Privacy Policy

Version of 9 September 2026

1. Data controller and contact details

The developer and publisher of the DumiColor mobile application (the "App") is:

Within the meaning of Article 4(7) of Regulation (EU) 2016/679 (the "GDPR"), the Developer acts as the data controller for the processing described in sections 3 and 6. No data protection officer has been appointed, as the conditions of Article 37 GDPR do not apply.

2. Scope

This Policy applies to all users of the App regardless of their location, and takes into account the GDPR, the Law of Ukraine on Personal Data Protection No. 2297-VI, and United States state consumer privacy legislation including the California Consumer Privacy Act as amended by the California Privacy Rights Act.

The App has no registration and no user accounts. The Developer does not ask for a name, an email address, a telephone number, or any other information that directly identifies a user.

3. Data processed on the device

The App stores in the device's local storage the user's settings (interface language, sound preferences, chosen field skin) and the state of an unfinished game so that it can be resumed.

Legal basis: Article 6(1)(b) GDPR, processing necessary to provide the functionality the user expects from the App.

This data is not transmitted to the Developer or to any third party, remains in the App's own storage, and is deleted together with the App. Its retention is determined by the user and limited to the time the App remains installed.

4. Data exchanged between devices

When two people play on separate devices, game messages travel directly between those devices over the local network. No server infrastructure is used to transmit or store them; game messages do not leave the local network and never reach the Developer.

To establish the connection, the operating system asks for permission to access the local network. That permission is used for this purpose only.

5. Advertising

The App is distributed free of charge and displays a banner advertisement served through Google AdMob (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland).

To serve and measure advertising, to personalise it and to prevent fraud, Google processes the following device data:

• the IP address and the approximate location derived from it;
• device identifiers and advertising identifiers, including the Identifier for Advertisers (IDFA);
• information about activity within the App;
• technical information about how the App performs.

For this processing Google acts as an independent controller and determines its terms. The Developer receives no access to this data and does not process it.

Google's terms are set out at How Google uses information from sites or apps that use our services.

Legal basis for personalised advertising in the European Economic Area, the United Kingdom and Switzerland: Article 6(1)(a) GDPR, the user's consent, requested before the first advertisement is shown. Withholding consent does not stop advertising; it prevents its personalisation.

Google's processing involves transfers to third countries, including the United States. Such transfers rely on the mechanisms provided for in Chapter V GDPR and applied by Google, including the European Commission's standard contractual clauses.

Separately, iOS asks for permission to track under App Tracking Transparency. Declining has no effect on the App's functionality.

6. Error reports

If the App crashes or runs into an internal error, it sends an error report to the Developer through the Sentry service (Functional Software, Inc., 45 Fremont Street, San Francisco, CA 94105, United States). A report contains a technical description of the failure (the stack trace), the sequence of screens opened before it, the device model, the operating system version and the App version. It contains no name, no contact details, no contents of a game, and no advertising identifier.

Legal basis: Article 6(1)(f) GDPR, the Developer's legitimate interest in keeping the App working. Reports are used for no other purpose, are kept by Sentry for 90 days and are then deleted. Sentry processes them on the Developer's behalf under a data processing agreement; the transfer to the United States relies on the European Commission's standard contractual clauses.

7. Rights of users in the EEA, the United Kingdom and Switzerland

Users have the rights set out in Articles 15 to 22 GDPR: access, rectification, erasure, restriction of processing, objection to processing, and data portability.

Because the Developer neither collects nor stores data that identifies a user, exercising these rights against the Developer is not technically possible: there is no data to which they could be applied. Rights concerning data processed by Google are exercised in the manner Google provides.

Consent to personalised advertising may be withdrawn at any time within the App or through the operating system's settings. Withdrawal does not affect the lawfulness of processing carried out before it.

Users have the right to lodge a complaint with the supervisory authority of their habitual residence, place of work, or place of the alleged infringement. The supervisory authority of the Republic of Slovenia is Informacijski pooblaščenec, Dunajska cesta 22, SI-1000 Ljubljana.

8. Rights of users in Ukraine

Processing is carried out in compliance with the Law of Ukraine on Personal Data Protection No. 2297-VI, and users have the rights set out in Article 8 of that Law. Compliance is supervised by the Ukrainian Parliament Commissioner for Human Rights.

9. Rights of United States residents

The Developer does not sell personal information and receives no consideration for it within the meaning of the California Consumer Privacy Act.

The display of personalised advertising may qualify as "sharing" of personal information for cross-context behavioural advertising. Users may opt out through the request presented in the App or through the device's operating system settings. Opting out does not limit the App's functionality and does not result in discriminatory treatment.

The categories of information involved are limited to those listed in section 5 and are processed by Google.

10. Children

The App is not directed to children under 13 and does not knowingly collect their personal data within the meaning of the Children's Online Privacy Protection Act. The Developer collects no data from which a user's age could be established.

If there is reason to believe that a child's personal data has been processed in connection with the App, a parent or guardian may write to the address in section 1.

11. Automated decision-making

The App carries out no automated decision-making producing legal effects concerning the user or similarly significantly affecting them within the meaning of Article 22 GDPR. Google's selection of advertisements does not constitute such decision-making.

12. Changes to this Policy

The Developer may amend this Policy. Amendments are published on this page before the corresponding version of the App is released on the App Store. The date of the current version appears at the top of this document.

13. Contact

Enquiries about this Policy are answered within one month of receipt.