Privacy policy

Last updated: 26 October 2026

Who we are

The data controller is Gerale Consulting di Germinario Alessio. For any question about this policy or your data, write to contact@geraleconsulting.com.

What this policy covers

This policy covers the mobile game Refract, published by Gerale Consulting di Germinario Alessio on Google Play and the App Store, and this website.

This website

This website uses no cookies, no analytics and no tracking. It is served by Google Firebase Hosting, which processes technical data such as your IP address and browser type to deliver the pages and protect the service.

The game

Refract does not require an account and never asks for your name, email address or other contact details. Your progress and settings are stored only on your device and are deleted when you uninstall the game.

To run the game we use the services below. Each one receives only the data described here.

Advertising: Google AdMob

The free version of Refract shows ads served by Google AdMob. To show and measure ads, AdMob may process your device's advertising ID, IP address and basic device information. In the European Economic Area, the United Kingdom and Switzerland the game asks for your consent first, and personalised ads are shown only if you agree; you can change your choice at any time from the game's settings. You can reset or delete your advertising ID at any time in your device settings. How Google uses data from apps that use its services.

Game settings: Google Firebase Remote Config

Firebase Remote Config lets us adjust game settings, such as how often ads appear, without an update. It processes a Firebase installation ID and basic app and device information. Firebase privacy information.

Crash reports: Sentry

When the game crashes or hits an error, it sends a report to Sentry so we can fix it. The report contains the device model, operating system and app version, performance data and a list of the game actions that led to the error. The game is set up not to send personal data such as IP addresses. Sentry privacy policy.

In-app purchases

Purchases are handled by Google Play or the App Store. We never receive your payment details; we only receive confirmation of which item was bought.

Legal bases

• Personalised ads: your consent, which you can withdraw at any time.
• Non-personalised ads, game settings, crash reports and security: our legitimate interest in offering a free game that works reliably.
• In-app purchases: performance of the contract you enter into when you buy.

How long data is kept

Data on your device stays until you uninstall the game. Crash reports are kept for up to 90 days. Data processed by Google and Sentry is kept according to their own policies.

Transfers outside the EU

Google and Sentry may process data in the United States. These transfers are covered by the EU-US Data Privacy Framework or by the European Commission's Standard Contractual Clauses.

Children

Refract is not directed at children under 13, and we do not knowingly collect personal data from them. If you believe a child has provided personal data, contact us and we will delete it.

Your rights

Under the GDPR you can ask to access, correct or delete your personal data, restrict or object to its processing, and receive it in a portable format. You can also withdraw consent at any time. Because the game does not ask who you are, we may need details from you, such as the device, to find the data concerned. You also have the right to lodge a complaint with the Italian data protection authority, the Garante per la protezione dei dati personali, or with the authority of your own country.

Changes

If this policy changes we will publish the new version on this page and update the date at the top.