Privacy Policy for Brilliq: Memory Card Game
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This privacy policy applies to the app Brilliq: Memory Card Game by Frabert UG (haftungsbeschränkt) and is available in German and English. The German version is the binding version.
Data controller
Frabert UG (haftungsbeschränkt)
Details under § 5 DDG: frabert.de/impressum
For privacy-related enquiries, please contact us via the Impressum.
What data is processed?
Data stored locally on your device
The app stores the following data exclusively on your device. This data is not transmitted to us or to any third party:
- Age bracket (age gate): Your age bracket (under 13, 13–15, 16 or older) is stored locally to comply with legal requirements under COPPA (USA) and GDPR Article 8 (EU). The age bracket controls whether personalised advertising may be requested.
- Game statistics: Personal best times and average move counts, broken down by board size and mode combination. No cloud sync.
- Game settings: Selected difficulty, wild modifier settings, motif selection, and other preferences. No cloud sync.
- Purchase status: Whether you have made the "Remove Ads" purchase is stored locally. The transaction itself is handled by the Apple App Store or Google Play; their own privacy policies apply to the purchase.
No user account, login, or cloud synchronisation is required.
Advertising data (Google AdMob)
The app displays advertisements through Google AdMob, a service of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. AdMob may process the following data:
- Device identifiers: the Advertising Identifier (IDFA) on iOS and the Google Advertising ID (GAID) on Android, if you have given consent to their use.
- Usage data about your device and app usage for delivering and optimising advertisements.
GDPR consent and App Tracking Transparency (iOS)
When you first open the app, you are asked whether you consent to personalised advertising:
- On iOS, Apple presents the ATT (App Tracking Transparency) prompt first, where you can allow or deny access to the IDFA.
- Google then presents the UMP (User Messaging Platform / Funding Choices) consent form under the IAB Transparency & Consent Framework (TCF v2.2).
If you do not consent to personalised advertising, only non-personalised ads are served. You can withdraw or change your consent at any time in the app's settings.
Ads appear only after a completed game, never during play, during a card flip, or during an AI turn.
Legal basis for processing by AdMob for personalised advertising: consent (Art. 6(1)(a) GDPR). For non-personalised advertising: legitimate interests (Art. 6(1)(f) GDPR).
For more information about Google's data processing, see Google's privacy policy: policies.google.com/privacy. AdMob is certified under the EU-US Data Privacy Framework; transfers to the US are made on that basis.
No analytics or tracking services
Beyond the advertising processing by AdMob described above, the app uses no analytics, crash-reporting, or other tracking services. No data is transmitted to Frabert UG.
Special categories: minors
The app is designed for all ages. The age gate collects an age bracket on first launch:
- Under 13: The app sets the Google child-directed content flag (COPPA). Personalised advertising is not permitted for this age group and is not requested.
- 13–15: In the EU, users under 16 are subject to heightened protection (GDPR Art. 8). The app disables personalised advertising for this age group.
- 16 or older: Personalised advertising is permitted, subject to your consent in the consent form.
The age bracket is stored exclusively on the device and is not transmitted.
Your rights
As a data subject under the GDPR, you have the following rights:
- Right of access (Art. 15 GDPR): You may request information about the data stored about you.
- Right to rectification (Art. 16 GDPR): You may request correction of inaccurate data.
- Right to erasure (Art. 17 GDPR): You may request deletion of your data, to the extent that no statutory retention obligations apply.
- Right to restriction of processing (Art. 18 GDPR): You may request that processing be restricted.
- Right to data portability (Art. 20 GDPR): You may receive your data in a structured, machine-readable format.
- Right to object (Art. 21 GDPR): You may object to processing based on legitimate interests.
- Right to withdraw consent (Art. 7(3) GDPR): You may withdraw any consent you have given at any time (e.g. for personalised advertising via the app's settings). Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
Since all game-related data is stored exclusively on your device, you can delete it at any time by uninstalling the app or using your device's storage management.
For access or deletion requests relating to data processed by AdMob, please contact Google directly (see above).
For requests to Frabert UG, please use the Impressum: frabert.de/impressum.
Right to lodge a complaint
You have the right to lodge a complaint with a supervisory authority. The competent supervisory authority for Frabert UG is the responsible German state data protection authority. A list of German supervisory authorities is available on the website of the Federal Commissioner for Data Protection and Freedom of Information: bfdi.bund.de.
Changes to this privacy policy
We reserve the right to update this privacy policy if legal requirements change or the app's features change. The current version is always available at frabert.de/apps/memory-game/privacy.
Last updated: 24 October 2026