Privacy Policy — No 3 in line!

Who we are

"No 3 in line! Addictive Puzzle" (bundle id com.artadian.nothree) is published by FREEDOM LLP, a limited liability partnership registered in England and Wales under company number OC407608. The contact address for FREEDOM LLP is 101 King's Cross Road, London WC1X 9LP, United Kingdom. That address is given here as the studio's contact address, not as the registered office, because no source available for this policy describes it as the registered office.

FREEDOM LLP is the controller of the personal data described in this policy. UK data protection law, including the UK GDPR, applies to that processing. Privacy questions go to [email protected]. That address appears in the record only as the studio's general contact, so its status as the privacy channel is not yet confirmed. To confirm: is [email protected] the mailbox that will receive privacy questions and data-rights requests, is it monitored, and who staffs it? To confirm: what is FREEDOM LLP's ICO registration number, and has a data protection officer been appointed? Article 13(1)(b) UK GDPR requires the DPO's contact details to be given here where one exists.

This policy states only what can be traced to a source. Where a fact is missing, it says so rather than filling the gap. The markers in the text are those gaps, and the policy is not approved for publication while any of them remain.

What this policy covers

This policy covers the "No 3 in line! Addictive Puzzle" app as distributed through the Apple App Store. The app is not published on Google Play, so no Google Play Data safety declaration exists for it. Nothing here is drawn from one, and there is no second store filing to check the Apple labels against. To confirm: is the game distributed through the Amazon Appstore, any other store, or as a web build, and does the same processing apply there?

The App Store declaration FREEDOM LLP filed is the only first-party record of what this app does. On 7 September 2026 the studio's working copies were searched, by bundle identifier and by name, so that each app's components could be checked against its own source. No project for this app was found among them. Components present in other FREEDOM LLP games are not treated in this policy as facts about this one. Where the text below stops short, that is why. To confirm: does a source project or a build archive for this app exist anywhere else — with a former contractor, an outsourced developer, or on an old build machine — so that the app's component list can be established?

The privacy link on the App Store listing still points to a page at thefreedom.uk. That page cannot be opened by anyone: the domain resolves, but the TLS handshake is refused because no certificate has been issued. This document is intended to replace it, and the privacy policy URL in App Store Connect has to be repointed here. To confirm: who updates the privacy policy URL in App Store Connect, and by when?

• This policy does not cover how Apple handles data in its own right as operator of the App Store and in-app purchasing, and it does not cover what other companies do with data once they hold it under their own terms. Those companies have their own privacy notices.

Data we handle

The privacy labels FREEDOM LLP filed for this app declare that it collects four categories of data, all four linked to the player's identity: Location, Identifiers, Usage Data and Diagnostics. Diagnostics is additionally declared in a form that is not linked to the player. All four categories are also declared as used to track players, which the next section explains.

These are Apple's category names. The label records the categories and their linkage. It does not record the individual data points, and it does not record which part of the app collects them. No project source for this app was found in the studio's working copies, so those details cannot be checked against code and the description below stops where the label stops. To confirm: what are the exact data points collected inside each App Store label category, and which app component collects each one? With no project source found for this title, this can only be answered from the shipping build.

• Location — declared as collected, linked to the player, and used for tracking. No purpose is on record, and a match-3 puzzle has no evident functional need for location, which raises a data-minimisation question under Article 5(1)(c). To confirm: does the app collect precise or coarse location, which component collects it, for what specific purpose, and is the Location label correct at all?
• Identifiers — declared as collected, linked to the player, and used for tracking. To confirm: which identifiers does the app collect (for example advertising identifier, vendor identifier, device identifier, Game Center player id), and which of them are used for tracking?
• Usage Data — declared as collected, linked to the player, and used for tracking. To confirm: what does Usage Data cover here — in-game interaction events, advertising interaction data, or both?
• Diagnostics — declared three ways at once: linked to the player, not linked to the player, and used to track. That filing is internally inconsistent. Under Apple's own definitions, data used to track a player is tied to that player's identity, so a Diagnostics stream that is not linked to the player cannot at the same time be tracked. Either two genuine streams are described or the label is corrected, before this policy publishes. To confirm: what does each Diagnostics stream contain, and why is Diagnostics declared both linked and not linked to the player while also being declared used to track?

Advertising and tracking

The app tracks players. The App Store declaration filed for it puts Location, Identifiers, Usage Data and Diagnostics under "Data Used to Track You". In Apple's terms that means data from this app is linked with data collected by other companies' apps or websites for targeted advertising or advertising measurement, or is shared with a data broker.

On iOS, tracking of that kind requires permission through Apple's App Tracking Transparency prompt. Where the prompt is shown, permission can be given or refused, and the answer can be changed later in iOS Settings under Privacy & Security, then Tracking. To confirm: does the current build present the App Tracking Transparency prompt, does all tracking stop for every integrated component when permission is refused or later withdrawn, and how is that enforced?

App Tracking Transparency is an Apple platform control over the advertising identifier. It is an extra control for players, not the lawful basis for advertising under UK data protection law, and it does not cover storing or reading information on the device. No company can be named in this policy: the App Store declaration names no recipient, and no project source for this app was found in the studio's working copies from which a component list could be read. To confirm: which advertising, attribution, analytics or ad-mediation SDKs are in the shipping build, and at what version? With no project source found for this title, the list has to come from the build itself or from the ad-network accounts. To confirm: does the app display third-party advertising, and is that advertising personalised?

In-app purchases

The app offers in-app purchases. Payment is taken by Apple inside the App Store, under Apple's own terms. The privacy labels filed for this app declare no purchases or financial information category.

The absence of that label does not by itself establish what the app receives. Server-side receipt checking or purchase restoration would make transaction identifiers personal data that no source currently covers, and no lawful basis for that processing is stated in this policy until it is known whether it happens at all. To confirm: does the app, or any FREEDOM LLP server, ask for or receive card details, App Store receipts, transaction identifiers or purchase history — for example to restore purchases or to validate a receipt — and if so, what is stored and for how long?

Data stored on your device

The App Store labels describe categories of data collected from the app. They do not describe what the app keeps on the phone or tablet itself. Identifiers are declared as collected, linked to the player and used for tracking, so at least some identifiers held on the device are read and passed on to other companies.

The compliance audit behind this policy records the game as Game Center enabled, taken from the App Store listing; the store declaration supplied for this policy does not mention Game Center, and no source itemises what it involves. Where Game Center features are used, Apple handles the associated player identifier, leaderboard and achievement data under Apple's own terms. The Game Center player identifier may also sit inside the declared Identifiers category, which is declared linked to the player and used for tracking, so it cannot be presented as a matter for Apple alone. To confirm: confirm from the App Store listing whether the game is Game Center enabled, which Game Center features the app uses, whether the Game Center player id is one of the declared Identifiers, and what Game Center data reaches FREEDOM LLP rather than staying with Apple.

No inventory of on-device storage exists in any available source, and no project source for this app was found in the studio's working copies from which one could be read, so this section cannot list what is stored. Under PECR regulation 6, storing or reading information on a device for anything other than a strictly necessary purpose needs consent, whether or not that information is personal data. To confirm: what does the app store on the device (game progress, settings, the tracking-permission choice, identifiers cached by SDKs), which of those items are transmitted, and is any of it included in iCloud backup or Game Center sync?

Why we may process data

The App Store declaration records which categories are collected, whether they are linked to the player, and whether they are used for tracking. It does not record purposes. One purpose follows from the declaration itself: all four categories sit under "Data Used to Track You", which in Apple's terms means advertising and advertising measurement across other companies' apps and websites. A second purpose follows from the same declaration recording that in-app purchases are offered.

Article 13(1)(c) UK GDPR requires every purpose to be stated with the lawful basis for it. The position for this app is set out below.

• Advertising and cross-app tracking, using Location, Identifiers, Usage Data and Diagnostics — lawful basis: consent, Article 6(1)(a) UK GDPR. Storing or reading information on the device for that purpose also needs consent under PECR regulation 6. To confirm: through what in-app mechanism is that consent obtained, recorded and withdrawn — granular, unbundled, no pre-ticked defaults, as easy to withdraw as to give — separately from Apple's App Tracking Transparency prompt? Some ad networks allow a consent platform to be switched on from the network's own dashboard without a code change, so confirm the answer from the dashboards as well as from the build.
• Purchase, entitlement and restore processing, using whatever the app receives from Apple — no lawful basis can be stated, because no source records whether FREEDOM LLP receives anything at all. In-app purchases are declared as offered, and no purchases or financial information category is declared. To confirm: does Article 6(1)(b) UK GDPR, performance of a contract, apply to purchase, entitlement or restore processing, and between which parties, given that Apple takes the payment? Answer this together with the receipts question in the In-app purchases section.
• Any other purpose for these categories — running game features, diagnosing crashes and performance problems, or usage analytics — cannot be stated. No source records one. To confirm: which purposes does the build actually pursue for each declared category, and which lawful basis applies to each? If legitimate interests is relied on for diagnostics or analytics, what is the interest, and is a legitimate interests assessment on file?
• Until every declared category and every purpose has a named lawful basis, this section is incomplete and the policy is not ready to be published.

Sharing

Because data from this app is declared as used to track players, it goes to other companies, or is combined with data those companies already hold, for advertising and advertising measurement. None of them can be named here. No list is on record, the App Store declaration names no recipient, and no project source for this app was found in the studio's working copies from which a component list could be read. To confirm: what is the full list of third parties that receive data from the app, and is each one a controller in its own right or a processor acting for FREEDOM LLP?

Apple also receives data in its own right, as the operator of the App Store and in-app purchasing, and of Game Center where that is used. Because the app is not on Google Play, three cross-checks that a Data safety declaration would provide do not exist for this app: no third-party sharing declaration, no encryption-in-transit statement and no deletion-request statement.

Nothing is on record about data leaving the United Kingdom. Articles 13(1)(e) and 13(1)(f) UK GDPR require the recipients and any transfer outside the UK to be set out, so this section must be completed before publication. To confirm: is any data transferred outside the United Kingdom, to which countries, under which safeguard (UK IDTA, the UK Addendum to the EU SCCs, or an adequacy regulation), and how can a copy of that safeguard be obtained?

How data is protected

No transport or security position is on record for this app. There is no project source in the studio's working copies from which the endpoints the app contacts could be read, and there is no second store filing carrying an encryption-in-transit statement. This policy therefore does not tell a reader whether anything leaves the device encrypted, because no source says so.

No claim about how data is protected may be published for this app until that is answered. To confirm: do transmissions from the app to third-party components use TLS, and what other security measures can FREEDOM LLP stand behind, so that a statement on how data is protected can be added?

Retention

No retention period is stated here, and no criteria for setting one. Retention has not been confirmed for any category, either at FREEDOM LLP or at the companies that receive data from the app. Stating a period that has not been confirmed would be worse than stating none.

The App Store declaration records nothing about retention, and no project source for this app was found in the studio's working copies in which a retention rule could be read. Article 13(2)(a) UK GDPR requires either the period or the criteria used to set it, so this section must be completed before the policy is published. To confirm: how long is each category of data (Location, Identifiers, Usage Data, Diagnostics) kept by FREEDOM LLP, and what period applies at each third party that receives it, taken from contract or from that company's published notice? To confirm: where a fixed period cannot be given for a category, what criteria determine how long it is kept?

Your rights

Under UK data protection law, players have rights over their personal data. These can be exercised by writing to [email protected]. No response time is stated in this policy: the law sets a deadline for answering, and it is not published here until the studio confirms who answers requests and that the deadline can be met. To confirm: who handles rights requests at FREEDOM LLP, and can the Article 12(3) UK GDPR response deadline be met? No response time is stated in the published text until that is confirmed. To confirm: is [email protected] the mailbox that receives data-rights requests, is it monitored, and who staffs it?

Data from this app is declared as used to track players, which means it is combined with data collected in other companies' apps and websites to select and measure advertising. The rights below apply to that processing too.

Objecting to advertising and tracking. This right is set out separately because it is the strongest one a player has here. A player can object at any time to the processing of their personal data for direct marketing, which includes profiling for advertising. The right is absolute: there is no balancing test, no exception and nothing to weigh against it, and FREEDOM LLP must stop that processing as soon as the objection is made. Because all four declared categories are declared as used to track players for advertising, this right covers that processing in full.

• Ask for a copy of the personal data held about you.
• Ask for inaccurate data to be corrected.
• Ask for data to be deleted.
• Ask for processing to be restricted.
• Object to processing carried out on a legitimate-interests basis. This one is qualified and is weighed against the reasons for processing — unlike the objection to direct marketing above, which is not.
• Ask for data to be provided in a portable form.
• Withdraw consent at any time for any purpose that relies on it, with no effect on processing already carried out. To confirm: what is the in-app route for withdrawing consent, and which purposes does it cover?
• Where the App Tracking Transparency prompt is shown, the answer given to it can be changed at any time in iOS Settings under Privacy & Security, then Tracking.
• Where the app asks for access to location, that permission can be changed at any time in iOS Settings under Privacy & Security, then Location Services.
• Complain to the Information Commissioner's Office, the UK regulator, at ico.org.uk.
• To confirm: how can a specific player's data be located, exported and deleted when it is held against an advertising or device identifier rather than an account, and how is a deletion request passed on to each company that received the data?

Children

The app carries an App Store age rating of 4+, so its audience includes children under 13. The same App Store declaration puts Location, Identifiers, Usage Data and Diagnostics under "Data Used to Track You", which is cross-app tracking for advertising.

On the record available, those two things cannot both stand. Article 8 UK GDPR sets 13 as the youngest age at which a child can consent to an online service on their own, and standard 12 of the ICO Children's code requires profiling for marketing to be off by default for children. Nothing on record shows an age screen in this app, profiling off by default, or any route to parental authorisation, and with no project source found for this app the configuration of its advertising components is unknown. Cross-app tracking of an audience that includes under-13s therefore has no available lawful basis as things stand.

That position is resolved in the product or in the filings — by switching the tracking off, or by correcting the App Store labels if they are wrong — and not by the wording of this document. To confirm: which will it be, and by when: is tracking switched off for this app, or are the App Store labels corrected? To confirm: does the app apply a neutral age screen, are tracking and personalised advertising off by default for under-18s as the ICO Children's code requires, is any child-directed or age-restricted setting applied to the advertising components, and how is parental authorisation obtained for under-13s under Article 8? To confirm: if the app does not in fact track players, are the App Store labels wrong, and will they be corrected before this policy is published?

Changes

Updated versions of this policy are published on this page. This document carries no effective date or version number yet. To confirm: what effective date and version identifier should the published policy carry, and who keeps the change log of material revisions and their dates?

The earlier policy hosted at thefreedom.uk cannot be reached by anyone, and no copy of its text survives — not on the live page and not in any archive that could be retrieved. Nothing players were previously told can be compared against this document, so the change log begins with this version. This document is intended to replace that page, once the privacy link on the App Store listing is updated to point here.

To confirm: when processing that relies on the player's permission changes materially, is permission asked for again, and through what mechanism?

Contact

Privacy questions and rights requests go to [email protected], or by post to FREEDOM LLP, 101 King's Cross Road, London WC1X 9LP, United Kingdom. That postal address is the studio's contact address; it is not described here as the registered office because no source available for this policy characterises it that way. To confirm: is [email protected] the confirmed, monitored channel for privacy questions and data-rights requests, and who staffs it?

Complaints can also be made to the Information Commissioner's Office at ico.org.uk. Raising the matter with FREEDOM LLP first is welcome, but not required.

To confirm: is the app offered to players in the EU or EEA, and if so, has FREEDOM LLP appointed an Article 27 EU representative to be named here?