Privacy Policy

Last Updated: February 2025

This Privacy Policy explains how David Kadlcek ("we", "us", or "our") collects, uses, and protects your information when you use the mobile application Headbands - Top Party Charades (the "Service").

1. Information We Collect

We prioritize your privacy. We do not store personal user data on our own servers. However, the app uses third-party services that may collect information used to identify you.

A. Automatically Collected Data

• Device Information: Device model, operating system version, and IP address (general location only, not precise GPS).
• Usage Data: Information about how you use the app, such as buttons clicked, features used, and time spent in the app.
• Diagnostics: Crash logs and performance data to help us fix bugs.

B. User Inputs (AI Features)

When you use AI-powered features (e.g., to generate custom decks), we process the text prompts you provide ("User Inputs"). These inputs are sent to our AI provider solely to generate the response.

2. How We Use Your Information

We use the collected data for the following "Legal Bases" (as defined by GDPR):

• To Provide the Service: Processing inputs to generate game content.
• Legitimate Interest: Analyzing crash logs to fix bugs and improving app performance via analytics.
• Legal Compliance: Complying with law enforcement requests if required.

3. Third-Party Service Providers

We share data with the following trusted third parties to operate the app. We do not sell your data to data brokers.

• Google Analytics for Firebase (Analytics) - Privacy Policy
• Firebase Crashlytics (Crash Reporting) - Privacy Policy
• RevenueCat (Subscription Management) - Privacy Policy

4. AI Features & Data Safety

Our app uses artificial intelligence to generate content.

• Data Sharing: Your text prompts are shared with Gemini to generate results.
• No Training: We do not use your personal inputs to train our own custom AI models.
• Retention: AI providers may retain inputs for a short period (typically up to 30 days) to monitor for abuse and safety, after which they are deleted.

5. Data Retention

No Server Storage: We do not store your personal account data on our servers.

• Local Data: Game progress and custom decks are stored locally on your device. If you delete the app, this data is lost.
• Third-Party Data: Analytics and subscription records are retained by our partners (Google/RevenueCat) according to their own retention policies.

6. Children’s Privacy

These Services do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13. If we discover that a child under 13 has provided us with personal information, we will immediately delete this from our records.

7. Data Deletion Requests

Since we do not store user accounts on our servers, you can delete your local data simply by uninstalling the app.

To request the deletion of data stored by our third-party partners (e.g., RevenueCat purchase history), please contact us at da.developer605@gmail.com, and we will assist you in locating your anonymous User IDs to submit a deletion request to them.

8. Refunds & Sharing Consumption Data

Consent to Share Consumption Data with Apple:
By using our app and making in-app purchases, you consent to our sharing of data regarding your usage and consumption of purchased content with Apple. This information may include details about how you have accessed and interacted with the purchased content. The purpose of sharing this data is to help Apple make an informed decision regarding refund requests. We ensure that such data sharing is done in compliance with Apple's policies and only as necessary to process your requests.

Refund Requests:
We do not have access to your billing information. All transactions are processed directly by the respective app store.

• iOS (Apple): You must request a refund directly from Apple via support.apple.com.

9. Your Privacy Rights (GDPR/EU)

If you are located in the European Economic Area (EEA), you have the right to:

• Access the personal data we hold about you.
• Request correction of inaccurate data.
• Request deletion of your data ("Right to be Forgotten").
• Object to the processing of your data.

10. US Privacy Rights (California/CCPA)

For residents of California and other US states with privacy laws:

• We Do Not Sell Your Data: We do not sell personal information to third parties for monetary value.
• Right to Know & Delete: You have the right to request details about the information we collect and to request its deletion.

11. Changes to This Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. You are advised to review this page periodically for any changes.

12. Contact Us

If you have any questions about this Privacy Policy, please contact us at: da.developer605@gmail.com.