Privacy Policy

The data controller responsible for this app is:

Sergej Birklin
Schützenhausstrasse 76a
8424 Embrach, Schweiz

Email: info@dublblockgame.com
Phone: +41 78 327 93 93

This privacy policy applies to the mobile application Dubl Block (the "App"), available on the Apple App Store, and to the website https://sebirkli.github.io/Dubl Block/. It explains what data is processed, how it is processed, and what rights you have.

This policy is designed to comply with the EU General Data Protection Regulation (GDPR), the Swiss Federal Act on Data Protection (nDSG/FADP), and the California Consumer Privacy Act (CCPA).

3.1 Local Game Data (no transmission)

Your game progress, scores, and settings are stored exclusively on your device using Apple's UserDefaults. This data is never transmitted to us or any third party. It remains on your device until you delete the app.

3.2 In-App Purchases

Purchase transactions are handled entirely by Apple through StoreKit 2. We do not receive or store your payment information, Apple ID, or billing details. Please refer to Apple's Privacy Policy for details on how Apple processes purchase data.

3.3 Game Center

If you use Game Center features (leaderboards, achievements), that data is managed by Apple through GameKit. We do not have access to your Game Center profile or personal information. See Apple's Privacy Policy for details.

3.4 Firebase Analytics (opt-in only)

If you explicitly grant consent, we collect anonymous usage analytics through Firebase Analytics (provided by Google). This data helps us understand how the app is used and improve the experience. The data collected includes:

• Anonymous device-level identifiers (not linked to your identity)
• App usage events (e.g., screens viewed, features used)
• Device type, operating system version, and app version
• Country/region (derived from IP address, which is then discarded)

Firebase Analytics does not collect your name, email, phone number, or any other personally identifiable information. You can withdraw your consent at any time in the app's Settings.

See Firebase Privacy Information and Google's Privacy Policy.

3.5 Data We Do Not Collect

• No user accounts or registration
• No names, email addresses, or phone numbers
• No location data
• No contacts, photos, or other device data
• No cross-app or cross-site tracking
• No advertising data (the app currently contains no ads)
• No cookies (this is a native app)

Data	Legal Basis (GDPR)	Explanation
Local game data	Art. 6(1)(b) — Contract performance	Necessary for the app to function as expected
Firebase Analytics	Art. 6(1)(a) — Consent	Collected only after you explicitly opt in

Under the Swiss nDSG, processing is based on legitimate interests for essential app functionality and on consent for analytics.

Service	Provider	Purpose	Data Location
App Store / StoreKit 2	Apple Inc.	App distribution, in-app purchases	USA / EEA
Game Center (GameKit)	Apple Inc.	Leaderboards, achievements	USA / EEA
Firebase Analytics	Google LLC	Anonymous usage analytics (consent only)	USA

Local game data is not transferred anywhere. It stays on your device.

When you opt in to analytics, Firebase Analytics data may be transferred to Google servers in the United States. This transfer is covered by the EU-US Data Privacy Framework, which the European Commission has recognized as providing an adequate level of data protection (adequacy decision of 10 July 2023).

For Swiss data transfers, the Swiss Federal Data Protection and Information Commissioner (FDPIC) has also recognized the EU-US Data Privacy Framework as adequate.

Data	Retention Period
Local game data (UserDefaults)	Until you delete the app from your device
Firebase Analytics data	14 months (Google default retention period)
Purchase history	Managed by Apple per their retention policy
Game Center data	Managed by Apple per their retention policy

If you are located in the European Economic Area (EEA), you have the following rights under the GDPR (Articles 15–22):

• Right of access (Art. 15) — request a copy of data we hold about you
• Right to rectification (Art. 16) — request correction of inaccurate data
• Right to erasure (Art. 17) — request deletion of your data
• Right to restriction of processing (Art. 18) — request limited processing
• Right to data portability (Art. 20) — receive your data in a portable format
• Right to object (Art. 21) — object to processing based on legitimate interests
• Right to withdraw consent (Art. 7(3)) — withdraw your analytics consent at any time via the app's Settings, without affecting the lawfulness of prior processing

To exercise any of these rights, please contact us at info@dublblockgame.com.

You also have the right to lodge a complaint with your local data protection supervisory authority.

If you are a resident of Switzerland, you have rights under the Swiss Federal Act on Data Protection (nDSG/FADP), including the right to information, rectification, and erasure of your data.

You have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC):

Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragter (EDÖB)
Feldeggweg 1
3003 Bern, Schweiz
www.edoeb.admin.ch

If you are a California resident, the California Consumer Privacy Act (CCPA) grants you the following rights:

• Right to know — request details about the categories and specific pieces of personal information we have collected
• Right to delete — request deletion of personal information we have collected
• Right to opt-out of the sale of personal information — we do not sell your personal information
• Right to non-discrimination — we will not discriminate against you for exercising your CCPA rights

Categories of Personal Information Collected

When analytics consent is granted: device-level identifiers (anonymized), usage data. These are used solely for improving the app experience.

Sale of Personal Information

We do not sell, rent, or share your personal information with third parties for monetary or other valuable consideration.

Exercising Your CCPA Rights

To submit a CCPA request, please contact us at info@dublblockgame.com. We will respond within 45 days as required by law.

Dubl Block is not directed at children under the age of 13. We do not knowingly collect personal information from children under 13. If you believe that a child under 13 has provided personal information through the app, please contact us at info@dublblockgame.com and we will promptly delete such data.

We take reasonable measures to protect information processed through the app. Local game data is stored within the app's sandboxed environment on your device. Analytics data transmitted to Firebase is encrypted in transit using TLS/SSL.

Dubl Block does not currently display advertisements. Should we introduce ads in the future, this privacy policy will be updated accordingly, and you will be prompted to review and consent to the updated policy before any ad-related data processing begins.

We may update this privacy policy from time to time. When we make changes that affect your rights or the way your data is processed, the policy version number will be incremented and you will be re-prompted for consent within the app.

The current version and the date of last update are displayed at the top of this page.

If you have any questions about this privacy policy or wish to exercise your rights, please contact:

Sergej Birklin
Email: info@dublblockgame.com
Phone: +41 78 327 93 93