The controller responsible for the processing of personal data in connection with the iOS application “Trend or Flop - Guess Up or Down!?” within the meaning of the General Data Protection Regulation (GDPR) is:

This Privacy Policy explains what data may be processed when using the app, for what purposes such processing takes place, which third-party services are used, and what rights users have regarding their personal data.

“Trend or Flop - Guess Up or Down!?” is a quiz and guessing game for iOS.

No registration or user account is required to use the basic features of the app.

We do not operate our own backend or server for storing player profiles or game progress.

The app itself does not request users to provide personal information such as:

• names,
• email addresses,
• telephone numbers,
• postal addresses or other contact details,
• photos or videos,
• voice recordings.

An exception applies to names or nicknames that users voluntarily enter in the local Party mode in order to distinguish between players on the same device. These names are processed only temporarily on the device and are automatically deleted once the app is closed. Further details can be found in Section 3.

The app does not require access to the device’s camera or microphone and does not request access to the device’s precise GPS location.

However, certain technical and personal data may be processed by third-party services integrated into the app, in particular Google AdMob for advertising purposes. Further details are provided below.

Certain information is stored locally on the user's device in order to save game progress, achievements, statistics and individual settings.

This may include, in particular:

• number of games played,
• number of correct answers,
• total number of answers,
• highest score,
• best streak,
• unlocked achievements,
• music on/off setting,
• volume settings,
• sound effects settings,
• haptic feedback settings,
• reduced motion setting,
• selected language.

In the local Party mode, users may also enter freely chosen names or nicknames for the participating players in order to distinguish between them during the current game.

These names are processed only temporarily on the device, are not permanently stored, and are not transmitted to us or to third parties. They are automatically deleted once the app is closed.

This information is stored locally on the device using Apple UserDefaults.

These locally stored game and settings data are not transmitted to our own server. We do not operate our own backend through which we could access these data or associate them with a particular user.

Locally stored app data can generally be removed by deleting or uninstalling the app from the device.

The app may read the language and/or region configured on the user's device in order to automatically select an appropriate default language.

For example, if the device is configured for a German region, the app may automatically use German as its default language. For other regions, English may be selected as the default language.

This process does not require access to GPS data or the user's precise physical location.

The selected language may subsequently be stored locally on the device so that the app can remember the user's language preference.

The free version of “Trend or Flop - Guess Up or Down!?” may display advertising.

We use Google AdMob, provided through the Google Mobile Ads SDK, for this purpose.

The app may display, in particular:

• banner advertisements,
• interstitial or full-screen advertisements.

According to Google, the Google Mobile Ads SDK may process information such as:

• IP address,
• device identifiers,
• the device's advertising identifier (IDFA), where permitted,
• approximate location derived from the IP address,
• crash logs,
• performance data,
• advertising data,
• information about advertisements shown to the user,
• user interactions with the app and advertisements.

Google currently states that its Mobile Ads SDK may collect IP addresses, device IDs, advertising data, user product interactions, performance information and certain crash information. An IP address may also be used to estimate the general location of a device.

Such processing may be carried out for purposes including:

• delivering advertisements,
• selecting suitable advertisements,
• measuring advertising performance,
• limiting how often particular advertisements are displayed,
• fraud and abuse prevention,
• security,
• advertising analytics,
• personalizing advertising where the necessary consent has been obtained.

Further information is available in the Google Privacy Policy.

Where required by applicable law, the user's consent will be requested before certain data processing for advertising purposes takes place.

Users may, in particular, be given the opportunity to decide whether they consent to data processing for personalized advertising.

Where the appropriate consent has been provided, advertisements may be personalized on the basis of permitted information concerning interests or activities.

If the required consent is not provided, non-personalized ads, limited ads or technical ad delivery may be used, depending on the available Google advertising configuration and applicable legal requirements.

Rejecting personalized advertising does not necessarily mean that no technical information is processed at all. Certain information may still be processed where legally permitted and technically necessary, for example for:

• delivering advertisements,
• security,
• fraud prevention,
• frequency capping,
• aggregated reporting or measurement.

Google itself distinguishes between personalized ads, non-personalized ads, limited ads and technical ad delivery.

We use the Google User Messaging Platform (UMP) to manage privacy and advertising consent choices.

UMP may be used to inform users about data processing for advertising purposes and to request their privacy choices and consent where required by applicable law.

This applies in particular to users in the European Economic Area (EEA), the United Kingdom and Switzerland, where applicable privacy and consent requirements must be observed.

Google requires publishers serving ads in these regions to make certain disclosures and obtain consent where legally required, and provides UMP as a consent management solution for this purpose.

Privacy and consent choices made by the user may be stored through the relevant consent mechanisms and made available to participating advertising services where technically and legally necessary.

Where consent has been provided, it may be changed or withdrawn at any time with effect for the future.

Where required by applicable privacy regulations, the app provides users with an option to reopen their privacy and advertising settings.

Users can therefore review and, where applicable, change previously selected privacy choices.

Google's UMP system supports privacy options that allow users to withdraw or modify consent choices.

Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.

Where the Identifier for Advertisers (IDFA) or other information is used for tracking within the meaning of Apple's requirements, Apple's additional privacy mechanisms apply.

Apple provides the App Tracking Transparency (ATT) framework for this purpose.

Where ATT authorization is required, the corresponding iOS system prompt will be displayed to the user.

The user may grant or deny this permission.

Refusing tracking permission does not prevent the basic use of the game.

Tracking permissions can also be managed through the privacy and tracking settings provided by iOS. Where the required permission has not been granted, the IDFA must not be accessed for tracking requiring ATT authorization.

“Trend or Flop - Guess Up or Down!?” offers an optional one-time in-app purchase.

Purchasing the Premium version may unlock additional Premium content or game modes and permanently remove advertising.

The Premium purchase is voluntary. Users are not required to purchase Premium in order to access the basic functionality of the app.

Payments are processed exclusively through Apple's App Store In-App Purchase system.

We do not receive users' complete:

• credit card details,
• bank account information,
• or other complete payment information.

Payment and Apple Account information required to process the transaction is handled by Apple in accordance with Apple's applicable terms and privacy policies. Further information is available in the Apple Privacy Policy.

No separate user account is required to use Trend or Flop.

The app does not provide:

• its own account login,
• public user profiles,
• public chat,
• private messaging between players,
• functionality for uploading personal photos or videos,
• functionality for publicly sharing personal user-generated content with other players.

Users therefore do not need to provide personal contact information in order to use the basic features of the game.

Where several people use a local multiplayer or Party mode, the game is played on the same device and not through our own online multiplayer system.

We do not sell users' personal data.

However, data may be processed or transferred in connection with the third-party services described in this Privacy Policy. This applies in particular to:

Google

in connection with Google AdMob and Google UMP.

Apple

in connection with iOS, the App Store and in-app purchases.

Apart from the services described in this Privacy Policy, we generally do not disclose personal data to third parties unless we are legally required to do so or another lawful basis for the disclosure exists.

Apple also requires developers to account for the data practices of third-party SDKs integrated into their apps.

When services provided by internationally operating companies such as Google and Apple are used, personal data may also be processed outside Germany or the European Economic Area.

Where such international transfers take place, the applicable legal requirements and safeguards for international data transfers apply.

Further information regarding international data transfers and the safeguards used by the respective providers can be found in their privacy policies.

Where the GDPR applies, the processing of personal data may be based on the following legal bases, depending on the particular processing activity:

Additional legal requirements may apply to storing information on a user's device or accessing information already stored on that device. Where consent is legally required for such processing, the relevant processing will only take place after the required consent has been obtained.

Game progress, statistics, achievements and settings stored exclusively by Trend or Flop on the user's device generally remain on that device.

Because these data are not stored on our own servers, we do not have a server-side copy of these locally stored data.

Locally stored app data can generally be removed by deleting or uninstalling the app from the device.

For information processed independently by Google or Apple as part of their respective services, the applicable retention and deletion policies of those providers apply.

Apple requires privacy policies to explain their data retention and deletion practices and how users can withdraw consent or request deletion of their data.

“Trend or Flop - Guess Up or Down!?” is a quiz and guessing game intended for a general audience.

We do not intentionally collect personal information directly from children through user accounts, profiles or communication features.

The app does not provide user accounts, public chat or functionality allowing players to directly exchange personal content with unknown players.

Where parental or guardian consent is legally required for a particular processing activity involving a minor, the applicable legal requirements must be observed.

Parents and guardians are encouraged to use Apple's privacy, advertising, Screen Time and purchase restriction features as appropriate for the age of the child. Additional information for parents and guardians may be provided in our Parents' Guide.

Trend or Flop does not require access to the following for its gameplay:

• camera,
• microphone,
• photo library,
• contacts,
• precise GPS location.

The app therefore does not request these permissions for its normal gameplay functionality.

The device's language or region setting used to select the default app language does not constitute access to the user's precise physical GPS location.

This must be distinguished from technical information that may be processed by integrated third-party services. For example, Google states that the Mobile Ads SDK may process an IP address, which may be used to estimate a device's general location.

Where the GDPR applies and the respective legal requirements are met, data subjects may have, in particular, the following rights:

• Right of access under Article 15 GDPR,
• Right to rectification under Article 16 GDPR,
• Right to erasure under Article 17 GDPR,
• Right to restriction of processing under Article 18 GDPR,
• Right to data portability under Article 20 GDPR,
• Right to object under Article 21 GDPR,
• Right to withdraw consent under Article 7(3) GDPR.

Consent may be withdrawn at any time with effect for the future. Withdrawal does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.

Because game progress and settings are stored locally on the user's device and we do not operate user accounts for the game, we generally cannot associate these local data with a particular individual or remotely delete them.

Under Article 77 GDPR, data subjects have the right to lodge a complaint with a competent data protection supervisory authority if they believe that the processing of their personal data infringes the GDPR.

This right exists without prejudice to any other administrative or judicial remedy.

We design the app according to the principle of data minimization.

In particular, the game itself does not require a dedicated user account and we do not operate our own server for storing users' personal game statistics.

Where third-party services such as Google AdMob, Google UMP or Apple services are used, the technical and organizational security measures of the respective providers also apply.

For data processing carried out by third-party services used in connection with the app, their respective privacy information also applies.

• → Google Privacy Policy
• → Apple Privacy Policy

Google's current disclosure for the iOS Mobile Ads SDK states that the SDK may collect categories including IP address, device ID, advertising data, user interactions, performance data and crash logs.

The services actually implemented in the app and the information provided in App Store Connect should remain consistent with the app's actual SDK configuration.

We reserve the right to update this Privacy Policy if the functionality of the app, third-party services used, technical procedures or applicable legal requirements change.

An update may be necessary, for example, if additional services or features are integrated into the app in the future.

The current version of this Privacy Policy will be made available through the privacy page provided for Trend or Flop.

If you have any questions regarding this Privacy Policy or the processing of personal data, you may contact: