Privacy Policy — Pick The Lock

Who we are

Effective date: To confirm: What date should this version carry? The version it replaces was dated 20 June 2026.

Pick The Lock: Tap Timing Rush (the "Game") is published by FREEDOM LLP, a limited liability partnership registered in England and Wales, company number OC407608, of 101 King's Cross Road, London WC1X 9LP.

FREEDOM LLP is the controller of any personal data handled through the Game. UK data protection law applies, including the UK GDPR. Write to [email protected].

• To confirm: What is FREEDOM LLP's ICO registration number?
• To confirm: Has FREEDOM LLP appointed a data protection officer, or an EU representative under Article 27 for players in the EU? The Game is distributed on both stores, so if a representative is appointed it must be named here.
• To confirm: Is [email protected] the confirmed channel for privacy and data-rights requests, is it monitored, and who staffs it?

What this policy covers

This policy covers the Game as distributed on the App Store and on Google Play (bundle identifier com.artadian.lockpicker). It does not cover any other game, website or service run by FREEDOM LLP.

It replaces the policy currently live at battleofgeniuses.com, dated 20 June 2026. Where the two differ, this version applies.

This version is a draft and must not be published while any review marker remains in it. Everything below is drawn from three sources: the two privacy declarations FREEDOM LLP filed with Apple and with Google; the App Store listing's age-rating and in-app-purchase entries; and — where marked as such — the policy this version replaces, whose claims are unverified and are reported here rather than adopted. Those are the only first-party records for this Game: no source code for it was available, so nothing here has been checked against the build. Where the records are silent, this policy says so instead of filling the gap.

Data we handle

In the Data safety declaration filed with Google Play, FREEDOM LLP states that the Game may collect three categories of data:

The privacy label filed with Apple says the opposite: that the Game collects no data at all. The two filings contradict each other, and this policy will not pretend they agree. To confirm: Which filing is correct — does the Game collect App activity, App info and performance and Device or other IDs, does it collect nothing, or do the iOS and Android builds differ, so that both filings are correct and this policy must state a separate position per platform? No source repository for this Game exists in the studio's working copies; a search by bundle identifier and by name found only this website's own files. The question can now be settled only against the shipping builds, or with whoever built them. Any filing that turns out to be wrong must be corrected before this policy is published. The policy being replaced also says the Game plays fully offline and needs no account, which the Google Play declaration contradicts. To confirm: Does the Game still require no account, sign-up or login, and does it connect to anything? Until this is settled, treat the wider Google Play declaration as describing what the Game may do.

The Google Play declaration records that data is encrypted while it is being sent, which means data can leave your device. To confirm: Where does data that leaves the Game go, who receives it, where is it stored, and what protects it once received? Neither filing lists a name, email address or phone number. A device identifier is still personal data under the UK GDPR, and crash or activity information tied to one is personal data too. That is why this policy, and the rights set out below, apply.

• App activity — information about how the Game is used.
• App info and performance — for example crash and performance information.
• Device or other IDs — identifiers connected to your device.

Advertising and tracking

Neither filing declares advertising. The Apple label declares no collection, and so declares no tracking of you across other companies' apps and websites. That is the Apple filing, which is one side of the unresolved conflict set out under "Data we handle"; it is not an assurance this policy can give until the correct filing is established. The Google Play declaration lists Device or other IDs among the data that may be collected, but does not say what those identifiers are for.

Device identifiers are the usual basis for advertising and measurement in mobile games. That is a general observation about mobile games, not a finding about this one, and this policy will not turn it into one. To confirm: Does the Game show advertising, or contain any advertising, attribution or analytics component? If so, which one, supplied by whom, and what does it receive? To confirm: Which identifiers does "Device or other IDs" cover — the device advertising identifier, an identifier created at install, or something else — and are any of them used for advertising or for tracking across apps?

If advertising or tracking is in use, this section must be rewritten to name the companies involved and to set out the choices open to you, before the policy goes live.

In-app purchases

The App Store listing declares that the Game has no in-app purchases. Neither filing records any purchase, payment or financial data category.

Nothing on record covers the Google Play build. To confirm: Does the Google Play build of the Game contain in-app purchases or any paid element? Only the Apple position is on record. Beyond the two entries above, this policy makes no claim about payment or financial information for either build.

Data stored on your device

The policy being replaced says the Game keeps your best time in storage on your device, that the record never leaves the device, and that it is deleted when the Game is uninstalled. That claim has not been checked against the build and is reported here, not adopted. To confirm: Is the best-time value held only on the device, or is it also sent off it, and does it fall within the App activity category declared on Google Play?

The Google Play declaration lists App activity — the category covering how the Game is used — among the data that may be collected, and records that data is encrypted while it is being sent. Gameplay information may therefore leave your device as well.

UK rules on storing or reading information on a device (PECR regulation 6) cover anything stored, not only personal data. To confirm: What else does the Game, or any component inside it, store on the device — an identifier, a settings file, a crash log — and does any of it survive uninstall?

Why we may process data

The store declarations say which categories of data the Game may collect. They do not say why, and this policy will not invent purposes. This section is therefore incomplete and the policy is not in a state to be published: the UK GDPR requires a purpose and a lawful basis for each kind of processing.

To confirm: For each category declared on Google Play — App activity, App info and performance, Device or other IDs — what is the purpose: fixing crashes, measuring how the Game is used, advertising, or something else?

To confirm: Which UK GDPR lawful basis applies to each purpose, and does the Game ask for consent inside the app where consent is required — for example before an advertising identifier is read?

Sharing

The Google Play declaration states that no data is shared with any third party.

That answer must be positively verified, not assumed correct. Crash, performance and identifier data is usually produced by a component supplied by another company, and data reaching that company would normally count as sharing. To confirm: Does any other company receive data from the Game? The identical "no data shared with third parties" answer filed for another FREEDOM LLP title was contradicted by that build's own advertising and analytics components, so this answer has to be verified against the shipping build rather than relied on. Name each recipient and what it receives, then correct the Google Play sharing answer.

To confirm: Is any data sent outside the United Kingdom? If so, to which countries, and under which transfer safeguard?

Security

The Google Play declaration records that data is encrypted while it is being sent. That is the only protection on record for the Game, and it covers data in transit only.

Nothing is declared about how data is held once it has been received, where it sits, or who holds it. See the review question in "Data we handle" about where data that leaves the Game goes and who receives it.

Retention

The Google Play declaration records that collected data cannot be deleted. On that filing, anything the Game collects is kept indefinitely and there is no route for you to have it erased. That cannot stand: the right to erasure applies regardless, so the position has to be fixed and the Play answer then corrected.

Neither filing states how long any category is kept, and this policy will not state a period it cannot support. To confirm: For each category declared on Google Play, how long is the data kept, and what causes it to be deleted?

The policy being replaced describes the best-time record as held only on the device and lost on uninstall. That is unverified, and the Google Play declaration lists App activity — which would cover a best time — among the data that may be collected, so this policy does not state that the record stays on the device. See the review question in "Data stored on your device".

Your rights

Under the UK GDPR you have rights over personal data about you: access to it, correction of it, erasure of it, restriction of and objection to its processing, and portability where it applies. If any processing turns out to rest on your consent, you can withdraw that consent at any time, which does not affect processing already carried out. If any data turns out to be used for direct marketing, you can object to that. To use any of these rights, email [email protected].

The Google Play declaration currently states that collected data cannot be deleted, so no deletion route is in place today. That is not compatible with the erasure right above. To confirm: What process will handle an access or erasure request, and what would a person need to give us so their data can be found when the only identifier held is a device ID? To confirm: What is the public deletion-request URL that anyone can reach without installing the Game or signing into it, and will it be linked from the Play Data safety form when the "data cannot be deleted" answer is corrected? Email is an additional route, not a sufficient one. No response time is stated here until that process exists.

If you are unhappy with how FREEDOM LLP handles your data, you can complain to the Information Commissioner's Office, the UK supervisory authority.

Children

The App Store lists the Game with an age rating of 4+, so young children can reach it. The policy being replaced says the Game is not intended for children under 13. The two positions do not match, and the audience must be settled before this policy is published. To confirm: Is the Game directed at children? What target audience is declared on Google Play, and does the 4+ Apple rating reflect the intended audience?

If children can reach the Game and it collects device identifiers, stricter rules apply, including the ICO's Age Appropriate Design Code. To confirm: If any advertising or analytics component is present, is it configured for a child audience on both platforms?

Changes

This policy may be updated. Changes take effect when the updated version is posted, and the effective date at the top is the date this version was last updated.

To confirm: At what address will this policy be published, and will the privacy links in App Store Connect and in the Play Console — including the URL field on the Data safety form — be repointed to it before it takes effect? The version it replaces is at https://battleofgeniuses.com/pick-the-lock-privacy/ and needs a permanent redirect.

If what the Game does with data changes, this policy will be updated. To confirm: Will FREEDOM LLP commit to correcting the App Store label and the Play Data safety form alongside this policy, so that all three say the same thing?

Contact

FREEDOM LLP, company number OC407608, 101 King's Cross Road, London WC1X 9LP, United Kingdom.

Email [email protected] with any question about this policy or about data handled through the Game — subject to the mailbox confirmation noted in "Who we are". Telling us which store you installed from, and which device you use, will help us look into it.