Privacy Policy - Gallery Roulette

1) Who we are (Data Controller)

• Legal entity: Yauheni Babanin (Polish sole proprietorship)
• Address: Sandomierska 15/16, 02-567 Warsaw, Poland
• Privacy contact: galleryrouletteapp@gmail.com
• DPO: Not appointed

2) What data we collect

2.1 Information you provide

• Name or nickname - shown to other players in your lobby.
• Photos/Videos you choose for a round - content you explicitly select for gameplay. You control what you share.

2.2 Automatically collected data

• Identifiers - internal user ID and device identifiers (for sessions, multiplayer, anti-fraud, and sync).
• Purchase data - subscription product identifiers and entitlement status via Apple StoreKit (we never see full payment details).
• Diagnostics - crash logs and performance metrics (e.g., Firebase Crashlytics/Performance, if enabled).
• Analytics - aggregated usage events (e.g., game start/end, feature usage) via Firebase Analytics and/or Amplitude (if enabled).
• Push tokens - to deliver optional notifications (you can disable in system settings).

We do not collect sensitive health data or precise geolocation.

We do not create a public gallery from your content.

3) Why we process data (legal bases)

• Provide the App - create lobbies, run rounds, show nicknames, process the content you select. (Contract)
• Manage purchases & Premium features - bigger party size, no ads, longer games, photo+video modes. (Contract)
• Security & abuse prevention - prevent spam/cheating, keep services reliable. (Legitimate interests)
• Improve the App & debug issues - analytics/diagnostics. (Legitimate interests and/or Consent where required, e.g., ATT)
• Legal compliance - taxes/audits for purchases. (Legal obligation)

4) Content control & retention

• You choose what to share. Before each round you pick which photos/videos can be used.
• Ephemeral gameplay. Content is processed only to run a round and show it to participants; we do not permanently publish it.
• Retention: gameplay content is kept only as long as necessary for session mechanics, then deleted or de-identified. Account/analytics/purchase records are retained as needed for operations and law.

5) Sharing of data (service providers)

We don't sell personal data. We share limited data with vendors who help us operate the App:

• Apple (StoreKit / App Store) - in-app purchases, subscription status, TestFlight.
• Firebase (Google) - hosting/services such as Analytics, Crashlytics, Cloud Functions, and FCM push. Data may be stored in us-central.
• Amplitude (now or in future) - product analytics.
• Adjust (now or in future) - attribution/analytics; if ATT permission is granted, Adjust may access the IDFA.
• RevenueCat (now or in future) - subscription entitlement management.

When data is transferred outside the EEA/UK, we rely on safeguards like Standard Contractual Clauses. Vendors act under data-processing agreements and only on our instructions.

6) Advertising & tracking

We currently do not show third-party ads in Premium. If we add advertising that uses the device's advertising identifier (IDFA), we will request permission via App Tracking Transparency (ATT) and update this Policy.

7) Children & general audience

The App is designed for a general audience and is not directed to children. We do not knowingly collect personal information from children where parental consent is required by law (e.g., under 13 in the U.S. or 16 in parts of the EU/UK).

If you believe we collected such information, contact us and we will delete it.

8) Security

We use technical and organizational measures to protect data (TLS in transit, access controls, least-privilege). No method is 100% secure.

9) Your rights

Depending on your location, you may have the right to access, correct, delete, restrict or object to processing, data portability, and to withdraw consent.

To exercise rights, email galleryrouletteapp@gmail.com. We may need to verify your identity.

10) International transfers

When data is transferred outside your country (e.g., to the U.S.), we use safeguards such as SCCs and vendor security programs. Details available on request.

11) Third-party links

The App may link to third-party pages (e.g., Apple subscription management). Their privacy practices are separate from ours.

12) Changes

We may update this Policy from time to time. We'll post the latest version in the App and/or on our website with the "Last updated" date.