Privacy policy

Puzzly Privacy Policy

Effective date: August 30, 2026

This Privacy Policy explains how Waraira Tek LLC (“Puzzly,” “we,” “us,” or “our”) handles information when you use the Puzzly mobile application (the “App”).

1. Who is responsible for your information

The data controller responsible for the processing described in this policy is:

Waraira Tek LLC

[email protected]

2. Information handled by the App

Puzzly does not require a Puzzly account. The information handled depends on the features you use.

Information stored locally on your device

The App stores the following in local device storage:

• puzzle results, including the game, date, completion time, mistakes, hints, and, where relevant, move count;
• current game-session start times;
• streaks and statistics derived from your results;
• whether onboarding was completed, onboarding interactions, and your selected puzzle preference; and
• App settings and technical identifiers used by integrated services.

Your puzzle history, onboarding records, and preferences are used to provide the App’s functionality and are not transmitted to Puzzly’s servers by the Puzzly code. They may nevertheless be included in device backups or handled by Apple according to your device and iCloud settings. Deleting the App generally deletes this local App data, although identifiers stored in the device Keychain by integrated services may persist after reinstallation.

Game Center information

If you choose to connect Apple Game Center, the App:

• reads your Game Center authentication state and display name;
• submits the elapsed completion time for an eligible current-day puzzle to its Game Center leaderboard; and
• displays Game Center leaderboard information through Apple’s interface.

Apple operates Game Center and processes Game Center account, player, score, and service data under its own privacy terms. Puzzly does not copy your Game Center profile into a Puzzly user-account database.

Purchase and subscription information

If purchases are enabled, Apple processes payments through your Apple Account. We do not receive your complete payment-card information.

We use RevenueCat to manage purchase entitlements. RevenueCat may process:

• an automatically generated anonymous App user identifier;
• purchase history, product and entitlement status, transaction and receipt information;
• App version, device type, operating system, locale, currency, IP address, and last-use time; and
• Apple Ads attribution information made available through Apple’s privacy-preserving AdServices framework.

We use this information to offer products, validate and restore purchases, determine premium access, prevent fraud, support customers, and understand purchase attribution and performance.

Advertising and App interaction information

Free users may see advertisements delivered through GrowthCat. GrowthCat creates random installation or session identifiers and may process:

• advertisement impressions, views, video progress, dismissals, and clicks;
• campaign, creative, placement, format, and event identifiers;
• App version, operating-system version, device family, locale, and country or region derived from device settings;
• technical request information such as IP address that is ordinarily visible to an internet service; and
• an anonymous installation identifier stored in local storage or the device Keychain.

This information is used to deliver and measure advertisements, limit or coordinate ad delivery, troubleshoot the service, prevent duplicate events and abuse, and produce analytics. GrowthCat’s current SDK privacy manifest states that it does not use this data to track you across apps or websites owned by other companies. Puzzly does not request access to Apple’s advertising identifier (IDFA).

Feedback and support information

If you choose to use the in-App feedback feature, we process the information you submit, which may include:

• feedback category, title, details, comments, and votes;
• an email address, if you choose to provide one;
• whether the submission came from a free or Pro user; and
• App version, build number, platform, operating-system version, device model, locale, and a random anonymous feedback identifier.

We use this information to respond to questions, investigate bugs, evaluate ideas, communicate about your request, and improve the App. Ideas may be shown on a public feedback board. Bug reports, general feedback, and questions are intended to remain private. Do not submit sensitive information or personal information about another person.

Information you choose to share

The App can generate a result summary for sharing through Apple’s share sheet. The destination and recipients are chosen by you. Puzzly does not receive the shared content merely because you use the share sheet; the selected destination handles it under its own privacy practices.

3. Summary of purposes and legal bases

Where laws such as the European Union or United Kingdom General Data Protection Regulation apply, we rely on the following legal bases:

Where we rely on legitimate interests, we balance those interests against your rights and reasonable expectations. Where processing is based on consent, you may withdraw consent at any time without affecting earlier lawful processing.

4. When information is shared

We do not sell your personal information. We share information only as needed with:

• Apple, for App Store distribution, payments, subscriptions, device services, and optional Game Center features;
• RevenueCat, Inc., for purchase and entitlement management and purchase attribution;
• GrowthCat, for advertisement delivery and measurement and optional feedback services;
• infrastructure, hosting, security, and professional-service providers acting for us under appropriate obligations;
• authorities or other parties when reasonably necessary to comply with law, protect rights and safety, investigate fraud or abuse, or establish and defend legal claims; and
• a buyer, successor, or adviser involved in a merger, financing, reorganization, sale, or similar business transaction, subject to appropriate safeguards.

Third-party policies include Apple’s Privacy Policy and RevenueCat’s Privacy Policy.

5. International data transfers

We and our providers may process information in countries other than the one where you live, including Spain and the United States. Those countries may have different data-protection laws. Where required, we use recognized safeguards for international transfers, such as adequacy decisions, contractual protections, or another lawful transfer mechanism.

6. Retention

We retain personal information only for as long as reasonably necessary for the purposes described above, including to provide services, maintain purchase records, respond to feedback, prevent abuse, and meet legal, accounting, tax, and dispute-resolution obligations.

In particular:

• local puzzle and preference data remains on your device until you clear it, reset the relevant setting, or delete the App;
• Game Center data is retained by Apple according to Apple’s policies and your Apple Account settings;
• purchase and entitlement records are retained for the life of the customer relationship and as required for financial, fraud-prevention, legal, and support purposes;
• advertising events and anonymous identifiers are retained for as long as needed for delivery, measurement, security, and reporting, then deleted or aggregated; and
• feedback, associated technical metadata, and optional contact details are retained while the request or public idea remains relevant and as needed to maintain a support and product-development record.

Some information may remain longer in backups or where retention is required by law. We may retain aggregated or de-identified information that can no longer reasonably identify you.

7. Your privacy rights and choices

Depending on where you live, you may have the right to:

• request access to or a copy of your personal information;
• request correction or deletion;
• object to or restrict certain processing;
• withdraw consent;
• request portability of information you provided;
• appeal a refusal of a request where local law provides that right; and
• complain to your local data-protection authority.

You may manage subscriptions through your Apple Account, choose not to connect Game Center, avoid submitting feedback, and stop advertising collection by purchasing an eligible ad-free entitlement or stopping use of the App. You can remove most locally stored Puzzly data by deleting the App. Because some anonymous identifiers may remain in the Keychain or on provider systems, contact us if you want us to coordinate a deletion request.

To exercise a privacy right, email [email protected] and state that your request concerns Puzzly privacy. We may need information sufficient to locate the relevant record and verify that you are entitled to make the request. Because Puzzly has no account, we may not be able to associate an anonymous record with you unless you provide the applicable identifier or other identifying details.

We will not discriminate against you for exercising a privacy right. These rights are subject to exceptions under applicable law.

8. Children’s privacy

Puzzly is not designed to solicit personal information from children. If you are under the age at which you may consent to data processing in your country, use the App only with permission and supervision from a parent or legal guardian, and do not provide an email address or personal details through feedback.

If you believe a child provided personal information without appropriate authorization, contact us so we can investigate and delete it where required.

9. Security

We use reasonable administrative, technical, and organizational measures designed to protect information. No electronic transmission or storage method is completely secure, so we cannot guarantee absolute security.

10. No cross-context behavioral advertising sale

We do not sell personal information for money. Based on the App’s current configuration, we do not use IDFA or GrowthCat data to track users across third-party apps or websites for targeted advertising. If our practices change, we will update this policy and provide any notice or choice required by law.

11. Changes to this policy

We may update this Privacy Policy to reflect changes to the App, our providers, our practices, or applicable law. We will post the updated policy, revise the effective date, and provide additional notice where required. We encourage you to review the policy periodically.

12. Contact us

For privacy questions or requests, contact:

Waraira Tek LLC

[email protected]