1. Data controller
The controller of your personal data is GoFox – Tecnologias de Informação Unipessoal, Lda., tax number (NIF) [NIF], registered at SanjoTec – Centro Empresarial e Tecnológico, Rua de Fundões, n.º 151, Sala B2.2, 3700-121 São João da Madeira, Portugal.
For any privacy question or to exercise your rights, contact us at info@gofox.pt or on +351 256 001 932 (charged as a call to a Portuguese landline). We are not required to appoint a Data Protection Officer; these contacts fulfil that role.
2. Scope and legal framework
This policy covers the Pack&GO! website and the Pack&GO! game for iOS and Android (the "app"). It follows the General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR"), Portuguese Law no. 58/2019 of 8 August, which implements it in Portugal, and Law no. 41/2004 of 18 August, as amended, on privacy in electronic communications.
3. Data processed on the website
The website is informational: it has no forms, no user registration and no member area, it uses no cookies and it loads no third-party content (fonts and images are served from our own servers).
As with any website, the server automatically logs each request: IP address, date and time, page requested, browser and operating system. We use these logs only to keep the website secure and working, based on our legitimate interest (GDPR Art. 6(1)(f)).
To open the website in your language, we read the language preferences your browser sends with each request. We don't store them: the chosen language only lives in the page address (see the Cookie Policy).
Links to the App Store, Google Play and social networks lead to third-party websites, which have their own privacy policies.
4. Data processed in the app
Pack&GO! never asks for your name, email or a password. We process the following data:
| Data | Purpose | Legal basis |
|---|---|---|
| A player ID generated by the app, an access key, game progress (levels, cities, coins, items and purchases made), platform, app version and language | Create your game account automatically, save your progress to the cloud and restore it on another device | Performance of a contract (GDPR Art. 6(1)(b)) |
| Your Google Play Games or Game Center account ID, if you link it | Connect your progress to your platform account, at your request | Performance of a contract (GDPR Art. 6(1)(b)) |
| In-app purchase confirmations (product, transaction ID, date) | Deliver purchased items, restore purchases and meet legal obligations | Performance of a contract and legal obligation (GDPR Art. 6(1)(b) and (c)) |
| The device's advertising ID, IP address, device model and system, and ad interactions | Show ads, measure their performance and prevent fraud; personalise ads, only if you consent | Consent for personalised ads (GDPR Art. 6(1)(a)); legitimate interest for non-personalised ads and fraud prevention (Art. 6(1)(f)) |
| App usage data and crash reports (game events, crashes, device model) | Understand how the game is played, fix bugs and balance the levels | Consent for usage statistics; legitimate interest for crash reports (GDPR Art. 6(1)(a) and (f)) |
| Name, email and message content, when you contact us | Answer your request | Legitimate interest and, where applicable, performance of a contract (GDPR Art. 6(1)(b) and (f)) |
Payments are processed by Apple (App Store) or Google (Google Play). We never receive your card or payment details.
We do not sell your personal data, and we make no solely automated decisions that have legal effects on you.
5. Advertising and consent
The app shows ads through Google AdMob. On first launch, if you are in the European Economic Area, the United Kingdom or Switzerland, you are shown a Google-certified consent form where you choose whether to accept personalised ads.
If you don't consent, you will still see ads, but they won't be personalised. You can change your choice at any time through the app's privacy option, or reset your advertising ID in your device settings. Withdrawing consent does not affect processing carried out before then.
More about how Google uses data: policies.google.com/technologies/partner-sites.
6. Recipients and processors
Your data may be shared with the following parties, who process it on our behalf or as independent controllers:
- The hosting providers of our servers, where your game account and progress are stored;
- Google Ireland Limited (Google AdMob, Google Firebase, Google Play and Google Play Games) — policies.google.com/privacy;
- Apple Distribution International Ltd. (App Store and Game Center) — apple.com/legal/privacy;
- Public authorities, where required by law.
7. International transfers
Some of these providers may process data outside the European Economic Area, including in the United States. In those cases the transfer relies on a European Commission adequacy decision (including the EU-U.S. Data Privacy Framework) or on standard contractual clauses approved by the European Commission (GDPR Art. 45 and 46).
8. Retention
- Game account and progress: for as long as the account exists. If you delete your account in the app, the data is erased from our servers within 30 days. Accounts with no activity for 2 years are deleted;
- Purchase records: for the period required by tax and accounting law;
- Server access logs: 12 months at most;
- Support messages: up to 2 years after the last contact;
- Advertising and analytics data: for the periods set out in Google's policies.
9. Your rights
Under GDPR Articles 15 to 22, you have the right to:
- access your personal data;
- have inaccurate data corrected;
- have your data erased (you can also delete your account directly in the app's settings);
- restrict processing;
- receive your data in a structured, commonly used format (portability);
- object to processing based on legitimate interest;
- withdraw your consent at any time, without affecting processing already carried out.
To exercise these rights, write to info@gofox.pt. We will reply within one month, which may be extended under GDPR Art. 12(3). Because the app doesn't ask for your name, we may ask for the player ID shown in the game's settings to find your data.
You also have the right to lodge a complaint with the Portuguese data protection authority, the Comissão Nacional de Proteção de Dados (CNPD), at cnpd.pt, or with the authority in your country of residence.
10. Children
Pack&GO! is a game for all ages. In Portugal, a person can only consent on their own to the processing of their data by online services from the age of 13 (Art. 16 of Law no. 58/2019). Below that age, consent must be given by a parent or legal guardian.
If you are a parent or guardian and believe we have collected data from a child without proper authorisation, contact us and we will delete it.
11. Security
We apply appropriate technical and organisational measures to protect your data, including encrypted connections (HTTPS), an individual access key per account and restricted access to our servers.
12. Changes to this policy
We may update this policy to reflect changes to the game, the website or the law. The date of the last update is shown at the top of the page. If the changes are significant, we will let you know in the app.
This document is also available in Portuguese. If the versions differ, the Portuguese version prevails.