Privacy Policy

Effective date: 8 November 2026

Last updated: 8 November 2026

This policy explains what data the game collects, why, who receives it, and what you can do about it. We wrote it in plain language. If something is unclear, write to us (see section 19).

1. The short version

This is a puzzle game. You do not need an account, and we do not run a game server. Here is what that means in practice.

• Your game stays on your phone. Your progress, coins, hints, settings and language are saved on your iPhone. If you use iCloud, Apple keeps a copy for you so the game can come back after a reinstall. We never receive that copy.
• Ads come from Google. The game is free because of ads. They are made possible by Google's advertising software (AdMob), and Google receives some technical data from your phone to show and measure them. Where the law asks for it (the European Economic Area, the United Kingdom and Switzerland), the game asks for your permission first. You can change your choice at any time.
• We never track you across other apps. The game does not show Apple's tracking prompt, and all ads in this version are not personalized.
• Purchases are handled by Apple. We never see your card or payment details.
• We do not use a third-party analytics or crash-reporting service. We only see what Apple shows every developer, and only for people who agreed to share it with developers.
• We never collect your name, phone number, precise location, contacts, photos or microphone.
• The game is not directed to children, but it has no age check and players of any age may play. See section 16.
• You can reset the game and ask us to delete anything you sent us. See sections 14 and 15.

The rest of this page gives the details and your rights.

2. Who we are

The app is published by Mehmet Aktug, an individual developer, trading as Lumina Studio ("we", "us"). We decide why and how the data described in this policy is used, so we are the "controller" under European and UK law (the party that decides why and how personal data is used), except where we say that Apple or Google decides for itself.

• Email: support@luminastudio.ai
• Website: https://wordpuzzle.luminastudio.ai
• Postal address: Universiteler Mah 1606 Cd B Blok B401, 06800 Ankara, Turkiye (Turkey)

3. What stays on your phone

The game keeps these things on your device, in the app's own storage. We do not receive them.

• Game progress, stars, coins, hints, settings and the language you chose.
• Hearts and the timer that gives them back. To make the timer fair, the game reads the clock of your phone and keeps a few clock readings so it can notice when the clock is set backwards. These readings never leave your phone.
• Your privacy choices (what you answered in the consent form).
• A random install ID that the game creates the first time it needs one. It is not linked to your name, your Apple Account or your phone number, and it is not derived from your advertising identifier. It stays on your iPhone: the game uses it only to choose which devices take part in a game test. The game does not send it to Google, to Apple or to any other service. It is replaced when you reset the game or turn analytics off.
• A short log of game events (for example "level finished"). It contains only numbers, yes/no values and short codes from a fixed list: no name, no email and nothing you type. It is used to improve the game on test devices and to attach to a support message only if you choose to send it. It is kept on the phone for at most seven days (and at most 500 events) and is erased when you turn off "Share anonymous usage data", refuse analytics consent or reset the game.
• The reminder that tells you your hearts are back, if you turn it on. It is a local notification scheduled on your phone; there is no push server and no push token.

Because this data stays on your phone, deleting the app deletes it (unless you use iCloud, see section 7).

4. What you send us

We receive data only when you write to us or visit our website.

• Support message. If you use Contact us in the game, your mail app opens a message to us. We receive your email address and what you write. If you tick the option, the message also carries device information (app version, iOS version, phone model class, language) and the event log from section 3, so you can see exactly what is attached before you send it.
• Report an ad. If you report an ad, we receive the ad network's name and, if you attach one, a screenshot.
• Word reports. If you report a word as wrong, the report is kept in a small queue on your phone. It reaches us only if you send it yourself in a support message.
• Our website. The website (wordpuzzle.luminastudio.ai) is a static site hosted by Vercel Inc. It sets no cookies, runs no analytics, advertising or tracking tools, and loads nothing from other sites. Like almost every web host, Vercel's servers record standard technical request data in server logs when you open a page: your IP address, the date and time, the page you asked for, your browser and device type and the page that linked to us. Vercel keeps these logs to deliver, secure and fix the website, under its own privacy policy. We do not use them to identify you or to build a profile of you.

We use what you send us only to answer you, fix the problem, improve the word lists and check the quality of ads. We keep support messages and ad reports for twelve months after the last message in the conversation, then delete them.

5. Ads, consent and tracking

Who shows the ads

The game uses Google Mobile Ads (the "AdMob" advertising software, technical name GoogleMobileAds) to show ads. To ask for your permission where the law requires it, the game uses Google's User Messaging Platform (technical name UserMessagingPlatform), a consent form that follows the industry standard used in Europe. Google runs both. We do not control the content of third-party ads and are not responsible for the products they promote.

The game shows no ads while you play. A short full-screen ad may appear between some levels, and you can choose to watch a video ad in exchange for a reward. Rewarded video ads are always your choice.

What Google receives

When the game asks Google for an ad, Google's software can receive and use: your ad requests, which ads were shown and clicked, identifiers of your device that the software creates or reads (such as the identifier that iOS gives to all apps of one developer on your device), the approximate location that can be worked out from your IP address, and technical logs from the ad software such as crash and performance data. Google may use diagnostic data for advertising and analytics purposes as well. Advertisers and ad partners that take part in AdMob's ad auction may receive ad-related data as well, under their own privacy policies. The game never shows Apple's tracking prompt, so iOS does not give the advertising identifier (IDFA) to the game or to Google's software. We ask the software not to collect approximate location, but Google can still work out a rough location from your IP address.

Google decides for itself how it uses ad data. Read how Google does this at https://policies.google.com/technologies/partner-sites and in Google's own privacy policy at https://policies.google.com/privacy. Google also publishes the ad technology partners that can take part in AdMob ads, with a link to each partner's own privacy policy, at https://support.google.com/admob/answer/9012903.

Your choices

• Consent form (European Economic Area, United Kingdom, Switzerland, and wherever else Google's consent platform requires it). The first time you open the game in these regions, and whenever your answer is needed again, a consent form appears before any ad is requested. If you say no, or do not answer, the game does not ask for ads until you agree, and it stays fully playable: only the rewards that come from watching an ad are unavailable in the meantime. You can change your answer at any time in Settings, Privacy and data, Privacy choices.
• Other countries. No form is needed, and the game asks Google for ads that are not personalized. Where a local law gives you a right to opt out of "sale" or "sharing" of data for advertising, the Privacy choices row in Settings (shown where Google's platform says it is required) is how you use it.
• Tracking across apps (iOS). iOS lets you decide whether an app may track you across other companies' apps and websites and may read the advertising identifier. The game does not ask for this permission and does not track you, and the game works the same for everyone. To see Apple's tracking switch for all apps, open Settings, then Privacy & Security, then Tracking on your iPhone.
• Limit ads in general. Use the iOS settings under Privacy & Security and Apple Advertising. You can also remove the full-screen ads for good with the Remove Ads purchase (section 6 of the Terms).

Age signals

Apple can tell apps the age range of the person who uses the device (Apple's Declared Age Range feature, technical name DeclaredAgeRange). If the game uses it and learns that the player is a minor, the game asks the ad software to treat the request as coming from a child or teenager, which means ads that are not personalized. We do not store the age range.

6. Purchases

Purchases (coins, hints, hearts, Remove Ads and bundles) go through Apple's StoreKit and the App Store. Apple is the seller of record and handles your payment details, receipts, refunds and Family Sharing. The game checks on your device that a purchase is genuine and then unlocks it. We do not run a server for purchases, we do not receive your name or card details, and we do not know who bought what. If you restore purchases, the game asks Apple which one-time purchases belong to your Apple Account. Apple's own privacy policy applies to what Apple does.

7. iCloud and Game Center

• iCloud. If iCloud is available, the game saves a small snapshot of your progress, coins, items and settings in the iCloud key-value storage of your own Apple Account, so you can restore it after a reinstall or on a new phone. This data goes from your phone to Apple's iCloud and back; only you can use it and we cannot read it. You control it in iOS Settings under your name, iCloud. Hearts and timers are not synced. Playing on two devices without a connection can lose one device's coin changes.
• Game Center (planned for a later version). If we add leaderboards and achievements, they use Apple's Game Center (technical name GameKit). Apple handles your alias and scores under Apple's rules, and we receive nothing about you.

8. Crash reports, usage data and analytics

Version 1.0 does not contain a third-party analytics, crash-reporting or remote-configuration service. This is what we use instead:

• Apple's tools. Apple shows developers crash reports, performance data (through Apple's MetricKit), downloads and retention figures in Xcode and App Store Connect, but only for people who turned on "Share With App Developers" in iOS Settings. We cannot tell who you are from this. The game also stores a short summary of such Apple reports (counts and an hour, at most 31 daily summaries) on your phone in a local file, and the file is attached to a support message only if you choose to send one.
• Update check. To offer you a newer version, the game can ask the public App Store listing of this app for its newest version number. The request carries only the app's own identifier, nothing about you or your game, and Apple answers with a version number. Like any internet request, it shows your network address to Apple. This check is switched off until a release turns it on, and we keep nothing from it.
• Our own event log from section 3, which stays on your phone.

If a later version adds an analytics or crash-reporting service, we will update this policy first, and where the law requires it the game will ask for your consent before anything is sent. The random install ID from section 3 is never sent anywhere and never linked to your advertising identifier or Apple Account.

9. Services and software in the app

Word lists, fonts and sounds that come with the app are listed with their licences in the app's credits.

10. What we never collect

Your name, email (unless you write to us), phone number, physical address, health or fitness data, payment details, precise location, contacts, photos, videos, audio, messages, browsing or search history, or an account of any kind. The game has no chat, no user-created content and no social features, and it does not ask for these permissions.

11. Why we may use your data (legal bases)

Under the GDPR and the UK GDPR we must name a legal reason for each use.

12. Who receives data, and moving it between countries

• Google (AdMob and the consent form) receives ad data (section 5). Google works worldwide, so data may be processed in countries other than yours, including the United States. Google and many ad partners use safeguards for such transfers where the law requires it, for example the EU-US Data Privacy Framework (and its UK and Swiss extensions) or standard contractual clauses.
• Apple receives purchase, iCloud, Game Center, diagnostic data and the update check request (section 8) under Apple's own policies.
• Vercel hosts our website and keeps standard server logs for it (section 4).
• Our mail provider holds your support messages.
• Authorities or advisers, only when the law requires it or to protect our rights.
• We do not sell your data for money, and we do not share it with data brokers.

13. How long data is kept

14. Your rights

Because we have no accounts, we usually cannot tell which data in a partner's system belongs to you, and the game never sends our install ID to a partner. When you write to us, we may ask you for details before we act, so we do not give your data to the wrong person. You can write to us at any time (section 19). We aim to reply within 7 days, and always within the time the law allows. Requests about ad data are best sent to Google as well.

• European Economic Area, United Kingdom, Switzerland (GDPR, UK GDPR, Swiss data protection law). You can ask for access to your data and a copy, correction, deletion, restriction of use, a copy in a portable format, and you can object to uses based on our legitimate interest. You can withdraw consent at any time (Privacy choices in Settings) without losing access to the game; this does not affect what happened before. You can complain to your data protection authority (in the UK, the Information Commissioner's Office; in Switzerland, the Federal Data Protection and Information Commissioner). We would like the chance to fix the problem first.
• Turkey (KVKK, Law No. 6698). You can ask us whether your data is processed, ask for information about it, learn its purpose and whether it is used as intended, learn who receives it at home or abroad, ask for correction, ask for deletion or destruction, ask that those actions be told to recipients, object to a result against you that comes only from automated analysis, and ask for compensation for harm caused by unlawful processing. To use these rights, email support@luminastudio.ai or write to the postal address in section 19; you can also complain to the Personal Data Protection Board. This notice is in English only in version 1.
• Brazil (LGPD). You can ask us to confirm that we process your data, to give you access, to correct it, to anonymize, block or delete it, to port it, to tell you who it was shared with, to explain the consequences of refusing consent, and you can revoke consent. You can complain to the national data protection authority (ANPD).
• India (DPDP Act 2023). You can ask for a summary of your data and its recipients, for correction and for erasure, you can withdraw consent, and you can use our grievance route (section 19) and then complain to the Data Protection Board of India. Nominating another person to exercise your rights for you is allowed.
• California and other US states (CCPA and CPRA, and similar laws). You can ask what data we hold, ask for deletion or correction, opt out of the "sale" or "sharing" of data for cross-context behavioral advertising, and you will not be treated worse for using these rights. We do not sell personal data for money. Ad partners that receive ad data from the game may count as "sharing" in some states; use Privacy choices in Settings and the tracking settings of iOS (section 5) to opt out.
• Elsewhere. Depending on where you live you may have similar rights. Write to us and say which country you are in.

15. Deleting your data

There are no accounts, so deleting is simple.

1. In the game: Settings, Privacy and data, Reset. You can reset the progress of one language or of everything. The reset erases progress, coins, items, stats and settings from your phone and from the iCloud snapshot (the iCloud change happens when you are online) and replaces the random install ID. It cannot be undone. Purchases stay, because Apple controls them, and you can restore them.
2. Remove the app to remove everything the game stored on your phone. Delete the iCloud data in iOS Settings, then your name, then iCloud, then Manage Account Storage if you no longer want the snapshot.
3. Ask us (section 19) by email with the subject "Delete my data" to delete the support messages and reports you sent. We aim to reply within 7 days.
4. Ad identifiers and Google. To ask Google about ad data, use Google's own privacy tools. Resetting the game does not remove data that Google or ad partners already received, and because the game never sends them its install ID, we usually cannot point them to your data.
5. Apple data (purchases, Game Center, diagnostics) is deleted through Apple.

16. Children

The game is not directed to children, and it has no age check: players of any age may play. It is a puzzle game for a general audience and has no mature themes, so Apple rates it 4+. That rating describes the content only; it does not mean the game is made for children, and the game is not in Apple's Kids Category. The game has no accounts, no chat, no user-generated content and no social features. It collects only the data listed in this policy and does not ask for a name, an email address or an age. We do not knowingly collect personal data from children.

About ads: all ads in this version are not personalized, and where the law requires it the consent form comes first (section 5). The game asks the ad software for ads with the highest content-rating filter (suitable for all audiences, "G"). Ads come from partners, so we cannot promise that every ad is suitable. If you are a parent and you see an ad that is not suitable, use "Report an ad" on the Support screen. You can also use Apple's Screen Time controls.

If you believe a child has given us personal data (for example in a support message), please write to us (section 19). We will delete it. In the European Union the age at which a child can give valid consent is set by each country (13 to 16); where a person is below that age, consent must come from a parent, and the game treats players with an age signal for minors as in section 5.

17. Security

The game stores its data in the protected storage of iOS and sends data only over encrypted connections. No system is perfectly secure. If we learn of a breach that affects you, we will tell you and the authorities concerned as the law requires.

18. Changes to this policy

We may update this policy when the game or the law changes, for example when we add a service. The new version will have a new "Last updated" date. For important changes we will tell you in the game, and if a change needs your consent, we will ask again. Old versions are kept so you can see what changed.

19. Contact

For questions, requests or complaints about this policy, write to Mehmet Aktug, trading as Lumina Studio, at support@luminastudio.ai, or by post to Universiteler Mah 1606 Cd B Blok B401, 06800 Ankara, Turkiye (Turkey).

This policy is first published in English.