Pinteza/Privacy
Privacy Policy
Last updated: 30 October 2026
This Privacy Policy explains how Iris Edge Studios ("we", "us", "our") collects, uses, and protects information when you use the mobile game Pinteza (the "App") on iOS and Android. We have tried to write this in plain language. If anything is unclear, contact us at legal@pinteza.app.
1. Summary
| Do we require an account? | No. You can play without signing up or giving us your name, email, or phone number. An anonymous player ID is created automatically for Duo and for comparing results (see §3.3). |
|---|---|
| Do we collect personal data directly from you? | No direct identifiers. We collect anonymous usage, device, and crash data automatically, and a short summary of each finished Daily or Chaos game so we can show you how it compares with other players (see §3). Usage and crash data are collected for everyone and have no switch in the App (see §3.1 and §3.4). |
| Can I stop the online comparison? | Every result is deleted automatically 90 days after it is recorded. You can delete yours sooner only from inside the App, under Settings, Data & Backup, with Delete my online results. We cannot do it for you by email, because your results are filed under an anonymous ID that the App never shows. Uninstalling the App stops anything further being sent (see §11). |
| Is there anything to buy? | Yes, one optional one-time purchase called Pinteza Plus. Apple or Google takes the payment, never us, and we never see your card or billing details. We use RevenueCat to know whether you own it (see §3.9). |
| Do we show ads? | Not currently. If we add advertising in the future, we will update this policy and request consent where required before doing so. |
| Do we sell your data? | No. We do not sell or rent your personal information. |
| Do we track you across other apps/websites? | No. The App does not read your device's advertising ID (§3.3 explains one exception that applies only to older versions of the App), we do not send your data to advertising platforms, and the App does not request App Tracking Transparency permission. |
| Do you send push notifications? | Reminders about the daily word and your streak are scheduled by the App on your phone. We no longer send streak tips: we stopped on 13 October 2026 (see §3.11). |
| Do you measure where players come from? | Only in a basic way. On Android the App reads the Google Play install referrer once and records in our analytics which link or campaign an install came from (see §3.10), with no name and no advertising ID. We stopped using the growth-measurement service Layers on 13 October 2026 (see §3.10.1). |
| Is the App directed to children under 13? | No. The App is intended for users aged 13 and older. |
2. Who we are (Data Controller)
The data controller responsible for your information is Alexandre Paiva, trading as Iris Edge Studios, an individual entrepreneur established in Portugal at Rua Celadias 7, Canelas Baixo, 4540-251 Canelas, Arouca. You can reach us at legal@pinteza.app for any privacy question or request.
3. Information we collect
We do not ask you for, or collect, your name, email address, phone number, contacts, photos, precise (GPS) location, or microphone/camera data in the App. The App collects the following automatically, through our own server and the third-party services described in §5:
3.1 Usage and gameplay data (analytics)
Pseudonymous events about how the game is played, for example: app opens, game/screen views, games started and finished, results shared, in-game progress (e.g. streaks, achievements), and interactions with menus. They also cover Duo matches, the shop, the Pinteza Plus screen and the steps of a purchase (for example which product was chosen and whether the purchase completed, failed or was cancelled), never your payment details. Firebase Analytics associates events with an app-instance identifier so it can produce aggregated reports. We do not attach your name, email, advertising ID, or a Pinteza account to those events, and we have switched off Firebase's collection of the advertising ID and its ad-personalisation signals.
Analytics are on for everyone and there is no switch for them in the App: the Usage statistics setting found in older versions of the App controlled only Layers (§3.10.1). To limit them, you can restrict the App's data use in your device settings, where your phone offers it (this also stops the Daily sync and Duo), uninstall the App, or email legal@pinteza.app to object (§6, §11).
3.2 Device and technical information
Device model, operating system and version, app version, device language and region settings, screen information, and similar technical data. Your approximate location (country/region level only) may be inferred from your IP address, on their own servers, by our analytics provider and by our own daily-word server (see §5). We do not collect or store GPS/precise location, and the App requests no location permission.
3.3 Identifiers
- A Firebase installation identifier generated by the analytics/crash services to distinguish devices for analytics and crash grouping. This is not your name and is not an advertising identifier.
- An anonymous, randomly generated player ID created by Firebase Authentication. It is used for two things: Duo (head-to-head) mode, so two devices can join the same match in real time, and online result submission (§3.8), so your results can be compared with other players' and so the same game is not counted twice. This is not your name, it is not an advertising identifier, and it is not linked to your identity. It is created the first time you finish a Daily or Chaos puzzle or open Duo, not when you install the App.
- A match code for Duo, which you choose to share so that a friend can join your match. On iPhone, the Duo invite and challenge pages of this website copy a short code (such as the Duo match code) to your clipboard so that the App can open the right match. The App never reads your clipboard.
- In Duo, the words you guess and when you sent each one, saved with the match so the other player can see your board once the duel is decided; a row the App cannot verify is shown to the other player as colours only. The match also stores each player's rank tier, which the other player sees, presence signals (the times each player was last seen in the match) and the preset expressions sent during the duel. Updated versions of the game refuse explicit and offensive words as guesses; older versions may still accept some. This is separate from §3.8, which never includes your guesses.
- Only in older versions of the App, and only if you turned on streak tips (Android), a push token from Google's Firebase Cloud Messaging and a OneSignal subscription ID, shown in Settings as the Tips ID (see §3.11). Updated versions of the App create neither. Neither is your name or an advertising identifier.
- Only in older versions of the App, and only if you switched on usage statistics and accepted (Android), a Layers install ID, a random identifier the Layers code creates on your phone the first time it runs, which Settings, Data & Backup shows as your Statistics ID, together with the other random identifiers that code generates for your installation (see §3.10.1). Updated versions of the App contain no Layers code. None of them is your name or an advertising identifier.
3.4 Crash and diagnostic data
If the App crashes or misbehaves, Google Firebase Crashlytics collects diagnostic information such as the crash stack trace, device state, device model and OS version, and an anonymous installation identifier, so we can find and fix the problem. A crash report can include a short technical log of the last steps before the problem, which can, rarely, contain a word you typed in the game. Crash reporting is on for everyone and has no switch in the App; the ways to limit it are the same as for analytics (§3.1).
3.5 Data stored on your device and device backups
Your game saves, streaks, scores, achievements, word collection, settings, and in-progress games, are stored locally on your device. So that your progress can survive a reinstall or a new phone, this local data may be backed up through your own device account using the operating system's standard backup features, namely iCloud on iOS and Android Auto Backup / Google Drive on Android. That backup is controlled by your Apple/Google account settings, is not accessible to us, and is not transmitted to our own servers. You can disable it in your device settings, and uninstalling the App removes the local copy.
On Android, the backup also carries the anonymous player ID described in §3.3, which is stored on your device, so a restored phone keeps the same ID. On iPhone and iPad, the App also keeps a copy of your save files in iCloud key-value storage, together with your device's model name and a list of up to 50 Duo opponents' anonymous player IDs, each with your wins and losses against that opponent.
3.6 Launch notification list (website only)
If you choose to give us your email address on our website to be notified when the app launches on a platform where it is not yet available (now that the Android version is out, that means iOS), we store that email only to send you news of that launch. We do not use it for advertising, we do not share, forward or sell it, and we delete it once the launch emails have been sent, or sooner on request. To be removed at any time, email legal@pinteza.app. The list is held on our website hosting provider (Cloudflare). This is the only place we ask for an email address, and only if you provide it.
3.6.1 Website language preference
When you choose a language in this website's language menu, a first-party pinteza_locale cookie is stored in your browser for up to one year. It contains only the selected language code and is used only to show that language when you next open the homepage, a Duo invite link or a challenge link. It is not used for analytics, advertising, or cross-site tracking. You can remove it in your browser's cookie settings; choosing another language replaces it.
3.6.2 Website download-link counts
Our download chooser and its store links can count requests by day, link source, page language, broad device platform, campaign/content label and destination (Google Play, App Store or the iOS notification page). These are aggregate counters, not individual visitor histories or proof of an install. The counters do not store IP addresses, full browser user-agent strings, email addresses, cookies or device identifiers. We retain these aggregate totals to compare our own links. Known previews and prefetch requests are excluded where detected; repeated requests and undetected automation can still be counted. Source labels can be missing or inaccurate. If you submit the launch notification form, its page and bounded source label are stored with your email until that launch list is deleted as described in §3.6. Cloudflare still processes ordinary hosting requests as described in §5.
3.7 Word reports (website only)
If you use the in-app Report a word link, it opens a short form on our website. When you submit it, we store the word you reported, the type of issue you selected, any optional note you add, and, to help us find it, your app version, language, where the report came from (which page or part of the App sent it), and your browser's user-agent string. We use this only to review and improve the word lists; we do not use it for advertising, do not forward it to anyone and do not sell it. Please do not put personal information in the optional note. This data is held on our website hosting provider (Cloudflare). We keep a report for as long as we need it to fix the word list, and for no more than 24 months. To have a report removed sooner, email legal@pinteza.app.
3.8 Gameplay results sent to us (the online comparison)
When you finish a Daily or Chaos puzzle, the App sends a short summary of that one game to our own server. Results are recorded automatically when a game finishes. Each one is deleted 90 days later (see §8), and you can delete yours sooner from the App (see §11).
What is sent: which puzzle it was, meaning the game mode, the puzzle's date (or week, for Chaos), the language you are playing in, for Portuguese which edition you play (Portugal or Brazil; none for English), the word length, and the board's maximum number of rows; how it went, meaning whether you solved it, how many guesses you used, how long the game took, and your score; and, technically, the app version and the anonymous player ID described in §3.3.
What is not sent, and not stored: not the words you guessed, not the answer, and no device identifier. Not your IP address: our server has to receive the request over the internet, like any website does, but the address is not stored with your result. No user-agent string is stored with it either (the App sends a standard one with every web request), there is no device fingerprint, and no location of any kind. Nothing from Practice, Sprint, Duo or the Anthology goes into this comparison: those results are never submitted to it (Duo uses its own matchmaking, described in §3.3 and §5).
Why we do it: so that the end-of-game card can tell you how you did against everyone else who played the same puzzle, for example that you were first today, or in the top 10%. That line is worked out from anonymous totals for that puzzle. We never show you another player's result, and we never show your individual result to anyone else.
3.9 Purchases (Pinteza Plus)
Pinteza Plus is an optional one-time purchase. The payment itself is taken by Apple or Google, not by us. We never see your card, your billing address, your Apple Account or your Google account, and no payment details ever reach our servers.
To know whether you own Plus, show the current offer, restore it on a new phone, and remove it if a purchase is refunded, we use RevenueCat, Inc. (United States), a purchase-management service. RevenueCat is initialized when the App starts, not only when you open the Plus screen. Buying Plus or tapping Restore purchases also sends the relevant store transaction to RevenueCat.
- a RevenueCat App User ID, a random identifier RevenueCat generates for your installation. It is not your name, it is not an advertising identifier, and it is not linked to your identity;
- the purchase receipt or token issued by the App Store or Google Play, the product identifier, which store you bought from, the country of your store account, the price and currency the store charged, and the dates of purchase, refund and restore;
- your device platform, operating system version and app version, so the entitlement can be matched to the right store account;
- your device's IP address, which RevenueCat receives as part of any connection to its servers.
The RevenueCat identifier is created when the App initializes its purchase service, even if you never buy anything. Your entitlement is also cached on your own device so that Plus keeps working offline.
We do not use any of this for advertising or profiling. Records connected to a sale are kept for as long as tax and accounting law requires us to keep them, which can be longer than the retention periods in §8 and can survive a deletion request.
3.10 How you found us (Android only)
On Android, the first time you open the App it reads the Google Play install referrer, a short string Google Play attaches to an install when you arrive from a link we published. We use it for two things: to carry a Duo invite code through the install so that a shared link still works after you download the game, and to record in our analytics which campaign or link an install came from. It contains no name and no advertising identifier. In older versions of the App, if you switched on usage statistics and accepted, the Layers code also read the referrer and sent it to Layers, except for installs from a Duo invite or a shared challenge link (see §3.10.1).
3.10.1 Growth statistics (Layers, discontinued on 13 October 2026)
Until 13 October 2026 we offered optional growth statistics through Layers Inc. (United States), a growth-measurement service, to learn which of our videos, posts, links and campaigns brought new players. They were off for everyone and ran only on Android, and only if you switched on Usage statistics under Settings, Data & Backup and tapped Accept. On 13 October 2026 we stopped using Layers and deleted our Layers project; Layers erases the project, with the statistics in it, within 7 days. Updated versions of the App no longer contain the Layers code or the Usage statistics setting. Older versions still contain them: if you switched usage statistics on in one of them, the App may still try to send Layers the data described below when you open it, until you switch the setting off or update the App. We can no longer see or use any of it.
In those older versions, with usage statistics on, Layers receives: a random Layers install ID, which Settings shows as your Statistics ID, and the other random identifiers the Layers code creates for your installation; your device model, Android version, app version, language and region settings, time zone and screen size; the Google Play install referrer described in §3.10, read once, when the Layers code first starts after you accept, meaning the campaign details of the link you installed from, when you tapped that link and when the install began, and the click identifier an ad network adds if you came from one of our ads; once, a short label for where your install came from (such as no known source, our website, a Duo invite or a shared challenge), which the App works out from that referrer, and whether you had already finished the tutorial, finished your first Daily puzzle and won a Daily puzzle; when you open the App, leave it or update it, and when each session starts and ends; and these game events, each with the app version: starting and finishing your first Daily puzzle, your first Daily win, every finished game (the mode, the language, whether you won, how many guesses you used, how long it took and your score), sharing a result or a streak, sharing or copying a Duo invite, joining a Duo match, opening the Pinteza Plus screen (where you opened it from, whether you already own Plus, how many days have passed since you installed the App and how many Daily puzzles you have finished), and starting a purchase of Plus and how it ended, with the product, its price, its currency and the store's transaction ID for a completed purchase. Layers never receives the install referrer of a Duo invite or a shared challenge link, which carries the invite's match code or the challenge word: for those installs the App stops the Layers code from reading the referrer, and it does the same whenever it cannot yet tell where the install came from and when the App was restored from another phone. When this data arrives, Layers records the IP address your phone connects from and uses it to estimate your city, region and country.
Those versions do not send Layers your name, email address, phone number, precise location, advertising ID (the App does not read it and removes the permission needed to read it; on Android 12 and older, see the exception in §3.3), the words you guessed, your anonymous player ID, your RevenueCat ID, crash reports, the invite links that open the App, or anything from your clipboard. We never connected Layers to any advertising platform, so it passes none of this data on to one, and we do not use it to show you ads. Layers processes this data on our behalf, as our service provider, under its own terms; its data-protection page says it acts as a processor on its customers' documented instructions. See layers.com/docs/api/operational/data-protection.
Some links we published in our videos, posts and ads before 13 October 2026 passed through a Layers link (on in.layers.com) on their way to Google Play, so that the campaign they belonged to travelled with the install. When you opened one, Layers recorded the visit, as any website does. We no longer publish such links, and the visits recorded for us are erased with our project.
In those older versions, to stop, switch off Usage statistics in Settings, Data & Backup, or update the App: the App closes consent in the Layers code, discards any statistics not yet sent and shuts that code down, so it stops sending data to Layers.
3.11 Streak tips (OneSignal, discontinued on 13 October 2026)
Reminders about the daily word and your streak are scheduled by the App on your phone and involve no one else; they are not affected. Until 13 October 2026 we also offered optional streak tips, occasional push messages sent through OneSignal, Inc. (United States) to players on Android who turned them on. On 13 October 2026 we stopped sending them, deleted every record OneSignal held for Pinteza players and switched our OneSignal account off. Updated versions of the App no longer contain OneSignal's code or the Streak tips setting. Older versions still contain them: if you turned streak tips on in one of them, the App may still connect to OneSignal when you open it, until you switch them off or update the App, and OneSignal may then receive the data described below. We no longer send tips or use any of this data.
In those older versions, with streak tips on, OneSignal receives: a push token issued by Google's Firebase Cloud Messaging and a OneSignal subscription ID for your installation (shown in the App as the Tips ID); your device model, operating system, mobile carrier, app version, language, time zone and country; whether notifications are allowed; and how you use the App and its notifications, meaning the time of your first and latest session, how many sessions you have had, how long the App was open, and which notifications you received and opened. Those versions also attach four short labels: the App's language, for Portuguese which edition you play (Portugal or Brazil), your current streak as a range (for example "4-6 days", never the dates you played), and whether your reminders to come back after a break are switched on. OneSignal does not store the IP address of players in the EU and the UK; for players elsewhere, it may store the IP address the App connects from. OneSignal may also record that a purchase was made in the App, never your payment details. If OneSignal's own code in the App fails, OneSignal may receive a technical report of that failure, with your device model, operating system version and the identifiers above, so that it can fix its software.
Those versions do not send OneSignal your name, email address, phone number, precise location, advertising ID, anonymous player ID or RevenueCat ID. To stop them connecting to OneSignal, switch off Streak tips or use Disable all in Settings, Notifications, or update the App. OneSignal processes any such data on our behalf under its Data Processing Addendum. How to have a record deleted is in §11.
4. How we use information
- operate and provide the game, including real-time matchmaking for Duo mode;
- show you how your result compares with other players who played the same puzzle;
- understand how the game is used so we can improve features, balance, and performance;
- detect, diagnose, and fix crashes, bugs, and stability issues;
- maintain the security and integrity of the App;
- comply with legal obligations.
We do not use your information for advertising or marketing. We do not build marketing profiles about you, and we make no automated decisions that produce legal effects about you.
5. Third-party services we use
We rely on the following Google Firebase services, provided by Google LLC / Google Ireland Limited:
| Service | Purpose | Data involved |
|---|---|---|
| Firebase Analytics | Usage/gameplay analytics | §3.1, §3.2, §3.3 |
| Firebase Crashlytics | Crash & stability diagnostics | §3.4 |
| Firebase Realtime Database | Duo real-time matchmaking | §3.3 (anonymous player ID, match code, game state) |
| Firebase Authentication | Anonymous player identity for Duo and for result submission | §3.3 |
| Firebase Cloud Messaging | Older versions of the App only: delivering streak tips (§3.11) | A push token for your installation, created only if you turned on streak tips in one of those versions. Updated versions of the App do not use it. |
We use RevenueCat, Inc. (United States) to manage the Pinteza Plus entitlement: to check whether you own it, to restore it on a new device, and to withdraw it if a purchase is refunded. The data involved is described in §3.9. See revenuecat.com/privacy.
In older versions of the App, and only if you turned on streak tips, OneSignal, Inc. (United States), as described in §3.11. We stopped using OneSignal on 13 October 2026. See onesignal.com/privacy_policy.
In older versions of the App, and only if you switched on usage statistics and accepted (Android), Layers Inc. (United States), as our service provider, as described in §3.10.1. We stopped using Layers on 13 October 2026. See layers.com/docs/api/operational/data-protection and layers.com/privacy.
We also use Cloudflare (Cloudflare, Inc.) to host this website and to run the small server that delivers each day's word to the App (pinteza.app/api/daily). When the App fetches the daily word, and when you browse this site, Cloudflare processes your IP address, a coarse timezone inferred from that IP (used only to decide which calendar day's word you may load, never stored as your location), and standard request logs. Cloudflare acts as our hosting and processing provider; we do not use this to identify you or to advertise. The aggregate download-link counts described in §3.6.2 are stored on Cloudflare D1. Cloudflare Web Analytics also measures visits to this website in aggregate (pages viewed, referring site, country, browser type and page-load timing). It sets no cookies, does not fingerprint your device and does not identify you. See cloudflare.com/privacypolicy.
This website can show the Pinteza trailer. The video is not loaded with the page: nothing is requested from YouTube (Google) until you press play, and only then does your browser load it from YouTube's privacy-enhanced address (youtube-nocookie.com). YouTube then receives your IP address and details of your browser and device, and may store cookies or similar identifiers, under its own terms and privacy practices. The App does not use YouTube. See policies.google.com/privacy. If you would rather not load it, leave it unplayed, or watch the trailer in your own YouTube app from our channel.
The same Cloudflare account runs the small server that records a finished game and returns your comparison (pinteza.app/api/result), described in §3.8. The one-game summary and the anonymous per-puzzle totals are stored in Cloudflare D1, Cloudflare's database service. Your IP address is not stored with your result.
After a Daily win, the App may ask Google Play or the App Store to show its own rating prompt. The store decides whether the prompt appears and handles any rating you give under its own terms; we receive nothing personal from it.
The App is built with the Unity engine. Versions released up to early October 2026 may send, through the Unity runtime, anonymous hardware statistics, such as your device model, operating system and graphics chip, to Unity Technologies. See unity.com/legal/privacy-policy. Later versions have it switched off.
Backups of your local save may also be processed by Apple iCloud (Apple Inc.) or Google Android Backup (Google LLC) under your own device account, as described in §3.5. These providers process data under their own terms and privacy practices. Google's handling of Firebase data is described at firebase.google.com/support/privacy and policies.google.com/privacy. We do not share your information with any other third parties except where required by law, or to protect our rights, safety, or property.
6. Legal bases for processing (EU/EEA & UK users)
- Legitimate interests (Art. 6(1)(f)): to run, secure, debug, and improve the App using anonymous analytics and crash diagnostics, to show you how your result compares with other players who played the same puzzle, in a way that does not override your rights. You have the right to object to processing on this basis at any time (Art. 21). To object to the online comparison, use Delete my online results in the App (§11), which deletes the results held against your anonymous player ID; to object to anything else, email legal@pinteza.app. Uninstalling the App stops anything further being sent.
- Performance of a contract (Art. 6(1)(b)): to provide Duo (head-to-head) matches when you choose to start or join one, and to sell, deliver, restore and, where refunded, withdraw the Pinteza Plus purchase described in §3.9.
- Legal obligation (Art. 6(1)(c)): to keep the records connected to a sale for as long as tax and accounting law requires.
- Consent (Art. 6(1)(a)): in older versions of the App, the streak tips sent through OneSignal (§3.11) and the growth statistics shared with Layers (§3.10.1), each off until you switched it on yourself. We stopped using both services on 13 October 2026. You can withdraw either consent at any time in those versions' Settings, or by updating the App; this does not affect what was done before. If we introduce advertising in the future, we will ask for consent first.
7. Advertising and purchases
The App contains no third-party advertising and does not itself read an advertising identifier (for the one exception in older versions of the App, see §3.3). Should we add advertising in a future release, we will update this Privacy Policy, disclose the partners and identifiers involved, and present an appropriate consent choice before any such data is collected, in line with applicable law.
We promote Pinteza with our own videos and posts and, at times, with ads on other platforms. Nothing about you is sent back to those platforms.
The App does contain one optional in-app purchase, Pinteza Plus. It is not advertising and it is not used for advertising. What is processed when you buy or restore it is set out in full in §3.9, and the purchase terms are in our Terms of Use.
8. Data sharing, retention, and international transfers
- Sharing: We do not sell, rent, or trade your information. Data is processed only by us and the services listed in §5.
- Retention: Analytics and crash data are retained according to the retention settings and operational periods configured in Firebase and the provider's applicable policy. We review these settings and keep the data only as long as needed for product measurement, security, and fault diagnosis. Duo match data (the match code, both players' guesses with their timing, rank tiers, presence signals and expressions) stays in our database after a match ends, and once a second player has joined, only the two players can read it. The App deletes a match when its host cancels or leaves it, or finds it abandoned the next time the host opens the App; a finished match is kept for as long as we run Duo. Local saves and their device backups remain until you delete them, disable backup, or uninstall the App.
- Retention of gameplay results (§3.8): a result stored against your anonymous player ID is deleted automatically 90 days after it is recorded, and sooner if you delete it from the App (§11). When a result arrives it is also added to the running totals for that puzzle, for example how many players solved it and in how many guesses. Those totals are plain counts, they carry no identifier of any kind and cannot be traced back to you or to your device, so we keep them indefinitely. Deleting your results removes the rows that identify you and leaves those anonymous counts as they are.
- Retention of purchase records (§3.9): RevenueCat keeps the entitlement record for as long as you may need to restore it, because a one-time purchase has no expiry and must be restorable on any future device. Records connected to a sale are also kept for as long as Portuguese tax and accounting law requires. This is a legal obligation under Art. 6(1)(c) and it can outlast a deletion request.
- Retention of streak-tip data (§3.11): we deleted every record OneSignal held for Pinteza players on 13 October 2026. If an older version of the App creates a new one, you can have it deleted (§11).
- Retention of growth statistics (§3.10.1): we deleted our Layers project on 13 October 2026, and Layers erases it, with the statistics and the IP addresses stored with them, within 7 days.
- International transfers: Firebase and the device-backup providers process data on Google's and Apple's servers, and RevenueCat on its own servers in the United States. Servers may be located outside your country, including in the United States and the European Union. Our website and our daily-word and result servers run on Cloudflare's network, which may likewise store and process data outside your country. Where required, these providers rely on safeguards such as the EU Standard Contractual Clauses for international transfers. In older versions of the App, if you turned streak tips on, OneSignal processes streak-tip data in the United States. It is certified under the EU-U.S. Data Privacy Framework and its UK Extension, which is what our transfers to OneSignal rely on, and its Data Processing Addendum applies the EU Standard Contractual Clauses if that certification ever stops applying. In older versions of the App, if you switched usage statistics on, Layers processes growth statistics in the United States and does not offer hosting in the European Union. Layers is not certified under the EU-U.S. Data Privacy Framework, and no adequacy decision covers this transfer. Data from those versions goes to Layers only after you switch on Usage statistics and accept a card that tells you it goes to a measurement service in the USA, so this transfer rests on your explicit consent (Art. 49(1)(a) of the GDPR and of the UK GDPR). This means your data is not protected there to the standard that EU and UK law require: for example, US public authorities may be able to access it, and you may find it harder to exercise your rights.
9. Security
We use reasonable technical and organizational measures to protect information, including encrypted (HTTPS/TLS) transmission to our service providers and access controls on backend data. No method of transmission or storage is 100% secure, but we work to protect your information and continuously improve our safeguards.
10. Children's privacy
The App is intended for users aged 13 and older and is not directed to children under 13 (under 16 in some EU/EEA countries where a higher age applies). We do not knowingly collect personal information from children below the applicable age. If you believe a child has provided us with information, contact us at legal@pinteza.app and we will delete it. In older versions of the App, streak tips and growth statistics rely on consent: if you are under 16 in an EU or EEA country where 16 is the age of digital consent, please do not turn them on without a parent's or guardian's permission.
11. Your rights and choices
Depending on where you live, you may have the right to: access, correct, delete, restrict or object to processing, data portability, withdraw consent, and lodge a complaint with your national data protection authority.
California residents (CCPA/CPRA): you have the right to know, delete, and correct your personal information, and to opt out of "sale"/"sharing". We do not sell or share your personal information as those terms are defined under California law, and we do not discriminate against you for exercising your rights.
Deleting the results you have sent us: use the App. Under Settings, Data & Backup, Delete my online results removes every result held against your anonymous player ID immediately (§3.8). In older versions of the App it also switches off streak tips (§3.11). This is the only way to delete your results early. They are filed only under that anonymous ID, which the App never shows you, and we never ask for your name or email address, so we cannot find them from an email request. Every result is deleted automatically 90 days after it is recorded in any case, and uninstalling the App stops anything further being sent. The anonymous per-puzzle counts described in §8 stay as they are, because they hold no identifier and there is nothing in them to trace back to you.
Streak tips (OneSignal): we deleted every record OneSignal held for Pinteza players on 13 October 2026. In an older version of the App, switch off Streak tips or use Disable all in Settings, Notifications, or update the App, to stop it connecting to OneSignal. If an older version has created a new record since, email legal@pinteza.app with the Tips ID shown under Settings, Data & Backup (tap it to copy it), and we will delete that record within 15 days. We need that ID because OneSignal holds no name or email address for you, so nothing else tells us which record is yours.
Growth statistics (Layers): we deleted our Layers project on 13 October 2026, and Layers erases it, with everything it held for Pinteza players, within 7 days. In an older version of the App, switch off Usage statistics in Settings, Data & Backup, or update the App, to stop it sending data to Layers.
Analytics and crash reports (Firebase): there is no switch for these in the App. You can restrict the App's data use in your device settings, where your phone offers it (this also stops the Daily sync and Duo), uninstall the App, or email legal@pinteza.app to object, with the details in §3.1.
How to exercise your rights / request deletion: email legal@pinteza.app. The only way to delete the online results tied to your pseudonymous player ID is the in-App control described above. Because we do not connect that ID or provider-generated installation identifiers to your name or email, an email address, region, device type, or play date alone may not let us locate those records. We will explain what can be identified and act on any identifier you can provide. You can remove locally stored game data by uninstalling the App and can disable device backups in your Apple or Google account settings.
12. Changes to this policy
We may update this Privacy Policy from time to time. When we make material changes, we will update the "Last updated" date above and, where appropriate, provide notice within the App or on our website. Where the law requires consent for a new use, we will ask for it before that use begins.
13. Contact us
Iris Edge Studios
Email: legal@pinteza.app
