Pocket Ninja AB
Privacy Policy — Inkwell Word Puzzle
Last updated: September 17, 2026
This policy explains what Inkwell Word Puzzle (“Inkwell”) does with data. It covers the iPhone app and this page. It is written in plain language on purpose.
On this page
1. Who we are
Inkwell is made and published by Pocket Ninja AB, a company registered in Sweden.
- Company registration number (organisationsnummer): 559107-4280
- Registered address: Sysslomansgatan 8, 112 41 Stockholm, Sweden
- Email: privacy@pocketninjagames.com
- Data protection officer: none appointed
Pocket Ninja AB is the data controller for the processing described here.
2. The short version
- Inkwell has no account. There is no sign-up and no login, and the game never asks you for a name, an email address or a phone number.
- No camera, microphone, contacts or location. The app never asks for any of them. It writes to your photo library only if you choose to save an image when you share a result.
- Your puzzle play stays private. The words you trace are never sent to anyone.
- You can turn analytics off in the app at any time: Settings → "Share usage data".
- Ads are optional. Plus removes them entirely, and no ad request is made for Plus players.
3. What we collect, why, and where it goes
3.1 Usage analytics — Mixpanel
We use Mixpanel to understand how the game is played, so we can fix what is confusing and build what is used.
| What | Why | Where it goes |
|---|---|---|
| In-game events: a board started, a board cleared, stars earned, a hint used, a purchase started, a purchase completed, an ad shown | Understand how the game is played and where players get stuck | Mixpanel |
| App version, interface language, device model and iOS version | Basic technical context for the numbers above, and comparison across versions and languages | Mixpanel |
| A random identifier generated on your device when the app is installed | Count one installation as one player across sessions | Mixpanel |
| If you sign in to Game Center: your Game Center player identifier, attached to the analytics profile as the user id | Recognise the same player across their devices | Mixpanel |
Events are stored on Mixpanel's EU infrastructure (api-eu.mixpanel.com).
What Mixpanel never receives: your name, the words you trace, any location derived from your IP address, and your advertising identifier.
You can switch this off at any time: Settings → "Share usage data". After that the app sends nothing further, and the profile held for you is deleted at Mixpanel.
3.2 Ads — Google AdMob
If you do not have Plus, Inkwell shows ads served by Google AdMob. Plus players see no ads, and no ad request is made for them.
| What | Why | Where it goes |
|---|---|---|
| Your device's advertising identifier (IDFA) — only if you allow tracking when iOS asks | Personalise and measure ads | |
| Your IP address | Serve and deliver the ad | |
| Device and app information | Serve and measure ads | |
| Which ads were shown and how you interacted with them | Measure ads and pay for the game |
Third parties, including Google, use cookies and device identifiers to serve and measure ads. You can read how Google uses this data at google.com/policies/technologies/partner-sites and manage your ad settings at adssettings.google.com. US users can also opt out at optout.aboutads.info.
Consent (EEA, UK and Switzerland). Google's consent form — its User Messaging Platform, built on the IAB Transparency & Consent Framework — is shown before the first ad. Apple's App Tracking Transparency prompt follows it. If you decline, ads are still shown but they are not personalised. You can change that choice at any time in Settings → "Ad choices".
Tracking. In Apple's sense of the word, Inkwell tracks you only through AdMob, and only if you say yes to the tracking prompt. The prompt reads: “This lets Inkwell show ads that are more relevant to you. Your puzzles and progress are never shared.” You can change your answer at any time in iOS Settings → Privacy & Security → Tracking.
3.3 Purchases — Apple and RevenueCat
Apple is the seller. Payment happens at Apple, and neither the app nor Pocket Ninja ever sees your card details. RevenueCat handles purchases and subscriptions for us.
| What | Why | Where it goes |
|---|---|---|
| Purchase history and receipts from the App Store | Confirm your purchase and unlock what you bought | Apple, and RevenueCat (our purchase provider) |
| An anonymous app user id generated by RevenueCat, not linked to any account of yours | Restore your purchases on the same Apple ID | RevenueCat |
| The country and currency of the purchase | Process the purchase and keep our accounting records | RevenueCat |
| That a purchase was started and that it completed | Understand where purchases succeed or stall | Mixpanel |
Manage or cancel a subscription in iOS Settings → your Apple ID → Subscriptions. Refunds are handled by Apple at reportaproblem.apple.com. Purchases in the App Store are handled by Apple under Apple's own privacy policy.
3.4 Game Center — Apple
Signing in to Game Center is optional and never forced. You can play everything without it.
| What | Why | Where it goes |
|---|---|---|
| Your Game Center player identifier and display name | Identify your leaderboard and achievement entries, and show your name in the game | Apple; the display name is also saved in your own save file on your device |
| Your scores: stars and streak | Game Center leaderboards and achievements | Apple |
| Your Game Center friends | Show how you compare with friends | Apple |
Your Game Center display name is kept in your own save file on your device. It is never sent to Mixpanel. Your Game Center player identifier is a separate value, and it is sent to Mixpanel when you sign in — see section 3.1.
3.5 Saved progress — your device and iCloud
Your progress, your settings and your record of what you have purchased are stored in a save file on your device.
If you are signed in to iCloud, that same file is synced through Apple's iCloud key-value storage so your progress follows you between your own devices. It sits in your own iCloud — Pocket Ninja has no access to it, and it is not sent to any server of ours.
Settings → "Reset progress" erases your progress on the device and the iCloud copy. Deleting the app removes the data held locally.
3.6 Reminders
If you turn reminders on, they are scheduled on your device by iOS. There is no push notification service and no device token, so nothing is pushed to your phone from us and nothing about a reminder leaves your device.
3.7 Looking a word up — Wiktionary
Tapping a word you have found opens that word on Wiktionary in your browser. From that point you are on a Wikimedia site and Wikimedia's own privacy policy applies. We send nothing to Wikimedia about you; we only open the page.
4. What we do NOT collect
- No name, email address, phone number or postal address
- No account, no password, no login of any kind
- No payment card, bank or other financial details
- No location. The app never asks for location permission, and no approximate location is derived from your IP address for our analytics.
- No contacts, no camera and no microphone
- No reading of your photo library — the app only adds an image to it, and only when you ask it to
- No user content: the game has no text field, chat or message of any kind
- No health, biometric or other special-category data
- No browsing history and no search history
- No crash, performance or other diagnostic data
- No words you trace, and no word list or puzzle content, sent off your device
5. Legal bases (EEA and UK)
| Purpose | Legal basis |
|---|---|
| Personalised ads and use of your advertising identifier | Your consent (GDPR Art. 6(1)(a)), collected through Google's consent form and Apple's tracking prompt |
| Product analytics | Our legitimate interest in improving the game (Art. 6(1)(f)), with an opt-out in Settings → "Share usage data" |
| Purchases and restoring them | Performance of a contract (Art. 6(1)(b)) |
| Keeping accounting records of purchases | Legal obligation (Art. 6(1)(c)) |
We do not sell your data. Ad personalisation involves profiling as defined in Article 4(4): it decides which ads you see. It produces no legal effects and nothing similarly significant for you, and we make no automated decisions about you in the sense of Article 22.
6. Who we share data with
We do not sell your data. We share it only with the companies needed to run the game, each of which is contractually required to protect it to a standard equivalent to our own:
| Company | Role |
|---|---|
| Mixpanel, Inc. | Product analytics, stored on EU infrastructure |
| Google Ireland Limited / Google LLC | Ad serving and measurement (AdMob), consent management (UMP) |
| RevenueCat, Inc. | Purchase and subscription handling |
| Apple Distribution International Ltd. / Apple Inc. | App Store payments, Game Center, iCloud, App Tracking Transparency |
We may also disclose data if the law requires it, or to establish or defend legal claims.
7. International transfers
Analytics events are stored on Mixpanel's servers in the European Union. Mixpanel, Inc. is a US company, and Google, RevenueCat and Apple may process data outside the EEA. Where data leaves the EEA, transfers rely on the European Commission's Standard Contractual Clauses and, where the recipient is certified, the EU–US Data Privacy Framework. Email us at privacy@pocketninjagames.com for a copy of the safeguards in place.
8. How long we keep data
| Data | Retention |
|---|---|
| Analytics events in Mixpanel | 2 years, or until you switch "Share usage data" off, whichever is sooner |
| Analytics profile (the identifier and its properties) | Deleted when you switch "Share usage data" off; otherwise kept for as long as our Mixpanel subscription is active |
| Ad identifiers and ad request data | Held by Google under Google's own retention policy |
| Purchase records | For the life of the subscription, then as required by Swedish bookkeeping law (7 years) |
| Progress saved on your device | Until you tap "Reset progress" or delete the app |
| Progress in your iCloud key-value storage | Until you reset progress or remove the app's iCloud data |
Your saved progress may also be included in your normal device backup, under your own Apple ID.
9. Your rights
If you are in the EEA or the UK, you have the right to access your data, to have it corrected or erased, to restrict or object to processing, and to receive it in a portable form. You can withdraw consent at any time — that does not affect anything done before you withdrew it. You also have the right to complain to a supervisory authority. In Sweden that is Integritetsskyddsmyndigheten (IMY), Box 8114, 104 20 Stockholm, imy@imy.se.
A practical note. Because Inkwell has no account, we usually cannot connect a request to a person, and under Article 11 GDPR we may have to tell you we cannot identify you. The app shows no identifier anywhere in its interface, so if you are signed in to Game Center your Game Center player identifier is the only thing that can tie a request to your data. If you write to us, please say that your request is about Inkwell. The controls in the app are the reliable route: turning off "Share usage data" deletes the analytics profile held for you, and "Reset progress" erases your saved game.
Your choices
- Stop analytics and delete your analytics profile: Settings → "Share usage data" → off.
- Change your ad consent (EEA, UK and Switzerland): Settings → "Ad choices".
- Stop personalised ads (iOS): Settings → Privacy & Security → Tracking.
- Delete all your progress: Settings → "Reset progress", which also clears the iCloud copy.
- Delete everything: delete the app, then remove its iCloud data in iOS Settings → your Apple ID → iCloud.
- Ask us something else: email privacy@pocketninjagames.com.
Your US state privacy rights (California, Colorado, Connecticut, Texas, Virginia and others)
We do not sell personal information for money. Letting our ad provider use device identifiers for personalised ads counts as "sharing" for cross-context behavioural advertising under Californian law.
| Category collected | Examples | Source | Purpose | Disclosed to | Sold / shared | Retention |
|---|---|---|---|---|---|---|
| Identifiers | A random installation id, the advertising identifier used by the ad SDK if you allow tracking, RevenueCat's anonymous app user id, Game Center player id | Your device | Analytics, ads, purchases, leaderboards | Mixpanel, Google, RevenueCat, Apple | Ad identifiers: shared | Analytics: events for 2 years; the profile until you switch "Share usage data" off, or while our Mixpanel subscription is active. Ad identifiers: Google’s own retention policy. |
| Internet or network activity | In-game events, ad interactions, app version, language, device model, iOS version | Your device | Analytics, ads | Mixpanel, Google | Ad data: shared | Same as above |
| Commercial information | Your purchase history and receipts, and the country and currency of a purchase | App Store, and the app itself | Provide what you bought, restore purchases, and keep accounting records | Apple, RevenueCat, Mixpanel | No | Purchase records: life of the subscription, then 7 years under Swedish bookkeeping law. The analytics copy: 2 years. |
| Inferences | Which ads may interest you | Ad provider | Ad personalisation | Shared | Google's own retention policy |
We collect no geolocation of any kind — not precise, not coarse. The app never asks for location, and no approximate location is derived from your IP address for our analytics.
We do not collect sensitive personal information as that term is defined in the California Consumer Privacy Act, and we do not collect the equivalent "sensitive data" categories under the Virginia, Colorado, Connecticut, Texas, Oregon, Montana, Minnesota, Maryland or other comparable state laws. We therefore have nothing to limit under the right to limit the use of sensitive personal information, and we ask for no consent to process sensitive data because we process none.
You have the right to know, to delete, to correct, to opt out of sale or sharing, and not to be treated differently for exercising those rights. Residents of Virginia, Colorado, Connecticut, Texas, Oregon, Montana, Minnesota, Maryland and other states with comparable laws have equivalent rights.
To opt out of sharing for targeted advertising: decline in the consent form, or turn tracking off in iOS Settings → Privacy & Security → Tracking. This applies to that device. To make any other request: email privacy@pocketninjagames.com, or use the in-app controls listed under "Your choices" above. We will respond within the time the applicable law allows, which is 45 days in most states, extendable once.
If we refuse your request, you can appeal. Reply to our decision, or send a new email to privacy@pocketninjagames.com with "Appeal" in the subject line, within 60 days of our decision. Include the decision you are appealing and why you disagree. A person who did not make the original decision will review it, and we will write back with the outcome and the reasons for it within 45 days. If we deny the appeal, we will tell you how to complain to your state attorney general, and you may contact them directly.
10. Children
Inkwell is rated 4+ on the App Store: its content is suitable for all ages. It is a game for a general audience rather than one made specifically for children, and it is not published as a "Made for Kids" app. It is not directed at children under 13. We do not ask your age, we do not knowingly collect personal data from children under 13, and we do not knowingly show personalised ads to anyone we know to be a minor. On a child's Apple Account, iOS turns off tracking requests by default.
If you are a parent or guardian and believe your child has used the app, email privacy@pocketninjagames.com and we will delete any data we can identify. We aim to reply within 30 days.
11. About this website
pocketninjagames.com embeds no third-party content and hosts its own fonts. We do not ask you for any personal data, and there is no form to fill in.
The site uses one essential item of browser storage to remember your cookie choice, and optional analytics that stay switched off until you accept them. If you accept, our hosting provider's analytics sets a first-party session cookie that expires after 30 minutes and records page views in aggregate. Nothing is loaded and no cookie is set until you agree. You can change your mind at any time from the "Cookie preferences" link in the footer, and the full detail is in our Cookie Policy.
Our hosting provider processes standard server request data for security and reliability.
12. Changes to this policy
We update this policy when the app changes. The date at the top always shows the current version. If a change materially affects how we handle your data, we will say so on this page and in the app's release notes before it takes effect.
13. Contact
Questions, requests or complaints: privacy@pocketninjagames.com
Pocket Ninja AB, Sysslomansgatan 8, 112 41 Stockholm, Sweden. Registration number 559107-4280.