Privacy Policy
Effective Date: August 30, 2026
This Privacy Policy applies to the mobile game Guess the Word - Emoji Game (collectively, the "Application"), developed and published by Nicolas Vergnaud ("Service Provider", "Data Controller", "we", "us", or "our").
1. Data Controller Information
Name: Nicolas Vergnaud
Location: Paris, France
Email: vergnaud.nicolas.apps@gmail.com
For any data protection inquiries or to exercise your privacy rights, please contact the Data Controller at the email address above.
2. User Registration & Personal Information
No Account Required: The Application does not require user registration or account creation. You can access and play the game directly upon download.
No Direct Collection: The Service Provider does not directly collect, store, or ask for personal details such as your name, email address, physical address, or phone number.
3. In-App Purchases (IAP) & Financial Data
Payment Processing: All In-App Purchases (IAP) made within the Application are processed directly and securely by Apple (App Store / StoreKit) or Google (Google Play Billing).
No Financial Data Handled: The Service Provider does not receive, collect, or store any of your financial data, billing addresses, or credit/debit card numbers.
Local Storage: Purchase entitlements and game progression (e.g., unlocked levels, hints, removal of ads) are managed locally on your device or via your platform's store account.
4. Automatically Collected Data & Third-Party SDKs
The Application integrates third-party software development kits (SDKs) to serve advertisements and optimize gameplay. These third-party services may collect certain device and usage data automatically.
Third-Party Service Providers
ironSource / Unity LevelPlay (Mediation & Ads): ironSource Privacy Policy
Unity Ads: Unity Privacy Policy
Types of Data Collected by Third Parties
Device identifiers (such as IDFA / GAID, Vendor ID, IP address).
Device characteristics (device model, operating system, language settings, screen resolution).
In-game performance and ad interaction data (impressions, clicks, video views).
5. App Tracking Transparency (ATT) & Consent
iOS Tracking: On iOS devices, the Application displays the Apple App Tracking Transparency (ATT) prompt upon launch.
User Choice: If you tap "Ask App not to Track", your Identifier for Advertisers (IDFA) will not be collected for targeted/personalized ads, and only contextual advertisements will be served. You can change your tracking preferences at any time in your device settings (Settings > Privacy & Security > Tracking).
6. Legal Bases for Processing (GDPR)
Under the General Data Protection Regulation (GDPR), the legal bases relied upon include:
Consent: For personalized advertising and tracking via the ATT framework / consent mechanisms.
Legitimate Interests: For fraud prevention, game stability, performance monitoring, and serving contextual ads.
Contract Performance: For delivering game features and digital content purchased through the App Store / Google Play.
7. International Data Transfers
Third-party ad networks and SDK providers may transfer data outside the European Economic Area (EEA). These transfers are governed by appropriate safeguards such as Standard Contractual Clauses (SCCs) approved by the European Commission.
8. Children’s Privacy
The Application is designed for a general audience and family gameplay. The Service Provider does not knowingly collect personally identifiable information from children under 13 years of age (or under 16 where required by local law). If we become aware that personal data from a child has been collected inadvertently without parental consent, we will promptly take steps to delete such data.
9. Data Retention & Deletion
Because the Service Provider does not operate backend servers holding personal accounts, your game progress and local settings remain on your device and can be deleted by uninstalling the Application.
Third-party ad networks retain data according to their individual retention policies (linked in Section 4).
To request assistance regarding data rights, contact: vergnaud.nicolas.apps@gmail.com.
10. Your Privacy Rights (GDPR & CCPA/CPRA)
Depending on your jurisdiction, you have the following rights:
GDPR (EU/EEA & UK): Right of access, rectification, erasure, restriction of processing, data portability, and the right to object or withdraw consent at any time.
CCPA/CPRA (California, US): Right to know what personal information is collected, right to delete, right to correct, and right to opt-out of the sale/sharing of personal information for cross-context behavioral advertising.
To exercise any of these rights, email vergnaud.nicolas.apps@gmail.com.
11. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated effective date.