Privacy Policy
Effective date: 22 May 2026 Last updated: 22 May 2026
This Privacy Policy explains how Robert Aneszko, a sole trader based in Poland (“we”, “us”, “our”), processes personal data in connection with the PicSort mobile game (“the App”).
We are the data controller for the purposes of the EU General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”). You can reach us at robert.aneszko@gmail.com for any privacy-related question.
1. Summary
- We do not require you to create an account.
- We do not ask for your name, email, or any direct identifier.
- Your game progress is stored locally on your device. It is not uploaded to our servers.
- We show ads in the App. Our ad partner (Google AdMob) may collect device identifiers and ad interaction data to serve and measure ads. On iOS, this only happens if you grant App Tracking Transparency permission and consent through the in-app privacy prompt.
- If you make an in-app purchase, Apple processes the payment. We never see your payment details.
2. What data we (and our partners) process
2.1 Data processed locally on your device only
The following data stays on your device and is not transmitted to us:
- Your in-game progress (current level, completed levels)
- Your virtual coin balance and booster inventory
- Your audio and haptics settings
- Your consent choices
This data is stored using Apple’s standard on-device storage. It is removed if you delete the App.
2.2 Data processed by our advertising partner (Google AdMob)
When ads are shown, Google AdMob may process:
- Device identifiers, including the iOS Advertising Identifier (IDFA) only if you grant App Tracking Transparency permission
- Coarse location (derived from IP address)
- Ad interaction events (impressions, clicks)
- App version and device model
If you do not grant App Tracking Transparency permission, or if you withdraw consent through the in-app privacy prompt, Google AdMob serves non-personalised ads and processes a reduced data set as described in its own privacy notices.
Google’s privacy practices are described at https://policies.google.com/privacy.
2.3 Consent state (Google User Messaging Platform, “UMP”)
We use Google’s User Messaging Platform to collect and store your consent for ad personalisation. UMP stores a record of your consent choices (the TCF consent string) on your device and shares it with our ad partners as required by the IAB Transparency and Consent Framework.
2.4 In-app purchases (Apple)
If you make an in-app purchase, Apple processes the transaction. Apple provides us only with a non-personal receipt confirming the purchase took place. We do not see your Apple ID, name, billing address, or payment method.
2.5 Diagnostic and crash data (Apple)
Apple may collect diagnostic and usage data from your device if you have enabled this in iOS Settings. This data is processed by Apple, not by us. We may receive aggregated crash reports through Apple’s standard developer tools; these do not identify you personally.
3. Legal basis for processing
We rely on the following legal bases under GDPR Article 6:
| Processing activity | Legal basis |
|---|---|
| Showing personalised ads | Your consent (Art. 6(1)(a)) |
| Showing non-personalised ads | Our legitimate interest in funding a free app (Art. 6(1)(f)) |
| Processing in-app purchases | Performance of a contract (Art. 6(1)(b)) |
| Storing your settings and progress on your device | Your consent, given by using the App (Art. 6(1)(a)) |
4. How long we keep data
We do not store personal data on our servers. Data stored on your device is kept until you delete the App.
Our advertising partner retains data according to its own retention schedule, described in its privacy notices.
5. Your rights under GDPR
You have the right to:
- Access the personal data we hold about you
- Rectify inaccurate data
- Erase your data (“right to be forgotten”)
- Restrict processing in certain circumstances
- Object to processing based on legitimate interest
- Withdraw consent at any time
- Lodge a complaint with a supervisory authority
Because we do not store personal data on our servers, the practical way to exercise the rights of erasure and access is to delete the App from your device. This permanently removes all locally-stored data.
To withdraw consent for ad personalisation, open the App’s Settings panel and tap Privacy Preferences. This re-opens the consent prompt.
To exercise any other right, or to ask a question, contact robert.aneszko@gmail.com.
5.1 Right to complain
You can lodge a complaint with the Polish data protection authority:
Urząd Ochrony Danych Osobowych (UODO) ul. Stawki 2, 00-193 Warszawa, Poland https://uodo.gov.pl
6. International transfers
Our ad partner (Google) and the App Store operator (Apple) are based in the United States. When their services process personal data, transfers to the US take place under the EU-US Data Privacy Framework and/or Standard Contractual Clauses as required by GDPR Articles 45–46.
7. Children
The App is not directed at children under 13. We do not knowingly collect data from children under 13. If you believe a child has provided data through the App, contact us and we will assist.
8. Changes to this policy
We may update this policy from time to time. The “Last updated” date at the top reflects the most recent revision. Material changes will be communicated through the App where reasonably possible.
9. Contact
Robert Aneszko (sole trader) Poland Email: robert.aneszko@gmail.com