Privacy Policy

Effective Date: October 19, 2025

Last Updated: August 31, 2026

1. Introduction

This Privacy Policy explains how Lucky Trails (“we”, “us”, or “our”) collects, uses, and protects your personal data when you use the Lucky Trails mobile application (the “App”) or visit our website at https://luckytrails.ie. This policy applies to all services and features offered through the App and the Website, and governs data processing in accordance with applicable Irish and EU data protection laws.

Lucky Trails is operated by Anastasiia Voloshchuk, a sole trader registered in Ireland, who acts as the data controller for all personal data collected through the App and Website.

We respect your privacy and are committed to protecting your personal information. By accessing or using the App or Website, you agree to the terms of this Privacy Policy.

2. Contact Information

If you have questions about how your data is handled, you can contact us at:

Email: luckytrails.ie@gmail.com
Business Address: 4 The Terrace, Strand St, Tramore, Co. Waterford, X91 KH39, Ireland

We aim to respond to all privacy-related inquiries within a reasonable timeframe.

3. Data We Collect

We collect and process the following categories of personal data depending on how you use our App or Website:

Account Data (App Only): Email address (if shared by authentication provider); User ID; Authentication provider (Google or Apple); Account creation and last login timestamps
Gameplay Data (App Only): Game progress, puzzle answers, points, last action timestamp; Number of saved states (save/resume); Experience completion status
Device & Technical Data (App): Device type and operating system; App version; Crash logs and performance diagnostics; Camera access status (only to determine if permission has been granted to take a selfie during specific game segments); Usage statistics and interaction data, collected via Firebase Analytics (e.g., feature engagement, session duration, device model)
Device & Technical Data (Website): When you access our Website, Vercel, our hosting provider, may process limited technical request information such as your IP address, browser and device information, requested pages, timestamps, and security-related data to deliver and protect the Website
Website Analytics Data: We use Vercel Web Analytics to collect anonymous information about visits to our Website, such as page views and general usage patterns. This information is not associated with an identified visitor, and Vercel Web Analytics does not use cookies.
Location Data (App Only): Collected only with your consent, and used solely to enable location-based gameplay
User-Generated Content: Optional - selfies submitted during designated challenges (only if the user explicitly consents to submit them)
Support & Feedback Data: Emails or other messages sent to our support team

4. How We Collect Data

We collect data through the following means:

When you create and log into an account, using third-party providers like Google or Apple
As you progress through quests and interact with puzzles within the App
When you voluntarily submit content, such as selfies or messages as part of gameplay or feedback
If you enable location sharing, to support real-world quest navigation
Automatically via Firebase (e.g., save and resume timestamps, App version and crash reports, session duration and feature usage)
If you grant camera access within your device settings, we may temporarily store the selfie image in local cache on your device to display it during the end-of-game sequence
Automatically through Firebase Analytics to understand how users interact with the App (e.g., how long users engage with quests, which features are most used)
When you visit the Website, Vercel processes limited technical request information as necessary to host, deliver and protect the Website
Automatically through Vercel Web Analytics to understand general Website traffic and usage. The analytics information collected is anonymous and does not use cookies.

5. Legal Basis for Processing

We rely on the following legal bases under the General Data Protection Regulation (GDPR):

Performance of a contract - to deliver the core functionality of the App, such as managing quests, saving progress, and providing access to purchased trails
Consent - for collecting location data during gameplay; photos submitted by users (e.g., selfies for in-game moments)
Legitimate interest - to maintain App and Website security, monitor performance, enhance usability, and understand general engagement through privacy-conscious analytics, including Firebase Analytics for the App and Vercel Web Analytics for the Website
Legal obligation - if required to comply with Irish or EU law, such as accounting or regulatory requirements

6. How We Use Your Data

We use your data to:

Create and manage your account
Save and sync your quest progress
Enable gameplay features (including real-world navigation)
Improve app functionality and troubleshoot bugs
Verify and manage your purchase entitlements using RevenueCat (we do not process payments directly)
Respond to support requests
Share user-submitted photos in marketing, only with opt-in consent
Operate, deliver and protect the Website through Vercel
Some visual elements within the App (e.g., illustrations or puzzle imagery) may be generated using artificial intelligence tools. These are used to enhance the user experience and do not involve the use of personal data or biometric identifiers
Monitor and improve engagement and performance using analytics data, including Firebase Analytics for the App and anonymous, aggregated Vercel Web Analytics data for the Website

7. Third-Party Services

We use the following trusted third parties, who may process data on our behalf:

Firebase (Google) - used for authentication, gameplay state management, and backend hosting
RevenueCat - used to verify and manage in-app purchase access and entitlements. RevenueCat does not process payments; transactions are handled by Apple and Google
Google Play / Apple App Store - payment processing and login integration
Vercel - Website hosting, delivery, security and Web Analytics. Vercel may process limited technical request information as necessary to provide and protect the Website. Vercel Web Analytics also provides anonymous, aggregated information about Website traffic and usage without using cookies.

All third-party processors are contractually bound to handle your data securely and in line with GDPR. Where data is transferred outside the EEA, we ensure appropriate safeguards such as Standard Contractual Clauses (SCCs) are in place.

8. Payment Information

All payments for Lucky Trails experiences are processed securely through the Apple App Store and Google Play Store. We do not collect or store any financial data (e.g., credit card numbers) on our servers. Please refer to the payment platforms' terms and privacy policies for more details:

9. Data Retention

We retain your data only as long as necessary to deliver services and meet legal obligations:

Account & Gameplay Data: Retained until your account is deleted
User-Submitted Photos: Only retained with consent, and may be deleted on request
Support Queries: Retained for up to 12 months
When you delete your account, all associated personal data is permanently removed from our system and third-party services (e.g., Firebase, RevenueCat) unless we are required by law to retain it for a limited time (e.g., for fraud prevention or tax compliance), in which case it will be securely stored and not used for any other purpose

10. Third-Party Links

Our App may include links to third-party websites or services (e.g., Google Maps). We do not control and are not responsible for the content or privacy practices of these third parties. We encourage you to review their Privacy Policies before using their services.

11. Your Rights

If you are located in the EU, you have the following rights under the General Data Protection Regulation (GDPR):

Right of Access - to know what data we hold about you
Right to Rectification - to correct inaccurate or incomplete data
Right to Erasure - to request deletion of your data
Right to Restrict Processing - to limit how we use your data
Right to Data Portability - to transfer your data to another provider
Right to Object - to object to our processing on certain grounds
Right to Withdraw Consent - at any time, where processing is based on consent
Right to Lodge a Complaint - with the Irish Data Protection Commission: https://www.dataprotection.ie/en/contact/how-contact-us

You can exercise your rights by contacting us at the email listed above.

12. Children’s Privacy

Our services are intended for users aged 16 and over. We do not knowingly collect data from anyone under 16 without verified parental consent. If such data is discovered, it will be deleted immediately. If you are a parent or guardian and believe your child has provided us with personal data without your consent, please contact us at luckytrails.ie@gmail.com.

13. Data Security

We apply appropriate technical and organisational measures to safeguard your data, including:

Secure login and account authentication via Google or Apple
Encrypted storage of gameplay and account data in Firebase
Strict access control to backend systems (limited to authorised personnel only)

If we become aware of a personal data breach, we will act promptly to contain the breach, assess the risk, and notify the Irish Data Protection Commission and affected users when required under applicable data protection laws.

However, no system is 100% secure, and we encourage users to protect their account credentials.

14. Changes to This Policy

We may update this Privacy Policy to reflect changes in our services or legal obligations. Changes will be posted on this page with the “Last Updated” date updated. Continued use of the App indicates acceptance of the revised policy.