Privacy Policy

1. Overview

This Privacy Policy describes the practices Gamaitic follows when collecting, using, and disclosing information about people who interact with our Services. It also explains the rights you have over that information and how to exercise them. By using the Services, you agree to the practices described in this Policy. If you do not agree, please do not use the Services.

2. Interpretation and definitions

Capitalized terms used in this Policy have the meanings set out below. The same definitions apply whether the term is used in the singular or the plural.

• CCPA means the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act.
• Company (also “we,” “us,” or “our”) refers to Gamaitic LLC. For the purposes of the GDPR, the Company is the Data Controller.
• Device means any computer, phone, tablet, or other device used to access the Services.
• GDPR means the EU General Data Protection Regulation (Regulation 2016/679) and its United Kingdom equivalent.
• Personal Information (or “Personal Data”) means information that identifies, relates to, describes, or could reasonably be linked to a particular individual.
• Services means our website at gamaitic.com and any application we publish, including Wordnect (the word-association puzzle game published on the Apple App Store).
• Service Provider means a third party that processes information on our behalf in order to operate the Services. For the purposes of the GDPR, Service Providers are Data Processors.
• Usage Data means information collected automatically when you use the Services, such as device model, operating-system version, and crash diagnostics.
• You means the individual using the Services. Under the GDPR you may also be referred to as the Data Subject.

3. Information we collect

3.1 Information you provide directly

• Account information. If a feature in one of our applications requires you to create an account, register, or sign in, we collect the information you provide during that process. This may include your name, email address, username or other profile identifier, telephone number, postal address, date of birth, profile photo, and any other information you choose to share with us at sign-up or while managing your account. In Wordnect specifically, you may set a display name that appears next to your score on the in-app leaderboard.
• Support correspondence. If you write to us, we receive your email address and the contents of your message.
• Optional in-app feedback. If a feature in one of our applications lets you submit feedback, we receive whatever you choose to send.

3.2 Usage Data

The Services automatically collect a limited amount of diagnostic and usage information:

• Crash diagnostics. When an application encounters an error, we may receive an automatically generated report describing the device model, the operating-system version, and the technical context of the failure. Crash reports do not include the contents of your files.
• Aggregate usage signals. We measure non-identifying signals about which screens are opened and which features are used, so we know what to improve. These signals do not include the content you create or view.
• Server logs. The provider that hosts our website automatically records standard request logs (such as IP address, time of request, the URL requested, and user-agent string) for security and abuse-prevention purposes. These logs are deleted on a rolling basis.

3.3 Subscription and purchase information

If you purchase, restore, or manage a paid subscription or in-app purchase within one of our applications, the transaction itself is processed by the platform store you bought from (your operating system’s app store), under that store’s own privacy policy. We use third-party subscription-management Service Providers to validate the resulting receipt and to keep your entitlements consistent across your devices. In Wordnect, this provider is RevenueCat, Inc. In the course of providing those services, such providers may receive information such as the transaction receipt issued by the platform store, an anonymous device-level identifier supplied by your operating system (the App Account Token), and your operating-system version and country code. These providers are contractually limited to using such information for the purposes described in this Policy.

3.4 Advertising

Some of our applications, including Wordnect, display advertisements supplied by Google’s AdMob platform. AdMob may collect or access information for the purposes of measuring ad performance, fraud prevention, and (subject to your consent) personalized advertising. The information AdMob may receive includes:

• Apple’s Identifier for Advertisers (IDFA), but only if you grant permission via the App Tracking Transparency prompt. If you decline, AdMob receives a zeroed-out identifier and serves non-personalized ads.
• The technical attributes of your device (model, OS version, language, country, coarse network information).
• An anonymous, time-limited advertising click/impression identifier.

You can change your AdMob consent at any time from Settings → About → Privacy Settings inside the app (where required by law) and you can revoke the IDFA permission from iOS Settings → Privacy & Security → Tracking. AdMob processes this information under Google’s own privacy policy at https://policies.google.com/privacy.

3.5 Cloud-synced game data

Some of our applications, including Wordnect, use Apple’s iCloud service (specifically the CloudKit public database) to synchronize a small amount of gameplay data across your devices and to power features such as leaderboards. The data we store in CloudKit on your behalf may include:

• An anonymous player identifier randomly generated on first launch.
• Your chosen display name (if you set one).
• Your weekly and lifetime leaderboard scores and the related metadata (difficulty, mode, level, week ID).

This data is stored under your iCloud account and is governed by Apple’s privacy practices in addition to ours. We do not see — and Apple does not share with us — your real Apple ID or email address. You can delete your leaderboard entry at any time by emailing support@gamaitic.com.

3.6 On-device sensor and media access

Some features in our applications make use of the device’s camera, microphone, or motion sensors. When such a feature is in use:

• The relevant sensor is activated only for the duration of that feature, and your device shows the system indicator that confirms it.
• Captured photos, audio, or motion readings are generally processed on your device, except where transmission is required to deliver the requested feature or as otherwise described in this Policy.
• Such information is generally retained only for as long as the feature requires it; longer retention, if any, is described in Section 6 (Data retention).
• You can withdraw any of these device permissions at any time in your device’s privacy settings. The corresponding feature may stop working, but the rest of the application continues to function.

Wordnect does not currently use the camera, microphone, or motion sensors.

4. How we use information

We may use the categories of information described above for purposes including, but not limited to:

• Providing, maintaining, and operating the Services;
• Diagnosing and resolving crashes, performance regressions, and other technical problems;
• Validating paid subscriptions and in-app purchases, and keeping entitlements consistent across your devices;
• Powering social and competitive features such as in-app leaderboards;
• Serving advertising and (with your consent) personalizing the ads you see;
• Responding to support, privacy, and security inquiries;
• Personalizing and improving your experience with the Services;
• Communicating updates, announcements, or other information related to the Services;
• Detecting, preventing, and addressing fraud, abuse, and security incidents;
• Conducting research, analytics, and product development; and
• Complying with legal obligations and establishing, exercising, or defending legal claims.

5. How we share information

We share information only in the limited circumstances described below.

5.1 Service Providers

We engage third parties to operate the Services on our behalf. These Service Providers are bound by contract to process the information they receive only for the purposes for which we engage them and consistent with this Policy. Categories of Service Provider we use include, without limitation:

• Hosting and infrastructure providers — serving our website and storing operational data.
• Subscription and in-app-purchase management — RevenueCat, Inc. validates Apple App Store receipts and synchronizes purchase entitlements across your devices. RevenueCat’s privacy policy is at https://www.revenuecat.com/privacy.
• Cloud sync and leaderboards — Apple Inc.’s iCloud / CloudKit service stores your anonymous player identifier, display name, and leaderboard scores. Apple’s privacy policy is at https://www.apple.com/legal/privacy.
• Advertising — Google LLC’s AdMob platform serves banner and rewarded-video advertisements in our applications and, where required by law, presents a consent form via Google’s User Messaging Platform (UMP). AdMob and Google’s privacy policy is at https://policies.google.com/privacy.
• Email and communications services — receiving, storing, and delivering messages to and from you.
• Crash, analytics, and product-development services — receiving the diagnostic and usage data described in Section 3.2.
• Other service providers — including, where applicable, payment processors, advertising and marketing partners, and consultants who support our business operations.

5.2 Legal requirements

We may disclose information when we believe in good faith that doing so is necessary to:

• Comply with applicable law, a subpoena, a court order, or a valid request from a public authority;
• Protect the rights, safety, or property of Gamaitic, our users, or the public; or
• Detect, prevent, or address fraud, security risks, or technical problems.

5.3 Business transfers

If Gamaitic is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of its assets, the information described in this Policy may be transferred as part of that transaction. We will provide notice of any such change through the Services before the information becomes subject to a different privacy policy.

5.4 With your consent

We may share information for any other purpose only with your specific, informed consent — for example, your consent for personalized advertising via the in-app AdMob/UMP consent form.

6. Data retention

We retain information only for as long as it serves the purpose for which it was collected:

• Crash diagnostics and aggregate usage signals are retained in aggregate form and aged out on a rolling basis.
• Subscription and in-app-purchase receipts handled by our subscription-management Service Providers are retained for the duration of the entitlement and for any further period required by tax or accounting law.
• Leaderboard scores stored in CloudKit persist for the lifetime of the app’s seasonal leaderboard cycle (weekly and lifetime), unless you ask us to delete your entry.
• Advertising identifiers and ad-event logs handled by Google AdMob are retained according to Google’s data-retention policies.
• Photos, audio, and motion-sensor readings captured for an in-app feature are generally retained only for as long as the feature requires.
• Support correspondence is retained for as long as we reasonably need it to handle your request and to maintain a record of past communications. You may ask us to delete your support history at any time.
• Server logs from our website host are deleted on a rolling basis.

7. International transfers

Gamaitic LLC is the Data Controller of the Personal Information described in this Policy. We are organized under the laws of the State of Wyoming, United States, and we and our Service Providers operate primarily in the United States. If you access the Services from outside the United States, the limited information described in this Policy may be processed in the United States, where data-protection laws may differ from those in your jurisdiction. By using the Services you consent to that processing.

Where required by applicable law — for example, for transfers from the European Economic Area, the United Kingdom, or Switzerland — we rely on lawful transfer mechanisms such as the European Commission’s Standard Contractual Clauses to safeguard your information.

8. Security

We use industry-standard administrative, technical, and physical safeguards to protect Personal Information, including encryption in transit (HTTPS/TLS) and access controls. No system can be guaranteed completely secure; if we become aware of a security incident affecting your information, we will notify you as required by applicable law.

9. Your rights

Depending on where you live, you may have the following rights with respect to your Personal Information:

• The right to know what categories of Personal Information we hold and how we process them;
• The right to access a copy of that Personal Information;
• The right to request that we correct inaccurate information;
• The right to request that we delete your Personal Information, subject to applicable legal exceptions;
• The right to request portability of your information in a structured, machine-readable format;
• The right to object to or restrict certain processing;
• The right to withdraw any consent you previously gave us, including any consent given via the in-app AdMob/UMP consent form;
• The right to lodge a complaint with your local data-protection authority.

To exercise any of these rights, email support@gamaitic.com with the subject line “Privacy.” We may need to verify your identity before fulfilling a request, and we will respond within the timeframe required by applicable law.

10. California privacy rights (CCPA / CPRA)

This section provides additional disclosures required by the California Consumer Privacy Act, as amended by the California Privacy Rights Act. It applies to natural persons who are California residents.

10.1 Categories of Personal Information collected

In the previous twelve months, we may have collected the following statutory categories of Personal Information from California residents, in each case as described elsewhere in this Policy:

• Identifiers — email addresses you choose to share with us in correspondence, IP addresses recorded in standard server logs, an anonymous player identifier generated by Wordnect, the App Account Token issued by Apple for purchase validation, and (with your express ATT permission) Apple’s Identifier for Advertisers (IDFA).
• Internet or other electronic activity — non-identifying usage signals, crash diagnostics, and AdMob ad-event signals generated by your use of the Services.
• Commercial information — records of paid subscriptions and in-app coin purchases.

We do not collect any of the following statutory categories from California residents: protected classification characteristics, biometric information, geolocation data, sensory data transmitted off the device, professional or employment information, education information, or inferences drawn from any of the above.

10.2 Sale or sharing

We do not currently “sell” Personal Information for monetary consideration. We may “share” certain identifiers (specifically, your IDFA when you grant ATT permission) with Google AdMob for the purpose of cross-context behavioral advertising, as those terms are defined in the CCPA. You may opt out at any time through Settings → About → Privacy Settings inside the app, by declining the App Tracking Transparency prompt, or by revoking tracking permission in iOS Settings → Privacy & Security → Tracking.

10.3 California rights

If you are a California resident you have the right to:

• Know the categories and specific pieces of Personal Information we have collected, the categories of sources, and the purposes for which we use the information;
• Request access to a copy of the Personal Information we hold about you;
• Request correction of inaccurate Personal Information;
• Request deletion of Personal Information, subject to legal exceptions;
• Opt out of any future sale or sharing of Personal Information;
• Limit our use of sensitive Personal Information; and
• Not be discriminated against for exercising any of these rights.

To exercise any of these rights, email support@gamaitic.com with the subject line “California Privacy.” We verify identity by matching the request against information we already hold (for example, an email address used for previous correspondence), and we respond within forty-five (45) days, with a possible extension as permitted by law.

10.4 Shine the Light

California Civil Code §1798.83 (the “Shine the Light” law) gives California residents the right to request information about the disclosure of certain Personal Information to third parties for those third parties’ direct-marketing purposes. We do not disclose Personal Information for third-party marketing.

11. Children’s privacy

The Services are not directed to children under 13, and we do not knowingly collect Personal Information from children under 13. If a parent or legal guardian believes that a child under 13 has provided us with Personal Information, please email support@gamaitic.com with the subject line “COPPA,” and we will promptly delete the information.

12. Do Not Track

Some browsers offer a “Do Not Track” (DNT) signal. Because there is no consensus on how to interpret DNT signals, our Services do not currently respond to them. We instead apply the data-minimizing practices described throughout this Policy by default, for every user.

13. Third-party links

Our Services may include links to third-party websites or services that we do not control. We are not responsible for their content or privacy practices. Please review their own privacy notices before providing them with information.

14. Changes to this Policy

We may update this Privacy Policy from time to time. When we do, we will revise the “Last updated” date at the top of this page. If the changes are material, we will provide additional notice through the Services. Your continued use of the Services after the changes take effect constitutes acceptance of the updated Policy.

15. Contact us