Privacy Policy — Word of Lines

Word of Lines is made by Pocket Ninja AB, a company registered in Sweden. “We”, “us” and “our” mean Pocket Ninja AB.

• Organisation number: 559107-4280
• Registered address: Sysslomansgatan 8, 112 41 Stockholm, Sweden
• Email: privacy@pocketninjagames.com

We are the controller of the personal data described here: we decide why and how it is used. We are based in Sweden, so the EU General Data Protection Regulation (GDPR) applies to how we handle your data, wherever you live. Apple and Google decide for themselves how they use some data, and we say so where that applies.

We have not appointed a data protection officer. Please send any privacy question to privacy@pocketninjagames.com.

• No account. No sign-up, no login, no name or email. Apple handles every payment.
• Your progress is yours. It is saved on your device and in your own iCloud account. We cannot read it; our statistics include a few numbers from it.
• Game statistics. Mixpanel shows us how the game is played, using a random identifier. In the EEA, the UK and Switzerland it runs only if you agree. Anyone can turn it off.
• Ads from Google pay for the game. Google gets your advertising identifier only if you allow tracking. We do not sell data for money.
• You are in control. Section 16 lists every switch, including the US opt-out in section 19. Section 18 explains how to get or delete your data.

• Personal data: anything that can be linked to you or your device, even without your name, such as a random identifier or an IP address. US laws call it personal information.
• Controller: the company that decides why and how data is used. Service provider (processor): a company that uses data only on our instructions.
• Legitimate interest: a legal reason to use data without asking first. It is allowed only when our interest is not outweighed by your privacy, and you can object to it.
• EEA: the EU countries plus Iceland, Liechtenstein and Norway.
• IDFA: your device's advertising identifier. Apps get it only if you allow tracking. IDFV: an identifier that works only within apps from one developer.
• Consent screen: Google's privacy form. It follows an advertising-industry standard (the IAB Transparency & Consent Framework) for recording your choices.
• Your Privacy Choices: the row in the game's Settings → Help & legal that opens Google's consent screen again, and the US opt-out.
• Privacy ID: the row in Settings → Help & legal that shows the random identifiers we need to find your data.

Do you have to give us data? No law and no contract requires you to give us personal data, and you never have to tell us who you are. Some features need some data to work:

• Each time you open the game, it asks RevenueCat what you own, and, once you have completed your first level, Google's consent tool checks whether a privacy choice is needed where you are. Both receive basic device details and your IP address.
• Buying or restoring a purchase needs Apple and RevenueCat to process the details in section 9. Without them, you cannot buy or restore.
• Ads, including rewarded videos, need Google to receive the data in section 7. When you are offline there are no ads, and no ad rewards.
• Game Center and iCloud sync need your Apple Account. Without them you can still play, but your progress stays on this device.

You can play every level without game statistics, without allowing tracking, without reminders and without buying anything.

We use Mixpanel (Mixpanel, Inc.) to understand how the game is played. Mixpanel is our service provider: it may only use this data to provide its service to us.

The identifier. When statistics first run, Mixpanel's code in the game creates a random identifier and stores it on your device. Every event carries it. It is not your name, your Apple Account or your advertising identifier, and we do not link it to Game Center or to anything else that says who you are. Turning statistics off keeps it, so your Privacy ID still finds your data. Deleting the game resets it. It still counts as personal data under European law, because it singles out your copy of the game.

Sent with every event:

• the game version, the platform, your device's maker and model (for example “Apple” and “iPhone14,5”), your iOS version, your screen size and resolution, and your device's language;
• whether you were on Wi-Fi or a mobile network when the game started;
• your game at that moment: days since you installed it, number of sessions, levels completed, coin balance, and whether you own Remove Ads or Word of Lines Plus;
• the time of the event, when the session started and the event's place in it, random identifiers for the session and the event, and whether this is a test version of the game.

Events we record:

• opening and leaving the game, how long you played, and how quickly the game started;
• starting, finishing or leaving a level: how long it took, hints and shuffles used, coins earned and spent, and when the game offered you help. We record how many bonus words you found and how long they were, never the words themselves;
• the tutorial, daily puzzles, the daily wheel, streaks, chapters, achievements, reaching the end of the levels available in your version, and tapping Share on a postcard (we do not learn where you shared it);
• ads requested, shown, failed, or watched to the end;
• purchases started, completed or failed, with the product and, in App Stores that use US dollars, the price; Word of Lines Plus being offered to you, starting and ending, and opening its management page;
• your answers to the tracking and notification questions, which reminders the game scheduled, and when you open one;
• your text-size setting and whether Reduce Motion is switched on, so we can check that the game works well with them. We do not record whether you use VoiceOver, and we do not use these settings to draw conclusions about you;
• each time the game asks iOS to show the rating window (we never learn whether you rated the game).

Approximate location. When Mixpanel receives an event, it works out your country, region and city from your IP address, and then discards the IP address. Neither we nor Mixpanel keep your IP address, and the game never asks for your precise location.

How it is sent and stored. Events wait on your device and are sent in small batches over an encrypted connection. Mixpanel stores our data in the European Union (api-eu.mixpanel.com).

Why we do it. To find levels that are too hard or too easy, and to balance coins and hints. To see whether players come back, find slow start-ups and other problems, and understand how ads and purchases perform. We look at trends across many players. We do not use statistics to single you out. We never share them with advertisers or combine them with data from other companies. Where we rely on our legitimate interest, we have weighed it against your privacy and what you can reasonably expect, and we limited the data to what the purpose needs. You can ask us for a summary of that assessment.

Your choice:

• In the EEA, the UK and Switzerland, statistics start only after you agree, so for players in these regions the game records nothing for the first levels. We ask in the consent screen shown after level 3 (or at the first break between levels after it), together with the questions about ads in section 7. If you do not agree, nothing is sent to Mixpanel, and Mixpanel's software stores nothing on your device. You can change your answer at any time in Settings → Help & legal → Your Privacy Choices.
• Everywhere else, statistics are on by default, based on our legitimate interest in improving the game.
• Anyone, anywhere, can turn statistics off in Settings → Help & legal → Share usage data. From then on the game sends nothing to Mixpanel and deletes any events still waiting on your device. Events already sent are deleted after 2 years, or sooner if you ask (section 18).

Word of Lines is free to play, and ads pay for it. The ads come from Google AdMob. We work with Google only. Google's consent screen lists the ad partners Google may work with.

Who decides. Google decides for itself how it uses ad data, under its own privacy policy and its terms with us: it is an independent controller. For players in the EEA and Switzerland, that is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Elsewhere, it is Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Because Google's ad software runs inside our game, we may share responsibility with Google for collecting ad data in the game and passing it to Google. We are responsible for informing you and asking for your consent, and Google is responsible for everything it does with the data after that. You can use your rights with either of us. If you write to us about Google's processing, we will tell you how to reach Google.

When ads start. The game starts Google's ad software only after you have completed your first level. Banners appear only on the route map. Full-screen ads start at level 8 and never interrupt a level. Rewarded videos play only when you choose to watch one.

Checking whether a choice is needed. After you have completed your first level, each time the game starts, Google's consent tool asks Google's servers whether a privacy choice is needed where you are. Google receives your IP address and basic device and app details for this. We do it to meet our legal duty to ask for and remember your consent.

Google's consent screen (EEA, UK and Switzerland). After level 3 (or at the first break between levels after it), the game shows Google's consent screen. It names Google and its ad partners, explains what they want to do, and lets you accept, refuse, or choose purpose by purpose. Until you have answered, the game requests no ads, rewarded videos included. If you refuse, Google may still show limited ads. These are not chosen using personal data about you, and Google may store data on your device for them only to detect fraud. Your answer is stored on your device. You can change it at any time in Settings → Help & legal → Your Privacy Choices.

Apple's tracking question (everywhere). Also after level 3 (or at the first break between levels after it), the game shows a short card that explains why ads matter to a free game. It has one button, Continue, which opens Apple's own question about tracking.

• If you allow tracking, Google may receive your device's advertising identifier (IDFA). Google and its partners can use it, together with information about the ads you see and tap, to personalise ads and to measure them across other companies' apps and websites.
• If you ask the app not to track, neither the game nor Google gets the IDFA. Apple's rules forbid using other identifiers to track you instead, and we do not.
• Your answer does not lock or unlock anything in the game.
• You can change it at any time in iOS Settings → Privacy & Security → Tracking. If you said no, the game will not ask again.

What Google receives when it shows ads, whatever you choose:

• your IP address, from which it estimates your approximate location;
• information about your device and the game;
• device identifiers. One works only within this game or within apps from the same developer (such as Apple's identifier for vendors, IDFV). Others are stored on your device by Google's software and read back, much like cookies on a website. Google uses them, for example, to limit how often you see the same ad, to measure ads and to detect fraud (with limited ads, only to detect fraud). Your advertising identifier (IDFA) is added only if you allow tracking;
• your interactions with ads (shown, tapped, watched);
• crash and performance data from its ad software.

Google uses this to deliver ads, measure them and protect against fraud. Whether it also personalises them depends on your choices above. Learn more in How Google uses information from sites or apps that use its services and in Google's Privacy Policy.

Install measurement. Some ads measure installs through Apple's SKAdNetwork, which reports results in aggregate without identifying you.

If you own Remove Ads or Word of Lines Plus, you will not see banners, full-screen ads or ads when you open the game. Rewarded videos stay available if you want them, so Google's ad software keeps running, and you will still see the consent screen and the tracking question.

US states. Where a US state privacy law lets you opt out of targeted advertising, or of the sale or sharing of your personal information, use Settings → Help & legal → Your Privacy Choices. See section 19.

We never give Google or any other advertiser your game statistics, your purchases or your saved progress.

Like most apps, the game and the software of the companies in this policy store small pieces of information on your device and read them back, the app equivalent of cookies. Swedish and EU law require your consent for this unless it is strictly necessary for something you asked for.

You can buy coins, the Piggy Bank, Remove Ads, and the Word of Lines Plus subscription.

• Apple handles payment. Every purchase goes through the App Store and your Apple Account. Apple processes the payment and handles receipts, taxes and refunds. We never see your card details, your Apple Account, your name or your billing address.
• RevenueCat confirms purchases. We use RevenueCat (RevenueCat, Inc.), our service provider, to check purchases with Apple and tell the game what you own. Each time you open the game, it asks RevenueCat what you own, even if you have never bought anything. RevenueCat gives your copy of the game a random, anonymous purchase identifier. With every request, its software sends that identifier; your device's identifier for vendor (IDFV: a random identifier that Apple gives each app maker on your device, not your advertising identifier); your device model, iOS version, game version, App Store country and preferred languages; and your IP address, as any connection does. When you buy or restore, or the game checks your purchases, RevenueCat also receives the details of your App Store transactions: product, transaction identifier, date, price and currency. It also receives your subscription status, and whether you allowed tracking, which its software reports automatically. We do not send RevenueCat your advertising identifier, your name or your email address.
• Why. To deliver what you paid for, and to tell the game what you own each time you open it. To restore your purchases on a new device, keep Plus active, make sure no purchase is paid out twice, and see our total sales.
• Restoring. Once on each install, the game quietly checks your Apple Account's purchases through RevenueCat, so Plus comes back after a reinstall without you tapping Restore purchases.

Word of Lines Plus is an auto-renewing subscription, monthly or yearly, billed by Apple. We learn its status only through RevenueCat: which plan you have, whether it is active, when the current period ends, whether it will renew, and whether there is a billing problem. That status is kept on each device and is not synced through iCloud. Apple may show its own messages about billing problems or price changes inside the game.

• Manage or cancel: iOS Settings → your name → Subscriptions, or Manage subscription in the game, which opens Apple's subscriptions page.
• Refunds: through Apple, at reportaproblem.apple.com.
• Terms: purchases are covered by Apple's Standard License Agreement.

After you have played a few levels, the game asks whether it may send you reminders: first a short card, then Apple's permission question. If you allow it, the game schedules reminders on your device, at most one a day on each device. They tell you that today's puzzle is ready, that your streak is about to end, that your piggy bank is full, or that your road trip is waiting.

Reminders are created on your device. There is no push server and no push token, and nothing about them is sent to us except the events listed in section 6. A reminder can show your streak length, or the name of your current route, on your lock screen.

You can turn reminders off at any time in iOS Settings → Notifications → Word of Lines. Settings → Notifications in the game takes you there (or asks iOS, if you have not answered yet).

Sharing postcards. Share opens the iOS share sheet with the postcard picture and a short line of text. You choose where it goes, and the game never learns where or whether you shared it. Save Image adds the picture to your Photos: the game can add to your photo library, but it cannot see it.

Rating the game. Now and then the game asks iOS to show Apple's rating window, and iOS decides whether it appears. Ratings and reviews go to Apple under your Apple Account. The game remembers when it last asked, in which version and how many times; this is part of your saved game and its iCloud copy.

Links. Help & support, this policy and the terms open in an in-app Safari window. Websites you open see your IP address and browser details, as any website does, and the game cannot see what you do there. Manage subscription and App Store links open Apple's own pages.

Writing to us. If you email us, we receive your email address, your message and anything you attach. We use your email only to answer you and to fix problems you report.

Crash reports from Apple. If you have turned on Share With App Developers (iOS Settings → Privacy & Security → Analytics & Improvements), Apple shares crash reports and usage statistics with us that do not identify you. Apart from Google's ad software (section 7), the game contains no other crash-reporting tool.

• your name, email address (unless you email us), phone number or postal address;
• your Apple Account details, Game Center identifier or nickname;
• your contacts, your photo library (the game only adds pictures when you ask it to), your camera or your microphone;
• your precise location;
• the words you play, or anything you type;
• your payment card details.

We do not run our own game servers. Data leaves your device only to the companies named in this policy. Our own code and our statistics never use your advertising identifier (IDFA) or your identifier for vendor (IDFV). RevenueCat's software sends your IDFV to RevenueCat with each request (section 9), and Google's ad software may use it as described in section 7. Google receives the IDFA only if you allow tracking.

We do not send your data to any AI service.

How these companies must protect your data. Mixpanel, RevenueCat and our email and hosting providers are our service providers (processors). Our contracts with them (data processing agreements under GDPR Article 28) let them use the data only to provide their service to us. They also require them to keep it secure and confidential, and to help us respect your rights. Google and Apple use the data they receive under their own privacy policies, and Google has agreed in its data protection terms with us to comply with data protection law. We work only with companies whose commitments give your data the same or equal protection as this policy and Apple's App Store rules require.

We may also disclose data when the law requires it, for example to a court or an authority, or to protect our rights or someone's safety. If Pocket Ninja AB or the game is ever sold, the new owner would receive the data and would have to keep protecting it as this policy describes.

Some of the companies above are based in the United States, so data about you may be processed there. This is how it is protected:

• Google. For players in the EEA and Switzerland, ad data goes to Google Ireland Limited, in Ireland. For players in the UK and the rest of the world, it goes to Google LLC, in the United States. Google LLC is certified under the EU–US Data Privacy Framework, its UK Extension and the Swiss–US Data Privacy Framework, and Google's terms with us include Standard Contractual Clauses where they are needed. Google explains its own transfers at policies.google.com/privacy/frameworks.
• Mixpanel, Inc. (United States) is certified under the same three frameworks. Mixpanel stores our data in the European Union (api-eu.mixpanel.com). Its staff and sub-processors may reach it from other countries under the same safeguards.
• RevenueCat, Inc. (United States) is not certified under the Data Privacy Framework. Our data processing agreement with RevenueCat includes the EU Standard Contractual Clauses, the UK International Data Transfer Addendum and the amendments Swiss law requires.
• Apple handles data for its own services under your Apple Account and Apple's privacy policy.

The EU–US Data Privacy Framework is covered by an adequacy decision of the European Commission (July 2023). For the UK, the UK Extension is recognised by UK regulations (October 2023), and for Switzerland, the Swiss Federal Council recognises the Swiss–US framework (September 2024). You can check a company's certification at dataprivacyframework.gov. Write to us for a copy of the Standard Contractual Clauses we rely on.

Settings in the game is the gear in the top-left corner of the route map.

None of these choices locks or unlocks anything in the game. If you refuse ad consent in Europe, fewer ads may be available, so a rewarded video may sometimes fail to load.

Under the GDPR, and the similar UK and Swiss laws, you have the right to:

• access your data and get a copy of it;
• correct it if it is wrong;
• delete it;
• restrict how we use it;
• take it with you in a portable format;
• withdraw your consent at any time, which does not affect what was done before;
• object to how we use it (see below);
• complain to a data protection authority.

Your right to object. Where we rely on our legitimate interest (game statistics outside the EEA, the UK and Switzerland; ads outside those regions, and limited ads everywhere; preventing purchase errors and fraud; answering your emails; this website's server logs), you can object at any time, on grounds relating to your situation. For game statistics, turn off Settings → Help & legal → Share usage data. For personalised ads, ask the app not to track, or use Your Privacy Choices. For limited ads, use the objection options in Google's consent screen. For anything else, email us at privacy@pocketninjagames.com.

Using your rights is free. We confirm that we received your request within 10 business days and answer within one month. If a request is complicated, we may need up to two more months; if so, we will tell you why within the first month. US state laws allow longer, but we keep to these shorter deadlines for everyone.

Complaints. You can complain to a data protection authority. Ours is the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten, IMY), Box 8114, 104 20 Stockholm, Sweden, imy@imy.se, imy.se. You can also complain to the authority in the EU country where you live or work, in the UK to the ICO, or in Switzerland to the FDPIC. We would be glad to hear from you first, so we can try to help.

Automated decisions. We do not make decisions about you based only on automated processing that have legal or similarly significant effects on you. If you allow personalised ads, Google uses automated processing to choose which ads to show; Google's Privacy Policy explains how.

Word of Lines has no accounts, so we cannot tell which data is yours unless you tell us. That is what the Privacy ID is for.

1. In the game, open Settings → Help & legal → Privacy ID and tap Copy. It contains your random statistics identifier and your anonymous purchase identifier.
2. Email it to privacy@pocketninjagames.com and tell us what you would like: a copy, deletion, a correction, or something else.

Copy your Privacy ID before you delete the game, because deleting it gives you a new statistics identifier and a new purchase identifier. If statistics are still on, also turn off Share usage data, or new events will arrive after the deletion.

With your Privacy ID we can:

• export or delete your game statistics at Mixpanel;
• export or delete your purchase record at RevenueCat. This does not cancel a subscription or refund anything, because Apple keeps your purchases. A new, empty record is created the next time you open the game, because the game asks RevenueCat what you own at every start.

We do not ask for more information than we need. The Privacy ID is shown only on your device, so we treat it as proof that the request is yours. For a copy of the specific data we hold, we may also ask you to confirm in writing that the Privacy ID comes from your own device; if you live in the US, we may ask you to sign that statement under penalty of perjury. If we cannot verify a request, we will tell you why. Without a Privacy ID we usually cannot find your data, because nothing we hold links it to you.

Some data you can delete yourself, faster than we could:

• the saved game on your device: delete the game;
• the iCloud copy: iOS Settings → your name → iCloud → Manage Account Storage → Word of Lines;
• Game Center data: through Apple, in iOS Settings → Game Center, or at apple.com/privacy;
• ad data held by Google: Google's Privacy Policy explains its own controls and your rights with Google. Asking the app not to track stops Google from receiving your advertising identifier.

Several US states, including California, Colorado, Connecticut, Texas and Virginia, give their residents extra privacy rights. This section applies where those laws apply to us.

Word of Lines is made for a general audience. It is not directed to children under 13, and it is not in the App Store's Kids category. We do not knowingly collect personal information from children under 13. In the US that includes the random identifiers and the ad data described in this policy.

The game does not ask your age. If your Apple Account is a child account, or says you are under 18, iOS does not let any app ask to track you, so neither the game nor Google receives your advertising identifier.

In the EEA, the UK and Switzerland, children below a certain age cannot agree to online services on their own. That age is 13 in Sweden and the UK, and up to 16 in some other countries. If you are below it, ask a parent or guardian to make the choices in Google's consent screen with you. If no one can help, choose not to consent: the game works just the same.

If you are a parent or guardian and think your child under 13 has played the game, write to privacy@pocketninjagames.com. If you can, include the Privacy ID from your child's device (Settings → Help & legal → Privacy ID). We will delete the game statistics and purchase records linked to it, and tell you how to delete what is stored on the device and in iCloud. Apple's Screen Time also lets you limit apps and purchases.

• Data sent to Mixpanel, RevenueCat and Google travels over encrypted connections.
• Your saved game is kept in the game's own protected storage on your device, and in iCloud under Apple's security.
• Only the people at Pocket Ninja who need it can open our statistics and purchase dashboards.

No system is perfectly secure. If a security incident puts your data at risk, we will act as the law requires, including telling the authorities and, where we can reach you, you.

This policy and our support pages are on our website, pocketninjagames.com. It 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.

When you open a page, our hosting provider receives the technical data your browser sends: IP address, browser type, the page requested and the time. We use it to deliver the pages and protect them against abuse, based on our legitimate interest in running a secure website (GDPR Art. 6(1)(f)). The host keeps it for a short period under their retention policy.

The website does not sell or share personal information. To opt out of sharing in the game, use Your Privacy Choices in the game, as section 19 describes.

We review this policy at least once a year and update it when the game or the law changes. The date at the top shows the latest version. Before an important change takes effect, such as a new kind of data or a new company receiving it, we will say so at the top of this page. We will also say so in the release notes of the game update that brings it. Where the change needs your consent, the game will ask you again.

Version history. October 5, 2026: first version.

Pocket Ninja AB, Sysslomansgatan 8, 112 41 Stockholm, Sweden. Registration number 559107-4280. Email: privacy@pocketninjagames.com.