Version 1.0 · Effective date: 24 July 2026
Table of contents
- Data controller
- Scope — the short version
- What data we process and why
- Payments and subscriptions (Apple)
- Support contact and bug reports
- Third-party services and SDKs
- Sharing of data
- Retention periods
- Your rights (GDPR)
- Withdrawing consent
- Deleting data and accounts
- Age of users
- Changes to this policy
1. Data controller
The controller of personal data is Jakub Jędrzejczak, a sole trader operating under the business name Jakub Jędrzejczak Trenpreneur, entered in the Polish Central Register and Information on Economic Activity (CEIDG):
- Address: ul. Słoneczna 16, 05-822 Milanówek, Poland
- Tax ID (NIP): 5291862937
- Business ID (REGON): 542257682
- Contact e-mail for data matters: oyey.games@gmail.com
The controller is not required to appoint a Data Protection Officer (DPO) and has not appointed one. For all matters concerning personal data, please write to the e-mail address above.
Processing is governed by the GDPR — Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016.
2. Scope — the short version
- The app requires no account and no sign-in.
- The app does not collect your personal data and does not profile users. It does not use location, the camera, the microphone, contacts, health data or advertising.
- Once downloaded, the games run offline; content and settings (e.g. player names, spice level, choice of forfeits) are saved locally on your device and are never sent to us.
- Payments and subscriptions are handled by Apple within the App Store. It is Apple, not us, that processes transaction and payment data (see section 4).
- We process personal data only when you contact us yourself (e.g. a support e-mail or a bug report) — in that case we process the data you send us (see section 5).
3. What data we process and why
Simply using the app (playing) means that we process no personal data at all on our servers. The table below covers the only situations in which data is processed — and shows who the controller is.
| Situation | Data | Purpose | Legal basis | Who processes it |
|---|---|---|---|---|
| Playing the game | No personal data. Settings and player names are stored locally on the device. | Running the app offline | Not applicable (the data never leaves the device) | Your device only |
| Purchase / subscription | Transaction and payment data | Completing the purchase, managing the subscription, “restore purchases” | Contract and legal obligations — on Apple’s side | Apple (controller), see section 4 |
| Contact / support | The e-mail address and content you provide yourself | Replying to your enquiry, handling complaints | Art. 6(1)(b) and (f) GDPR | The controller (Oyey) + e-mail provider (Google / Gmail) |
| Bug report (crash) | The e-mail address and any information you send in the report | Fixing bugs, improving stability | Art. 6(1)(f) GDPR (legitimate interest) | The controller (Oyey) |
4. Payments and subscriptions (Apple)
All in-app purchases (a single game, Lifetime access, the weekly subscription) are processed through Apple In-App Purchase. This means that:
- billing runs through your Apple ID account;
- we neither see nor store your card details or full billing data — they are processed by Apple as the payment service provider;
- how Apple processes data is described in the Apple Privacy Policy;
- you manage your subscription (including cancellation) and any refunds in your Apple ID / App Store settings — details in the Terms (§ 6).
From Apple we receive only aggregate, statistical sales information (e.g. the number of purchases), which does not allow any individual user to be identified.
5. Support contact and bug reports
When you e-mail us (support, a question, a complaint, a bug report), we process your e-mail address and the content of your message — solely in order to reply and handle the matter. Providing this data is voluntary, but necessary for us to be able to get back to you.
We handle correspondence using e-mail provided by Google (Gmail). We keep your e-mail for as long as it is needed to handle the matter and for the limitation period for any potential claims.
6. Third-party services and SDKs
To the best of our knowledge as at the date of publication, the app does not use any third-party analytics, advertising or tracking tools (e.g. Google Analytics, Firebase, PostHog, ad networks, pixels). In particular:
- we do not use tracking for advertising purposes (App Tracking Transparency / IDFA);
- we do not use advertising SDKs;
- we do not use AI/ML solutions that process your data;
- we do not embed cookies or similar technologies for marketing purposes.
The only third parties involved in the operation of the service are Apple (app distribution and payments) and Google (Gmail) as our e-mail provider (handling contact).
7. Sharing of data
We do not sell personal data and we do not share it with third parties for marketing purposes. Data may be processed only by:
- Apple — for app distribution and payment handling;
- Google (Gmail) — as our e-mail provider, if you contact us;
- competent authorities — only where required by law.
Using Apple’s and Google’s services may involve transfers of data outside the European Economic Area (including to the USA). Both providers state that they apply the transfer mechanisms provided for in the GDPR, in particular the standard contractual clauses (SCC) approved by the European Commission, and both Apple and Google participate in the EU–U.S. Data Privacy Framework. Details in the privacy policies of Apple and Google.
8. Retention periods
- In-game data (player names, settings) — stored locally on your device until you delete it or uninstall the app.
- E-mail correspondence — for as long as the matter is being handled and for the limitation period for claims.
- Transaction data relating to purchases — held by Apple, in line with Apple’s policies and accounting regulations.
9. Your rights (GDPR)
To the extent that we process your data (i.e. when you contact us), you have the right to: access your data, rectify it, erase it, restrict processing, data portability, object to processing and — where processing is based on consent — withdraw that consent.
You also have the right to lodge a complaint with the supervisory authority: the President of the Personal Data Protection Office (PUODO), ul. Stawki 2, 00-193 Warsaw, Poland.
To exercise your rights, write to oyey.games@gmail.com.
10. Withdrawing consent
As a rule, the app does not operate on the basis of consent (it collects no data). If features requiring consent appear in the future (e.g. a marketing newsletter), you will be able to withdraw your consent at any time — without affecting the lawfulness of processing carried out before the withdrawal — by writing to oyey.games@gmail.com or using the relevant option in the message or in the app.
11. Deleting data and accounts
The app does not allow you to create an account, so there is no account to delete. To remove data stored locally, simply clear the app’s data or uninstall it. To have the e-mail correspondence you sent us deleted, write to oyey.games@gmail.com. Details: Data deletion.
12. Age of users
The app is intended solely for adults (18+) — that is also its age rating in the App Store. Inside the app you can additionally switch off the most explicit cards with the “18+ cards” toggle in settings. The app is not directed at minors and we do not knowingly collect their data.
13. Changes to this policy
We may update this policy (e.g. when the app’s features or our providers change). The current version is published at https://oyey.eu/privacy-en.html together with its effective date. We will flag any material changes in the app or on the website.