Blacktop GM Privacy Policy

Version 1.0 · Effective 7 October 2026 · Publisher: Petar Otovic (Morava) · Contact: contact@morava.dev

1. Who we are and what this policy covers

Blacktop GM ("the game" or "the app") is published by Petar Otovic, an independent developer based in Serbia who publishes under the name Morava ("we", "us", "our"). This policy explains what information the game handles, why, who it is shared with, how long it is kept, and the choices and rights you have.

It applies to:

It does not cover Google Play, the Apple App Store, Sign in with Apple or Google Sign-In, or the advertising partners named in section 5. Each of those is run by its own company under its own privacy policy, which we link to where it is relevant.

Effective date: 7 October 2026 · Last updated: 7 October 2026 · Version: 1.0

Data controller (where the EU or UK GDPR applies): Petar Otovic, 18106, Serbia.

Contact for privacy questions and requests: contact@morava.dev

2. The short version

Blacktop GM is an offline game first. Everything you build in it lives on your own device, and we collect as little as the game needs to work.

3. Information we collect, and where it comes from

We collect information in five ways. Most of it is handled by the game on your device and never reaches us.

3.1 Information that stays on your device

The game writes these files to its own private storage on your phone. They are not sent to us or to anyone else by the game. We cannot read them. Your phone's operating system may include them in a device backup (Google Backup on Android, iCloud Backup on iOS) under your own backup settings and the privacy policy of Google or Apple.

Deleting the game deletes all of these. The game has no cloud save, so we cannot recover them for you.

3.2 Advertising information (Google AdMob)

The only ads in Blacktop GM are rewarded videos: nothing plays unless you tap a button to watch an ad for an in-game perk. The ads are served by Google AdMob, a service of Google LLC. When an ad loads or plays, Google's Mobile Ads software inside the game collects and sends to Google:

Google uses this to pick, show, cap, measure and bill ads, to detect fraud, and, where you have consented or where the law allows it, to show you ads based on your interests. Google may share some of this with its advertising partners for the same purposes (see section 5). We receive only aggregated reports from Google: how many ads were shown and what they earned. We never receive your advertising ID or IP address from Google.

3.3 In-app purchases

Pro and GM token packs are sold through Google Play Billing on Android and Apple's App Store (StoreKit) on iOS. Google or Apple takes your payment under its own terms and privacy policy. We never receive your card or bank details. The store sends the game a purchase confirmation (product name, purchase or order token, purchase state and time), which the game records on your device as described in 3.1. Google and Apple also show us order records in our developer dashboards (order number, product, country, date, amount and currency, and refund status) so that we can handle refunds and keep accounts.

3.4 Online account and online teams (optional)

You can play Blacktop GM without an account. If you choose to sign in, we and our hosting provider Supabase store:

The GM name, city and team name are free text. If you type your real name or other personal details there, we will hold them as part of your team. Please do not include other people's personal information.

3.5 Messages you send us

If you email us for support, a refund question or a privacy request, we receive your email address, your message, any attachments you include, and anything we need to ask you to confirm your identity.

3.6 What we do not collect

The game does not collect your precise location, contacts, calendar, photos, files, camera or microphone input, health or fitness data, biometric data, messages, browsing history, or any government, financial or payment account numbers. It does not read other apps on your device except as noted in 3.2 for advertising. It does not let you upload photographs: faces, crests and jerseys are drawn inside the game.

Summary

CategoryExamplesWho collects itWhere it is held
Game saves and purchase recordFranchises, game logs, Pro, GM tokens, tour flagThe game, on your device onlyYour device (and your own OS backup)
Advertising identifiers and device dataAdvertising ID, IP address, device model, OS, ad viewsGoogle AdMob, inside the gameGoogle's systems
Purchase confirmationsProduct, order token, time, refund statusGoogle Play / App Store, then the gameYour device; Google's or Apple's systems; our developer dashboards
Account dataAccount ID, email, sign-in provider, created and last sign-in timesUs, via Supabase AuthSupabase on AWS, United States (us-east-1)
Online teamsNames you type, crest, jersey, GM face, staff, rosterUs, via our serverSupabase on AWS, United States (us-east-1)
Server security logsIP address, device type, request timeSupabaseSupabase on AWS, United States, short-term
Support messagesEmail address, message contentUsOur email account

We use personal information only for the purposes below. Where the EU GDPR, UK GDPR or Swiss law applies, the table also gives the legal basis we rely on for each purpose.

PurposeInformation usedLegal basis (GDPR / UK GDPR)
Provide the online account and keep the teams you send usAccount data, profile data, online teamsPerformance of a contract with you (Art. 6(1)(b)): our terms and this policy
Enforce the team limit, Pro entitlement and creation rules, and prevent cheating or abuseProfile data, online teams, security logsLegitimate interests (Art. 6(1)(f)): keeping the online game fair and secure
Show you a rewarded ad when you ask for one, and earn the revenue that keeps the game freeAdvertising identifiers and device data (collected by Google)In the EEA, UK and Switzerland: your consent (Art. 6(1)(a) and the ePrivacy rules), which you can withdraw at any time. Elsewhere: our legitimate interest in funding the game, subject to the opt-outs in section 5
Deliver what you buy, restore purchases, and handle refunds and disputesPurchase confirmations, order records from Google or ApplePerformance of a contract (Art. 6(1)(b)); legal obligation (Art. 6(1)(c)) for tax and accounting records
Keep the service secure, diagnose faults and investigate misuseSecurity logs, account dataLegitimate interests (Art. 6(1)(f)): security and integrity of the service
Answer your questions and act on your privacy rightsSupport messages, account dataLegitimate interests (Art. 6(1)(f)) for support; legal obligation (Art. 6(1)(c)) for rights requests
Comply with law, court orders and lawful requestsAny of the above, as requiredLegal obligation (Art. 6(1)(c))

Where we rely on legitimate interests, we have weighed them against your interests and rights and concluded they are not overridden, because the processing is limited, expected, and under your control. You can object at any time (section 11).

No marketing. We do not send marketing email or push notifications, and we do not use your information for marketing.

No automated decisions about you. We make no decisions with legal or similarly significant effects on you by automated means. The game's own simulation acts only on fictional players. Google may build an interest profile from your advertising activity to pick ads, but only where you have consented or opted in as described in section 5.

Providing information is voluntary. You can play the whole game without an account and without watching ads. You need an account only for the online features, and the information in 3.4 is needed to provide them. If you do not provide it, we cannot offer you those features.

5. Advertising and your choices

What you will see. Blacktop GM shows rewarded video ads only. The game never shows an ad you did not ask for: an ad plays only after you tap a button offering an in-game perk in return for watching it. There are no banner, interstitial, app-open or native ads.

Who serves them. The ads come from Google AdMob. Google and the advertising partners it works with may serve two kinds of ad:

The partners that may receive your data for personalised ads are those on Google's ad technology partners list. How Google uses the data is described in How Google uses information from sites or apps that use our services. We never pass your name, email address or account ID to Google's advertising systems.

European Economic Area, United Kingdom and Switzerland. Before the game requests its first ad, it shows a consent notice from Google's User Messaging Platform, a consent management platform certified by Google under the IAB Europe Transparency and Consent Framework. You can accept, reject, or choose purpose by purpose and partner by partner. Your choice is stored on your device as a consent string that Google and the listed partners read. If you do not consent, Google serves only limited ads that do not use your advertising identifier, and some rewarded ads may not be available; the rest of the game works exactly the same. You can change or withdraw your choice at any time inside the game under OFFICE → PRIVACY OPTIONS. Withdrawing consent does not affect what was done before you withdrew it.

Apple devices. On iOS, Google can read your device's advertising identifier (IDFA) only if you allow tracking when iOS asks "Allow Blacktop GM to track your activity across other companies' apps and websites?". If the game does not ask, or you decline, the identifier is not available and ads are not personalised with it. You can change this at any time in Settings → Privacy & Security → Tracking. Apple's SKAdNetwork lets advertisers measure installs from ads without identifying you.

United States. In California, Colorado, Connecticut, Virginia, Texas, Oregon and the other states with privacy laws, you can opt out of personalised advertising, which those laws may call a "sale", "sharing" or "targeted advertising", inside the game under OFFICE → PRIVACY OPTIONS. When you opt out, the game tells Google to apply restricted data processing, so it serves ads without personalisation and does not sell or share your data for that purpose. We also honour the Global Privacy Control signal where the platform passes it to us. Section 12 has the full list of your rights.

Everyone, everywhere. You can also limit personalised ads through your device:

Minors. We do not knowingly serve personalised ads to anyone under 18. If the app store signals, or you tell us, that a device is used by a minor, we treat its ads as non-personalised. Section 10 says more about children.

Pro does not change any of this. Buying Pro adds game features; it neither removes nor adds ads, because there are no ads to remove.

6. Who we share information with

We do not sell personal information, we do not share it with data brokers, and we do not give it to anyone for their own marketing. Information reaches other companies only in the ways below.

RecipientWhat they receiveWhyTheir role and policy
Google LLC (AdMob and the Google Mobile Ads SDK)Advertising identifier, IP address, device and app details, ad interactions, your consent choicesTo serve, measure, cap and bill the rewarded ads you choose to watch, to detect fraud, and, with your consent or where the law allows, to personalise adsGoogle decides for itself how it uses this data for ad serving. Google may pass it to the ad-technology partners it works with for the same purposes. Google Privacy Policy · How Google uses information from sites or apps that use our services · Google's ad technology providers
Supabase, Inc. (hosting, sign-in, database and server functions, running on Amazon Web Services in the United States)Account data, profile data, online teams, security logsTo run the online account and keep your teamsOur processor, acting only on our instructions under a data processing agreement. Supabase Privacy Policy
Apple Inc.The identity token and email (or relay email) from Sign in with Apple; App Store purchasesTo let you sign in with your Apple ID, and to sell Pro and GM tokens on iOSIndependent controller. Apple Privacy Policy
Google LLCThe identity token, email, name and picture link from Google Sign-In; Google Play purchasesTo let you sign in with your Google account, and to sell Pro and GM tokens on AndroidIndependent controller. Google Privacy Policy
Our email provider (unlimited.rs, a brand of United Internet d.o.o., Serbia)Messages you send usTo receive and answer your messagesOur processor

We may also disclose personal information:

A note for California residents. Allowing Google to use your advertising identifier to personalise ads can count as "sharing" for cross-context behavioural advertising under California law, even though no money changes hands. Section 12 explains how to opt out, and we honour the Global Privacy Control signal. We do not knowingly sell or share the personal information of anyone under 16.

7. How long we keep information

We keep personal information only as long as the purpose in section 4 needs it, and then delete or anonymise it. The periods below apply to each category.

CategoryKept forWhy this long
Game saves, game logs, purchase record, templates, tour flagOn your device until you delete the franchise or uninstall the game. We never hold a copyThey are yours; the game cannot work without them
Account and profile dataUntil you delete your account, then removed from our live systems within 30 days and from our provider's backups within a further 30 days. We may delete an account that has not signed in for 24 months, after trying to notify you at the email on the accountTo run the account for as long as you want it
Online teamsUntil you delete the team or the account, on the same schedule as account dataThey belong to the account
Security logs held by our hosting providerA short period, never longer than 90 daysTo diagnose faults and investigate abuse
Order records shown to us by Google Play and the App StoreFor as long as tax and accounting law requires, up to 10 years from the purchaseLegal obligation
Support messages and privacy requestsUp to 2 years after the last message, and at least 24 months for records of privacy requests where California law requires itTo follow up on a case, and to show we handled requests properly
Advertising data collected by GoogleUnder Google's own retention rules: Google anonymises IP addresses in its advertising logs after 9 months and cookie or identifier information after 18 months. Google data retentionSet by Google as the controller of that data

We may keep a copy of information for longer where the law requires it, where it is needed for a legal claim, or in anonymised form that no longer identifies you.

8. Where your information goes (international transfers)

We are based in Serbia. Our server runs in the United States (Amazon Web Services, Virginia region, operated by Supabase). Google and Apple process data in the United States and in other countries where they operate. If you live in the European Economic Area, the United Kingdom or Switzerland, your information therefore leaves those areas.

We protect it with the safeguards the law recognises:

RecipientCountrySafeguard
Google LLC (advertising, Google Sign-In, Google Play)United States and worldwideCertified under the EU–US Data Privacy Framework, its UK Extension and the Swiss–US Data Privacy Framework; Google's standard contractual clauses as a fallback
Apple Inc. (Sign in with Apple, App Store)United States and worldwideCertified under the EU–US Data Privacy Framework, its UK Extension and the Swiss–US Data Privacy Framework
Supabase, Inc. (hosting)United StatesEuropean Commission Standard Contractual Clauses (module two, controller to processor), the UK International Data Transfer Addendum, and the Swiss adaptations, all in Supabase's data processing addendum
UsSerbiaInformation you send straight to us is not a "transfer" under the GDPR, but we handle it under this policy and to GDPR standards. There is no European Commission adequacy decision for Serbia.

The EU–US Data Privacy Framework was upheld by the EU General Court in September 2025; an appeal to the Court of Justice is pending. If the Framework were ever invalidated, transfers to Google and Apple would continue under standard contractual clauses. You can ask us for a copy of the safeguards we rely on at the contact address in section 15.

For Switzerland (Art. 19 FADP): your information is disclosed to the United States, where the Data Privacy Framework provides adequate protection for certified companies and standard contractual clauses cover the rest, and to Serbia, which is not on the Federal Council's list of countries with adequate protection. For disclosures to Serbia we rely on the exceptions in Art. 17 FADP: the performance of our contract with you for the account and online teams, and your consent when you choose to contact us.

9. Security

We protect the information we hold with measures appropriate to the small amount and low sensitivity of that information.

No system is perfectly secure. Keep your device's operating system up to date, protect your Apple or Google account with a strong password and two-factor authentication, and tell us at once if you think your account has been misused.

10. Children

Blacktop GM is made for adults and teenagers. It is rated for ages 13 and over and is not directed at children under 13. It has no features that appeal mainly to young children, and we do not market it to them.

Under 13 (United States, COPPA). We do not knowingly collect personal information from children under 13. Do not create an online account, send us a message, or watch ads if you are under 13. If we learn that we have collected personal information from a child under 13 without verifiable parental consent, we will delete it as quickly as we can. If you are a parent or guardian and believe your child has given us personal information, contact us at contact@morava.dev and we will delete it.

Under the age of digital consent (EEA, UK, Switzerland). Where the GDPR applies, children below the age of digital consent in their country (between 13 and 16, depending on the country; 13 in the United Kingdom) cannot consent to personalised advertising or create an account without a parent or guardian. If you are below that age, use the game without an account and do not accept personalised ads. If we learn we hold an account for a child below that age without parental consent, we will delete it.

Under 16 and under 18 (US states). We do not sell or share the personal information of anyone we know to be under 16, and we do not show personalised ads to anyone we know to be under 18. Where a state law requires parental or the minor's own consent for targeted advertising, we treat the absence of that consent as an opt-out.

Age signals from the app stores. Some places, including Texas, Utah, Louisiana and California from 2027, require Google Play or the App Store to tell apps a user's age category. If we receive such a signal, we use it only to apply age-appropriate protections: switching off personalised ads and blocking account creation where required. We never use it for advertising, analytics or profiling, we do not share it, and we do not keep it longer than needed to apply those protections.

Parents. Google Play and the App Store offer family controls that can block purchases, restrict apps by rating and manage a child's device: Google Family Link and Apple Screen Time.

11. Your rights in the EEA, the United Kingdom and Switzerland

If you are in the European Economic Area, the United Kingdom or Switzerland, you have these rights over the personal information we hold about you. All of them are free to exercise.

Information we get from others. When you sign in, Apple or Google sends us the account data listed in section 3.4: an identifier, your email address or relay address, and, from Google, your name and profile picture link. This is the only information about you that we receive from a source other than you or the game.

How to exercise a right. Email contact@morava.dev from the email address on your account, or write to the address in section 15. If we cannot tell that the request comes from the account holder, we will ask you to confirm it, for example by signing in or replying from the account email. We answer within one month. For complex or numerous requests we may take up to two further months, and we will tell you within the first month if so. We keep a record of each request for 24 months.

Advertising data held by Google. Google is a separate controller of the advertising data described in section 3.2. You can exercise your rights over it directly with Google through Google's privacy policy and My Ad Center. We will help you if you contact us.

Complaints. If you are unhappy with how we handle your information, we would like to put it right: write to us first, and we will acknowledge your complaint within 30 days and tell you the outcome. You also have the right to complain to a supervisory authority at any time:

12. Your rights in the United States

California (the CCPA as amended by the CPRA), Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Iowa, Delaware, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky and Rhode Island give their residents rights over personal information, and Oklahoma, Louisiana, Alabama and Vermont follow in 2027 and 2028. Most of these laws apply only to businesses above a size threshold that we may not meet. We honour the rights below for every United States resident regardless. This section is also our California notice at collection and our disclosure under the California Online Privacy Protection Act.

Personal information we have collected in the last 12 months

CategoryWhatWhere it comes fromWhySoldShared for cross-context behavioural advertisingDisclosed for a business purpose to
IdentifiersAccount ID, email address, name from Google Sign-In; advertising ID and IP addressYou; Apple or Google when you sign in; your device, through Google's ad softwareAccount, security, advertisingNoAdvertising ID and IP address: yes, to Google and its ad partners, only while personalised ads are onSupabase (hosting) and our email provider; Apple and Google for sign-in
Customer recordsThe name and email on your accountYou; the sign-in providerAccountNoNoSupabase
Commercial informationProducts bought, order records and refund status; GM tokens heldGoogle Play or the App Store; the game on your deviceDeliver purchases, refunds, accountingNoNoNobody beyond Google or Apple, who already hold them
Internet or network activityAd views, taps, app interactions and diagnostics collected by Google's ad softwareYour device, through GoogleAdvertising, analytics, fraud preventionNoYes, to Google and its ad partners, only while personalised ads are onNobody
Geolocation (approximate only)Country or city derived from your IP address by GoogleYour device, through GoogleAdvertising, fraud preventionNoYes, as aboveNobody
InferencesAn interest profile Google may build to pick adsGoogleAdvertisingNoBuilt by Google only while personalised ads are on; we draw no inferencesNobody
User contentThe online teams you create: names you type and designs you makeYouAccount featuresNoNoSupabase

We do not collect protected classifications, biometric information, audio or visual recordings, professional, employment or education information, precise geolocation, or sensitive personal information: we never hold passwords, government identifiers, financial account numbers, health information or precise location. Section 7 gives the retention period for each category.

Your rights

Do Not Sell or Share My Personal Information

We do not sell personal information. The only "sharing" or "targeted advertising" is personalised advertising through Google (section 5). To opt out, open OFFICE → PRIVACY OPTIONS → Do Not Sell or Share My Personal Information in the game. The game then tells Google to apply restricted data processing for your device, and we will not ask you to opt back in for at least 12 months. We honour the Global Privacy Control and other opt-out preference signals where the platform passes them to us. We do not sell or share the personal information of anyone we know to be under 16, and we do not show personalised ads to anyone we know to be under 18.

How to make a request

Email contact@morava.dev, or delete your account inside the game. We respond within 45 days; if we need longer we will tell you within that time and take at most 45 more days. Requests are free unless they are plainly excessive. To protect your information we verify requests: for account data, by having you sign in or reply from the email on your account; for anything else, by matching what you tell us against what we hold. An authorised agent may make a request for you if they show us your signed permission, and we may still confirm the request with you directly. We keep a record of requests for 24 months.

Appeals. If we refuse a request, reply within 60 days with the word "Appeal" and your reasons. We will answer in writing within 45 days (60 days in Texas and Louisiana) with our decision and the reasons for it. If we still refuse, you can complain to your state attorney general: find your attorney general. California residents can contact the California Privacy Protection Agency or the Attorney General.

Other California and state notices

13. What the app store labels say

Google Play's Data safety section and Apple's App Privacy details are filled in to match this policy, including data collected by the Google Mobile Ads software inside the game. This table is the same information in the stores' own categories. "Linked to you" means the store treats it as identifying you; "tracking" is Apple's term for linking data about you with data from other companies' apps and sites for advertising.

WhatCollected byGoogle Play Data safetyApple App PrivacyLinked to youUsed for tracking
Advertising identifierGoogle AdMobDevice or other IDs, collected and shared, for advertising and fraud preventionIdentifiers: Device ID, for third-party advertisingYesYes, only where you allow it (section 5)
Approximate location from IP addressGoogle AdMobLocation: Approximate location, collected and shared, for advertising and fraud preventionLocation: Coarse Location, for third-party advertisingYesYes, only where you allow it
Ad views, taps and app interactionsGoogle AdMobApp activity: App interactions, collected and shared, for advertising and analyticsUsage Data: Product Interaction and Advertising Data, for third-party advertising and analyticsYesYes, only where you allow it
Diagnostics and crash data from the ad softwareGoogle AdMobApp info and performance: Diagnostics and Crash logs, collected, for analyticsDiagnostics: Performance Data and Crash DataPerformance yes, crash noNo
Account IDUs (Supabase)Personal info: User IDs, collected, optional, for account managementIdentifiers: User ID, for app functionalityYesNo
Email addressUs (Supabase)Personal info: Email address, collected, optional, for account managementContact Info: Email Address, for app functionalityYesNo
Name from Google Sign-InUs (Supabase)Personal info: Name, collected, optional, for account managementContact Info: Name, for app functionalityYesNo
Online teams you createUs (Supabase)App activity: Other user-generated content, collected, optional, for app functionalityUser Content: Gameplay Content, for app functionalityYesNo
Game saves, purchase record, templatesNobody: stays on your deviceNot collectedNot collected——
Payment detailsGoogle Play or Apple, never usNot collected by the gameNot collected by the game——

All data in transit is encrypted. Everything we hold about an account can be deleted from inside the game (section 15). The data Google collects for advertising is governed by Google's privacy policy and deleted or anonymised on Google's schedule (section 7).

Google Play account deletion link: https://morava.dev/blacktop-gm/delete-account/

14. Changes to this policy

We will update this policy when the game's data practices change, when the law changes, or at least once every 12 months when we review it. The current version is always at https://morava.dev/blacktop-gm/privacy/ and inside the game under OFFICE → PRIVACY POLICY. The effective date and version number at the top tell you when it last changed.

If a change materially reduces your rights or expands how we use personal information already collected, we will tell you before it takes effect with a notice inside the game and, for account holders, by email to the address on the account, and we will ask for your consent again where the law requires it. Continuing to use the game after a change takes effect means the new policy applies, except where consent is required.

15. Contact us

For any question about this policy, to exercise a right, or to delete your account or data:

We answer within 30 days (45 days for California requests, extendable once by a further 45 days with notice). If you are in the EEA, UK or Switzerland and are not satisfied with our answer, section 11 explains how to complain to your data protection authority.