Developer
Kotoba Ciphers is developed by Pierre Libran, trading as Galerne Studio (sole trader, SIRET: 10699681200017), 23 rue Dumenge, 69004 Lyon, France.
Contact: galernestudio.support@proton.me
Overview
Kotoba Ciphers ("the App") is a word puzzle game. This policy explains what data is collected when you use the App and how it is used.
We do not require account registration, and we do not directly collect any personal information from you. All game progress is stored locally on your device.
Data We Do Not Collect
We do not collect, store, or transmit:
- Names, email addresses, or account credentials
- Location data
- Photos, contacts, or files from your device
- Any personally identifiable information
Advertising & Consent (AdMob)
The App displays ads through Google AdMob (Google LLC, USA). Under the GDPR and ePrivacy Directive, personalized advertising requires your explicit prior consent.
On first launch, users in the EU/EEA and UK are shown a consent prompt via Google's User Messaging Platform (UMP). You can choose to receive personalized or non-personalized ads, or decline entirely. You can update your choice at any time via: Settings → Google → Ads → Manage your Google account.
When you consent to personalized ads, AdMob may collect and use:
- Device identifiers (e.g. Android Advertising ID)
- IP address and approximate location (country/region level)
- Ad interaction data (impressions, clicks)
- Device model, OS version, and language settings
This data is processed by Google under their own privacy policy: policies.google.com/privacy. Transfers to the USA are covered by Standard Contractual Clauses.
Legal basis: consent (GDPR Art. 6.1.a) for personalized ads; legitimate interest (Art. 6.1.f) for non-personalized ads (frequency capping, fraud prevention).
Push Notifications (Firebase)
The App uses Firebase Cloud Messaging (Google LLC, USA) to send optional push notifications — for example, daily puzzle reminders.
To deliver notifications, FCM assigns a device token to your installation. This token is a unique identifier for your device and app install. It is not linked to your name or email address, and is only used to route notifications to your device.
You can disable notifications at any time via your device settings (Settings → Apps → Kotoba Ciphers → Notifications). Disabling notifications removes the FCM token from our systems.
Data is processed by Google under Standard Contractual Clauses: firebase.google.com/support/privacy.
Legal basis: legitimate interest (GDPR Art. 6.1.f) — delivering notifications you have explicitly enabled on your device.
Children's Privacy
Kotoba Ciphers is intended for users aged 13 and older (16 in the EU where consent-based processing applies). The App is not directed at children under these ages. We do not knowingly collect personal data from younger children.
If you believe a child has used the App in violation of this policy, please contact us at galernestudio.support@proton.me so we can take appropriate action.
Data Retention
- Game progress: stored locally on your device only. Deleted when you uninstall the App.
- FCM device token: deleted when you disable notifications or uninstall the App.
- AdMob data: subject to Google's own retention policies — see policies.google.com/privacy.
Your Rights (GDPR)
If you are in the European Union or UK, you have the right to access, correct, delete, or object to the processing of your personal data, and to withdraw your advertising consent at any time.
Since we do not hold personal data directly, requests relating to AdMob or FCM data should be directed to Google. For any other questions, contact us at galernestudio.support@proton.me. We will respond within 30 days.
You may also lodge a complaint with your local data protection authority — in France: the CNIL; in the UK: the ICO.
Changes to This Policy
We may update this Privacy Policy as the App evolves. Updates will be reflected by a new "Last updated" date at the top of this page.
Contact
For any questions about this policy: galernestudio.support@proton.me