Privacy Policy — Solitaire – EyeDark Card Game

1. Scope and Applicability

This Privacy Policy explains how the independent developer operating under the name EyeDark ("we," "us," or "our") handles personal data in connection with the mobile game Solitaire – EyeDark Card Game (the "App").

For the purposes of the EU General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR") and the California Consumer Privacy Act as amended by the CPRA ("CCPA"), we process the personal data described below. Our contact details appear in Section 11.

2. Data We Process and Why

We have designed the App to minimise data collection. The table below describes every category of data the App processes, its source, purpose, and the legal basis under the GDPR.

2.1 Local Game Data (stored only on your device)

Game progress, completed deals, scores, move history, selected themes, and hint usage are stored locally on your device. We do not transmit this data to our servers. Because it never leaves your device, we do not "collect" it in the GDPR/CCPA sense.

2.2 Custom Background Images

If you choose to set a personal photo as the game background, the image is read from your photo library and stored locally within the App's sandbox. We never upload, transmit, or have access to your custom background images. The photo picker is used solely to let you select an image for on-device display.

Legal basis (GDPR): Your consent, given when you grant photo library access and select an image. You may withdraw this consent at any time by removing the custom background and revoking photo access in iOS Settings.

2.3 Game Center Data (Apple)

The App integrates Apple's Game Center to display leaderboards and upload scores. When you use this feature, Apple processes your Game Center player ID, nickname, and score under Apple's own privacy policy and terms. We access only the data Apple exposes through the Game Center APIs (player alias and score) for the sole purpose of populating leaderboards within the game. We do not receive your Apple ID, email address, or any other Apple account credentials.

Legal basis (GDPR): Performance of a contract / your request to participate in leaderboards (Art. 6(1)(b)). Apple's processing is governed separately by Apple's privacy policy.

2.4 Analytics Data (Mixpanel)

We use Mixpanel, a third-party product analytics service, to understand how the App is used and to improve gameplay experience. Mixpanel may collect the following categories of data:

Usage Events: Actions you take within the App (e.g., starting a game, using a hint, changing themes, completing a deal).
Device & App Metadata: Device model, operating system version, App version, and a randomly generated user identifier (not your Apple ID).
Coarse Location (derived): Country-level location inferred from network information. Mixpanel does not collect precise GPS location.

Mixpanel does not receive your custom background images, your name, your email address, or your Apple ID. The data is used solely for aggregate analytics and product improvement, not for advertising, data brokerage, or cross-app tracking.

Legal basis (GDPR): Your consent (Art. 6(1)(a)), which you provide when you first launch the App and accept analytics tracking. You may withdraw consent at any time (see Section 6).

Mixpanel acts as our data processor and processes data on our behalf under a Data Processing Agreement. For more information, see Mixpanel's Privacy Notice.

2.5 No Advertising or Cross-App Tracking

The App does not integrate advertising networks, does not display ads, and does not track you across apps or websites. We do not request App Tracking Transparency (ATT) permission because Mixpanel's SDK, as configured in this App, is not used for tracking as defined by Apple. We do not collect the Advertising Identifier (IDFA).

3. How Long We Keep Data

Local game data and custom images: retained on your device until you delete the App or remove the data. We have no server-side copy to delete.
Game Center scores: retained by Apple according to Apple's retention policies.
Mixpanel analytics events: retained for two (2) years from the event date, after which they are automatically deleted, consistent with Mixpanel's default retention policy.
Crash logs (if any): retained for no longer than [90] days from receipt, unless aggregated and anonymised.

4. Sharing and Third Parties

We do not sell or rent personal data. The third parties involved in the App's functionality are:

Apple Inc. — Game Center and App Store distribution. Apple's handling of data is described in Apple's Privacy Policy.
Mixpanel, Inc. — Product analytics. Mixpanel processes usage data on our behalf as a data processor, solely for analytics purposes. Mixpanel does not use the data for its own purposes or combine it with third-party data.

We may also disclose data if required by law, court order, or a competent regulatory authority, or to protect the rights and safety of users or the public.

5. International Transfers

Mixpanel processes data in the United States. Where personal data from the EEA/UK is transferred to Mixpanel, we rely on Mixpanel's Standard Contractual Clauses (SCCs) and its EU Data Processing Addendum to ensure an adequate level of protection. You may request a copy of the relevant safeguards by contacting us.

6. Your Rights Under the GDPR (EU/EEA Users)

If you are located in the European Economic Area, the United Kingdom, or Switzerland, you have the following rights:

Right of access — to obtain confirmation of whether we process your personal data and a copy of it (Art. 15).
Right to rectification — to have inaccurate data corrected (Art. 16).
Right to erasure — to request deletion of your personal data (Art. 17).
Right to restriction — to limit how we use your data (Art. 18).
Right to data portability — to receive data you provided to us in a structured, machine-readable format (Art. 20).
Right to object — to object to processing based on legitimate interests (Art. 21).
Right to withdraw consent — where analytics processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

How to opt out of Mixpanel analytics: You can disable analytics tracking through the App's settings (if available) or by contacting us at hello@imoregame.com. When you opt out, Mixpanel's SDK will stop sending any further data from your device, and any locally queued, unsent events will be deleted.

We will respond to verifiable requests within one month, extendable by two further months where requests are complex. You also have the right to lodge a complaint with your local supervisory authority.

7. Your Rights Under the CCPA/CPRA (California Residents)

California residents have the following rights regarding "personal information":

Right to know — the categories and specific pieces of personal information we have collected, sources, purposes, and categories of third parties with whom it is shared.
Right to delete — to request deletion of personal information we have collected, subject to exceptions.
Right to correct — to request correction of inaccurate personal information.
Right to opt out of sale or sharing — we do not sell or share personal information for cross-context behavioural advertising. No opt-out link is required; however, you may contact us with any question about this status.
Right to limit use of sensitive personal information — we do not collect sensitive personal information as defined by the CPRA.
Right to non-discrimination — we will not deny, charge different prices, or provide a different level of service because you exercised a privacy right.

To exercise these rights, email hello@imoregame.com. You may designate an authorised agent to submit a request on your behalf, subject to verification.

8. Children's Privacy

The App is not directed to children under 13 in the United States (COPPA) or under 16 in the European Union (the default age of digital consent under the GDPR, unless a Member State has set a lower age not below 13). We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, contact us and we will take appropriate steps to delete it.

9. Security

We rely on the iOS sandbox and Apple's platform security to protect locally stored data. Data transmitted to Mixpanel is encrypted in transit using industry-standard protocols. No method of electronic storage is completely secure, but because the App minimises collection and does not transmit gameplay images, the attack surface is limited. You are responsible for maintaining the security of your device and Apple ID.

10. Changes to This Policy

We may update this Privacy Policy to reflect changes in law, Apple requirements, or App functionality. The "Last Updated" date at the top will change. Material changes will be highlighted in the App or on the App Store listing where appropriate. Continued use after the effective date constitutes acceptance of the revised policy.

11. Contact Us

Developer: EyeDark

Privacy Contact: hello@imoregame.com

For GDPR-related inquiries, please include "GDPR Request" in the subject line. For CCPA/CPRA requests, include "California Privacy Request."