Privacy Policy
Last updated: October 13, 2026
This Privacy Policy explains how personal data is handled in the mobile games and apps published by Loewenherz Consulting (the “Apps”) and on this website. Loewenherz Consulting is run by a single independent developer, so “I”, “me” and “my” in this policy refer to me, the developer.
1. Who is responsible
The controller responsible for data processing under the EU General Data Protection Regulation (GDPR) is:
Eugen Quiring
Email: consulting.loewenherz+privacy@gmail.com
I do not run my own servers or user accounts. I do not ask for your name, email address or phone number inside the Apps.
2. What data is processed
Depending on the App and on the choices you make, the third-party services built into the Apps (see section 6) may process:
- Device information: device model, operating system and version, language, screen size, time zone
- IP address and the approximate location (country or region) derived from it
- Advertising identifiers (Apple IDFA, Google Advertising ID) and app-set or vendor identifiers (IDFV, App Set ID) – the advertising identifiers only with your permission where this is required
- Usage data: app opens, session length, game progress, levels, in-game events, ad views and clicks
- Install attribution data: which ad campaign or store led to the install
- Crash reports and diagnostic data: error logs, app state at the time of the crash, performance data
- Purchase information: which in-app product was bought and the transaction confirmation (no payment card data – see section 7)
- Your consent and tracking choices
3. Data that stays on your device
Content you create in the Apps (for example saved cards, records or game progress) is stored only on your device and is never sent to me. Camera, photo and location access, where an App asks for it, is used on your device for the feature it is requested for. If an App shows nearby places, your approximate position is sent to the public data service that provides them (see section 6), without any identifier linking it to you.
Deleting an App removes this data from your device. I cannot restore it.
4. Purposes and legal bases
| Purpose | Legal basis (GDPR) |
|---|---|
| Showing personalised ads, measuring ad performance, install attribution linked to advertising identifiers | Your consent, Art. 6(1)(a) |
| Showing non-personalised ads to fund free Apps | Legitimate interest, Art. 6(1)(f) |
| Crash reporting, fixing bugs, app stability | Legitimate interest, Art. 6(1)(f) |
| Usage analytics and game balancing, remote configuration of game settings | Legitimate interest, Art. 6(1)(f), or consent where required |
| Delivering in-app purchases | Performance of a contract, Art. 6(1)(b) |
| Preventing fraud and abuse, meeting legal obligations | Art. 6(1)(c) and (f) |
I do not sell your personal data, and I do not use it to make automated decisions that have legal or similarly significant effects on you.
5. Consent, tracking and ads
- EEA, UK and Switzerland: on first launch the Apps show a consent form (Google User Messaging Platform, IAB TCF). You can accept, reject or choose per purpose. You can change your choice at any time in the App’s settings, where available, or by reinstalling the App.
- iOS: the Apps ask for permission through Apple’s App Tracking Transparency prompt before accessing the IDFA. You can change this at any time in Settings → Privacy & Security → Tracking.
- Android: you can delete or reset your Advertising ID in Settings → Google → Ads (or Settings → Privacy → Ads).
If you decline, you will still see ads, but they will not be personalised.
6. Third-party services
The Apps use third-party providers in these categories. Each processes data under its own privacy policy. Not every App uses every category.
- Advertising and ad mediation networks
- Consent management
- Install attribution and ad measurement
- Analytics, crash reporting and remote configuration
- Public data services that provide location-based content
- App stores (Apple App Store, Google Play) for distribution and in-app purchases
The current list of advertising partners for each App, with links to their privacy policies, is shown in the App’s consent screen and privacy settings. The partners authorised to sell my ad inventory are listed in my app-ads.txt file.
This website is hosted by Netlify, Inc. (USA), which processes your IP address and request data in server logs to deliver the site. The website uses no cookies and no analytics.
7. In-app purchases
Some games offer optional in-app purchases. Payments are handled entirely by Apple (App Store) or Google (Google Play). I never receive your payment card details, name or billing address – only a confirmation that a purchase was made so that the item can be delivered.
8. International transfers
Some of the services above are based in, or process data in, the United States or other countries outside the EEA. Where this happens, transfers rely on the EU–US Data Privacy Framework where the provider is certified, or on the European Commission’s Standard Contractual Clauses.
9. Data retention
Data on your device stays there until you delete it or uninstall the App. Data processed by the third-party services is kept according to their retention settings.
10. Children
The Apps are intended for adults and are not directed at children. I do not knowingly collect personal data from children.
11. Your rights (GDPR)
If you are in the EEA, the UK or Switzerland, you have the right to:
- Access the personal data held about you (Art. 15)
- Have inaccurate data corrected (Art. 16)
- Have your data deleted (Art. 17)
- Restrict processing (Art. 18)
- Data portability (Art. 20)
- Object to processing based on legitimate interest (Art. 21)
- Withdraw your consent at any time, without affecting processing done before the withdrawal (Art. 7(3))
- Lodge a complaint with a data protection supervisory authority, for example the Berlin Commissioner for Data Protection and Freedom of Information (datenschutz-berlin.de)
Because I do not run user accounts, I usually cannot link data held by third-party services to you. Requests about that data can be made to the respective provider.
12. California residents
Under the CCPA/CPRA you have the right to know what personal information is collected, to request its deletion and correction, and to opt out of its “sale” or “sharing” for cross-context behavioural advertising. I do not sell personal information for money. To opt out of ad-related sharing, decline tracking on iOS or delete your Advertising ID on Android (see section 5).
13. Security
I take reasonable technical and organisational measures to protect data, and the Apps communicate with third-party services over encrypted connections. No method of transmission or storage is completely secure.
14. Changes
I may update this policy when the Apps or the services they use change. The “Last updated” date at the top shows the current version.