Privacy Policy for "BlockWords"

Last updated: December 28, 2025

1. Introduction and Controller

We take the protection of your personal data very seriously. This privacy policy informs you comprehensively about the processing of personal data when using our mobile application "BlockWords" (hereinafter "App"). This declaration complies with the requirements of the General Data Protection Regulation (GDPR) of the EU as well as international data protection standards (e.g. CCPA, LGPD).

Controller within the meaning of the GDPR:

Hasan Turan

trnstudios@outlook.de

We use trusted third-party providers to provide functions. These providers may transfer data to third countries (e.g. USA). We ensure an appropriate level of data protection through standard contractual clauses.

A. Advertising (Google AdMob)

To finance the free app, we integrate advertisements via Google AdMob.

• Processed Data: IP address, Advertising ID, location (approximate), app interactions.
• Purpose: Display of personalized or non-personalized advertising.
• Your Choice: When launching for the first time (in the EU), we ask for your consent via a Consent Management Tool (CMP). You can revoke this consent at any time in the app settings.
• Provider: Google Ireland Ltd. / Google LLC.
• Privacy Policy: https://policies.google.com/privacy

B. In-App Purchases (RevenueCat)

We use RevenueCat to process purchases (e.g. "No Ads", "Star Packs").

• Processed Data: Purchase history, anonymous App User ID, product ID, transaction time. We do not process credit card data ourselves; payment processing is carried out solely via Apple (App Store) or Google (Play Store).
• Purpose: Management of subscriptions and purchases, restoration of purchases.
• Legal Basis: Performance of potential contract (Art. 6 para. 1 lit. b GDPR).
• Privacy Policy: https://www.revenuecat.com/privacy

C. App Framework (Expo)

The app was developed using the Expo framework.

• Processed Data: Technical logs during updates (OTA updates), crash reports.
• Purpose: Maintenance and technical stability.
• Privacy Policy: https://expo.dev/privacy

4. App Store Permissions

The app requires access to certain device functions to function correctly:

• Network Access: To load advertisements and verify purchases.
• Vibration/Haptics: For haptic feedback in the game (can be disabled in settings).
• Tracking (iOS "App Tracking Transparency"): We ask for permission to use your Advertising ID for personalized advertising. You can decline this ("Ask App not to track").

5. International Data Transfer

Some of our partners (Google, RevenueCat) are located in the USA. The transfer takes place on the basis of EU Standard Contractual Clauses (SCC) or the Data Privacy Framework (if the provider is certified) to protect your data as best as possible.

6. Storage Duration

• Local Data: Remains stored as long as the app is installed on your device or until you delete the data in the app settings.
• Third Parties: Data (such as Advertising IDs) is generally anonymized or deleted by Google after a certain period (e.g. 13 months), provided no new consent is given.

7. Your Rights (User Rights)

Under the GDPR and other laws (CCPA), you have the following rights:

1. Access: You can request information about the data stored by us at any time.
2. Deletion: You can request the deletion of your data (locally by uninstalling, with third parties via opt-out).
3. Objection: You can object to the processing (esp. for advertising) at any time.
4. Withdrawal: Consents granted (e.g. in the cookie banner/CMP) can be revoked at any time in the app settings.

To exercise your rights, please contact us at the email address mentioned above.

8. Data Security

We implement technical and organizational measures to protect your data against loss, misuse, or access by unauthorized persons. Communication with servers (AdMob, RevenueCat) generally takes place exclusively via encrypted channels (HTTPS/SSL).

9. Children

This app is intended for a general audience. We do not knowingly collect personal data from children under 13 years of age (or 16 years in the EU) without parental consent.

10. Changes to this Declaration

We reserve the right to adapt this privacy policy (e.g. for new features). The current version is always linked in the app or the App Store entry.