Bubbleton Privacy Notice

Who we are

Bubbleton is made by 61 West Labs Ltd (“61 West Labs”, “we”), a company registered in England and Wales, company number 17425611, registered office 46 Trelawney Road, Hainault, IG6 2NH. We decide how Bubbleton’s data is used, so we are its “controller” under UK data protection law. For anything about this notice or your child’s data, email hello@61westlabs.co.uk.

This notice covers the Bubbleton app only. Our other games are covered by the games privacy policy, and this website by our website privacy policy.

The short version, for grown-ups

• No account and no sign-in. We never ask for a name, email address, phone number, photo or location.
• No typing. There is no chat, no messaging and no free text anywhere in the game.
• No ads, no analytics, no tracking. No advertising ID, no third-party analytics or crash-reporting tools, and we don’t sell or share data for marketing.
• The age question stays on the phone. We never receive it.
• Online, we keep only game data under a random id: a made-up name, scores with replays, and a copy of the progress. It is deleted automatically after 24 months without play.
• Leaderboards are off for players under 13 unless a grown-up turns them on.
• Delete it any time from the app, or by email. See how to delete Bubbleton data.

What goes to our server, and why

When the phone is online, Bubbleton talks to our game server. This is everything it stores:

Leaderboards are optional. If the age answer is 12 or under, they are off until a grown-up turns them on in Settings → For grown-ups (behind the grown-up check). For everyone else they are on when the game is installed, and a player or grown-up can switch them off in Settings → “Show me on leaderboards”. While they are off, no new scores are posted; the game still shows the Daily Run ghost, which only downloads. Scores posted earlier stay on the leaderboards for the periods below, or until Delete my data. Runs played in Gentle mode are never ranked.

Internet addresses (IP addresses): our server sees the phone’s IP address when it connects, like any website does. It uses it only for a short time, in memory, to stop anyone flooding the server with requests. It never writes it to the database or its logs. The secure proxy in front of the server keeps no access log; its error log can occasionally record the IP address of a connection that fails before reaching the game server. Those entries aren’t linked to any player and are deleted after at most 30 days.

Server logs record which kind of request came in, whether it worked and how long it took. They don’t contain IP addresses, names or progress. When a player deletes their data, the log notes that a random player id was deleted, and nothing else about it.

What stays on the phone

These are saved on the phone or tablet only. We never receive them:

• The age answer (“5 or under” up to “18 or older”), asked once when the game starts for the first time.
• Play time (today and this week, shown in the grown-up corner) and the break reminder setting.
• Gentle mode, sound, language and other settings.
• The picture card made when a player taps Share. The phone makes it and hands it to the phone’s own share menu; it shows the score and the player’s outfit, never a name. We don’t receive it or know where it goes.

The age answer, play time and the break reminder are kept in a separate place on the phone that is left out of the phone’s own backups (Google backup on Android, iCloud backup on iPhone) and phone-to-phone transfers, so they never move to another phone; a new phone asks the age question again. If the phone’s own backup is switched on, it may include the game’s other saved settings and progress, in your Google or Apple account. That backup belongs to you and is handled by Google or Apple; we can’t see it.

Children

Bubbleton is made for all ages, including young children, and we have designed it to collect as little as possible:

• The age question is neutral (no answer is picked for you, and no answer is better than another) and stays on the phone. It only changes how the game plays: for players aged 8 or under, Gentle mode is switched on (fewer critters, calmer attacks, an extra heart, not ranked), only a grown-up can switch it off, and the game doesn’t show leaderboard rank messages.
• Leaderboards are off for players aged 12 or under (by the age answer) until a grown-up turns them on. On phones that already had the game, they were switched off once, with a message saying so.
• A grown-up check (a short sum a young child is unlikely to answer) guards everything that leaves the game or can’t be undone: links to websites and email, sharing, changing the age answer, turning leaderboards on for a player under 13, and Delete my data.
• Purchases go through the Google Play or App Store payment screen, which asks for the account holder’s password, fingerprint or face. We recommend switching on Google Play’s parental controls or Apple’s Ask to Buy for children.
• No sign-in, no typed names, no chat, no ads, no location, no contacts, no camera or microphone.

We don’t check anyone’s age, because we don’t collect anything that would need it. If you have any concern about your child’s data, email us and we’ll help.

Purchases

Seaside Park stages 1–3 are free. The full game is a single one-off purchase; there are no subscriptions, no loot boxes and nothing else to buy. Gems and shells are earned by playing and can’t be bought.

Payment happens in Google Play or the App Store under their own terms and privacy policies; we never see card or bank details. Purchases are managed for us by RevenueCat, which receives the store receipt and the game’s random player id (never a name or email) so it can confirm the purchase and restore it on another phone. When a player’s data is deleted, we also ask RevenueCat to delete its record for that player id. Refunds are handled by the store you bought from.

What we don’t do

No advertising, no advertising IDs, no analytics or crash-reporting services, no location, no contacts, no microphone or camera, no selling or renting of data, and no profiling of players for marketing. We don’t send notifications.

Where data is kept, and who helps us

The game server and its database run on a server we manage at IONOS in London, United Kingdom. All traffic is encrypted (HTTPS). The database is backed up every night; backups are encrypted with our own key before they leave the server, stored in Google Drive (Google can’t read them) and deleted after 30 days.

Our service providers are:

• IONOS (UK): server hosting.
• Google: app distribution (Google Play) and storage for our encrypted backups.
• Apple: app distribution (App Store).
• RevenueCat (United States): purchase records. When RevenueCat handles data in the US, it is protected by safeguards approved under UK law (such as the UK’s International Data Transfer Addendum, or the UK Extension to the EU–US Data Privacy Framework).

We don’t share Bubbleton data with anyone else, unless the law requires us to.

How long we keep things

• Player id, made-up name, cloud save and all-time leaderboard scores: until you delete them (in the app or by email), or automatically 24 months after the game last connected to our server.
• Daily Run scores: deleted 13 months after the day they were played.
• Run replays: deleted 90 days after the run (the score itself stays for the periods above). We need them only to check scores are genuine and for the Daily Run ghost.
• Backups: 30 days, so anything deleted is gone from the backups within 30 days too.
• Server logs (no IP addresses): overwritten automatically as new entries come in.
• Purchase records at Google, Apple and RevenueCat: kept by them as their own policies and tax law require. Deleting Bubbleton data doesn’t undo a purchase; the full game stays with the store account and can be restored.

Deleting your data

1. Open Bubbleton and tap Settings.
2. Tap For grown-ups and answer the grown-up check.
3. Tap Delete my data and confirm twice.

This deletes the player id, made-up name, all scores and replays and the cloud save from our server straight away, asks RevenueCat to delete its purchase record for that player id, wipes the game’s data on that phone, and starts the game again like a new install. If the phone is offline, the phone’s data is wiped at once and the online data is deleted the next time the game connects.

You can also email hello@61westlabs.co.uk, with the player name shown in the game (Profile, or next to your score on the leaderboards). Full details are on how to delete Bubbleton data.

Why we are allowed to use this data

UK data protection law needs a reason (a “lawful basis”) for each use:

• Leaderboards, checking scores are genuine, cloud save and keeping the server safe: our legitimate interests in running a fair, secure game that doesn’t lose players’ progress. We have weighed these against players’ interests, with extra care because many players are children, and keep only what these features need. We don’t rely on a child’s consent.
• The full-game purchase: to perform the purchase contract with the account holder who bought it, and to keep the records the law requires.

Families in the United States

Bubbleton doesn’t collect personal information such as names, email addresses, photos, voice or location from children. The only identifier it uses is the random player id described above, and we use it only to run the game for that player: to keep scores and saved progress, check scores are genuine, restore a purchase and keep the service secure. We never use it for advertising, to build a profile of a player, or to contact anyone, and we don’t disclose it to anyone except RevenueCat for purchases. We keep it only as long as those uses need, as set out in “How long we keep things” above, and never indefinitely. A parent can review or delete their child’s data at any time as described above.

Your rights

Under UK data protection law (the UK GDPR and the Data Protection Act 2018), you, or a parent or carer on a child’s behalf, can ask us to show you the data we hold, correct it, delete it, send it to you in a common format, or stop using it. Email hello@61westlabs.co.uk with the player name from the game. We reply within one month. If you’re not happy with our answer, you can complain to the Information Commissioner’s Office (ICO), the UK’s data protection regulator.

Changes to this notice

If Bubbleton starts handling data differently, we’ll update this page and the date at the top before the change reaches the game, and mention anything important in the game’s release notes. We won’t start collecting anything new from children without updating this notice first.