Privacy Policy

1. Controller

The controller responsible for data processing is:

2. About Remember Path!

Remember Path! is a mobile puzzle game developed for iOS and Android. The game focuses on memory-based gameplay where players memorize paths and navigate through levels. This is an international game available to users worldwide.

3. Data We Collect

We collect and process the following types of data in connection with the Remember Path! game:

3.1 Personal Data You Provide Directly

• Email Address: When you contact us via email for support or inquiries, we process your email address and the content of your message.
• In-App Purchases: If you make purchases within the app, we do not collect or store your payment information directly. Payment processing is handled by third-party services (see Section 4).
• Account Information: If you choose to create an account or sign in via third-party services, we may collect your username and profile information associated with that account.

3.2 Data Collected Automatically

When you download, install, or use the game, certain technical data is collected automatically:

• Device Information: Device model, operating system version, device identifiers (such as Apple's IDFV for iOS or Android Advertising ID), and platform type (iOS/Android).
• App Usage Data: Information about how you interact with the game, including game sessions, levels played, time spent in the app, features used, and in-app events (such as completing levels, using power-ups, or making purchases).
• Crash Reports and Diagnostics: Information about errors, crashes, or performance issues to help us improve the app's stability and performance.
• IP Address: Your device's IP address may be collected for security purposes and to deliver content.

4. Google AdMob

We use Google AdMob to serve advertisements within the Remember Path! game. AdMob is an advertising service provided by Google LLC ("Google").

4.1 How AdMob Works

AdMob uses mobile advertising identifiers and other information to deliver relevant ads to users. When you use the app, AdMob may collect and process the following data:

• Advertising ID: A unique, user-resettable identifier for advertising purposes (Apple's IDFV/IDFA on iOS, Google Advertising ID on Android).
• Device and Network Information: Information about your device type, operating system, network provider, and IP address.
• App Usage Data: Data about your interactions with ads, including ad impressions, clicks, and whether you installed an app after seeing an ad.
• Location Data: Approximate location information may be used to serve location-relevant ads. Precise GPS location is not collected without your explicit consent.

4.2 Purpose of AdMob Data Processing

The data collected by AdMob is used for the following purposes:

• Serving personalized advertisements based on your interests and app usage
• Measuring ad performance and effectiveness
• Preventing fraud and abuse in advertising
• Improving ad targeting and delivery

4.3 Legal Basis for AdMob Processing

For users in the European Economic Area (EEA), UK, and Switzerland, the legal basis for processing personal data through AdMob is your consent (Article 6(1)(a) GDPR). You will be prompted to provide consent when you first use the app, and you can withdraw your consent at any time through your device settings or in-app privacy settings.

For users in other regions, the legal basis is our legitimate interest(Article 6(1)(f) GDPR / equivalent local laws) in monetizing the app through advertising and providing a free gaming experience. You have the right to object to this processing (see Section 11).

4.4 AdMob Data Sharing

Google may share the data collected through AdMob with its subsidiaries and partners for the purposes described above. Google operates globally, and your data may be transferred to and processed in the United States and other countries where Google maintains servers. For users in the EEA, UK, and Switzerland, appropriate safeguards are in place for international data transfers.

4.5 AdMob Data Retention

Google retains AdMob data according to its own data retention policies. You can find more information in Google's Privacy Policy:https://policies.google.com/privacy. You can also review Google's AdMob-specific privacy information:https://support.google.com/admob/answer/6128543.

4.6 Opting Out of AdMob Personalization

You can opt out of personalized advertising from AdMob and other Google services:

• On Android: Go to Settings > Google > Ads > Opt out of Ads Personalization, or reset your Advertising ID
• On iOS: Go to Settings > Privacy > Apple Advertising > Turn on "Limit Ad Tracking"
• Online: Visit Google Ad Settings orNAI Opt-Out

5. RevenueCat

We use RevenueCat to manage in-app purchases and subscriptions across iOS and Android platforms. RevenueCat is a service provided by RevenueCat, Inc., a company based in the United States.

5.1 Data Collected by RevenueCat

RevenueCat collects and processes the following data in connection with in-app purchases:

• App User ID: A unique identifier assigned to your installation of the app, used to track purchases across devices (if you restore purchases or use the same account on multiple devices).
• Platform Account Information: Your Apple App Store account ID (for iOS) or Google Play account information (for Android), which is used to verify and process purchases.
• Purchase Information: Details about your purchases, including product identifiers, purchase dates, prices, subscription status, renewal dates, and whether a purchase has been refunded or canceled.
• Device Information: Device model, operating system, and platform type to ensure compatibility and proper delivery of purchased content.
• Payment Status: Whether a subscription is active, expired, or in a trial period.

5.2 Purpose of RevenueCat Processing

RevenueCat processes this data to provide the following services:

• Processing and verifying in-app purchases and subscriptions across iOS and Android
• Managing subscription status, renewals, and entitlements across platforms
• Providing analytics and insights about app revenue and user purchases (aggregated and non-identifying where possible)
• Handling refunds, chargebacks, and other payment-related issues
• Enabling cross-platform purchase restoration (so you can access your purchases on multiple devices)

5.3 Legal Basis for RevenueCat Processing

The legal basis for processing purchase-related data is the performance of a contract (Article 6(1)(b) GDPR), as the processing is necessary to fulfill your in-app purchases and provide you with the purchased content and features.

For analytics and improvements, the legal basis is our legitimate interest(Article 6(1)(f) GDPR) in understanding app usage and improving our services. This processing does not override your fundamental rights and freedoms.

5.4 RevenueCat Data Sharing

RevenueCat may share your purchase data with its service providers and partners as necessary to provide its services. RevenueCat operates in the United States, and your data may be transferred to and processed there. For users in the EEA, UK, and Switzerland, appropriate safeguards (such as Standard Contractual Clauses) are in place for international data transfers.

5.5 RevenueCat Data Retention

RevenueCat retains purchase and subscription data for as long as necessary to provide its services and as required by law. You can find more information in RevenueCat's Privacy Policy:https://www.revenuecat.com/privacy.

6. How We Use Your Data

We use the data we collect for the following purposes:

• To Provide and Improve the Game: Delivering the game to you, maintaining its functionality, and improving features, performance, and user experience.
• To Serve Advertisements: Displaying relevant ads through Google AdMob to support the free version of the game.
• To Process Purchases: Managing in-app purchases and subscriptions via RevenueCat and the respective app stores.
• To Provide Support: Responding to your inquiries and providing customer support.
• To Ensure Security: Detecting, preventing, and addressing technical issues, fraud, or other security concerns.
• To Comply with Legal Obligations: Fulfilling our legal and regulatory obligations, including responding to legal requests and enforcing our policies.

7. Data Sharing and Disclosure

We do not sell your personal data to third parties. We may share your data in the following circumstances:

7.1 Service Providers

We share data with the following categories of service providers:

• Advertising Networks: Google AdMob, as described in Section 4.
• Payment Processors: RevenueCat and the respective app stores (Apple App Store and Google Play Store) for processing in-app purchases.
• Hosting and Infrastructure: Providers that host our servers and infrastructure, under appropriate data processing agreements.

7.2 Legal Requirements

We may disclose your data if required to do so by law or in response to valid requests by public authorities (such as a court or government agency) or to protect our rights, property, or safety, or the rights, property, or safety of others.

7.3 Business Transfers

We may share or transfer your data in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

8. International Data Transfers

Remember Path! is an international game available to users worldwide. Your data may be transferred to, stored, and processed in countries other than your own, including the United States, where our service providers (Google, RevenueCat) are based.

For users in the European Economic Area (EEA), United Kingdom, or Switzerland:

• Your personal data may be transferred to countries outside the EEA/UK that do not provide the same level of data protection as your country of residence.
• We ensure that appropriate safeguards are in place for such transfers, including:
  • Standard Contractual Clauses (SCCs) approved by the European Commission
  • Binding Corporate Rules (BCRs) for Google's intra-group transfers
  • Other appropriate legal mechanisms for international data transfers
• You can request a copy of the safeguards we use for international transfers by contacting us at the email address provided in Section 1.

9. Data Retention

We retain your data for as long as necessary to provide our services and as described below:

9.1 Email Communications

If you contact us via email, we retain your message and our response for as long as necessary to resolve your inquiry and for a reasonable period thereafter for reference purposes. We will delete your email data upon request or when it is no longer needed.

9.2 Purchase Data

Purchase and subscription data processed through RevenueCat is retained for as long as your account is active and for a period thereafter to comply with legal and tax obligations. Please refer to Section 5.5 for RevenueCat's retention practices.

9.3 AdMob Data

AdMob data retention is governed by Google's policies. Please refer to Section 4.5 for more information.

9.4 Analytics and Usage Data

Aggregated, non-personally identifying analytics data may be retained indefinitely for statistical and business analysis purposes.

10. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit using TLS/SSL protocols
• Secure storage practices for sensitive data
• Regular security audits and vulnerability assessments
• Access controls and authentication mechanisms
• Compliance with industry standards and best practices

Despite our efforts, please note that no method of transmission over the internet or method of electronic storage is 100% secure. We cannot guarantee absolute security.

11. Your Rights

Depending on your location and applicable data protection laws, you may have the following rights regarding your personal data:

11.1 For Users in the European Economic Area (EEA), UK, and Switzerland (GDPR)

• Right of Access (Article 15 GDPR): You have the right to request access to the personal data we hold about you and to receive a copy of that data.
• Right to Rectification (Article 16 GDPR): You have the right to request that we correct any inaccurate or incomplete personal data we hold about you.
• Right to Erasure (Article 17 GDPR): You have the right to request that we delete your personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected.
• Right to Restriction of Processing (Article 18 GDPR): You have the right to request that we restrict the processing of your personal data in certain circumstances.
• Right to Data Portability (Article 20 GDPR): You have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format and to transmit that data to another controller.
• Right to Object (Article 21 GDPR): You have the right to object to processing of your personal data based on our legitimate interests (Article 6(1)(f) GDPR) or for direct marketing purposes.
• Right to Withdraw Consent: Where we process your personal data based on your consent, you have the right to withdraw that consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
• Right to Lodge a Complaint: You have the right to lodge a complaint with a data protection supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement.

11.2 For Users in California (CCPA/CPRA)

• Right to Know: You have the right to request that we disclose to you what personal information we collect, use, disclose, and sell about you.
• Right to Delete: You have the right to request that we delete your personal information that we have collected from you, subject to certain exceptions.
• Right to Opt-Out of Sale: You have the right to opt-out of the sale of your personal information. We do not sell your personal information in the traditional sense, but certain data sharing may be considered a "sale" under CCPA. You can opt-out of personalized advertising as described in Section 4.6.
• Right to Non-Discrimination: You have the right not to receive discriminatory treatment for the exercise of any of your privacy rights.

11.3 For Users in Other Jurisdictions

You may have similar rights under the data protection laws of your jurisdiction. Please contact us to discuss your rights and how we can assist you.

11.4 Exercising Your Rights

To exercise any of your rights described above, please contact us atrememberpath@apposaurus.de. We will respond to your request within the timeframe required by applicable law.

12. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us:

Email: rememberpath@apposaurus.de
General Contact: hello@apposaurus.de

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make changes that are material or that significantly affect your privacy rights, we will provide you with prominent notice prior to the change becoming effective. For non-material changes, we may update this policy without individual notice.

We encourage you to review this Privacy Policy periodically for any updates. Your continued use of the game after we post any changes constitutes your acceptance of those changes.

14. Children's Privacy

The Remember Path! game is not directed to children under the age of 13 (or 16 in the EEA, UK, and Switzerland). We do not knowingly collect personal data from children under these ages.

If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us immediately. If we become aware that we have collected personal data from children without verification of parental consent, we take steps to remove that information from our servers.

15. Links to Third-Party Services

The game may contain links to third-party websites, services, or app stores. This Privacy Policy does not address, and we are not responsible for, the privacy practices of any third parties. We encourage you to review the privacy policies of any third-party services you access through our game.

16. Governing Law and Jurisdiction

This Privacy Policy shall be governed and construed in accordance with the laws of Germany, without regard to its conflict of law provisions. Our company is based in Germany, and we comply with the General Data Protection Regulation (GDPR) for users in the European Union.

If you are located outside Germany, please note that your information may be transferred to and maintained on servers or databases located within Germany or other jurisdictions as described in this policy.