Privacy policy for Peg Solitaire

• No account, no sign-in. The app sends me no data on its own.
• What you create in the app stays on your device.
• The app shows ads from Google. Whether Google may use data for personalised ads is your choice at first launch.

Responsible for the app Peg Solitaire is:

For any question about data protection, write to [email protected]. There is no data protection officer, because the law does not require one for a business of this size.

The app stores on your device which boards you solved, the board you chose last and your playing time (for the rating request), plus whether sound is on and whether you bought “Remove ads”.

This data lives only on your device; I have no access to it. It is needed for the features you use (section 25(2) no. 2 TDDDG, Art. 6(1)(b) GDPR). Deleting the app removes it.

If backups are turned on (iCloud or Google), the operating system includes the app data in them. You control this in your device settings; Apple’s or Google’s terms apply.

The app is funded by ads from Google AdMob, a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. At first launch, a dialog from Google asks whether Google may use data for personalised ads and measurement. On iPhone, the system then also asks whether the app may track you across apps from other companies (App Tracking Transparency).

If you agree, Google receives from your device the advertising ID (IDFA or Android advertising ID), your IP address, details about the device and operating system, the app, and which ads you see and tap. Google derives an approximate location from the IP address. The legal basis is your consent (Art. 6(1)(a) GDPR, section 25(1) TDDDG).

If you decline, the app still shows ads, but without personalisation and without the advertising ID. Even then Google technically receives your IP address and device details to deliver the ad, cap how often it appears and detect fraud. The legal basis is my legitimate interest in funding the free app (Art. 6(1)(f) GDPR).

You can change your choice at any time under the privacy options in the app’s settings. On iPhone, change the tracking permission under Settings › Privacy & Security › Tracking.

If you buy “Remove ads”, the app loads no more ads and Google’s ad SDK stays idle.

Google is itself responsible for processing for its own purposes. Data may reach the USA. The company is certified under the EU-US Data Privacy Framework; the adequacy decision of the European Commission covers this transfer (Art. 45 GDPR). See Google’s privacy policy and How Google uses data from apps.

Purchases are handled by Apple (App Store) or Google (Google Play) through your store account. I receive neither your name nor payment details. The app learns from the store only whether a purchase exists and remembers that on your device. The legal basis is fulfilling the purchase (Art. 6(1)(b) GDPR).

Now and then the app asks for a rating through the system dialog. The app decides when based on counters on your device; Apple or Google decide whether the dialog appears. A rating goes straight to the store, not to me.

For questions, write to [email protected].

I use your message only to help you and delete it once the matter is settled. The legal basis is your use of the app (Art. 6(1)(b) GDPR) or my legitimate interest in answering (Art. 6(1)(f) GDPR). The mailboxes are hosted by STRATO GmbH, Berlin, as my processor.

When you download or update the app, Apple or Google process data such as your account details and device ID under their own responsibility. I have no influence on this. From the stores I receive only aggregated statistics (such as downloads per country) and crash reports not linked to you, if you allowed sharing them in your device settings.

Where I process personal data about you, you have these rights:

• Access to your data (Art. 15 GDPR)
• Correction of wrong data (Art. 16 GDPR)
• Erasure (Art. 17 GDPR)
• Restriction of processing (Art. 18 GDPR)
• Receiving your data in a common format (Art. 20 GDPR)
• Withdrawal of consent, at any time and for the future (Art. 7(3) GDPR)

Objection (Art. 21 GDPR): Where processing rests on a legitimate interest (Art. 6(1)(f) GDPR), you may object to it at any time on grounds relating to your particular situation. I then stop, unless there are compelling legitimate grounds that override your interests, or the processing serves legal claims.

An informal email to [email protected] is enough. You may also lodge a complaint with a data protection authority (Art. 77 GDPR), for example the one responsible for me:

www.baden-wuerttemberg.datenschutz.de

I do not use automated decision-making or profiling within the meaning of Art. 22 GDPR.

When the processing changes, I update this policy. The date at the top shows the last revision. The German version prevails.