Pondering Privacy Policy

This Privacy Policy describes how Analytical Labs Ltd ("we", "us", or "our") collects, uses, stores, and protects information when you play our mobile application Pondering (the "Game" or "App"), distributed via the Apple App Store and Google Play Store.

1. Identity of the Data Controller

Analytical Labs Ltd is the Data Controller responsible for your personal data under global data protection laws, including the European Union General Data Protection Regulation (EU GDPR), United Kingdom GDPR (UK GDPR), California Consumer Privacy Act (CCPA / CPRA), and Brazil General Personal Data Protection Law (LGPD).

Contact Email: into@analyticalabsltd.com

2. Categories of Data Processed & Legal Bases

We process the following categories of data for specific legal and functional purposes:

A. Local On-Device Gameplay Data

• Data Processed: Level progress, completion times, daily puzzle streaks, coin balance, hint inventory, unlocked frog skins, and audio/haptic preferences.
• Storage & Transfer: Stored locally on your device via native app storage preferences. This data is not transmitted to or stored on our external servers.
• Legal Basis: Performance of a Contract / Legitimate Interest to provide core game functionality.

B. Mobile Advertising Identifiers

• Data Processed: Advertising ID (Apple IDFA on iOS, Google Advertising ID / GAID on Android), IP address, general coarse location (country/city), and ad interaction telemetry.
• Purpose: To serve contextual ads, frequency-cap interstitials, and deliver optional rewarded video ads via Google AdMob.
• Legal Basis: Consent (obtained via User Messaging Platform (UMP) dialogs in the EEA/UK, and App Tracking Transparency (ATT) prompts on iOS devices).

C. In-App Purchase Records

• Data Processed: Product IDs, transaction timestamps, digital purchase receipts, and entitlement tokens.
• Purpose: To validate real-money purchases (coin packs, starter pack, lifetime boost, remove ads) and grant digital inventory.
• Financial Safety: All payment transactions are handled exclusively by Apple Inc., Google LLC, and validated via RevenueCat, Inc. We never receive or store credit card or banking details.
• Legal Basis: Performance of a Contract.

D. Diagnostics & Telemetry

• Data Processed: Non-personally identifiable gameplay events (e.g., tutorial completion, level completion time, hint usage, app performance/crash metrics).
• Purpose: Game balancing, anti-cheat enforcement, and performance optimization.
• Legal Basis: Legitimate Interest to maintain and improve application quality.

3. Third-Party Partners & International Transfers

We partner with trusted third-party service providers who process data in compliance with strict privacy agreements and international transfer safeguards (Standard Contractual Clauses):

4. Advertising Choices, ATT & Opt-Out Controls

You maintain full control over advertising privacy settings on your device:

• EEA & UK Consent (Google UMP): Players in the EEA and UK can adjust or withdraw consent for personalized ads at any time inside the Game Settings under Ad Privacy Choices.
• iOS App Tracking Transparency (ATT): You can toggle tracking permissions for Pondering under iOS Settings > Privacy > Tracking. If disabled, non-personalized contextual ads are displayed.
• Android Opt-Out: On Android devices, you can opt out of interest-based ads under Settings > Privacy > Ads > Delete Advertising ID.
• US State Rights (CCPA / CPRA): We do not sell personal data for monetary compensation. To opt out of cross-context behavioral advertising sharing, disable ad tracking via your device settings or the in-game consent controls.

5. Your Rights Under Global Data Laws

Depending on your jurisdiction (including EU/UK GDPR, California CCPA, Brazil LGPD, Canada PIPEDA, Australia Privacy Act), you possess the following rights:

• Right to Access / Know: Request information on categories of data processed.
• Right to Erasure / Deletion: You can erase all gameplay progress, coins, and settings instantly by clearing App Data in your device settings or uninstalling Pondering. To request deletion of telemetry logs linked to your advertising ID, contact us at into@analyticalabsltd.com.
• Right to Restrict or Object: Object to processing based on legitimate interests or withdraw advertising consent.
• Right to Non-Discrimination: We will never discriminate against you for exercising your privacy rights.
• Right to Lodge a Complaint: You have the right to lodge a complaint with your local Data Protection Authority (DPA) or Information Commissioner.

6. Children's Privacy Compliance

Pondering is a general audience puzzle game. We do not knowingly collect personal data from children under the age of 13 (or under 16 in the EEA/UK). If you are a parent or guardian and believe your child has provided personal data, please contact us at into@analyticalabsltd.com and we will immediately take steps to delete any such data.

7. Data Security & Retention

We maintain appropriate administrative and technical safeguards to protect data against unauthorized access or disclosure. Local gameplay data remains on your device until erased by you. Technical telemetry logs are retained only as long as necessary for anti-cheat and performance analytics before anonymization.