Pinbrawl Privacy Policy

1. Who is responsible

Pinbrawl is made by Matthias Schedel, Illerstraße 37, 87487 Wiggensbach, Germany. For anything in this policy, write to matthias.anton.schedel@gmail.com. There is no separate company and no data protection officer; the same address answers both.

2. What stays on your device

Everything the game remembers about you is written to your device’s own local storage and is never uploaded anywhere:

• The castle. Which upgrades you have bought and fitted — masonry, doors, archers and their posts, the ball rack, the garrison — plus how much gold you are holding and how far you have got.
• Your best score. A single number.
• Two switches. Whether sound is muted and whether the phone buzzes.

None of this is transmitted, backed up to a Pinbrawl server, or readable by anyone but you. Deleting the app deletes all of it. Pinbrawl operates no backend, holds no account, and has nothing for you to log in to.

3. The one ad

The game offers a rewarded video exactly once per run, at the moment your castle falls, in exchange for handing the run back to you. Nothing else in the game is an ad, and no ad ever plays that you did not choose to watch. Decline and the run simply ends.

The video is served by Google AdMob (Google Ireland Limited for users in the EEA, Gordon House, Barrow Street, Dublin 4). Google’s Mobile Ads SDK is embedded in the iOS and Android apps. It contacts Google twice: when the game starts, to read what you have consented to and to start itself, and again when an ad is requested. Google receives the kind of data any ad request carries:

• your IP address, and the coarse region it implies;
• device and app information — device model, operating system version, language, the app’s identifier and the SDK’s own version;
• ad interaction data — that an ad was requested, shown, watched through or dismissed;
• the advertising identifier of your device. On iPhone and iPad that is the IDFA, and only if you granted Apple tracking permission — without it iOS hands out a zeroed identifier and Google gets nothing that identifies your device across apps. On Android it is the advertising ID and the app set ID, which the system provides without asking you first; you can reset it, or switch personalisation off entirely, in Android Settings → Privacy → Ads.

Google acts as an independent controller for this data. What it does with it is described in Google’s privacy policy for its business services and in AdMob’s own documentation. This can involve transfers to Google servers outside the EU, which Google covers with the European Commission’s standard contractual clauses.

Pinbrawl itself never sees any of it. The game receives one thing back from the SDK: whether the video was watched through far enough to pay the reward.

Consent, and how to refuse

Before the ads SDK is started at all, the app runs Google’s consent flow (the UMP SDK). Where a consent message is required — the EEA, the UK and comparable regions — the form is shown and your answer decides what happens next. On iOS the app then asks Apple’s own App Tracking Transparencyquestion, which is what decides whether the advertising identifier is readable. Android has no equivalent prompt: the advertising ID is readable unless you have turned it off in the system settings, so there the consent form is the only question you are asked.

• Refuse consent and the SDK is never permitted to request an ad. There is then no ad, no offer at the end of a run, and the game plays exactly the same.
• Refuse tracking and ads still play, but non-personalised: the identifier reads as all zeros and Google cannot match the request to you across apps.
• Change your mind about tracking at any time in iOS Settings → Privacy & Security → Tracking.
• Change your mind about consent: your answer to Google’s form is stored on the device by the UMP SDK. Pinbrawl does not yet offer an in-app button to reopen that form; deleting and reinstalling the app clears the stored answer and you will be asked again. If you would rather not do that, mail me and I will tell you when the button ships.

The legal basis for the ad processing is your consent, Art. 6(1)(a) GDPR, together with § 25(1) TDDDG for the storage of and access to information on your device. It is withdrawable, and withdrawing it costs you nothing but the continue.

Apple’s attribution (SKAdNetwork)

The app carries the SKAdNetwork identifiers of the ad networks that buy through AdMob. SKAdNetwork is Apple’s own, privacy-preserving install-attribution system: it lets a network be credited for an install through Apple, without the app or the network being told who you are. Pinbrawl receives nothing from it.

4. What Pinbrawl does not do

• No analytics SDK, no crash-reporting SDK, no attribution SDK, no fingerprinting. Google’s ads SDK reports its own performance to Google — start-up time, hang rate, energy use — and that is the only diagnostic data that leaves the phone.
• No location permission of any kind — the app never asks iOS or Android where you are, and neither system ever prompts you for it. The coarse region Google infers from your IP address when an ad is requested, described in section 3, is the only sense in which location is involved at all.
• No contacts, photos, microphone, camera, calendar, or health data. The app asks for none of these permissions.
• No payment data. The iOS app does sell consumable packs of orc gems through the App Store, and Apple handles all of it: the sheet, the card, the receipt. I never see a card number, a name or an address — the game is told only that a transaction completed, and writes the gems into the save on your device. There is no subscription, and the Android app has no store at all.
• No user accounts of mine, no email addresses, no chat, no user-generated content. Pinbrawl has nothing for you to log in to and nowhere for you to type.
• The leaderboards are Apple’s. The iOS app submits two numbers — how far your castle has climbed this season, and how many orcs you have killed in total — to Game Center, under the Game Center account your device is already signed in to. Apple holds the boards and shows them on Apple’s own screen; the game reads back nothing about you but the nickname you chose there, and does not store it. Sign out of Game Center and nothing is submitted. The Android app has no leaderboards.
• No selling or sharing of personal data with data brokers. Nothing is sold, because nothing is collected to sell.

Builds of Pinbrawl for desktop carry no ads SDK at all, and therefore make no network requests whatsoever.

5. Distribution

The app is distributed by Apple through the App Store and TestFlight. Apple processes downloads, and — if you have enabled sharing with developers in your iOS settings — provides me with aggregated, anonymised App Store statistics and crash reports. These are counts and stack traces, not people; I cannot identify you from them. Apple’s own privacy policy governs that processing.

The Android app is distributed by Google through Google Play. Google processes downloads and gives me the same kind of aggregated, anonymised statistics and crash reports — counts and stack traces, not people. Google’s own privacy policy governs that processing.

6. Retention

• On-device save data: kept until you delete the app. I never have a copy.
• Ad request data: held by Google under Google’s own retention rules. I hold none of it.
• Email you send me: kept as long as needed to answer you, and deleted afterwards.

7. Children

Pinbrawl is not directed at children under 13, and no part of it is designed to appeal specifically to them. It collects no personal data from anyone on its own account. If you believe a child has provided personal data through the app, write to the address in section 1.

8. Your rights

Under the GDPR you have the right to access, rectify, export, erase and restrict your personal data, to object to processing, and to withdraw consent at any time. Because the game keeps nothing about you on any server of mine, most of these are exercised on the device itself:

• Withdraw tracking permission in iOS Settings → Privacy & Security → Tracking, or on Android reset or switch off the advertising ID in Settings → Privacy → Ads.
• Delete the app to erase every byte the game has stored about your play.
• To exercise a right against Google for the ad data it holds, contact Google directly — it is the controller for that data.
• For anything else, write to matthias.anton.schedel@gmail.com.

You also have the right to complain to a supervisory authority. For Germany that is the authority of your federal state; mine is the Bayerisches Landesamt für Datenschutzaufsicht (BayLDA), Ansbach.

9. Security

The app implements no cryptography of its own and stores no credentials, because it has none to store. All traffic the ads SDK makes is over HTTPS.

10. Changes

If this policy changes materially, the date at the top of the page changes with it and the change is mentioned in the release notes of the version that introduces it.