania this is the State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija), L. Sapiegos g. 17, LT-10312 Vilnius, vdai.lrv.lt. You may also contact the authority in your own country of residence.

10. Security and data transfers

Because we do not collect personal data, we do not store it on servers or transfer it outside the European Economic Area. Locally saved game data is protected by your device and browser.

11. Changes to this policy

We may update this policy — for example, before we add ads to the game. When we do, we will publish the new version on this page and change the effective date at the top. If a change means the game starts processing personal data in a new way, we will update the policy before the change takes effect, and we will update the in-store information as required by Google Play.

12. Contact

Questions about this policy or your privacy? Email info@vebsana.lt or write to UAB Vebsana, Šilutės pl. 44-25, LT-94138 Klaipėda, Lithuania.

This policy is also available in Lithuanian. Both versions have the same content.