Privacy Policy

01WHO IS RESPONSIBLE

The controller of the processing described in this policy is FinGames — Aaron ADA (EI), 67 avenue Pasteur, 91550 Paray-Vieille-Poste, France.

For any question about your data or to exercise your rights, write to fingames.support@gmail.com.

02THE SHORT VERSION

• There is no account, no login, and no advertising, analytics or tracking library.
• Your first name, avatar, answers, progress and results are stored only on your device. We have no server that receives them and no way to read them.
• Our subscription provider RevenueCat receives technical and purchase data, including an anonymous identifier and a device identifier, in order to confirm whether your subscription is active. This data is processed in the United States.
• Apple processes your payment under its own privacy policy. We never receive your payment details.
• A crash reporter (Sentry) is included in the application but is currently switched off: it sends nothing.
• We do not sell your data and do not use it for advertising.

03DATA STORED ONLY ON YOUR DEVICE

The application stores the following on your device, so that it works from one session to the next:

• the first name you choose to enter (it may be left empty) and the avatar you pick among the built-in illustrations — no photo is ever requested;
• your answers to the first-launch questions: your situation, your goal, the firms you target, the level you declare, and how you heard about the application;
• the placement test: whether you completed it, skipped it or left it, and the level it measured;
• your progress: lessons and checks completed, best scores, experience points and league — the league is calculated on your device and is shared with no one;
• your practice and assessment history: dates, modes, desks and firms chosen, difficulties, scores, accuracy and response times;
• your preferences: language, theme, sound, daily goal, and the time of your practice reminder;
• your subscription status as last confirmed by the store, and whether introductory screens have been seen;
• technical data kept by the subscription component (RevenueCat): the anonymous identifier described in section 4 and a cached copy of your subscription status and of the offers.

None of this data is sent to us. The placement test and your scores are calculated on your device and are used only to adapt what the application shows you; they produce no decision with legal or similarly significant effects.

Deleting the application deletes all of this data from your device.

04DATA SENT TO REVENUECAT (SUBSCRIPTIONS)

To know whether you have an active subscription, the application uses RevenueCat, a service provided by RevenueCat, Inc. (United States), which acts as our processor. The application contacts RevenueCat when it starts, when it returns to the foreground, when the subscription page loads the offers, when you buy, and when you restore a purchase.

RevenueCat then receives:

• an anonymous identifier generated at random by the application on your device (it contains no information about you);
• the identifier for vendor (IDFV) that iOS assigns to your device for applications of the same publisher;
• your device model, the iOS version, the version of the application, and the languages set on your device;
• the country of your App Store account, and technical indicators about the purchase environment;
• the status of the iOS tracking permission (the application never asks for this permission and does not track you);
• when you buy or restore a subscription: the transaction data provided by Apple — product purchased, price and currency, purchase and expiry dates, and transaction identifiers;
• your IP address, which is technically transmitted with any connection to an online service.

RevenueCat does not receive your first name, avatar, answers, progress, scores or history. We do not send RevenueCat any identifier of our own, email address or name.

This happens whether or not you have subscribed: without it, the application could not know whether your subscription is active.

The device identifier (IDFV) is sent automatically by RevenueCat’s software; the application offers no setting to prevent it. We do not use it ourselves, and neither it nor any other data listed here is used for advertising or to track you.

Through RevenueCat’s service, we can consult the records it holds for our application — the anonymous identifier, the purchases and the technical data above — and statistics about our subscriptions, such as the number of subscribers, renewals, cancellations and revenue. None of this tells us who you are.

Although the identifier is anonymous, this data can relate to you indirectly and is therefore treated as personal data.

05PURCHASES THROUGH APPLE

Subscriptions are sold through Apple’s App Store. Apple processes your payment, your Apple Account and your purchase history as an independent controller, under its own privacy policy:

Apple

https://www.apple.com/legal/privacy/

We never see, receive or store your payment details, your Apple Account or your email address.

06CRASH REPORTS

The application includes a crash reporter provided by Sentry. It is currently switched off and sends no data.

If we switch it on in a future version, this policy will be updated before that version is released, stating where the reports are hosted and for how long they are kept. It would then only report failures: the error, where it occurred in the code, the device model and the system and application versions.

A crash report would never contain:

• the first name you entered, or any text you typed;
• your progress, your scores or your history;
• which screens you visited, or how long you stayed.

The reporter is configured not to attach your IP address or any user identifier to a report. As with any connection, the IP address would still be transmitted to establish it.

07NOTIFICATIONS

If you enable practice reminders, iOS asks for your permission and the reminder is scheduled on your device. It passes through no server: the application does not use remote (push) notifications.

You can switch reminders off at any time, in the application or in your device settings.

08WHAT WE DO NOT DO

• no advertising, and no advertising identifier (IDFA);
• no usage analytics, audience measurement or screen tracking: we do not measure what you do in the application — the only statistics we receive concern subscriptions (section 4);
• no tracking across applications or websites, and no sale or rental of data;
• no access to your contacts, photos, files, camera, microphone or location.

09PURPOSES AND LEGAL BASES

• Checking, providing and restoring your subscription (RevenueCat, section 4): performance of the contract you enter into when you subscribe (Article 6(1)(b) GDPR), and, before you subscribe, our legitimate interest in knowing whether access must be granted (Article 6(1)(f) GDPR).
• Subscription statistics provided by RevenueCat (section 4), used to manage our activity: our legitimate interest in running and managing it (Article 6(1)(f) GDPR).
• Answering your messages to support (section 13): our legitimate interest in answering you (Article 6(1)(f) GDPR), or the performance of the contract when your message concerns your subscription.
• Crash reports, if they are switched on in the future (section 6): the legal basis will be stated in the updated policy.

The data kept only on your device (section 3) is not transmitted to us: it is used on your device solely to make the application work.

10RECIPIENTS AND TRANSFERS OUTSIDE THE EU

The only recipient of the data described in section 4 is RevenueCat, Inc., our processor, and the subcontractors it uses to provide its service (hosting, databases, logging, monitoring and, according to its data processing agreement, AI service providers), most of which are located in the United States. The up-to-date list is published in RevenueCat’s data processing agreement:

RevenueCat

https://www.revenuecat.com/dpa

This data is therefore transferred to the United States. The transfer is governed by the standard contractual clauses adopted by the European Commission, incorporated into RevenueCat’s data processing agreement. You can obtain a copy of these safeguards by writing to us.

Two other providers receive data in narrower cases, described in section 13: Google, which hosts the support mailbox and may process your messages in the United States under its own terms, and GitHub, which hosts our website.

11HOW LONG DATA IS KEPT

• Data stored on your device: until you delete it or delete the application.
• Data processed by RevenueCat: retention period being finalised — details on request at fingames.support@gmail.com. When our contract with RevenueCat ends, it deletes or returns this data on our request, under its data processing agreement.
• Messages sent to support: retention period being finalised — details on request at fingames.support@gmail.com.
• Data processed by Apple: according to Apple’s privacy policy.

12YOUR RIGHTS

Under the GDPR and the French Data Protection Act, you have the right to access your data, to have it rectified or erased, to restrict its processing, to object to processing based on our legitimate interest, and to data portability where it applies.

For the data kept on your device, you exercise these rights directly: you can change it in the application, and deleting the application erases it. We hold no copy of it.

For the data processed by RevenueCat, write to fingames.support@gmail.com. Because we do not know your identity, we need a way to find the corresponding record: write to us and we will send you the procedure, which is being finalised with our provider.

We answer within one month, which may be extended in the cases provided for by the GDPR.

If you believe your rights are not respected, you may lodge a complaint with the French data protection authority, the CNIL, or with the authority of your country of residence:

CNIL

https://www.cnil.fr

13SUPPORT AND WEBSITE

If you write to fingames.support@gmail.com, we receive your email address and the content of your message, which are processed by our email provider, Google (Gmail), and used only to answer you.

Our website (https://fingames.app) is hosted by GitHub Pages (GitHub, Inc., United States; GitHub B.V., Netherlands, for visitors in the European Economic Area), which receives the IP address of visitors when serving the pages, under GitHub’s own privacy statement. The website uses no cookies and no analytics; it only remembers the display theme you choose, in your browser.

14CHILDREN

FinGames is intended for users aged 16 and over. It is not directed at children, and we do not knowingly process data about children under that age.

We do not ask for your age or identity. Purchases are subject to the parental controls of your Apple Account (such as Ask to Buy).

15CHANGES TO THIS POLICY

If the application starts processing new data or uses a new provider, this policy will be updated before that version is released, and the change will be shown in the application.

This policy was last updated on 27 September 2026.

16CONTACT

For any question about this policy:

Controller

FinGames — Aaron ADA (EI)

Email

fingames.support@gmail.com

Address

67 avenue Pasteur, 91550 Paray-Vieille-Poste, France