Privacy Policy

1. Introduction

Cocoa Sandwich LLC ("we," "us," or "our") operates TruckSim GPS, a companion application and related services for Euro Truck Simulator 2 (ETS2) and American Truck Simulator (ATS). This Privacy Policy explains how we collect, use, and protect your information when you use our application, website, and related services.

2. Information We Collect

Account Information

When you create an account or sign in through a supported authentication provider (Google, Apple, or Patreon), we may collect your email address, display name, and profile picture as provided by your identity provider. If you sign in with Apple and choose to hide your email, we receive Apple's private relay email address instead of your personal email.

Guest Accounts

You can use the app without signing in. The app then creates a guest account with a random identifier and no name or email. Its data is handled the same way as a signed-in account's.

Linked Accounts

If you optionally link a Patreon account to access subscription features, we receive your Patreon user ID, email address, and membership status from Patreon. This information is used solely to verify and manage your subscription entitlements.

Purchase and Subscription Data

When you subscribe to TruckSim GPS Pro, we collect purchase and subscription information including transaction history, subscription status, billing period, and entitlement records. This data is processed by RevenueCat (acting as our data processor) for subscription management and receipt validation, and by the Apple App Store or Google Play Store for payment processing.

In-Game Data

TruckSim GPS processes real-time in-game data from ETS2 and ATS, such as vehicle position and speed, together with game profile and configuration data that the app needs to work with your setup. When you use navigation, we also store your route requests and driving distance to run the Service, apply usage limits and improve routing. This is entirely in-game data and does not include any real-world GPS or location information.

PC Telemetry and the Relay Server

PC Telemetry is the free Windows program that sends game data from your PC to the app. On your home network the app talks to it directly, and nothing goes through our servers. When your phone and PC are not on the same network, the app connects through our Relay Server instead. For that, PC Telemetry and our servers handle:

• A random identifier for your PC, which says nothing about you or your computer, and a random identifier for each linked phone or tablet.
• For pairing with a QR code or a code, your PC's name and local network addresses. They are encrypted on your PC before they reach our servers, which keep them only while the code is valid (two minutes).
• If a phone used the Relay Server with your PC in the last 30 days, PC Telemetry keeps a small waiting connection open to our Relay Server while a game is running or its window is open in front, so the app can reach your PC again without a new QR code. The Relay Server sees your PC's public IP address, its identifier, the phone's identifier and encrypted connection data, and keeps none of it after the connection closes.
• Game data sent through the Relay Server is encrypted end to end between the app and your PC. Our servers and Cloudflare pass it along without being able to read it, and none of it is stored.

Usage Analytics

We collect information about how you use the Service, including features accessed, session activity, and general usage patterns. This data helps us improve the app and is collected through the analytics services listed below. It is linked to an identifier for your device, not to your name or email.

Device Information

We may collect your operating system version, app version, and device platform for compatibility, debugging, and service improvement purposes.

3. How We Use Your Information

• Authentication: to verify your identity and manage your account
• Service delivery: to provide navigation and other app features
• Subscription management: to determine your access tier, validate purchases, and manage entitlements
• Service improvement: to analyze usage patterns and improve features
• Service operations: to manage fair-use limits, prevent abuse, and maintain service quality
• Advertising: to display ads to free-tier users and measure ad performance (Pro subscribers are ad-free)
• Communication: to send important service updates (if you opt in to our mailing list)

4. Legal Basis for Processing

If you are located in the European Economic Area (EEA) or the United Kingdom, we process your personal data under the following legal bases:

• Contract performance: Processing necessary to provide the Service, including authentication, subscription management, and navigation features (GDPR Article 6(1)(b)).
• Legitimate interests: Processing necessary for our legitimate interests, including service improvement, analytics, fraud prevention, and maintaining fair-use limits, where these interests are not overridden by your rights (GDPR Article 6(1)(f)).
• Consent: Processing based on your consent, such as personalized ads or subscribing to our mailing list. You may withdraw consent at any time (GDPR Article 6(1)(a)).

5. Third-Party Services

We use the following third-party services that may process your data:

• Firebase (Google): Authentication, identity management, and analytics. When you sign in with Google, your Google account information (email, name, profile picture) is accessed in accordance with the Google API Services User Data Policy. We only request the minimum data necessary for authentication. Firebase Privacy Policy
• RevenueCat: Acts as a data processor on our behalf for subscription management, receipt validation, and entitlement tracking. RevenueCat processes your purchase history and subscription status. RevenueCat also tells us the store country of your Apple or Google account (country level only), which we use for regional pricing and subscriber statistics. RevenueCat maintains SOC 2 Type II and ISO 27001 certifications. RevenueCat Privacy Policy
• Patreon: OAuth authentication and membership verification for users who subscribe through Patreon. Patreon Privacy Policy
• Apple App Store / Google Play: Payment processing for in-app subscriptions. Governed by Apple and Google privacy policies
• Unity LevelPlay (ironSource): Advertising. We display ads to free-tier users using Unity LevelPlay (formerly ironSource). This SDK may collect device information (device model, operating system, language, carrier, connection type), advertising identifiers (IDFA on iOS, Advertising ID on Android), IP address, and ad interaction data (views, clicks, installs). Approximate location (city/country level) may be inferred from your IP address for ad targeting purposes. Where the law requires it (for example in the EEA and the UK), the app asks for your consent before showing personalized ads, and you can change your choice at any time in the app's settings. On iOS, the app also asks your permission through App Tracking Transparency before enabling personalized ads. Unity Privacy Policy
• Mixpanel: Product analytics. We use Mixpanel to understand how users interact with the app, including feature usage, session activity, navigation events, and app performance. Mixpanel collects device information (device model, OS version) and coarse location (city/country level, derived from IP address). Mixpanel does not collect precise location data. You can opt out of Mixpanel tracking at mixpanel.com/optout. Mixpanel Privacy Policy
• Firebase Crashlytics (Google): Crash reporting. Crashlytics collects crash logs, stack traces, and device state information to help us diagnose and fix app issues. Your Firebase user ID may be associated with crash reports for debugging purposes. Firebase Privacy Policy
• Sentry: Error monitoring for our servers. Error reports can include technical data such as your user ID and are deleted after a limited period. Sentry Privacy Policy
• netcup GmbH: Server hosting. Our API server and its database run on servers operated by netcup GmbH (Karlsruhe, Germany; data center in Vienna, Austria) under a GDPR data processing agreement. Server logs include your IP address and are kept for a short period for security and troubleshooting. Our Relay Servers, which pass encrypted connections between the app and PC Telemetry, also run on netcup servers, in Germany and the United States. netcup Privacy Policy
• Cloudflare: Website hosting, security, and analytics, and delivery of content the app downloads, such as map data. Connections to our Relay Servers also pass through Cloudflare (see PC Telemetry and the Relay Server above). Cloudflare Privacy Policy
• EmailOctopus: Mailing list management (opt-in only). EmailOctopus Privacy Policy

6. Data Sharing

We share your data only with the third-party service providers listed above, solely for the purposes of providing and improving TruckSim GPS. We do not sell your personal data to data brokers or other third parties.

Our advertising partner (Unity LevelPlay) may collect and share device identifiers and ad interaction data with advertising networks for the purpose of serving and measuring advertisements. This data sharing applies only to free-tier users who see ads. Pro subscribers do not see ads, and no ad-related data is collected or shared for Pro users.

7. Data Security

We protect your information using industry-standard measures, including encryption of data in transit, secure storage of authentication credentials, and use of reputable infrastructure providers. While we take reasonable measures to protect your data, no method of transmission over the internet is 100% secure.

8. Data Retention

• Account data: retained until you delete your account
• Purchase and subscription data: retained for the duration of your account and as required by applicable financial and tax regulations
• Real-time in-game data: processed in real time; not stored, except the route and driving history below
• Route and driving history: retained for your account and deleted with it
• IP addresses: kept for a limited time for security, abuse prevention and usage limits
• Game profile and configuration data: retained for your account and deleted with it
• Usage analytics: retained in pseudonymous form for service improvement, under our analytics providers' retention periods

9. Your Rights

GDPR Rights (EEA and UK Residents)

If you are a resident of the European Economic Area or the United Kingdom, you have the right to:

• Access your personal data
• Rectify inaccurate personal data
• Erase your personal data ("right to be forgotten")
• Port your data to another service
• Object to processing of your personal data
• Restrict processing of your personal data
• Withdraw consent at any time, where processing is based on consent

You also have the right to lodge a complaint with your local data protection supervisory authority if you believe your rights have been violated.

CCPA Rights (California Residents)

If you are a California resident, you have the right to:

• Know what personal information is collected
• Delete your personal information
• Opt-out of the sale of personal information (we do not sell your data)
• Correct inaccurate personal information
• Non-discrimination for exercising your rights

Account Deletion

You can request deletion of your account and associated data at any time through the app settings or by contacting us at [email protected].

• Upon requesting deletion, you will be signed out immediately.
• Your account enters a 14-day grace period during which you may cancel the deletion by signing back in.
• After the grace period, your account and the personal data linked to it are permanently deleted from our systems and from the service providers that hold your account data. Some providers, such as crash reporting and analytics, keep limited technical data for their own retention periods before deleting it.

For users who signed in with Apple, we will also revoke the associated Apple token as part of the deletion process, in compliance with Apple's requirements.

10. Children's Privacy

TruckSim GPS is not directed at children under the age of 13. We do not knowingly collect personal information from children under 13. If we become aware that we have collected data from a child under 13, we will take steps to delete it promptly. If you believe a child has provided us with personal data, please contact us at [email protected].

11. International Data Transfers

Your data may be processed in various locations around the world, including the United States and the European Union, depending on the service providers involved. We ensure appropriate safeguards are in place for international data transfers in accordance with applicable data protection laws.

12. No Real-World Location Data

TruckSim GPS does not collect, store, or transmit any real-world GPS or location data. All position, route, and navigation data refers exclusively to in-game coordinates within Euro Truck Simulator 2 and American Truck Simulator. The app does not access your device's GPS hardware or location services.

13. Automated Decision-Making

TruckSim GPS does not use automated decision-making or profiling that produces legal effects or similarly significant effects on you.

14. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated effective date. For significant changes, we will notify users through the app or our website. Your continued use of TruckSim GPS after changes are posted constitutes acceptance of the updated policy.

15. Contact

If you have questions about this Privacy Policy or wish to exercise your data rights, contact us at:

Cocoa Sandwich LLC
Email: [email protected]