Privacy Policy — MindSharp Challenges
Effective Date: 2026-07-03
This Privacy Policy applies to the MindSharp Challenges mobile application (the "Application"), developed and operated by Onur Demircan (the "Service Provider"). By using the Application, you agree to the practices described in this policy.
Data Controller Information
Onur Demircan acts as the Data Controller responsible for the processing of your personal data.
For data protection inquiries or to exercise your GDPR rights, please contact the Data Controller using the information above.
Overview
MindSharp Challenges is a skill and puzzle game. No account registration is required — the Application can be used immediately upon download. The Service Provider is committed to minimizing data collection and being transparent about the limited data that is processed.
What Information Does the Application Collect?
1. Analytics Data (Optional — User-Controlled)
The Application integrates Unity Analytics to help the Service Provider understand how players interact with the game (e.g., which games are played most, session lengths, crash reports). This data is used solely to improve the Application's gameplay and stability.
This feature is opt-in. The Application provides an in-game setting that allows you to enable or disable analytics data sharing at any time. When you disable this setting, no analytics data will be sent.
When analytics is enabled, Unity may collect:
- Device type and model
- Operating system version
- Mobile country and language
- Session duration and in-game events (e.g., levels started/completed)
- Application crash and error reports
- A non-personally-identifiable device identifier
This data is aggregated and anonymized. Unity acts as a data processor on behalf of the Service Provider. Please review Unity's Privacy Policy for more information: https://unity.com/legal/privacy-policy
2. Photo Library / Gallery Access (Optional — Feature-Triggered)
Certain purchasable in-game customization items (such as custom background images or custom sliding puzzle images) allow you to select a photo from your device's gallery to personalize the game's visuals.
This access is triggered only when you choose to use such a customization feature. When triggered:
- The Application will request permission to access your device's photo library via the operating system's standard native permission dialog (iOS or Android).
- You may grant or deny this permission at any time. Denying permission will simply prevent the customization feature from working; all other features of the Application remain fully functional.
- The selected image is copied to the Application's local storage on your device for display purposes.
- The image is never uploaded, transmitted, or shared with the Service Provider or any third party. It remains entirely on your device.
- iOS users: The permission prompt will display a reason message explaining why gallery access is needed. You can manage this permission at any time in your device Settings → Privacy → Photos.
- Android users: The Application will request the relevant media access permission. You can manage this in your device Settings → Apps → MindSharp Challenges → Permissions.
3. Game Progress Data and Cloud Save
The Application stores game progress locally on your device, including game preferences, settings (such as your analytics opt-in/opt-out choice), purchased item states, gem balance, and high scores.
To allow your progress to be restored if you reinstall the Application or switch devices, the Application uses platform-provided cloud save services:
- Android: Your game progress is automatically backed up to Google Play Games Services (Saved Games), a service provided by Google. This requires you to be signed in to your Google Play Games account. Google may associate the save data with your Google account identifier.
- iOS: Your game progress is automatically backed up to iCloud Key-Value Storage, a service provided by Apple. This requires iCloud to be enabled on your device and uses your Apple ID.
The data uploaded to these cloud services consists exclusively of your in-game progress (game settings, scores, purchased item states, gem balance). It does not include your name, email address, photos, or any other personal content beyond the game data itself.
The Service Provider does not have direct access to this cloud-stored data. It is stored and managed entirely within your Google or Apple account infrastructure, and is subject to Google's and Apple's respective privacy policies.
If cloud save is unavailable (e.g., you are offline or not signed in to a platform account), the Application continues to function normally and stores data locally on your device only. Local data will be lost if you clear the Application's data or uninstall without an active cloud save.
4. Information the Application Does NOT Collect
- No name or email address (there is no registration or account system within the Application itself)
- No precise or approximate location data
- No contacts, microphone, or camera data
- No payment information (in-app purchases are handled entirely by Google Play Store and, where available, the Apple App Store)
- No photos or personal files beyond what you explicitly select for in-game customization, which remains on your device only
Children's Privacy
MindSharp Challenges is rated 3+ on Google Play (and 4+ on the Apple App Store where available). The Application is designed to be appropriate for all ages, including young children, and the Service Provider takes children's privacy seriously.
COPPA (United States)
The Application is designed to comply with the Children's Online Privacy Protection Act (COPPA). The Service Provider does not knowingly collect personal information from children under 13. Specifically:
- No personal data is required to play the Application.
- Analytics data, when enabled, is anonymized and does not include personal identifiers.
- Gallery access is never used to collect or transmit photos.
- Cloud save functionality relies on the player's Google Play Games or Apple Game Center account. Google Play Games requires users to be at least 13 years old. Apple's Game Center is subject to Apple's Family Sharing and parental controls. The Service Provider does not control account eligibility requirements set by Google or Apple.
Because the Application is general-audience and contains no features that require personal data collection beyond what is managed by Google or Apple's own account systems, parents and guardians are encouraged to use their platform's parental controls (Google Family Link or Apple Screen Time) to manage their child's access to cloud services and analytics. Parents can also disable the in-game analytics setting at any time.
GDPR-K / UK GDPR (European Economic Area & United Kingdom)
The Service Provider takes steps to ensure the Application does not process personal data of children in a manner that requires specific consent under the GDPR or UK GDPR. If a parent or guardian believes their child has somehow provided personal information, please contact the Service Provider at gravityvortexstudios@gmail.com and the information will be deleted promptly.
Legal Basis for Processing (GDPR)
Where the GDPR applies, the Service Provider relies on the following lawful bases:
- Consent: Analytics data collection via Unity Analytics is processed based on your explicit opt-in consent given through the in-game setting. You may withdraw consent at any time by disabling the analytics setting, without affecting any processing that occurred before withdrawal.
- Legitimate Interests: The Service Provider has a legitimate interest in (a) understanding general usage patterns via anonymized analytics to improve the Application, and (b) enabling cloud save functionality so players do not lose their game progress when reinstalling or switching devices. These interests are balanced against your rights and are implemented through Google's and Apple's established, privacy-compliant infrastructure rather than any server operated by the Service Provider.
- Legal Obligation: To comply with applicable laws or government requests.
Third-Party Services
The Application integrates the following third-party services that may process data. The Service Provider does not operate its own servers for data storage.
- Unity Technologies — Unity Analytics: The Application uses Unity Analytics for optional, opt-in gameplay analytics. Unity Technologies acts as a data processor on behalf of the Service Provider. Unity's Privacy Policy: https://unity.com/legal/privacy-policy
- Google LLC — Google Play Games Services: On Android, the Application uses Google Play Games Services (specifically the Saved Games API) to back up and restore your game progress to your Google account. This requires signing in to Google Play Games. Google LLC processes the save data in accordance with its own privacy policy. Google's Privacy Policy: https://policies.google.com/privacy
- Apple Inc. — iCloud Key-Value Storage & Game Center: On iOS, the Application uses iCloud Key-Value Storage to back up and restore your game progress to your Apple account, and Apple Game Center for platform authentication. Apple Inc. processes this data in accordance with its own privacy policy. Apple's Privacy Policy: https://www.apple.com/legal/privacy/
- Google LLC / Apple Inc. — In-App Purchases: In-app purchases are processed entirely by Google Play or, where available, the Apple App Store. The Service Provider does not receive or store any payment information.
- NativeGallery Plugin: Used solely to access device photos when a player uses a customization feature. It does not transmit any data externally — all image handling is local to your device.
International Data Transfers
The Application integrates third-party services that may process data on servers outside the European Economic Area (EEA), including in the United States:
- Unity Technologies (Analytics): May process anonymized analytics data in the United States. Unity employs Standard Contractual Clauses (SCCs) as a GDPR transfer mechanism.
- Google LLC (Play Games Services): May process cloud save data on Google's global infrastructure. Google employs SCCs and other approved GDPR transfer mechanisms.
- Apple Inc. (iCloud, Game Center): May process cloud save data on Apple's global infrastructure. Apple employs SCCs and other approved GDPR transfer mechanisms.
The Service Provider does not independently operate servers or transfer data outside the EEA. All international data transfers occur through the established infrastructure of Google and Apple, which maintain their own GDPR compliance programs.
Does the Application Use AI?
No. The Application does not use Artificial Intelligence or machine learning technologies to process your personal data or to provide features.
Does the Application Collect Location Data?
No. The Application does not collect, request, or use precise or approximate location data from your device.
Data Retention
- Analytics data (via Unity Technologies, when opted in): Retained per Unity's policy, typically up to 24 months, after which it is deleted or anonymized.
- Cloud save data (via Google Play Games Services or iCloud): Retained within your Google or Apple account for as long as you maintain that account or until you delete the saved data through your platform account settings. The Service Provider has no direct control over retention of data held in your Google or Apple account.
- Locally stored preferences and images: Stored on your device until you uninstall the Application or clear app data. If cloud save is active, game progress is preserved in the cloud even after local data is cleared.
- Aggregated/anonymized analytics: May be retained indefinitely as it is no longer personally identifiable.
Your Rights
GDPR Rights (EEA / UK residents)
- Right of Access: Request access to your personal data.
- Right to Rectification: Request correction of inaccurate data.
- Right to Erasure: Request deletion of your personal data.
- Right to Restrict Processing: Request that the Service Provider limits how they use your data.
- Right to Data Portability: Request a copy of your data in a machine-readable format.
- Right to Object: Object to processing based on legitimate interests.
- Right to Withdraw Consent: You can withdraw your analytics consent at any time via the in-game settings, or by contacting the Service Provider.
To exercise any of these rights, contact: gravityvortexstudios@gmail.com
The Service Provider will respond within one month, extendable by up to two months where necessary. If you believe your rights have been violated, you may lodge a complaint with your local Data Protection Authority: https://edpb.europa.eu/about-edpb/members_en
UK residents: Contact the Information Commissioner's Office at https://ico.org.uk
California Privacy Rights (CCPA/CPRA)
California residents have the following rights regarding personal information:
- Right to Know: Request disclosure of categories and specific pieces of personal information collected.
- Right to Delete: Request deletion of personal information.
- Right to Correct: Request correction of inaccurate personal information.
- Right to Opt-Out of Sale/Sharing: The Service Provider does not sell or share personal information for cross-context behavioral advertising.
- Right to Non-Discrimination: You will not be discriminated against for exercising your CCPA/CPRA rights.
To exercise these rights, contact: gravityvortexstudios@gmail.com
Opt-Out Options
- Analytics: Disable analytics data sharing via the in-game settings at any time.
- Gallery Access: Deny or revoke the photo library permission in your device's system settings at any time.
- Cloud Save (Android): You can sign out of Google Play Games on your device to prevent cloud save syncing. Existing cloud save data can be deleted from your Google account at https://myaccount.google.com.
- Cloud Save (iOS): You can disable iCloud for the Application in your device Settings → [Your Name] → iCloud. Existing cloud data can be managed through your iCloud account settings.
- Complete Opt-Out: Uninstall the Application to stop all local data collection. Note that data already stored in your Google or Apple account (cloud saves) and anonymized analytics data already sent to Unity are not automatically deleted upon uninstallation. Cloud save data can be deleted through your respective platform account as described above.
Security
The Service Provider implements reasonable safeguards appropriate for a mobile application. The Service Provider does not operate its own servers or databases. Game progress data stored in the cloud is held within your Google or Apple account, both of which maintain enterprise-grade security infrastructure.
The primary data security considerations are:
- Cloud save data is protected by your Google or Apple account credentials and their respective security measures (two-factor authentication, etc.).
- Locally stored images selected for customization remain on your device under your control.
- Analytics data transmitted to Unity is anonymized before transmission.
No security system is completely impenetrable. In the event of a personal data breach within data that the Service Provider directly controls, the Service Provider will notify the relevant supervisory authority within 72 hours as required by law. Breaches of Google's or Apple's infrastructure are the responsibility of those companies to report under their own legal obligations.
Changes to This Privacy Policy
This Privacy Policy may be updated periodically. The effective date at the top of this document will be updated accordingly. Material changes will be communicated via an updated Application version or within the Application itself. Previous versions are available upon request by contacting gravityvortexstudios@gmail.com.
Contact
For any privacy-related questions or requests: