Tobias Reithmeier

Legal

Privacy in my apps

This privacy policy covers all iOS apps by Tobias Reithmeier, including Sudoku Pro, CLAUDIO, Quadrivium, Tsugi, NonoQuest, Plot Spark, 365 Lens, Find Picture Pairs, Alpine Drift, PauseFirst, Color Mood Circle and Candy Ricochet. It applies to future apps in the same way. An overview of the apps is available under Apps. The website itself is covered by the website privacy policy.

The principle: no data collection

My apps do not collect personal data. There is no developer server that data is sent to. The exceptions are the pseudonymous usage statistics of Candy Ricochet, Find Picture Pairs and 365 Lens and the usage data CLAUDIO sends only with consent, which go to TelemetryDeck (see Candy Ricochet, Find Picture Pairs, 365 Lens and CLAUDIO below). In concrete terms:

This storage on the device is necessary for the features you use in the respective app. Where it involves access to your device, it is based on Section 25(2) No. 2 of the German Telecommunications Digital Services Data Protection Act (TDDDG).

The following sections describe the exceptions: features where an app talks to services outside the device. Each one names the apps it applies to.

Game Center

Sudoku Pro and NonoQuest can use Game Center, Apple's game service for leaderboards and achievements; NonoQuest uses only the achievements. This is optional. If you use Game Center, leaderboard and achievement data is sent to Apple; this runs through your Apple Account and is governed by Apple's privacy policy. The leaderboards show the Game Center alias you chose yourself and the score you reached. I do not receive real names, email addresses or any other contact details.

In-app purchases

Several apps offer in-app purchases, among them CLAUDIO, Sudoku Pro, NonoQuest, PauseFirst, 365 Lens and Candy Ricochet. These purchases run entirely through Apple's StoreKit: Apple handles payment and receipt. I receive no payment details and no address data, only the sales report from Apple.

App recommendations

Sudoku Pro and Find Picture Pairs show other apps by the same developer. To do so, they fetch publicly available data from the App Store, title and icon, via Apple's lookup API. No personal data is transmitted; for technical reasons, Apple sees the IP address.

Candy Ricochet: usage statistics

Candy Ricochet sends pseudonymous usage statistics, so I can see which levels are too hard and where players give up. It uses the analytics service TelemetryDeck (TelemetryDeck GmbH, Augsburg, Germany). What is sent:

I do not link this data to a name or account; there is no user account, no advertising ID, and the data is not used for tracking across apps or websites. Development builds and store screenshot runs send nothing.

You can switch this off at any time in the app under Settings > Privacy > "Anonymous usage data" (the menu label is simplified; technically the data is pseudonymous). From then on no new event is sent; events the service had already queued on the device before that may still be delivered. The legal basis is my legitimate interest in improving the game (Art. 6(1)(f) GDPR); you can object with the switch. More on the provider: TelemetryDeck privacy policy.

Find Picture Pairs: usage statistics

From version 2.3, Find Picture Pairs sends pseudonymous usage statistics, so I can see which modes, grid sizes and card themes are played. It uses the same analytics service, TelemetryDeck (TelemetryDeck GmbH, Augsburg, Germany). What is sent:

I do not link this data to a name or account; there is no user account, no advertising ID, and the data is not used for tracking across apps or websites. Store screenshot runs send nothing; events from development builds are marked as test data.

You can switch this off at any time in the app under Settings > Legal > "Usage statistics". From then on no new event is sent; events the service had already queued on the device before that may still be delivered. The legal basis is my legitimate interest in improving the game (Art. 6(1)(f) GDPR); you can object with the switch. More on the provider: TelemetryDeck privacy policy.

365 Lens: usage statistics

From version 2.0, 365 Lens sends pseudonymous usage statistics, so I can see which lessons are used, how far people get in the course and where the purchase flow breaks off. It uses the same analytics service, TelemetryDeck (TelemetryDeck GmbH, Augsburg, Germany). What is sent:

Photos, texts, places, dates and names are never part of an event. I do not link this data to a name or account; there is no user account, no advertising ID, and the data is not used for tracking across apps or websites. Store screenshot runs send nothing.

You can switch this off at any time in the app, in Settings under "Usage statistics". From then on no new event is sent and the service is stopped; events it had already queued on the device before that may still be delivered. The legal basis is my legitimate interest in improving the course (Art. 6(1)(f) GDPR); you can object with the switch. More on the provider: TelemetryDeck privacy policy.

CLAUDIO

CLAUDIO is a player for your own audio files and only plays what you set up yourself. To do that, the app can connect to the following services, all of them optional and all of them configured by you:

In every case, the connection runs between the device and the service you chose. I am not involved and do not see this data.

CLAUDIO: usage data

From version 15.1, CLAUDIO asks once whether the app may send usage data, so I can see which features are used and where things go wrong. The question has two equal answers and no preselection; the choice applies per device. If you choose "No", CLAUDIO sends nothing, not even a note that you declined, and the analytics service is never started. After a "Yes", CLAUDIO uses the analytics service TelemetryDeck (TelemetryDeck GmbH, Augsburg, Germany). What is sent:

Titles, file and folder names, server addresses, user names, search terms, podcast addresses and the text of error messages are never part of an event. I do not link the data to names or accounts; there is no user account, no advertising ID, and the data is not used for tracking across apps or websites. Store screenshot runs and automated tests send nothing.

TelemetryDeck processes the data on servers in the EU. In TelemetryDeck's assessment the data is anonymous to the provider; the data processing agreement is part of TelemetryDeck's terms of service. The legal basis is consent (Art. 6(1)(a) GDPR, and Section 25(1) TDDDG for access to the device). You can withdraw it at any time in the app under Settings > System > "Send usage data". From then on CLAUDIO sends no new events and the service is stopped; events it had already queued on the device before that may still be delivered. After "Reset App", CLAUDIO asks again on the next launch. More on the provider: TelemetryDeck privacy policy.

PauseFirst

PauseFirst blocks other apps and unlocks them only after a small task. The app itself does not connect to the internet; PauseFirst does not send any Screen Time data off the device. In detail:

In the app's settings, "Delete all data" removes the selection, the settings, the statistics, the installation ID and any admin code, and lifts all blocks; on the next start the app creates a new random ID. If only the app is deleted, its keychain entries may remain on the device; they never leave the device. The system log is managed by iOS. Your rights under the GDPR and the contact details are covered in the sections below.

Camera and photos

365 Lens works with the camera and the photo library; Sudoku Pro can save an image to the library. Color Mood Circle takes photos with the camera or picks them through the iOS photo picker, scales them down and removes location and other metadata before saving them. 365 Lens can look up the place name of a photo: only if place names are switched on does the app send the photo's GPS coordinates to Apple Maps; that is covered by Apple's privacy policy. Access is granted by the system first and stays on the device. The apps themselves do not upload any images. Images can be passed on from the app via the iOS share sheet - this happens only when you explicitly choose to share, and where the image goes is determined by the destination you pick.

Crash reports

If you have agreed in the iOS settings to share diagnostic data with developers, your device sends crash reports to Apple; I see them there in aggregated form. This is a system setting, not a feature of the apps, and can be turned off in the iOS settings. The legal basis is your consent (Art. 6(1)(a) GDPR), which you can withdraw at any time by turning the option off.

Your rights under the GDPR

Under the GDPR you have the right of access, rectification, erasure, restriction of processing, data portability and objection (Art. 15 to 21 GDPR), the right to withdraw consent, and the right to lodge a complaint with a supervisory authority. An honest note on this: since the apps do not collect personal data, there is usually nothing on file to disclose. For Candy Ricochet, Find Picture Pairs, 365 Lens and CLAUDIO, pseudonymous usage data is held by TelemetryDeck; without the device identifier it can usually not be tied to a person. You can object or withdraw consent at any time with the switch in the app. I will answer requests all the same.

Controller and contact

The controller within the meaning of the GDPR is the operator named in the legal notice. For support and privacy questions: support@nerdwana.net.

If you email me, I process your address and the content of your message only to answer your request (Art. 6(1)(b) or (f) GDPR). I delete the message once it is resolved, unless statutory retention periods apply.

This English version of the privacy policy is provided for ease of understanding only. The legally binding version is the German version DE; in case of any discrepancy, the German version prevails.

This policy covers the apps only. The website itself is covered by the website privacy policy.