Privacy

This privacy policy describes the processing activities for the website dacoder.eu as well as the apps Moodara, Brightcal, LehrerZeit, Placekeeper - My Places and PDF Shrink & Scan & OCR, No-Words, Jewelume Coloring Puzzle. This policy also covers Sortello: Category Sort.

Controller

Mario Koopke
Gartenfelder Str. 43
13599 Berlin, Germany
Email: info@dacoder.eu
(Publisher of the apps Moodara, Brightcal, LehrerZeit, Placekeeper - My Places and PDF Shrink & Scan & OCR, No-Words, Jewelume Coloring Puzzle)
Sortello: Category Sort

Scope

This policy applies to:

• iOS / iPadOS: Sortello: Category Sort.

1. Website: dacoder.eu

1.1 Hosting & server log files

When you visit the website, the server processes, among other things, your IP address, date/time, referrer, user agent and requested resources in order to provide the website and defend against attacks. Legal basis: Art. 6(1)(f) GDPR (legitimate interests in secure, stable operation). Log data is generally stored only briefly and then deleted.

1.2 Cookies & tracking

Only technically necessary cookies are used. This includes the language cookie bcLang, which stores your selected language. The cookie is set for 365 days and is used exclusively to provide the website in your chosen language. There is no third-party tracking (for example, Google Analytics).

1.3 Contact

If you contact us by email, we process your data in order to handle the request (Art. 6(1)(b) or (f) GDPR). Data is deleted once the request has been resolved unless statutory retention duties apply.

1.4 Social media: Facebook and Instagram

We maintain a presence on Facebook and may also operate a presence on Instagram in the future in order to provide information about our services and communicate with interested users.

Social media services are only integrated on our website as normal external links. If you click such a link, you leave our website. From that point on, personal data may be processed by the respective provider, in particular your IP address, device information and usage data. We have only limited influence over this processing.

The provider of Facebook and Instagram is Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland. Further information can be found in Meta’s privacy policy.

Our Facebook profile is currently available at https://www.facebook.com/profile.php?id=61590353112365. An Instagram profile may be added in the future; in that case, Meta’s privacy information will also apply.

When you visit our social media profiles, personal data is generally processed by Meta as an independent controller. Insofar as Meta provides us with aggregated statistics or so-called insights about our presence, joint controllership with Meta may exist to that extent.

The legal basis for operating our social media presences is Art. 6(1)(f) GDPR (legitimate interests in information, public presence and communication).

2.1 App: Moodara (iOS)

• Purpose: mood journal; recording moods and optional notes as well as local evaluations and overviews.
• Processed data: mood entries with timestamp, mood, and an optional free-text note.
• Storage & transmission: entries are stored locally on your device by default. If you enable iCloud synchronisation, the entries are stored or synchronised via Apple iCloud / CloudKit (Private Database in the container iCloud.dacoder.Wiegehtesmir) in your iCloud account. We operate no own servers for this data.
• Recipients / third parties: Apple as the provider of iCloud / CloudKit, but only if you enable iCloud synchronisation. There is no disclosure to advertising or analytics providers.
• Permissions: optional local notifications (reminders) are scheduled exclusively on-device via UNUserNotificationCenter. No push servers are used.
• Export / sharing: in the “Summary” feature, the app can combine all notes into a text, save it as Notes.txt in a temporary folder, and then share it via the iOS share sheet. This only happens if you actively trigger it.
• Support contact: when contacting support, the app can optionally insert technical diagnostic data into an email, in particular app name, version / build, device model with identifier, iOS version, and selected app language. The email is only sent if you actively send it yourself.
• Control: iCloud synchronisation can be disabled in the app. Export / sharing and support email are optional and only triggered by you.
• Legal basis: Art. 6(1)(b) GDPR for providing the app’s functionality; for notifications Art. 6(1)(a) GDPR.
• Storage period: until deletion in the app or uninstallation. If iCloud synchronisation is enabled, according to the iCloud settings and backups in your Apple account.

2.2 App: Brightcal (iOS)

• Purpose: Brightcal is a calendar app for private users and small business use cases, with a focus on readability, day, week and month views, templates, and convenient location and navigation features.
• Processed data: Calendar data is displayed, created and edited on your device via Apple EventKit. The app also stores app settings locally, such as views, filters, colors and font size, as well as templates as files in the app storage.
• Storage and transfer: Calendar data, app settings and templates are generally processed locally on your device. We do not operate our own servers for this data.
• Optional iCloud sync: If you enable template sync, templates are stored as JSON data in your private iCloud / CloudKit database and synchronized between your devices. This takes place via Apple and not via our own servers.
• Weather (optional): If you enable the weather feature, the app uses WeatherKit. Depending on your settings, location data may be used to retrieve weather information for your location. Weather data is provided by Apple; Apple's privacy policy also applies.
• Places / navigation (optional): Addresses or places from events and templates can be used to open Apple Maps, Google Maps or Waze with a tap. The respective address or search text is then passed to the navigation app you choose.
• In-app purchases: Purchases, subscriptions and restorations are handled through Apple StoreKit. Apple processes payments and transaction data on its own responsibility; the app only receives the purchase status or entitlement from Apple.
• Permissions: Calendar access is required. Notifications and the app badge are optional. Contacts are optional, for example for birthdays or address search. Location is optional, for example for weather or location-based features.
• Control: Optional features such as template sync, notifications, contacts or location can be disabled at any time in the app or in iOS settings.
• Legal basis: Art. 6(1)(b) GDPR for providing the app features; for optional features such as notifications, contacts or location, Art. 6(1)(a) GDPR.
• Storage period: Calendar content remains in the iOS calendar. App settings and templates are stored locally; if template sync is enabled, they are also stored in your private iCloud database until you delete them or disable sync.

2.3 App: LehrerZeit (iOS)

• Purpose: LehrerZeit is a time tracking app designed for teachers. The app supports the recording and evaluation of working time and entries.
• Processed data: the app only processes the data that you create or enter yourself, in particular time entries (for example start/end times and duration), categories created by you, and the evaluations and overviews generated from them within the app.
• Processing: this data is generally stored and processed locally on your device. No user account is required. We operate no own servers to store or process your content.
• Internet connection: the app’s core functions, in particular time tracking, categorisation and evaluation, can generally be used without an internet connection. An internet connection may however be required if you use iCloud synchronisation, App Store features, in-app purchases or updates.
• iCloud synchronisation: if you have enabled iCloud on your device, your data may be synchronised via iCloud with your Apple account. This synchronisation takes place exclusively through Apple services and not through the provider’s own servers. Data uploaded to iCloud may remain there even after the app has been deleted until it is also removed from iCloud.
• Export / sharing: data is only exported from the app or shared through system share functions if you actively trigger this yourself.
• No disclosure: the provider does not transmit personal data to its own servers or to third parties for analytics, advertising or tracking purposes. Processing via iCloud only takes place if you have enabled this function on your device or in your Apple account.
• In-app purchases / trial period: the app may offer paid features, subscriptions or trial periods. Processing takes place exclusively through Apple (In-App Purchases / App Store). We do not receive payment data such as credit card information.
• Permissions: only the system functions required for the app’s functionality are used. Where iCloud is used, this is based on your device settings and your Apple account.
• Legal basis: Art. 6(1)(b) GDPR for providing the app’s functionality; where consent is required, Art. 6(1)(a) GDPR.
• Storage period / deletion: you can delete your data within the app. The data remains on your device or – if synchronisation is enabled – in your iCloud account until you delete it there or uninstall the app. For guidance on fully deleting all app data, including iCloud data, you can contact support at support@dacoder.eu.

2.4 App: LehrerZeit (Android)

• Purpose: LehrerZeit is also available on Android as a time tracking app for teachers. The app supports the recording and evaluation of working time and entries.
• Processed data: the Android app only processes the data that you create or enter yourself, in particular time entries (for example start/end times and duration), categories created by you, and the evaluations and overviews generated from them within the app.
• Processing: this data is generally stored and processed locally on your device. No user account inside the app is required. We operate no own servers to store or process your content.
• Google Drive synchronisation: if you wish, data can be synchronised or backed up via Google Drive manually or automatically when new entries exist. This takes place through Google Drive or related Google services and not through the provider’s own servers. Data stored in Google Drive may remain there even after the app has been deleted until it is also removed from Google Drive.
• Export / sharing: data is only exported from the app or shared through system share functions if you actively trigger this yourself.
• No disclosure: the provider does not transmit personal data to its own servers or to third parties for analytics, advertising or tracking purposes. Processing via Google Drive only takes place if you actively use this function.
• In-app purchases / trial period: the app may offer paid features, subscriptions or trial periods. Processing on Android takes place exclusively via Google Play or the purchase services connected to it. We do not receive payment data such as credit card information.
• Permissions: only the system functions required for the app’s functionality are used. Where Google Drive is used, this is based on your Google account settings and your use of the relevant Google services.
• Legal basis: Art. 6(1)(b) GDPR for providing the app’s functionality; where consent is required, Art. 6(1)(a) GDPR.
• Storage period / deletion: you can delete your data within the app. The data remains on your device or – if synchronisation is enabled – in your Google Drive account until you delete it there or uninstall the app. For guidance on fully deleting all app data, including Google Drive data, you can contact support at support@dacoder.eu.

2.5 App: PDF Shrink & Scan & OCR (iOS)

• Purpose: creation, compression and text recognition (OCR) of documents.
• Processing: all created scans, PDFs and recognized text are processed and stored exclusively locally on your device. There is no transmission to our own servers.
• OCR (text recognition): text recognition is performed fully on-device via Apple Vision. No data is sent to external services for processing.
• Storage & file services: files are stored locally. If you use iCloud or other system-based file services, documents may be synchronized or stored through these services. This takes place exclusively through the respective provider’s infrastructure and not through our own servers.
• Permissions:
  • Camera: for scanning documents
  • Photos: for saving or selecting image content, if you use this function
  • Files: for saving, opening and managing documents
• Export / disclosure: documents are only disclosed if you actively export them via the share function or use system-based file services.
• No disclosure / no tracking: the provider does not transmit personal data to its own servers or to third parties for analytics, advertising or tracking purposes. There is no tracking or analytics.
• In-app purchases: the app may offer paid features as a one-time purchase. Processing takes place exclusively through Apple (App Store). The provider does not process payment data such as credit card information.
• Legal basis: Art. 6(1)(b) GDPR for providing the app’s functionality.
• Storage period: the data remains on your device or in the file services you use until you delete it or uninstall the app.

2.6 App: Placekeeper - My Places (iOS)

• Purpose: Placekeeper - My Places is a personal place storage app for saving, finding and sharing places, photos, notes, addresses, coordinates, websites and categories.
• Processed data: places you create with title, category, address, coordinates, website, notes, photos, photo metadata, creation and modification dates, plus app settings such as categories, design, language, map, photo, storage and iCloud settings.
• Storage & iCloud sync: data is generally stored locally on your device. If you enable iCloud sync, places, categories, photos, notes, settings and deletion information are synchronized through Apple iCloud / CloudKit (Private Database in the container iCloud.Dacoder.Placebook) with your iCloud account. This takes place through Apple and not through our own servers.
• Photos & storage: photos may be stored in original size or, if you enable it, in compressed form. When compression is enabled, original files are replaced with smaller versions to save storage space.
• Temporary sharing: if you share an entry as a link, the app creates an encrypted package from the Placekeeper - My Places app with the selected content, depending on your choice including photos and notes, and uploads it temporarily to dacoder.eu. The key is passed in the link fragment and is not sent to the server. The server processes the encrypted file, a random share ID, size, expiry time, download status and displayed share title. Shared packages are deleted after retrieval or no later than after 24 hours.
• Navigation, maps & contacts: addresses or coordinates can be passed to your selected navigation app. Map and place features use Apple MapKit / Core Location; location access only occurs with your permission. If you enable contacts on the map, the app locally processes names and addresses from your contacts to show them on the map. Contact photos are not required.
• In-app purchases: Premium is handled as a one-time purchase through Apple StoreKit. Apple processes payment and transaction data on its own responsibility; the app only receives the purchase status.
• Support contact: when contacting support, the app can optionally insert technical diagnostic data into an email, such as app version, device, iOS version, language, iCloud/sync status, premium status and local counters. No personal content such as places, notes or photos is attached.
• Control: iCloud sync, photo compression, contacts on the map, location access, sharing and support email are optional or controlled by you.
• Legal basis & storage period: legal bases are Art. 6(1)(b) GDPR for providing the app functions, Art. 6(1)(a) GDPR for optional permissions and iCloud sync, and Art. 6(1)(f) GDPR for secure operation of the temporary sharing service. Local data remains until deletion in the app or uninstallation. iCloud data remains in your iCloud account until deleted there. Temporary share files are deleted after retrieval or no later than after 24 hours; hosting server logs are generally stored only briefly.

2.7 App: No-Words (Android & iOS)

• Purpose: No-Words allows members of private, invitation-based groups to share their current status in a simple visual form. The app may for example be used by families, couples, groups of friends or supportive groups. No-Words is not a medical device, not an emergency system and not a substitute for medical, psychotherapeutic or other professional advice.
• Accounts and managed profiles: Registered accounts use an email address, display name and technically generated user ID. Passwords are processed by Firebase Authentication; we do not receive access to the plaintext password. An adult may create a managed profile, especially for a child or another supported person. Managed profiles use their own technical user ID and display name, but no separate email address or password. Independent registration of regular accounts by children is not intended. Guardians may contact support@dacoder.eu to request access, rectification or deletion or to withdraw previously granted consent.
• Processed data: Depending on the functions used, this may include email address, display name, user IDs, email verification status, managed-profile assignments, group names, memberships, roles, aliases, custom status definitions and validity periods, current status, timestamps, expiry times, reactions, invitations and join requests, notification and privacy settings, app and installation identifiers, device type or model, operating system, app version, language, push notification tokens and technical security data such as IP address, user agent and app-check or integrity signals. Status information may in individual cases allow conclusions about a person’s well-being and may therefore constitute health data.
• Purposes, legal bases and visibility within groups: Processing takes place to provide accounts and managed profiles, manage private groups, display status messages and reactions, process invitations, send notifications and prevent misuse or unauthorized access. Legal bases are in particular Art. 6(1)(b) GDPR, Art. 6(1)(f) GDPR and, for voluntary functions or consent-based processing, Art. 6(1)(a) GDPR. Where status information constitutes health data, processing takes place where required on the basis of explicit consent under Art. 9(2)(a) GDPR. For children, the legal requirements of Art. 8 GDPR also apply. Groups are not publicly searchable and group data and current status information are generally only visible to invited or confirmed group members.
• Recipients, notifications and security: No-Words uses Google Firebase services, in particular Firebase Authentication, Cloud Firestore, Cloud Functions, Firebase Cloud Messaging, Firebase Installations and Firebase App Check, as well as the Apple Push Notification Service on iOS where push notifications are used. Installation, updates and distribution take place via Google Play and the Apple App Store. Apple and Google may process data on their own responsibility. Depending on the service used, processing may also take place outside the EEA under the safeguards of the respective provider. Notifications are optional and can be disabled in the app or operating system. If detailed notifications are enabled, for example a group name or alias, sender name and a short status label may appear via the push service or on the lock screen.
• Storage, export and deletion: Data transmission to Firebase is encrypted and additional access controls, device assignments and integrity checks are used. Content is not end-to-end encrypted because server-side group functions have to be provided. An optional biometric app lock is processed locally on the device only. The app does not use advertising, advertising IDs, analytics or tracking services and does not access location, contacts, camera, microphone or the private photo library. Accounts, managed profiles, groups and memberships are generally stored for as long as they are required for use of the app or until they are deleted. Time-limited status messages are cleaned up after expiry, inactive groups or unused managed profiles may be deleted after 180 days of inactivity and, where offered, data can be viewed, exported or deleted within the app.

2.8 App: Jewelume Coloring Puzzle (iOS)

• Purpose and local game data: Jewelume Coloring Puzzle is a puzzle game for iPhone and no user account is required. Game progress, started levels, settings, daily puzzle progress, earned rewards, crystals and unlocked features are generally stored locally on the device. We operate no own server for this game data. Local processing takes place on the basis of Art. 6(1)(b) GDPR. Locally stored data can be removed by resetting app data or deleting the app.
• Advertising via Google AdMob: The app uses Google AdMob to display advertisements. For users in the EEA and Switzerland, the provider is generally Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The app may show voluntarily started rewarded ads and occasional interstitial ads. An in-game reward is only granted if the respective ad has been watched in full and this is confirmed by the advertising service. The Google Mobile Ads SDK may process in particular IP address and the approximate region derived from it, device, app and advertising identifiers, technical information about device, operating system and app version, interactions with the app and ads, information about displayed advertising and diagnostic, performance and crash data. These data may be used for ad delivery, measuring advertising performance, fraud and abuse prevention, error diagnostics and, depending on consent and device settings, ad personalization. Further information: Google Privacy Policy and Google data use in apps.
• Consent and privacy choices: Where required by law, a privacy choice is obtained via Google User Messaging Platform before ads are loaded. Depending on region, consent and device settings, personalized, non-personalized or limited ads may be served. Even non-personalized or limited ads may process technically required data such as IP address, device information and diagnostic and interaction data. Where consent is required, processing is based on Art. 6(1)(a) GDPR and Section 25(1) TDDDG. Consent can be changed or withdrawn at any time with effect for the future via the “Privacy & Cookie Settings” item in the app. Where processing without consent is permitted and necessary for technical provision, security or fraud prevention, Art. 6(1)(f) GDPR may apply. Users in US states with specific privacy laws can object via the app’s privacy settings to disclosure or “sale or sharing” of personal data and to personalized advertising; if so, restricted data processing is enabled where supported by Google.
• In-app purchases: Optional in-app purchases are handled exclusively through Apple StoreKit and the Apple App Store. We do not receive credit-card or other complete payment data. The app stores locally only the information required for proper provision and restoration of a purchase, such as unlocked features and, where applicable, an Apple transaction identifier. Apple processes purchase, payment, device and account data on its own responsibility.
• Storage period, deletion and further permissions: Local game progress and settings remain on the device until reset in the app, removed through system settings or the app is deleted. For Google’s and Apple’s processing and storage periods, their own privacy policies also apply. Requests relating to data processed directly by Google or Apple may also be addressed to those providers. Jewelume Coloring Puzzle does not require a user account and does not access contacts, camera, microphone or precise location. The provider does not use any own analytics or tracking service and does not transfer game progress to own servers.

This policy also applies to the iOS and iPadOS app Sortello: Category Sort.

2.9 App: Sortello: Category Sort (iOS / iPadOS)

• Purpose, account and local game data: Sortello is a category and sorting puzzle game for iPhone and iPad. No Sortello account is required. The provider operates no own server for game saves or gameplay and uses no own analytics service. The following are generally stored locally: completed and unlocked levels, best move counts, games in progress, completion counts, sorting tokens, Master Stamps earned and spent, daily and repeat rewards, advertising rewards already viewed or credited, discovered collection entries, purchased cosmetic content, selected avatars, frames, backgrounds and other design options, language, music, sound and haptics settings, Sortello Plus status, and verified StoreKit transaction identifiers needed to deliver or restore purchases or prevent duplicate credits. These data generally contain no names, addresses, messages or other personal game content entered by the user. Core functions are based on Art. 6(1)(b) GDPR.
• Optional iCloud synchronisation: The user must enable synchronisation. Compatible progress, especially level status, best scores, sorting tokens, Master Stamps, collection entries, cosmetic unlocks, reward balances and required transaction records, is stored via Apple CloudKit in the private iCloud database of the user's Apple Account and synchronised between the user's own devices. The provider operates no own synchronisation server. Apple independently processes account, device and technical connection data. Disabling synchronisation stops future syncing but does not necessarily delete existing iCloud data. Data may remain after the app is deleted until removed through iCloud management. For access, export or deletion assistance, contact support@dacoder.eu.
• Optional Game Center: Game Center is provided by Apple and is optional. If enabled, Apple processes the Game Center player identity, display name, account and device data and reported achievements. Sortello reports achievement progress calculated from completed levels, Master Stamps and discovered collection entries. Sortello currently has no own multiplayer features, friends lists or own leaderboards. The provider does not store the Game Center player identity on an own server.
• Google AdMob and advertising: Sortello uses Google Mobile Ads SDK and Google User Messaging Platform. It may show voluntarily started rewarded ads and occasional interstitial ads between rounds. Google and participating advertising partners may process IP address and approximate region, device or advertising identifiers, displayed-ad data, product and ad interactions, app launches and video views, crash logs, performance and other diagnostics, and device, operating-system and app information. Purposes may include ad delivery and measurement, analytics, fraud and abuse prevention, diagnostics and app functionality. Depending on region, consent, settings and Google configuration, personalised, non-personalised or limited ads may appear. Even non-personalised or limited ads process technically necessary data. SKAdNetwork may be used for aggregated installation and conversion measurement. Sortello may ask for your optional permission through Apple’s App Tracking Transparency (ATT), using Google UMP. The IDFA advertising identifier and tracking across apps and websites are used for this purpose only after your explicit ATT permission. Without it, ad personalisation is disabled; the game and optional rewarded ads remain available. You can change ATT permission in iOS Settings. Regional privacy choices through Google UMP apply separately. The provider uses no own tracking or analytics service, but AdMob may process data for advertising and measurement.
  Google Privacy Policy · Google data use on partner sites and apps · Google Mobile Ads data disclosure
• Consent and privacy choices: Where required, Google UMP obtains consent or a privacy choice before advertising is requested. The Ad privacy option is available in the app where Google requires it; available choices can be changed and consent withdrawn there with future effect. Core app functionality is based on Art. 6(1)(b) GDPR. Where consent is required, Art. 6(1)(a) GDPR and Section 25(1) TDDDG apply. Technically necessary processing, security or fraud prevention may be based on Art. 6(1)(f) GDPR where permitted. No single legal basis is claimed for all Google processing.
• In-app purchases: Purchases are handled exclusively through Apple StoreKit and the App Store. Sortello offers Sortello Plus as a non-consumable one-time purchase and four consumable sorting-token packages; there are no subscriptions. Apple independently processes Apple Account, payment, transaction, tax and device data. The provider receives no credit-card or complete payment data; the app receives only verified purchase status, product information and required transaction identifiers. Identifiers are stored to deliver products correctly, restore Sortello Plus and prevent multiple credits for consumable packages. Consumed sorting-token packages cannot be restored like a non-consumable purchase.
• Support contact: Support is opened by email only at the user's initiative. The prepared message contains the selected support category, app version and build number, device category, iOS version, current region or locale and any message voluntarily added by the user. It is sent to support@dacoder.eu only after the user sends it in the email app. Support data is stored until the request is handled, subject to statutory retention obligations.
• Permissions and services not used: Sortello has no user account or own gameplay server and does not access contacts, camera, microphone, photo library or precise location. The approximate region that Google may derive from the IP address is separate from precise-location access. The provider operates no own analytics or tracking servers.
• Storage period and deletion: Local game data generally remains until the app or its app data is deleted. Offloading the app alone is not complete data deletion. Private CloudKit data may remain in iCloud after uninstallation. Game Center data and achievements, purchase history and payment data, and AdMob data are governed by Apple's or Google's settings and retention rules. Support emails are deleted after the request is completed unless statutory retention duties apply. The provider promises no specific Apple or Google deletion period.
• Recipients and third-country transfers: Potential recipients or independent controllers are Apple, particularly for App Store, StoreKit, iCloud or CloudKit and Game Center; Google, particularly Google Ireland Limited for AdMob and UMP; and participating Google advertising partners. Depending on the service, Apple or Google may process data outside the EEA under the transfer mechanisms stated by the respective provider.
  Apple Privacy Policy

3. App Stores, TestFlight, Google Play, Apple & Google

Installation, distribution and updates take place through Apple services (App Store/TestFlight). Apple may process personal data on its own responsibility, for example Apple ID, device, payment or usage data. According to Apple, personal data of individuals in the EEA, the United Kingdom and Switzerland is controlled by Apple Distribution International Limited in Ireland; international transfers are governed by Standard Contractual Clauses. More information can be found in Apple’s privacy policy.

Installation, distribution, updates and in-app purchases for Android versions may take place through Google Play. Google may process personal data on its own responsibility, for example Google account, device, payment or usage data. Where you use optional synchronisation via Google Drive in an Android app, that processing takes place through Google services and based on your Google account settings. More information can be found in Google’s privacy policy.

4. Legal bases, recipients and third-country transfers

• Legal bases: Art. 6(1)(a), (b) and (f) GDPR and, where applicable, Art. 9(2)(a) GDPR.
• Recipients: no regular disclosure by the provider; exceptions may include website hosting, Apple and Google for distribution, updates, in-app purchases and cloud-related services such as iCloud or Google Drive, Google Firebase for No-Words and Google AdMob for in-app advertising in Jewelume Coloring Puzzle / Sortello: Category Sort.
• Third-country transfers: generally none by us; where Apple or Google services are used, in particular Google Play, Google Drive, Firebase or AdMob, processing may also take place in third countries in accordance with the safeguards of the respective provider.
• Recipients and third-country transfers: Potential recipients or independent controllers are Apple, particularly for App Store, StoreKit, iCloud or CloudKit and Game Center; Google, particularly Google Ireland Limited for AdMob and UMP; and participating Google advertising partners. Depending on the service, Apple or Google may process data outside the EEA under the transfer mechanisms stated by the respective provider.
  Apple Privacy Policy

5. Your rights

Under Art. 15–21 GDPR, you have the right of access, rectification, erasure, restriction of processing, data portability and objection, as well as the right to lodge a complaint with a data protection supervisory authority. Where processing is based on your consent, you may withdraw that consent at any time with effect for the future.

6. Changes

2026-09-02