Privacy Notice

Last updated: 29.9.2026

1. Controller

Responsible for data processing within the meaning of the EU General Data Protection Regulation (GDPR):

CPKI GmbH
Rohrbacher Str. 87
69115 Heidelberg
Germany

Email:

2. Overview

This Privacy Notice applies to the CPKI family of logic games available for mobile devices, including Hashi, Sudoku and other puzzle games published by CPKI GmbH.

The games:

  • store game progress and history locally on your device,
  • display advertisements via Google AdMob,
  • offer optional premium upgrades via in-app purchase,
  • do not require account registration,
  • do not use external analytics tools beyond services necessary for advertising and purchase processing.

3. Data Processed by the Games

3.1 Local Game Data

The games store certain information locally on your device, including:

  • game progress,
  • completed puzzles,
  • game history,
  • settings and preferences,
  • premium entitlement status.

This data is stored solely on your device and is not transmitted to us unless required by platform providers or legal obligations.

Legal basis: Art. 6(1)(b) GDPR (performance of the app functionality).

4. Advertising (Google AdMob)

The free versions of the games display advertisements provided by Google AdMob.

Google may process information such as:

  • device identifiers,
  • IP address,
  • approximate location,
  • advertising identifiers,
  • interaction data related to ads.

Advertising may be personalized depending on your consent settings and your device/platform configuration.

Google acts as an independent controller for certain processing activities.

More information:

Legal basis:

  • Art. 6(1)(a) GDPR (consent), where required,
  • Art. 6(1)(f) GDPR (legitimate interests in app financing through non-personalized advertising), where applicable under local law.

You may manage advertising and consent preferences through:

  • your device privacy settings,
  • platform consent dialogs,
  • your Google account settings.

5. In-App Purchases

The games offer optional premium upgrades through:

  • Apple App Store, and/or
  • Google Play Store.

Payment transactions are processed by the respective platform provider. We do not receive or store your payment card information.

The games use RevenueCat to process and manage purchase information and premium entitlement status. RevenueCat may receive and process limited technical and transaction information necessary to provide these services, such as information relating to the device and the purchase or platform transaction.

We may receive limited transaction information necessary to verify your purchase status.

RevenueCat processes end-user information on behalf of the app developer as a processor where applicable under the GDPR.

More information:

Legal basis: Art. 6(1)(b) GDPR.

Platform privacy policies:

6. No User Accounts

The games do not require user registration and do not maintain user accounts.

7. Children

The games are not specifically directed at children under the age defined by applicable local law for consent to digital services.

If you believe that personal data from a child has been processed unlawfully, please contact us.

8. Data Sharing

We do not sell personal data.

Data may be shared only:

  • with platform providers (Apple, Google),
  • with advertising providers (such as Google AdMob),
  • with service providers necessary for purchase processing and entitlement management (such as RevenueCat),
  • where legally required,
  • where necessary to enforce legal claims or comply with legal obligations.

9. International Data Transfers

Service providers such as Google, Apple or RevenueCat may process data outside the European Economic Area (EEA), including in the United States.

Where required, such transfers are based on adequacy decisions or appropriate safeguards under Arts. 44 et seq. GDPR.

10. Data Retention

Locally stored game data remains on your device until:

  • you delete it,
  • uninstall the game,
  • or clear app storage through your device settings.

Retention periods for platform providers, advertising services and purchase-processing services are governed by their own policies.

11. Your Rights Under GDPR

You may have the following rights under applicable law:

  • right of access,
  • right to rectification,
  • right to erasure,
  • right to restriction of processing,
  • right to data portability,
  • right to object,
  • right to withdraw consent at any time,
  • right to lodge a complaint with a supervisory authority.

Competent supervisory authority in Germany may depend on your federal state.

12. Changes to This Privacy Notice

We may update this Privacy Notice from time to time.

Updated versions will be published within the games or on the relevant app store page.

13. Contact

If you have questions regarding privacy or data protection, please contact:

CPKI GmbH