Legal
Privacy for apps & games
Dumpling Days
Updated: 9 October 2026. The following information applies specifically to Dumpling Days. Different age, advertising and tracking rules for other games on this shared page do not apply to Dumpling Days. The first App Store launch is being prepared for Germany. Advertising and purchase setup is not complete; production ad requests remain disabled during preparation.
Controller and contact
Kübler Web & Design, owner Jens Kübler, Birnenstieg 13, 38855 Wernigerode, Germany. Email: info@kuebler-webdesign.de, phone: +49 171 2782633. Full legal notice.
Playing, saving and age group
Dumpling Days works without a game account. Progress, pearls and Lantern Light, character growth and memories, equipment, room decoration, language, audio, vibration and motion preferences are stored in the app's private storage on your device. We operate no game server and do not receive your save. The cloud room and album are local play areas without public chat, user profiles or uploads.
The age question saves only an age group and that an answer was given, not the entered birth year. It uses the youngest possible age within the selected year. Offline play does not require an age answer. Minors and players without confirmed adult eligibility receive no advertising or new purchase offers. Existing Ad-free ownership can be restored regardless of age group.
Where supported by the operating system and required by regional rules, the app uses Apple's age-range request. It receives no identity document or date of birth. Required age sharing that is unavailable or declined is not bypassed using the app's own age question. An age group is not a parental control or a promise of suitability for every childhood age; the App Store age rating also applies.
Limited local status files record consent, App Store country, age range, Ad-free entitlement and ad progress. They help prevent disallowed ad requests and duplicate rewards. They are not automatically sent to us. Necessary local game operation relies on Article 6(1)(b) GDPR and the strictly necessary device-access exception in section 25(2) no. 2 German TDDDG.
Optional ad videos and privacy choices
Only voluntary, clearly labelled Google AdMob videos for adults are planned. A completed video grants 12 units of cosmetic Lantern Light. The ad configuration limits the offer to a maximum of five individual videos per 24 hours; interactive ads and ad pods are disabled. Ads are restricted to Google’s G content rating, and sensitive and restricted ad categories are blocked. No external mediation providers are configured. There are no banners, automatic ad interruptions or ads in the cloud room. Play, levels and growth remain available without watching an ad. Active Ad-free also removes optional ad offers.
The app requests non-personalized ads and does not use your save to build advertising profiles. Google's publisher first-party ID and the ad SDK's own crash reporting are disabled before it starts. This does not mean Google processes no data. Requests for consent information or ads may involve an IP address and approximate region derived from it, device and app details, identifiers, ad views and interactions, and performance and diagnostic data. These support ad delivery, security, limiting and measurement, and improvement of advertising services. Google's SDK data disclosure.
Non-personalized ads can use identifiers for frequency capping and aggregate reporting. The app does not request iOS tracking permission. This is not a blanket promise that every operation by an advertising provider is anonymous. Before production activation, the specific provider selection and data use must match the App Store privacy disclosures; real ad requests remain disabled until then.
Google's User Messaging Platform presents the required privacy choices to adult players. Requesting these choices can itself connect to Google. The flow starts only after adult and Ad-free checks. In the German launch market, ads require consent to device access and Google's permission to request ads. Refusal is not bypassed with limited ads. You can inspect the offered purposes and providers in Google's form.
Consent for optional device access and the related processing relies on section 25(1) TDDDG and Article 6(1)(a) GDPR. Where legitimate interests are indicated for individual purposes, you may object in the form. Managing and respecting your privacy choices fulfils data-protection duties under Article 6(1)(c) GDPR. Open Settings → “Ad privacy choices” to reopen your choices where Google provides this for your region. Withdrawal applies for the future and does not affect earlier lawful processing. Refusal and withdrawal do not block offline play. The iOS tracking setting does not replace these choices.
Google identifies Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, as its independent controller for European advertising data. Google may process data on servers outside the European Economic Area, including the United States. The applicable Google privacy and transfer terms govern the service. Google privacy, information from partner apps and Google advertising data-protection terms explain recipients, transfer safeguards, retention and rights. We cannot promise a fixed deletion period under our control for all Google data.
One-time Ad-free and Apple
The only planned purchase is permanent Ad-free, without a subscription. It removes every optional ad offer. The German target price is €2.99; the price Apple displays before purchase applies. Pearls, tools, cosmetic packs, levels and growth advantages are not sold.
Apple processes purchase and restoration. The app reads verified entitlements and transactions locally to activate, restore and update Ad-free after revocation. There is no publisher purchase server and no payment information is sent to us. Processing is necessary to provide the purchased content under Article 6(1)(b) GDPR. Apple's services are also governed by Apple's privacy policy. Removing a local save does not revoke a purchase held by Apple.
Retention and deletion
Local data remain in the app container while present. Deleting the app and its data removes that storage; offloading can retain data. iCloud and computer backups depend on your Apple settings. The game does not manage these backups. We cannot remotely view or delete your local save. Purchase records, consents and advertising data stored by a provider are also subject to that provider's retention rules.
Support, reporting ads and your rights
Open Settings → “Privacy & legal” → “Report inappropriate ads” to choose an email draft or copy the contact address. The draft contains questions for you to complete. It includes no saves, identifiers, age information, logs or screenshots, and sends nothing automatically. You may also write directly to the address above. Reporting does not require an Ad-free purchase.
If you voluntarily email us, we process your address and message to answer the enquiry. Email is processed at IONOS. Necessary contractual enquiries rely on Article 6(1)(b) GDPR; otherwise Article 6(1)(f) applies with an interest in answering and documenting enquiries. We delete data when no longer needed, unless legal retention or necessary legal defence requires keeping it. Do not send passwords or full private save files. Screenshots are optional; remove private notifications.
Depending on the processing, you have rights of access, correction, erasure, restriction, portability, objection and consent withdrawal. Use the contact address for requests. You may complain to a data-protection authority, including the Data Protection Commissioner of Saxony-Anhalt. Age groups only gate ad and purchase offers; they do not create individual prices or other automated decisions with legal or similarly significant effects.
External links open in your browser when you choose them. Visits to this website are additionally covered by the website privacy notice. Dumpling Days help.
This privacy policy applies to all apps and games by Kübler Web & Design in the app stores. For this website, see the general privacy policy. Help, contact and reporting inappropriate ads: Help & contact for apps. Provider information: Imprint. Last updated: 2026-09-26.
Apps covered:
- Axolotl Paradise (iOS)
- Tubalot – Desk Trickshots (iOS)
- Depotaro (iOS)
1. Controller
Kübler Web & Design, owner Jens Kübler, Birnenstieg 13, 38855 Wernigerode, Germany
E-mail: info@kuebler-webdesign.de · Phone: +49 171 2782633 · Imprint
2. Principles
Our games need no user accounts. We do not collect or store personal data on our own servers and use no tracking or analytics SDK of our own.
3. Data on your device
Game progress and settings are stored only on your device (Art. 6(1)(b) GDPR, § 25(2) no. 2 TDDDG). How long they are kept and how to delete them is in section 9.
4. Advertising and consent
Ad-supported games show ads via Google AdMob and – per app – possibly further ad partners that may bid through AdMob mediation (status per app in section 11). Depending on your choices these providers process device and advertising identifiers (Apple's IDFA only if you allow tracking), IP address, approximate location, device and app information, ad interactions and diagnostics.
From the “16 and over” age group, Google’s certified consent dialog (IAB TCF) asks for your consent before any ad is loaded wherever Google requires it: in the EEA, the UK and Switzerland. In certain US states Google shows a notice with an opt-out instead (section 7); in other countries no such dialog appears. For an age group under 16 (see section 11 for how each app assigns it) no consent dialog appears (section 5). Whether a dialog or notice is needed is checked by Google’s consent SDK (User Messaging Platform) with Google at every start after the age question – also for players under 16 and also if you then decline; Google receives the IP address and device and app information. What happens without consent differs per app and is described in section 11 (“Without consent”); every game stays fully playable.
Legal bases: Personalized ads and storing and accessing information on your device for advertising happen, wherever Google shows a consent dialog, only with your consent (Art. 6(1)(a) GDPR, § 25(1) TDDDG). The consent SDK’s check and storing your choice on the device serve to obtain and document consent (Art. 6(1)(c) in conjunction with Art. 7(1) GDPR, § 25(2) no. 2 TDDDG). Non-personalized or limited ads without consent to ad profiles – for an age group under 16 always non-personalized and flagged as coming from a minor – are based on our legitimate interest in offering the games free of charge and funding them through ads (Art. 6(1)(f) GDPR). IP address and device and app information are processed to serve and bill ads, cap their frequency and detect fraud.
Right to object: You can object at any time, on grounds relating to your particular situation, to processing based on legitimate interests (Art. 21(1) GDPR), for example by e-mail to info@kuebler-webdesign.de. Without an internet connection the game makes no ad requests.
Change or withdraw your consent: at any time in the game; the path per app is in section 11 (“Change your consent”). Withdrawal takes effect for the future. Access to the advertising ID (IDFA) is controlled separately on iPhone under Settings → Privacy & Security → Tracking; this does not change your choices in the consent dialog.
Advertising ID on iPhone (App Tracking Transparency)
Games with personalized ads also ask on iPhone, through Apple’s App Tracking Transparency prompt, whether the device’s advertising ID (IDFA) may be used. A short note from Google explains what it is for first. The prompt only appears from the “16 and over” age group; where Google shows a consent dialog, only after your choice there. If you decline, ad partners get no IDFA; the game stays fully playable and rewards do not depend on it. Tubalot – Desk Trickshots then requests only non-personalized ads – as it also does when tracking requests are turned off in the iOS settings. You can change your choice any time under Settings → Privacy & Security → Tracking.
Reward videos are optional and labeled as ads. Ad content is limited to “suitable for all ages”. You can report inappropriate ads to us: Help & contact for apps (“Report an ad” per app).
5. Children and teenagers
For Axolotl Paradise from version 1.1.1, the age question, age groups and advertising follow only the rules in its app section below (under 13, 13–17, 18 and over; the first outing can take place before its own age question). The following general first-start and age-16 rules do not apply to this version of Axolotl Paradise.
Our games are for all ages and not directed at children in particular. Games with an age question (Axolotl Paradise, Tubalot – Desk Trickshots) ask neutrally for your age on first start (for example the year of birth), with nothing preselected, and store only the age group (under 13, 13–15, 16 and over), never the year. How the age group is worked out and how to change it is given per app in section 11. If the age group is under 16, ad requests are flagged as coming from a minor (13 to 15 as “under the age of consent”, under 13 as “child-directed” under the US COPPA rule, section 6); only non-personalized ads are requested, no interstitials are shown, and there is no consent dialog and no tracking prompt. The age answer is needed to start the game; it is not required by law. Ad consents are voluntary; every game stays playable without them.
Age range from Apple: If Apple provides an age range (the “Declared Age Range” interface, iOS 26.2 or later and only where Apple requires an age range for your account, for example in Texas and Brazil), Tubalot – Desk Trickshots uses that range instead of asking. iOS may ask you itself whether the range may be shared. The game receives only the range, never a date of birth, and as always stores only the age group. Without it, the game uses its own age question.
No ads for minors in the EEA, the UK and Switzerland: Players under 16 are never shown a consent dialog. For an age group under 16, Tubalot – Desk Trickshots therefore loads no ads if your App Store country is in the EEA, the UK or Switzerland, if it is unknown, or if Google’s consent SDK reports that the GDPR applies. There are then no reward videos, and the game stays fully playable.
Brazil: In the Brazilian App Store, Tubalot – Desk Trickshots requests only non-personalized ads, whatever the age or consent.
6. Children under 13 (USA, COPPA)
For users in the USA who are placed in the “under 13” age group (Axolotl Paradise, Tubalot – Desk Trickshots), the following also applies. We do not collect personal information from children ourselves; the age group is stored only on the device. With each ad request Google receives only age flags derived from it (such as “child-directed”), never the age or year of birth.
What the ad partners technically receive: With every ad request, Google AdMob and – where enabled – the ad partners listed in section 11 receive the IP address, device and app information (for example device type, operating system, app version, language setting), SDK-internal identifiers (persistent identifiers under COPPA) and information about ad views and interactions. Children are never shown a tracking prompt, so the ad partners receive no advertising ID (IDFA) – unless tracking was allowed for this game on the device earlier (for example before the age was changed); that permission remains until it is withdrawn under Settings → Privacy & Security → Tracking. The requests stay “child-directed” and non-personalized even then.
Purpose: every request is tagged “child-directed”. This rules out personalized advertising, and the data only supports internal operations within the meaning of 16 CFR § 312.2: serving and billing ads, frequency capping, detecting fraud and abuse, fixing technical errors. No user profile, no contact with the child.
Safeguards: only non-personalized ads with content “suitable for all ages”; no interstitials and no tracking prompt; the ad SDK's cross-app identifier (first-party ID) and its crash reports are switched off. We run no servers of our own and no analytics SDK.
Retention: We store no data about children. Google keeps ad data under its own retention rules; see also section 9.
Contact for parents: Kübler Web & Design, Jens Kübler, Birnenstieg 13, 38855 Wernigerode, Germany · Phone: +49 171 2782633 · E-mail: info@kuebler-webdesign.de. As we store no data about your child, we cannot review or delete any. You delete the game progress by deleting the app; you stop further ad requests by no longer using it or by playing offline. We are happy to answer questions about ad data and pass them on to Google at your request; you can also contact Google directly via Google’s privacy policy.
7. Notice for users in the USA
In certain US states Google shows a notice instead of a consent dialog. It lets you opt out of data being shared with Google for personalized ads (under some state laws this counts as a “sale” or “sharing” of data or as targeted advertising); later you can do this via “Change your consent” in section 11, where the game offers it. For an age group under 16 (see section 11 for how each app assigns it) we share no data for personalized ads. Google as a third party may collect data over time and across apps (section 4). The apps do not respond to browser signals such as “Do Not Track” because they are not browsers; what counts is Apple’s setting “Allow Apps to Request to Track”. You can request access, deletion or correction by e-mail to info@kuebler-webdesign.de; exercising these rights will not lead to any disadvantage.
8. Transfers outside the EU and level of protection
Google processes the ad data as an independent controller. For AdMob, the Google Ads Controller-Controller Data Protection Terms apply between us and Google. In them Google has contractually committed to process the data in line with applicable data protection law, that is with a level of protection equal to the one described in this policy. Google and the listed partners may transfer data to the USA based on the EU-US Data Privacy Framework or EU standard contractual clauses. We do not use ad partners without such a basis. We only enable further ad partners if they commit by contract – with us or through Google – to an equal level of protection.
9. Retention and deletion
On your device: game progress, settings, age group and ad counters stay stored until you change them in the game or delete the app; deleting the app makes iOS remove them. Your choice in the consent dialog is also stored on the device by Google's consent SDK until you change it or delete the app.
Backups and Photos: If your iPhone backs up apps to iCloud or a computer, the game progress may be part of those backups; it disappears there when you delete the backup or it is replaced. You control this in the iOS settings, not us. Replay videos you save to Photos from the share menu (Tubalot – Desk Trickshots) stay there until you delete them in the Photos app – even after deleting the game. Whatever you share yourself (clips, codes) then lies with the recipients and the services used.
With us: We store no game data on servers of our own. We process questions, bug reports and ad reports sent by e-mail (including screenshots) to answer them, fix bugs and block inappropriate ads (Art. 6(1)(f) GDPR, for questions about a service Art. 6(1)(b)). The e-mails are held by our e-mail provider IONOS, which processes them on our behalf. We keep them as long as needed to handle them and delete them afterwards unless statutory retention duties apply.
With Google: Google keeps ad data under its own rules: How Google retains data. For the other ad partners, their privacy policies linked in section 11 apply.
10. App stores
The apps are distributed via the Apple App Store (and possibly Google Play), whose operators process data under their own responsibility, for example for downloads and app statistics: Apple, Google.
11. Details per app
Axolotl Paradise
This app section was updated on 7 October 2026 and applies to version 1.1.1.
Stored on your device: Game progress and settings, including your collection and nest, language, sound and age group, plus local counters for sessions and ad frequency and your consent status. There are no accounts, chat or purchases. We do not store these details on our own servers. Optional reminders are scheduled locally by your device; no data is sent to us for them. Uninstalling the app deletes its local data.
Age question: The game asks for the birth year of the person actually playing. Since their birthday is unknown, it uses the youngest possible age for that birth year. Only the age group under 13, 13–17 or 18 and over is saved, never the birth year. To correct it, hold the gear for about one second and choose “Change” next to “Age group” in the grown-ups’ area.
Age range from Apple: On iPhones with iOS 26.2 or later, the game checks at every start through Apple’s “Declared Age Range” interface whether Apple calls for an age-range request. If required, it asks Apple for the range before its own age question and on later starts; iOS may ask for permission to share it. The game temporarily processes the age range, how it was declared and Apple’s eligibility response. It receives neither a name nor a birth date through this interface. Only the derived age group is saved locally; response files are removed after use, and the production app does not write these details to device logs. Apple’s range is an upper limit on your own answer. If Apple requires a range but shares none, at most the 13–17 group applies. No ads load while the start check runs. If it cannot reliably establish whether a request is required, ads in that session remain limited to at most 13–17 until a reliable answer arrives. The purpose is enforcing the game’s age limits and protection against unsuitable advertising; the legal basis is the legitimate interest described for this purpose (Art. 6(1)(f) GDPR). Neither we nor ad partners receive the age range or birth year. Ad requests carry only the resulting protection flags. You can manage permission to share the range in your Apple Account settings.
Advertising: Optional reward videos and occasional interstitials between outings; no banners. Only Google AdMob is integrated: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (EEA/Switzerland), or Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (other countries). AppLovin, Unity Ads and Liftoff are not integrated from version 1.1.1. The data categories, consent and transfer information on this page apply to Google; Google’s privacy policy.
Age-related advertising rules: Personalised ads, interstitials and a new tracking prompt are considered only for an age declaration of 18 or over. Under 18, ad requests are non-personalised and marked “under the age of consent”; under 13, they are also “child-directed”. No ads load before the age question is answered. Ad content is limited to G. Ads still depend on Google allowing requests and your consent choices; the game remains playable if no suitable ad is available. To change consent, hold the gear for about one second and choose “Ad privacy settings”, where Google provides that control for your region. Any previously granted iOS tracking permission is separately managed under Settings → Privacy & Security → Tracking.
Sharing a nest postcard: Only after you expressly tap the control does the app create an image of the game view on your device and open the iOS share sheet. We never receive the image. It is sent only to the destination you choose there; that recipient’s own privacy policy applies. Temporary image files are removed after sharing or cancelling. The app does not read your photos or access your camera or contacts; “Save to Photos” is excluded from this share sheet.
Tubalot – Desk Trickshots
Stored on your device: game progress and settings (progress, stars, best scores, unlocked designs and video progress per design, language, sound, age group), counters that limit how often ads appear, technical status files for ads (consent and tracking status, App Store country) and the last up to three replay videos you created for sharing (not backed up). No accounts, no chat, no purchases.
Ads: optional reward videos and occasional interstitials between two rounds; no banners.
Reward videos are labeled “Ad Video”, only play after you tap them and give two extra balls, an aim guide (the exact path for one shot), skipping a mission or progress towards a design (one or two videos depending on the design; designs can also be earned with stars). Interstitials appear only in the campaign after tapping “Next Mission”: never in the first session, at the earliest after three completed missions and three minutes of play, at least three minutes apart, at most three times per session and never for players who state an age under 16.
Ad partners:
- Google AdMob – Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (for users in the EEA and Switzerland); Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (other countries). Transfer: USA (EU-US Data Privacy Framework). Privacy policy · How Google uses information from apps
Without consent: Without your consent to storing and accessing information on your device (TCF purpose 1) the game loads no ads at all, not even limited ads. There are then no reward videos, which the game mentions neutrally on the designs screen; it stays fully playable and designs can also be earned with stars. Without consent to ad profiles (TCF purposes 3 and 4) the game requests only non-personalized ads. For players under 16, see “Children and teenagers”.
Age question: yes, on first start (see section 5); you can change your answer under Options → Privacy & Help → “Hold to Change Age” (hold the button for one second); the game then asks Apple again, and an age range shared by Apple takes precedence.
Age range from Apple: used when Apple provides it (iOS 26.2 or later, where Apple requires it); otherwise the game uses its own age question.
App Tracking Transparency: yes, only from the “16 and over” age group; where Google shows a consent dialog or notice, only after it (see section 4); as long as you have not allowed tracking, only non-personalized ads.
In the Brazilian App Store: always non-personalized ads only, whatever the age or consent.
Change your consent: in the game under Options → Privacy & Help → Ad Consent (the button appears where Google provides ad settings for your region, e.g. in the EEA).
When you tap “Share” in the replay, the game creates a video; the last three stay inside the app only. A video reaches Photos only if you save it from the share menu (add-only access to Photos). You share friend codes and clips yourself via the share menu or the clipboard; we never receive them. The Daily Trickshot and duels work without any server.
Help and ad reports: Help & contact · Report an ad
Imprint: Imprint; in the game under Options → Privacy & Help → Legal Notice; licenses under Options → About Tubalot → Licenses.
Depotaro
Depotaro section updated on 8 October 2026. The app and its optional Ad-Free purchase are currently prepared for the same 172 territories; Brazil, mainland China and Vietnam are excluded. For Depotaro, the age and advertising rules in this section take precedence over the general under-16 rules above.
Stored on your device: progress, move records, favourites, unfinished jobs, depot upgrades, daily and bonus receipts, ad-break counters, sound, haptics and language; also the age band with its source, method and check timestamp, local family restrictions and active play time for the current UTC day. Protected family settings store a randomly salted PIN verifier with rate-limited failed attempts, not the plaintext PIN. Apple-verified purchase entitlement is checked on the device; a permanent local withdrawal is additionally stored as a separate blocking marker, so older save copies cannot undo it. No accounts, no chat.
Ads: optional reward videos and occasional interstitials between two rounds; no banners.
Purchases: Ad-Free is a one-time, non-consumable in-app purchase, not a subscription. It permanently removes all ads. The German base price is EUR 2.99; Apple shows the local currency price before purchase. Apple processes purchases. We receive no payment or Apple account data and send no purchase receipts to our own servers. Depotaro checks signed entitlements locally through StoreKit. Restore: Pause → Settings → Ad-Free → Restore purchases. Refunded or revoked purchases may lose their entitlement. Ad-Free includes depot bonuses without a video, with the same reward limits.
A cached video interstitial may appear at the end of every three completed tasks, before the success card. Full-screen ads are at least 90 seconds apart. Without an available ad or required consent, play continues immediately; skipped breaks are not caught up later. Reward videos remain optional and available to adults after a successful delivery. One video can grant +1 depot progress once per delivery task: at most twice per UTC day and up to 16 bonuses in total. Hints, undo, all puzzles and depot upgrades remain obtainable for free without ads. Under 18 or when age is unknown, no automatic Google ad or consent requests are started. Settings → Privacy & info → Withdraw consent permanently stops future advertising processing by Depotaro on this device with one tap, including after restart, a later adult-age approval or a purchase refund. No purchase, PIN, internet connection or loaded Google form is needed. Google privacy choices additionally manage the partner decisions offered by Google; they never undo the local stop. Local withdrawal does not delete data previously held by partners; separate rights and contact routes are explained in the section “Your rights”. A verified Ad-Free purchase disables both ad formats and future ad requests. There are no banners.
Ad partners:
- Google AdMob – Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland / Ireland. Transfer: USA (EU-US Data Privacy Framework). Privacy policy
Without consent: Without consent to storing and accessing information on the device (TCF purpose 1), Depotaro loads no ads. Without consent to ad profiles (TCF purposes 3 and 4) or without ATT permission, only non-personalised ads are requested. Minors and players with unknown age receive no ads. The game remains fully playable; after local withdrawal no further automatic Google ad or consent requests are started.
Age question: yes, The supported Apple age service is checked on launch and after returning to the app, independently of ads and purchases. Required system answers are distinguished from optional answers and errors. Where available, a separate own age entry is outside the video-bonus flow and does not replace a required system signal. Its exact number is evaluated only transiently; the age band is stored (see section 5); Settings → Privacy & info → Age check. A protected minor signal cannot be cleared by choosing an adult answer.
Age range from Apple: The regional requirement check runs independently of ads and Ad-free ownership. An unavailable or failed required Apple response is not replaced by a self-declaration; puzzles remain playable without ads. Minor protection takes precedence over conflicting declarations. The age band and its provenance are stored, never a date of birth. Older supported iOS versions without the regional Apple requirement-status service may offer a separate neutral entry.
App Tracking Transparency: yes, only after consent (see section 4); as long as you have not allowed tracking, only non-personalised ads.
Brazil: currently excluded for the app and Ad-Free purchase. The defensive rule for a Brazilian or unknown storefront permits only non-personalised ads and does not authorize availability in that territory.
Change your consent: Settings → Privacy & info → Withdraw consent; Google privacy choices for additional partner decisions, when Google offers them.
No account or game server. Puzzles and saves work offline. There are 108 main jobs, 20 practice puzzles, four extra challenges and a separate bank of 14 daily puzzles on a 14-day UTC rotation. Daily puzzles are not newly generated every day. Deleting the app deletes local progress.
Family & play time: Family & play time shows active puzzle time counted on this device for the UTC day. A local PIN protects changes to the daily limit and ad/purchase restrictions. The PIN does not verify guardian identity or replace Apple's Family Sharing, Screen Time or Ask to Buy. Menus, pauses and time in the background do not count as active puzzle time. Reaching the daily limit saves the puzzle position. Restoring existing purchases and privacy options remain available. Minor and unknown age keep advertising disabled independently of the family settings
Help and ad reports: Help & contact · Report an ad
Imprint: Imprint; Pause → Settings → Privacy & info → Legal notice; Licenses in the same menu.
12. Your rights
You have the right of access, rectification, erasure, restriction, data portability, objection and withdrawal of consent (Art. 7(3), 15–21 GDPR); withdrawal takes effect for the future and does not affect the lawfulness of processing carried out before it. As we store no data on servers, requests about ad data can also be sent directly to Google or the listed partners. No automated decision-making within the meaning of Art. 22 GDPR takes place; with your consent Google builds ad profiles for personalized ads.
You also have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR), in particular in the member state of your habitual residence, place of work or place of the alleged infringement. The authority responsible for us is: Landesbeauftragter für den Datenschutz Sachsen-Anhalt (Saxony-Anhalt, Germany), https://datenschutz.sachsen-anhalt.de.
13. Changes
We update this policy when our apps or the law change. You can tell significant changes by the “Last updated” date at the top.