Privacy Policy

01Data controller

The controller of your personal data is Damian Kowalczyk WebSolutions (Polish tax ID/NIP 9462735077), the developer of the app, operating as WebSolutionsLab and based in Poland (“we”, “us”).

For anything related to your personal data, write to contact@websolutionslab.dev. No data protection officer has been appointed, as none is required.

02What this policy covers

This policy covers the 5 Seconds app for iPhone downloaded from the App Store (bundle ID dev.websolutionslab.fiveseconds), in every language it is available in.

It does not cover the websolutionslab.dev website, nor processing that Apple and Google carry out on their own behalf. They have their own privacy policies, linked below.

03What we do not collect

• There are no accounts and no sign-up. We never ask for your name, email address or phone number.
• Player names entered in the play-with-friends mode exist only in the device’s memory for the duration of a game. They are never saved or sent anywhere.
• The app does not use GPS location, contacts, photos, the camera or the microphone.
• We use no analytics tools and run no server of our own. We cannot see how, when or how often you play.
• We do not sell personal data.

04Data stored on your device

So that the game remembers your choices, it stores on your device:

• settings: language, theme, sound and vibration, number of rounds and answer time,
• whether you have Premium (so that it also works offline),
• in the iOS Keychain: the free-game counter and the time at which free games come back.

This information never leaves your device and we have no access to it. Storing it is strictly necessary for the app to work, so it does not require separate consent.

Settings are removed when you delete the app. The iOS Keychain entry may survive deleting and reinstalling the app. This is intentional, so that reinstalling does not reset the free-game limit. The entry holds only a counter and a timestamp and nothing that identifies you.

05Advertising (Google AdMob)

The free version shows ads served by Google AdMob: a banner at the bottom of the screen, and a rewarded video that plays only when you ask for it and unlocks an extra game. The service is provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) and Google LLC (USA).

Once you buy Premium, no ads are shown and the ad module is not started at all.

Before the first ad is requested, users in the European Economic Area, the United Kingdom and Switzerland see Google’s consent form. iOS then asks whether you allow the app to track you (App Tracking Transparency). Only after both steps does the app contact Google.

When showing ads, Google may process:

• your IP address, which may be used to estimate your approximate location (country, region),
• the device advertising identifier (IDFA), only if you allow tracking in the iOS prompt; otherwise only identifiers limited to the app or its developer,
• device information: model, operating system version, language,
• ad data: which ads were shown, tapped or watched to the end,
• technical data about how the ad module performs, such as loading times and crash reports.

Purposes: serving ads and measuring their performance, preventing ad fraud and abuse, and, if you consent, tailoring ads to your interests. Install campaigns may be measured through SKAdNetwork, an Apple mechanism that does not reveal the device identifier.

Legal basis: in the EEA, the UK and Switzerland, your consent (Art. 6(1)(a) GDPR) given in Google’s form. If you do not consent, ads are not personalised or are not shown at all, and the game works exactly the same. Elsewhere, our legitimate interest (Art. 6(1)(f) GDPR) in funding the free version of the app.

For ad personalisation and its own purposes, Google acts as an independent controller. Details: Google Privacy Policy and How Google uses information from sites or apps that use its services.

How to change your choice:

• in the app: Settings → “Privacy settings” (the option appears in countries where the consent form is required),
• in iOS: Settings → Privacy & Security → Tracking,
• entirely: by buying Premium, which turns ads off.

Withdrawing consent does not affect the lawfulness of processing carried out before it was withdrawn.

06Buying Premium (Apple and RevenueCat)

Premium is a one-time purchase in the App Store. Payment is handled entirely by Apple as an independent controller. We never receive your name, email address, Apple ID or card details. Apple’s terms: Apple Privacy.

To check whether you have Premium and to restore the purchase on another device, we use RevenueCat (RevenueCat, Inc., USA), which acts on our behalf as a processor. The app contacts it on launch, even if nothing has been bought. RevenueCat receives:

• a random, anonymous identifier created when the app is first launched (not linked to your identity or your Apple ID),
• the App Store purchase receipt and in-app purchase history,
• device type, operating system version, the date the app was last used and, technically, the IP address of the connection.

Legal basis: performance of a contract, that is delivering and restoring the Premium you bought (Art. 6(1)(b) GDPR). Details: RevenueCat Privacy Policy.

07Recipients and transfers outside the EEA

Data may be received only by the parties described above: Google (ads), RevenueCat (purchase handling) and Apple (payment and app distribution). We disclose it to anyone else only where the law requires it, for example at the request of a competent authority.

Some data is transferred to the USA:

• Google LLC participates in the EU-US Data Privacy Framework, under which the European Commission has recognised an adequate level of protection,
• RevenueCat stores data on Amazon Web Services in the USA. The transfer is based on a data processing agreement incorporating the Standard Contractual Clauses approved by the European Commission,
• Apple uses its own safeguards, described in its privacy policy.

08How long we keep data

• Data on your device: until you delete the app; the iOS Keychain counter until the device is erased or the app overwrites it.
• Google: according to Google’s data retention policy.
• RevenueCat: for as long as you use the app, or sooner if you ask us to delete it (see “Your rights”).
• Email correspondence: for as long as needed to resolve your request, and then until any possible claims become time-barred.

09Your rights

Under the GDPR you have the right to:

• access your data and receive a copy of it,
• rectify your data,
• have your data erased,
• restrict processing,
• data portability,
• object to processing based on legitimate interest,
• withdraw consent at any time (see the advertising section for how).

To exercise these rights, write to contact@websolutionslab.dev. We will reply without undue delay and within one month at the latest.

We do not know who you are, so a request on its own may not be enough for us to find your data (Art. 11 GDPR). If you have Premium, include the order ID from Apple’s confirmation email and we will find and delete the related data in RevenueCat. You can remove the data stored on your device by deleting the app, and you can block the advertising identifier in iOS settings.

You also have the right to lodge a complaint with a supervisory authority. In Poland this is the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warsaw, uodo.gov.pl). You may also complain to the authority in the country where you live or work.

10Children

The app is rated 17+ in the App Store because of its “Adults only” question category (available only with Premium). It is not directed at children, and we do not knowingly collect their data.

If a child has used the app and you believe their data may have reached one of the services described here, write to contact@websolutionslab.dev and we will help remove it. Parents can also turn ad tracking off in Screen Time settings.

11Security and automated decisions

Connections to Google, RevenueCat and Apple are encrypted (HTTPS). The game counter is kept in the encrypted iOS Keychain. We run no database of our own, so there is nothing there to steal.

We make no decisions about you based solely on automated processing, including profiling, that would have legal effects. Google’s ad selection is automated but has no such effects.

12Information for US residents

We do not sell personal data for money. However, sharing data with Google to show personalised ads may count as “selling” or “sharing” under the laws of some states (such as California). You can opt out by declining tracking in the iOS prompt or by turning it off in Settings → Privacy & Security → Tracking.

13Changes to this policy

We update this policy when the app or the law changes. The current version is always at this address, and the date of the last change is shown at the top of the page. We will also mention significant changes in the App Store release notes.

Questions about this policy? Write to contact@websolutionslab.dev or visit the support page.