Privacy Policy

1. Data Controller

The controller of your personal data is:

For any questions regarding the processing of your personal data, please contact us at the email address above.

Data Protection Officer: We have not appointed a Data Protection Officer as we are not required to do so under GDPR Article 37 (small-scale processing by a sole proprietor).

2. Information We Collect and Legal Basis

2.1 Data Stored Locally on Your Device

The App stores the following data locally on your device:

• Match history and statistics
• App settings and preferences (theme, language, animations)
• Consent preferences
• Game session data for match recovery

Legal basis: Legitimate interest (Art. 6(1)(f) GDPR) - to provide core app functionality and ensure a good user experience. We have conducted a balancing test and concluded that storing this data locally does not override your fundamental rights, as the data never leaves your device and you have full control over it.

Note: This data is stored only on your device and is not transmitted to our servers or any third parties.

2.2 Analytics Data (Firebase Analytics)

With your consent, we use Firebase Analytics to collect usage data. This includes:

• App usage patterns and feature engagement
• Device type and operating system version
• App crashes and performance data
• Country/region (derived from IP address)
• IP address (personal data - used by Firebase for geolocation, then truncated)

Legal basis: Consent (Art. 6(1)(a) GDPR) - you can enable or disable analytics collection at any time in App Settings → Privacy.

2.3 Advertising Data (Google AdMob)

With your consent, we display personalized advertisements through Google AdMob. Google collects:

• Advertising ID (personal data - unique device identifier)
• IP address (personal data)
• Device information (model, OS version)
• Interaction with ads (clicks, views)

Legal basis for personalized ads: Consent (Art. 6(1)(a) GDPR) - you can opt out in App Settings → Privacy.

Legal basis for non-personalized ads: Legitimate interest (Art. 6(1)(f) GDPR) - to maintain a free, ad-supported version of the App. We have conducted a balancing test and concluded that displaying non-personalized ads does not override your fundamental rights, as these ads do not track your behavior across apps or create a profile of your interests. Non-personalized ads still require basic device information and IP address to function.

Note: If you do not consent to personalized ads, you will see contextual (non-personalized) ads instead. Premium subscribers do not see any ads.

2.4 Purchase Data (Google Play Billing)

If you make in-app purchases:

• Transaction is processed entirely by Google Play
• We receive only: purchase status, subscription expiry date, and transaction ID
• We do not have access to your payment card details or billing address

Legal basis: Contract performance (Art. 6(1)(b) GDPR) - necessary to provide premium subscription services.

3. Cookies and Similar Technologies

The App and integrated third-party services (Google AdMob, Firebase) may use:

• Mobile Advertising ID - a resettable identifier on your device used for ad personalization
• Firebase Instance ID - used for analytics and crash reporting
• Local storage - for saving your preferences and consent choices

You can reset your Advertising ID or opt out of ad personalization in your device settings:

• Android: Settings → Google → Ads → Reset advertising ID / Opt out of Ads Personalization

4. International Data Transfers

Your data may be transferred to and processed in countries outside the European Economic Area (EEA), including the United States, where Google (Firebase, AdMob) operates servers.

We ensure appropriate safeguards for such transfers through:

• EU-U.S. Data Privacy Framework - Google LLC is certified under this framework
• Standard Contractual Clauses (SCCs) - approved by the European Commission

For more information about Google's data protection practices, see: Google Privacy Policy

5. Data Retention

Note on consent records: Your consent preferences are stored locally on your device. We do not maintain server-side records of individual consent choices. Anonymized, aggregated consent statistics may be collected through Firebase Analytics for compliance monitoring purposes.

6. Your Rights Under GDPR

Under the General Data Protection Regulation, you have the following rights:

6.1 Right of Access (Art. 15)

You have the right to obtain confirmation whether we process your personal data and to access that data. This includes the right to obtain a copy of your consent preferences and information about when consent was given.

6.2 Right to Rectification (Art. 16)

You have the right to have inaccurate personal data corrected.

6.3 Right to Erasure ("Right to be Forgotten") (Art. 17)

You have the right to request deletion of your personal data. You can:

• Delete local data via App Settings → Privacy → Clear Local Data
• Contact us to request deletion of any data we may hold
• Manage Google data at Google Account Settings

6.4 Right to Restriction of Processing (Art. 18)

You have the right to request restriction of processing of your personal data in certain circumstances.

6.5 Right to Data Portability (Art. 20)

You have the right to receive your personal data in a structured, commonly used, machine-readable format.

6.6 Right to Object (Art. 21)

You have the right to object to processing based on legitimate interests. You can:

• Disable analytics collection in App Settings → Privacy
• Disable personalized ads in App Settings → Privacy

6.7 Right to Withdraw Consent (Art. 7(3))

You have the right to withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing before withdrawal. You can change your consent preferences in App Settings → Privacy.

6.8 Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority. For users in Poland, this is:

To exercise any of these rights, please contact us at: michalzgietsoftware@gmail.com

We will respond to your request within one month.

If your request is complex or we receive multiple requests from you, we may extend this period by up to two additional months. We will inform you of any such extension within one month of receipt of the request, together with the reasons for the delay (Art. 12(3) GDPR).

7. Data Sharing

We do not sell your personal data. We share data only with:

• Google LLC (Firebase Analytics, AdMob, Play Billing) - as data processor for analytics, advertising, and payment processing
• Legal authorities - only if required by law or court order

8. Third-Party Services

The App uses the following third-party services, each with their own privacy policies:

• Google Play Services
• Firebase Analytics
• Google AdMob

9. Automated Decision-Making and Profiling

We do not use your personal data for automated decision-making or profiling that would produce legal effects or similarly significantly affect you (Art. 22 GDPR).

Note: Google AdMob may use automated systems to select which advertisements to display based on your interests and behavior. However, this ad targeting does not constitute automated decision-making under GDPR Article 22, as it does not produce legal or similarly significant effects on you.

10. Children's Privacy

The App is not intended for children under 16 years of age (in accordance with GDPR Article 8 and Polish law).

We do not knowingly collect personal data from children under 16. If you are a parent or guardian and believe your child has provided us with personal data, please contact us immediately at michalzgietsoftware@gmail.com and we will take steps to delete such information.

11. Security Measures

We implement appropriate technical and organizational measures to protect your personal data, including:

• Encryption in transit - all data transmitted to third-party services uses TLS/HTTPS encryption
• Secure local storage - app data is stored in the application's private storage area, inaccessible to other apps
• Minimal data collection - we only collect data necessary for the App's functionality
• Regular updates - we regularly update the App to address security vulnerabilities
• No server-side storage - we do not operate our own servers; your match data stays on your device

Backup recommendation: We recommend enabling regular device backups to prevent data loss, as we do not maintain server-side copies of your match data. If you uninstall the App or clear app data, your local data will be permanently deleted.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by:

• Posting the new Privacy Policy on this page
• Updating the "Last updated" date
• Showing a notification in the App (for material changes)

We recommend reviewing this Privacy Policy periodically for any changes.

13. Contact Us

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