This Privacy Policy explains how Rillich GmbH (“we”, “us”, “our”) handles information when you use Panda Memory: Kids Match Game (the “App”) on Android or on iPhone and iPad. Rillich GmbH is the controller responsible for this processing under the EU General Data Protection Regulation (GDPR).
1) Summary
- No account, no names, no ads. The game works offline, and your child’s progress stays on the device.
- Optional usage statistics with Google Firebase Analytics help us find out, for example, which levels are too hard. In the EU, the EEA, the UK and Switzerland they only run after a parent agrees. Everywhere else they are on by default. Parents can switch them off at any time in the parents’ area.
- The optional purchase that unlocks all worlds is handled entirely by Google Play or the Apple App Store. We never see payment details.
2) Information We Process
A) Data stored on the device
The App stores on the device: game progress (solved levels and puzzle pieces), settings, the parents’ choice about usage statistics, and whether the Pro unlock is owned.
B) Region check (on the device only)
To decide whether it has to ask for consent before collecting usage statistics, the App looks at the region set in the system settings, the time zone and, on Android, the country of the SIM card and mobile network. It needs no permission for this. The check happens on the device, and the App does not send these details anywhere.
C) In-app purchase (optional; unlocks all worlds)
The App offers a one-time purchase, Panda Memory Pro, which unlocks all worlds and levels. It is processed by Google Play Billing on Android and by Apple’s App Store on iPhone and iPad, under their own privacy policies. We do not receive your name, payment method or other payment details, and we do not run our own purchase server.
To unlock purchased content and to restore it after a reinstall or on another device, the App asks Google Play or the App Store whether Pro is owned: at start, when the App returns to the foreground, and when you tap “Restore purchase”. Purchases and settings are protected by a parent check (a short math question).
If usage statistics are on, the purchase is also recorded there (see D), including the product, its price and currency.
D) Usage statistics (Google Firebase Analytics)
We use Firebase Analytics, a service of Google, to understand how the App is played and to improve it, for example to find levels that are too hard or too long, to see which worlds are played, and to check that the purchase screen works.
When it runs
- EU, EEA, UK and Switzerland (and whenever the App cannot tell the region): only after a parent taps “Allow” in the dialog addressed to parents that appears when the App is first started. Until then, nothing is collected.
- All other regions: on by default. Parents can switch it off in the parents’ area.
What is collected
- An app instance ID: a random identifier that Firebase creates on the device. It is not linked to a name, an email address or any account, and it is replaced when usage statistics are switched off or the App is reinstalled.
- How the App is used: screens opened; levels started, completed or quit (world, level, number of cards, duration, number of non-matching pairs turned over); worlds completed; the parent check (opened, passed or closed, number of wrong answers); the purchase screen and the purchase steps (viewed, started, completed, pending, cancelled, failed with the store’s error message, result of a restore); the price and currency of a purchase.
- Two settings about progress: whether Pro is unlocked, and how many puzzle pieces have been won.
- Collected by Firebase automatically: first start, sessions, time spent in the App, app updates, removal of the App (Android only), country, language, device category (phone or tablet), operating system and version, and app version. Google uses the IP address to determine the country; according to Google, Google Analytics does not log or store IP addresses.
What is not collected
- No names, email addresses, contacts, photos, messages or precise location.
- No advertising IDs: neither Google’s Advertising ID nor Apple’s IDFA. On iPhone and iPad, the vendor identifier (IDFV) is not collected either.
- No ads, no advertising attribution, no remarketing, and no tracking across other companies’ apps or websites. Consent for ad storage, ad user data and ad personalization is always set to “denied”.
- The data is not used to build profiles of children or for advertising.
Switching it off
Tap the gear button in the menu, answer the parent check, and switch off “Usage statistics”. Collection stops right away, and the analytics data stored on the device, including the app instance ID, is deleted. Switching it off withdraws a consent given earlier; it does not affect processing that took place before.
Recipient and transfer outside the EU
Firebase Analytics is provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, which processes the data on our behalf. The data may be transferred to Google LLC in the USA. Google LLC is certified under the EU–U.S. Data Privacy Framework; Google also uses the EU Standard Contractual Clauses. More information: Firebase privacy and security and the Google Privacy Policy.
Retention
Usage statistics are kept for 14 months and then deleted automatically.
3) Legal Basis
- Usage statistics in the EU, EEA, UK and Switzerland: consent (Art. 6(1)(a) GDPR and § 25(1) of the German Telecommunications Digital Services Data Protection Act, TDDDG). Because the App is meant for children, the consent is given by a parent (Art. 8 GDPR).
- Usage statistics in other regions: our legitimate interest in understanding and improving the App (Art. 6(1)(f) GDPR). Parents can object at any time by switching usage statistics off in the parents’ area.
- Purchases: performance of the purchase contract (Art. 6(1)(b) GDPR).
Users in the USA (COPPA): the app instance ID is a persistent identifier that is used only to support the internal operations of the App, that is, to analyze and improve how it works. It is not used for advertising, to contact anyone, or to build a profile of a child.
4) Sharing of Information
We do not sell personal information, and we do not share it for advertising.
- Google (Firebase Analytics) processes usage statistics on our behalf, as described in section 2 D.
- Google Play and Apple process purchases as independent providers, under their own privacy policies.
5) Children’s Privacy
The App is made for children from 3 years and their families. Children never have to enter personal information. Purchases and the parents’ area are behind a parent check, and in the regions listed above usage statistics only run with a parent’s consent.
If you believe a child has provided personal information to us (for example via email), contact us at info@rillich.com and we will delete it.
6) Data Retention
- Data on the device stays there until you delete the App or its data.
- Usage statistics are deleted automatically after 14 months.
- Purchase records are kept by Google Play or Apple under their own policies.
7) Security
Usage statistics are sent to Google over an encrypted connection. Because the App works without an account and without our own servers, very little data leaves the device.
8) Your Rights & Deletion
Under the GDPR you have the right of access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and to object (Art. 21), and you can withdraw a consent at any time (Art. 7(3)). You can also lodge a complaint with a data protection supervisory authority, in particular in the country where you live or where we are based (Saxony, Germany).
- The usage statistics are tied only to the random app instance ID, so we usually cannot tell which data belongs to you. The quickest way to delete it is to switch usage statistics off in the parents’ area, which deletes the ID on the device.
- You can delete all data stored by the App by uninstalling it, or on Android by clearing the App’s storage in the system settings.
- For questions about your data or about purchases, contact us at info@rillich.com.
9) Changes to This Policy
If we change how the App handles data, we will update this policy before the change takes effect, as well as the Google Play “Data safety” section and the App Store privacy details. The effective date at the top shows the current version.