--- title: "Unisu app privacy policy for iOS and Android" description: "Privacy policy for the Unisu iOS and Android app: local storage, usage analytics, contact requests, data recipients and your personal data rights." lang: "en" canonical: "https://unisu-sudoku.app/en/privacy/" --- Pola Labs # App privacy Privacy policy for the Unisu mobile app for iOS and Android. **Version:** 1.3 **Date:** October 28, 2026 This policy describes personal data processing in **Unisu Sudoku** for iOS and Android. Separate privacy notices apply to the website. ## 1\. Controller **Stubbe + Finke PartG** Masen 52 22419 Hamburg Germany Contacts: Anna Stubbe and Julian Finke. Privacy contact: [hello@pola-studio.de](mailto:hello@pola-studio.de). Website: [pola-studio.de](https://pola-studio.de/). No data protection officer is currently appointed. ## 2\. Privacy information and consent This policy explains the processing of your data. Acknowledging it is not blanket consent. Section 11 describes the current analytics implementation and the separate consent controls that have not yet been implemented. ## 3\. General Information About the App Unisu generally provides puzzles and lessons locally on your device. The version described here has: - no user accounts - no advertising - no enabled in-app purchases - no cloud synchronisation of complete saved games operated by us Complete saved games are not sent to us. This differs from the analytics events in section 11 and the information included when you send an enquiry. ## 4\. Download via App Stores When downloading the app or using the native review dialog, Apple or Google process account, device, download and, where applicable, diagnostic data under their own privacy policies. This processing is separate from our app functions. ## 5\. Local Storage on Your Device The app stores saved games, notes, progress, lesson progress, statistics, Streak, language, display and game preferences, onboarding details and local reminder data on your device. It also stores the analytics identifier described in section 11. Strictly necessary device access for requested game functions falls under section 25(2)(2) TDDDG. Article 6(1)(b) GDPR applies where personal data is necessary to provide the agreed app functions. An analytics identifier is not covered by this exception simply because it is stored locally. Resetting data removes app preferences and local storage. It does not delete information already sent to servers. Operating-system backups may separately retain app data and restore it after reinstallation, depending on device and account settings. Uninstalling therefore does not guarantee deletion of every copy. ## 6\. Local Notifications If you enable daily reminders and grant the operating-system permission, notifications are scheduled on your device. We do not operate a cloud push service or collect a push token for this purpose. You can disable reminders in the app or system settings. This permission is not consent to analytics. ## 7\. Contact Form An app enquiry includes the topic, email address, message and form confirmation. It also includes app version, device model and manufacturer, platform and operating-system version, and settings for visual hints, notes, sound, haptics, daily reminders and difficulty. These details are currently included for every contact topic. The enquiry is sent to our backend over HTTPS, saved in a feedback database and emailed in full to our team. The server adds receipt time and notification status. The database record remains if the internal email fails. Contacting us is optional. The form cannot be sent without an email address, topic, message and the required confirmation. You can email us directly instead. Article 6(1)(b) GDPR applies to contractual matters; otherwise Article 6(1)(f) applies to our interests in handling enquiries and understanding reported problems. ## 8\. Contact by Email For email enquiries, we process the sender address, message and any other information you provide to handle your request. The legal basis is Article 6(1)(b) GDPR for contractual matters, or Article 6(1)(f) for our interest in responding to other enquiries. ## 9\. Hosting and Server Operation The website, contact backend, database and self-operated Umami instance are hosted by **DigitalOcean, LLC, USA**, in our selected server region of **Frankfurt am Main, Germany**. DigitalOcean uses **Cloudflare, Inc., USA**, for content delivery and infrastructure protection. This involves IP addresses, timestamps and technical connection data. Article 6(1)(f) GDPR applies to our interest in secure, reliable operation. Message contents are processed under the legal basis applicable to the enquiry. Selecting Frankfurt does not mean all CDN, support and email processing takes place exclusively in Germany. ## 10\. Server Log Data Server requests may involve IP address, time, requested address, browser and operating-system information, referrer, transferred volume, and status or error data. We use these for delivery, troubleshooting and security under Article 6(1)(f) GDPR. No uniform fixed deletion period for these technical logs has yet been established. ## 11\. Analytics with Self-Hosted Umami The app is configured to use self-operated **Umami** for usage analytics and error reports. Analytics is initialised automatically at startup. A random identifier is stored locally and is intended to be sent when the analytics service is reachable, allowing the same installation to be recognised across launches. It contains no name or email address; associated data is nevertheless **pseudonymous, not automatically anonymous**. The configured data includes: - launches, first launch, onboarding steps, selected goals and visited areas; - puzzle starts, abandonment and completion, mode, difficulty, duration, mistakes, hints, notes, undo use, level and Streak; - setting changes, platform, app version and loading time; - error reports containing error type, shortened error text, a stack excerpt and technical error-location details. Requests also involve IP addresses and connection data. Analysis is intended to improve usability and stability, rather than personalised advertising. Self-hosting or operating without conventional analytics cookies does not automatically make the data anonymous. **Current implementation:** Separate voluntary analytics consent and a dedicated withdrawal control have not yet been implemented. Non-essential analytics access requires consent under section 25(1) TDDDG; consent-based processing of personal analytics data requires Article 6(1)(a) GDPR. General acknowledgement of the privacy policy during onboarding does not replace this consent. Describing the current implementation does not claim that the missing consent has already been obtained. ## 12\. No Advertising, No In-App Purchases, No User Accounts The app version described contains no advertising, no enabled in-app purchases and requires no user account. We do not use the described data for personalised advertising. ## 13\. No Location Data, Camera, or Microphone Access The app does not require camera, microphone or precise-location access. IP addresses involved in server connections may independently allow an approximate regional inference. ## 14\. Retention Period We have not yet established fixed deletion periods or a comprehensive automatic deletion process for technical logs, enquiries and backups. Enquiries are stored in the database and as email copies and are currently managed manually. Retention depends on the need to handle and follow up requests, maintain security, meet applicable retention obligations or pursue legal claims. Data must be deleted once its purpose ends unless another legal basis permits retention. You can contact us about deletion. Deleting data from an active system does not automatically remove existing backup copies. No fixed deletion period has yet been configured for analytics events or error reports either. ## 15\. Legal Bases for Processing Agreed app functions and contractual enquiries rely on Article 6(1)(b) GDPR. Other enquiries and necessary security processing rely on Article 6(1)(f), with the interests explained above. Legally required retention relies on Article 6(1)(c). Analytics requiring consent is subject to the separate requirements in section 11; legitimate interests do not replace necessary device-access consent. ## 16\. Recipients of Personal Data Authorised team members handle enquiries. DigitalOcean and its infrastructure providers process technical data and hosted content. **Brevo** sends complete internal contact notifications. **Google** provides our team’s email mailbox. These services process message contents, email addresses and technical delivery/receipt data. Brevo is used here for sending messages, not to subscribe you to a newsletter. Details: [DigitalOcean DPA](https://www.digitalocean.com/legal/data-processing-agreement), [Brevo terms including its DPA](https://www.brevo.com/legal/termsofuse/), [Google privacy information](https://policies.google.com/privacy). ## 17\. Transfer to Third Countries In addition to our Frankfurt server region, the infrastructure and email services may process data internationally, including in the USA. DigitalOcean’s published DPA provides for the EU-U.S. Data Privacy Framework for covered US transfers and EU standard contractual clauses in the fallback situations specified there. Applicability depends on the recipient, valid certification and contractual coverage. The inclusion of all required processing and transfer terms for every service we use has not yet been fully documented. We therefore do not claim verified safeguards for every international data flow. You can ask our privacy contact for information and, where applicable, copies of the relevant safeguards. ## 18\. Withdrawal of Consent Where processing relies on valid consent, you can withdraw it for the future without affecting earlier lawful processing. The current app has no separate analytics withdrawal control. Questions, objections and deletion requests can be sent to [hello@pola-studio.de](mailto:hello@pola-studio.de). ## 19\. Right to Object under Art. 21 GDPR **Objection under Article 21 GDPR:** Where processing relies on Article 6(1)(f), you can object at any time for reasons arising from your particular situation. Processing may then continue only where overriding compelling grounds or legal claims justify it. ## 20\. Access, Rectification, and Deletion Subject to legal conditions, you can request access to, correction and deletion of your personal data at [hello@pola-studio.de](mailto:hello@pola-studio.de). The usual response period is one month; any legally permitted extension must be explained. We cannot remotely access saved games stored solely on your device. ## 21\. Right to Restriction of Processing You may request restriction of processing under the legal conditions, including where data accuracy is disputed, processing is unlawful or an objection is being assessed. ## 22\. Right to Data Portability Where data is processed automatically on the basis of consent or a contract, the legal conditions may entitle you to data portability in a commonly used, machine-readable format. ## 23\. Right to Lodge a Complaint with a Supervisory Authority You may complain to a data protection authority, particularly where you live, work or believe an infringement occurred. The authority for our registered location is the [Hamburg Commissioner for Data Protection and Freedom of Information](https://datenschutz-hamburg.de/service-information/beschwerde-oder-hinweis-einreichen), Ludwig-Erhard-Str. 22, 20459 Hamburg, Germany. ## 24\. Data Security Our contact forms use HTTPS to send information to the endpoint. This does not automatically make email communication end-to-end encrypted. We do not make solely automated decisions about you with legal or similarly significant effects under Article 22 GDPR. ## 25\. Changes to this Privacy Policy We update these notices when the described processing changes. Any newly required consent must be obtained separately; continued use alone does not constitute consent.