Privacy policy

1 · Who we are

Honest Ludo is published by Lustig Fairchild Ltd., a company registered in Bulgaria, in the European Union, with its seat and address of management at 14 Aleksandar Malinov str., apt. 7, Varna 9000, Bulgaria.

It is registered in the Commercial Register of the Registry Agency, Republic of Bulgaria under 208942846.

For the purposes of the General Data Protection Regulation we are the controller for the limited processing this policy describes. Being established in the European Union, we are not required to appoint a representative under Article 27, and the nature and scale of the processing do not require a Data Protection Officer under Article 37. Neither appointment is made, and this policy says so rather than leaving you to infer it.

2 · What this policy covers

This policy covers Honest Ludo on Android, as distributed through Google Play, together with its two app shortcuts. They are parts of the same download.

The App Store edition of the game is not covered here, and will have its own policy when it is released. The two editions are distributed by different companies and built for different systems, and one document cannot be true of both.

3 · What the app keeps on the device

Everything the game keeps stays in its own storage on the device:

• Your games — the game in progress, the games you save and the names you give them, and the rule sets you make, with their names and codes. A saved game or rule set you delete waits in Recently deleted for 30 days, then goes for good.
• Your record of play — finished matches with their replays, your Daily results, and the dice ledger, which counts every roll so you can see for yourself that the dice are fair.
• Your settings — the game's speed, sound and haptics, the board's colours, animations, spoken detail and the other choices in Settings, what you last chose for a new game, which tips you have dismissed, a few counts that decide when, rarely, to ask for a rating, and when the app last checked for an update.
• Whether Pro is unlocked, as Google Play last confirmed it, so that Pro works offline.

Players are seats and colours. The game never asks anyone's name, age or e-mail address, and the only names it keeps are the ones you give your saved games and rule sets. We never see any of it. It is not sent to us, and there is no code in the app that could send it.

Erase all my data, in Settings › Data, removes your saved games, rule sets, the game in progress, recorded matches, Daily results and the dice ledger from the device, once you have typed a word to confirm it. Your settings are kept, and Pro, which belongs to your Google account, is not affected. Match history, Daily history and the ledger can also be cleared on their own. Uninstalling the app removes everything it keeps.

4 · Files you export, and codes you share

Nothing leaves the device through the app unless you send it. Save writes a file to the place you choose in Android's own file picker; Share hands it to the app you choose in Android's share sheet. That place's or app's own terms apply from there.

• A match's verification file, its match and ledger records and a Daily record hold the dice, moves, commitments and scores of what you chose to export — never a name, an account or a device identifier.
• Share code and Share these rules hand a rule set's short code to the app you choose.

A file waiting to be handed over is kept in a temporary folder that no backup includes.

5 · What Android's backup and transfer include

If backup is turned on for your device, Android includes the game's database — your games, rule sets, matches, Daily results and the ledger — and your settings in the backup it makes to your Google Account, and the same is what moves when you transfer to a new phone. Whether Pro is unlocked is never included, so a new device asks Google Play again, and nor are exported files.

That backup is made by the operating system, stored by Google under your Google Account, and restored by Android when you set up a device. We do not receive it, cannot read it and cannot delete it. Google provides it to you, under your agreement with Google — it is not something we do with your data.

The practical consequences, stated rather than implied:

• Your games leave the device in that backup only if backup is on.
• Erase all my data removes them from the device at once, but not from a backup Android has already made: that copy stays until Android next backs the app up.
• Uninstalling the app removes everything from the device. A copy can remain in your backup until Android replaces it or Google deletes it; you manage it in your device's backup settings.
• The only controls over this are Android's and Google's. The app has no switch of its own for it.

6 · Permissions

The app never asks you for a permission. It has no access to your location, contacts, camera, microphone, photos, files or calendar, and it sends no notifications.

Android grants a few at installation, without a prompt: control vibration, for the game's haptics, which you can turn off in Settings; and the Google Play billing service, full network access and view network connections, which belong to Google Play's billing library inside the app — see section 7. The app's own code opens no connection.

7 · Google Play's parts of the app

Three features of the app are Google Play's own. Each runs through the Google Play app on your device, and it is Google that collects what each one needs, under its own privacy policy. The app itself collects nothing, and none of it reaches us; the one exception, the record of a sale, is in section 11.

• Pro. Buying it opens Google Play's own purchase screen, and Restore asks Google Play whether your account owns it. The app reads the answer on the device and unlocks what you bought; if Google Play later says Pro is no longer on the account, the app says so. Google Play's billing library in the app also reports to Google how its own calls fare — whether they succeed, and any trouble reaching Google Play — which Google uses to improve the library and to support errors. That is why the app has network access at all; we receive none of it, and cannot switch it off.
• The update check. When you open the app, it asks Google Play whether a newer version is available. For this, Google collects information about your device, the app's version and the parts of it that are installed. Google states that this data is encrypted in transit, is not transferred to third parties, and is deleted after a fixed retention period. If there is an update, Google Play may offer it on its own sheet, which you can decline; one you accept is installed when you next leave the app.
• The rating card. Rarely — at most once for each version, and only after the app has been in use for some days — the app asks Google Play to show its rating card, and Rate on Google Play in Settings asks for it whenever you tap it. Google Play decides whether it appears. If you rate the app or write a review, Google collects them and publishes them on the app's Google Play listing, as with any review. Google states that this data is encrypted in transit, and you can delete your review in Google Play at any time. The app is not told whether the card appeared or what you chose.

The app's Data safety section on Google Play lists this data, because Google Play asks every app to include what the Google Play libraries it uses collect. It is collected by Google, for the purposes above, under Google's privacy policy; section 10 says in what capacity.

8 · Where the app's links go

A few rows hand you over to somewhere else, and only when you tap them:

• Privacy policy in Settings, and Website in About, open pages of this website in your browser; the website's own privacy notice, at /privacy/, covers the visit.
• How the dice work and Check a file online, in About, open the game's own website, honestludo.app. The file check there runs in your browser and uploads nothing.
• Support, in About, opens your email app with our support address.
• Recommend another app opens one of our other apps in Google Play. It appears once one is available there.

Google Play's own terms and privacy policy apply on its pages. Nothing is sent to us, except an email you choose to send.

9 · What we never do

The app collects no personal data and sends nothing to us. We run no servers of our own. We do not sell, rent or trade anything about you. There is no profiling and no automated decision-making. The app does not read the advertising ID and is not enrolled in any attribution or measurement framework.

That is not the same statement as “your data never leaves your device”, which would be untrue here: section 5 says what does leave it, section 7 what Google collects, and section 11 the one record that reaches us.

10 · The role of Google

Google is not our processor: it handles your data under its own terms, not on our instructions — even where, as below, it sells to you on our behalf.

• As the distributor of the app through Google Play, Google has its own relationship with you, under the Google Play terms of service and its own privacy policy. The app is free to download.
• For what you buy in the app, Google takes the payment and keeps your payment details and the record of your purchase, under the same terms and policy. In the European Economic Area, the United Kingdom and some neighbouring territories, Google is the merchant of record for the sale, acting as our agent; elsewhere it handles the payment for the sale. What it gives us is described in section 11.
• Through the Google Play app on your device, Google runs the app's update check and its rating card, and collects what each one needs, as described in section 7. A rating or review you leave is published by Google Play, not by us.
• As your backup provider, Google holds the Android backup described in section 5 under your Google Account and your agreement with Google.

Google's handling of your data under each of these relationships is governed by Google's privacy policy, at policies.google.com/privacy, not by this one.

11 · What we receive when you buy in the app

Anything you buy in the app is bought through Google Play's billing system, and Google takes the payment. Your payment details stay with Google: we never see your card or bank details, and Google gives us neither your name nor your e-mail address.

For each sale, Google Play gives us a record of it, in Google Play Console — the service through which we publish the app — and in its monthly reports to us:

• the order number and Google Play's own code for the purchase, the date and time, the product, its price and the tax charged;
• the country of your Google Play account, and the model of the device the purchase was made on;
• in some cases your state or region, and — where Google is not the merchant of record for the sale, as section 10 explains — your postal code and your city, which Google provides for tax.

Nothing else comes with it: nothing about how you use the app, and nothing from it. The app sends us nothing about the purchase either; it asks Google Play, on the device, whether the purchase is yours, and unlocks what you bought.

We use these records for our accounts and our tax returns, and for nothing else. They are seen only by whoever keeps our accounts and by authorities entitled to them by law. Because no name comes with them, we cannot tell whose purchase a record is unless you tell us: Google Play's receipt shows the order number, which begins GPA.

12 · Legal bases for processing

For the app itself, we process no personal data, so no legal basis arises. What the app keeps stays on the device, except that Android may include it in the backup it makes to your own Google Account; that backup is made and held by Google for you, under your arrangement with Google, and never reaches us.

Where Google Play gives us the record of a purchase, described in section 11, the basis is Article 6(1)(c): accounting and tax law require us to keep it.

Where you write to us, the basis is Article 6(1)(f), our legitimate interest in responding to correspondence about our software. You may object at any time by asking us to stop, and we will.

13 · Your rights, and how to exercise them

Under the GDPR and the UK GDPR you have rights of access, rectification, erasure, restriction and objection, and the right not to be subject to automated decision-making. Write to support@lustigfairchild.com. We answer within one month, which is the period Article 12(3) allows.

It is worth being concrete about what such a request would be about here, rather than listing rights and leaving you to guess.

Not what is in the app. What you keep in it sits on your device and, if Android backup is on, in your own Google Account's backup — never with us. Uninstalling the app removes it from the device, and the app's own erase removes what you made in it sooner; the backup is yours to manage in your device's backup settings. There is nothing for us to produce, correct or erase, because we never had it.

The record of a purchase, if you bought something in the app. We hold what section 11 lists, and no name comes with it — so send us the order number from Google Play's receipt, and we will tell you what the record says, or correct it. We cannot delete it while the law requires us to keep it, and we delete it when the law no longer does.

Your correspondence, if you have written to us. That we do hold, and it is what a request would concern: what we have, correcting it, deleting it, or asking us to stop. Ask and we will do it.

That is the whole of it. We hold nothing else about you, so for anything beyond those three the honest answer to a request is that there is nothing to give you.

One right genuinely does not apply: portability under Article 20 covers processing based on consent or on a contract, and we process correspondence on the basis of legitimate interests, and purchase records because the law requires it. We would rather say so than list a right we could not honour.

14 · Children

The app is meant for people aged 13 and over, and is not designed for children. It asks no one their age, because it collects nothing from anyone. We do not knowingly process children's personal data, and there is no mechanism in the app by which we could.

15 · Retention, security and international transfers

The app itself sends us nothing, so there is nothing from it to schedule for deletion. Support correspondence is kept for 24 months.

The record of a purchase, described in section 11, is kept for as long as accounting and tax law requires us to keep the records it supports, and is then deleted.

The app's own data never reaches us, so we make no international transfer of it and hold nothing of yours on any server of ours to secure. The security of your Android backup, and where in the world Google stores it, are matters for Google's privacy policy; on the device, the app relies on the operating system's own protection of app data.

16 · Notice for residents of the United States

We do not sell or share personal information as those terms are used in the California Consumer Privacy Act, and the only personal information we have in connection with this app is the record of a purchase described in section 11, which we use for our accounts and nothing else. We do not use or disclose sensitive personal information beyond what is permitted. No financial incentive is offered for personal information, and nobody is treated differently for exercising a right.

The same holds under the comparable laws of other US states. You may contact us at the address in the last section in any case.

17 · Other jurisdictions

Where local law gives you stronger rights than this policy describes, those rights apply, and nothing here limits them.

18 · Changes to this policy

Every version is dated and numbered, and superseded versions stay published at /legal/archive/ so you can read what applied before. Where a change affects you, the version number moves by a whole number rather than a decimal.

This is the first version of this policy. It covers the Google Play edition only; the App Store edition, when it is released, will have its own.

19 · Contact, and how to complain

support@lustigfairchild.com, or by post at the address in section 1.

You also have the right to complain to a data protection supervisory authority, and you do not have to come to us first. Ours is the Commission for Personal Data Protection in Bulgaria, at cpdp.bg. You may instead complain to the authority in the country where you live or work.