Privacy Policy — Spellsearch

Who we are

Spellsearch: The Word Puzzle is published by FREEDOM LLP, a limited liability partnership registered in England and Wales under company number OC407608. Its address for correspondence about this policy is 101 King's Cross Road, London WC1X 9LP, United Kingdom.

FREEDOM LLP publishes the app and filed its App Store privacy declarations. UK data protection law applies, including the UK GDPR and the Data Protection Act 2018. To confirm: confirm FREEDOM LLP's controller status. It turns on whether FREEDOM LLP operates any server that receives data from this app, which nothing on record establishes. To confirm: once the components built into the app are known, confirm whether any of their suppliers is a joint controller rather than a processor.

Whether other law also applies depends on where the app is offered. To confirm: is the app offered to players in the EU or EEA? If it is, EU GDPR also applies to them, and an Article 27 EU representative must be appointed and named in the Contact section before this policy is published.

• App: Spellsearch: The Word Puzzle
• App identifier: com.artadian.wordgame
• Contact: [email protected]

What this policy covers

This policy covers the Spellsearch: The Word Puzzle mobile app and the personal data handled when you use it. It does not cover the app stores themselves, or any website or app you reach from it. Those are run by other companies under their own policies. To confirm: does the app display advertising? If it does, this section must also say that adverts lead out to third-party sites under their own policies.

The app is distributed through the Apple App Store. It is not published on Google Play, so no Google Play Data safety declaration exists for it, and nothing in this policy is drawn from one. To confirm: confirm the App Store is the only distribution channel — no other store and no web build — and that no Google Play listing is planned. If a Play listing is ever created, a Data safety declaration matching this policy must be filed first.

This policy is written from the App Store privacy declarations FREEDOM LLP filed for this app. That is the only first-party record available: no build and no source code of this app could be found when this policy was drafted, so what is inside the app has not been inspected. Where a fact is missing for that reason, this policy says so instead of guessing. This version replaces a document dated 1 March 2022 that was hosted by a third party, named a different developer and a different app, and gave a personal email address as its contact. That document does not describe Spellsearch, and none of its statements are carried over.

Data we handle

In the App Store privacy declarations for this app, FREEDOM LLP declared four categories of data as collected: location, identifiers, usage data and diagnostics. All four are declared as used to track you, and all four are declared as linked to your identity.

Diagnostics is declared twice — once as linked to your identity and once as not linked to it. That is only coherent if some diagnostic data carries an identifier and some does not, so this policy does not describe diagnostics as anonymous.

The list below is the declaration itself. What sits inside each category has not been confirmed, because the app was not available to inspect. Any earlier statement that information stays on your device and is not collected does not describe this app, and it is not repeated here.

• Location — collected, linked to your identity, and declared as used to track you across other companies' apps and websites for advertising. To confirm: is this precise or coarse location, which part of the app collects it, and is it used for anything other than advertising?
• Identifiers — linked to your identity and declared as used to track you. To confirm: which identifiers does the app use — the device advertising identifier, a vendor identifier, or an identifier the app generates itself?
• Usage data — information about how you use the app, linked to your identity and declared as used to track you. To confirm: which usage events are recorded, and where are they sent?
• Diagnostics — technical data about crashes and app performance, declared as used to track you, and declared both as linked and as not linked to your identity. To confirm: which diagnostics are linked to your identity and which are not?
• To confirm: does FREEDOM LLP operate a server that receives data from this app, or does everything go straight from the app to other companies' components? The studio does run its own analytics service at api.appanalytics.ai, which two of its other titles send data to over TLS, but nothing establishes whether this app sends anything to it.

Advertising and tracking

The app tracks you. In the App Store declarations, location, identifiers, usage data and diagnostics are all declared as data used to track you. Under Apple's definition that means data from this app is linked with data collected about you by other companies, in their apps or on their websites, for targeted advertising or advertising measurement, or is passed to a data broker.

No advertising, attribution or analytics company is named in this policy. The app was not available to inspect, and the components in FREEDOM LLP's other titles are not evidence about this one: the studio's titles carry different sets of components, and one of them carries no advertising, attribution or analytics component at all. To confirm: which advertising, attribution and analytics components are built into this app, and which of them carry out cross-app tracking? To confirm: does the app itself display advertising, is it personalised by default, and is there a control inside the app to turn personalised advertising off?

On iOS, an app must ask permission before using the device advertising identifier to track you, and you can change that choice in your device settings under Privacy and Security, then Tracking. That prompt is an Apple platform control. It is not by itself consent under UK data protection law, and it does not cover the separate UK rule that requires consent before information is stored on or read from your device. To confirm: does the app present the App Tracking Transparency prompt, what changes in the app if a user declines, and is there a separate in-app consent mechanism that meets UK consent standards? In the two titles whose source was available, no first-party consent flow was found in the studio's own code, and nothing establishes the position for this app. If there is none here, the consent basis relied on below is not available and the declared tracking cannot lawfully run.

In-app purchases

The App Store declaration for this app records that it offers in-app purchases. Payment for an App Store purchase is taken by Apple in its own store, under Apple's terms and privacy policy. To confirm: confirm that all payment is handled by the app store, and that no payment or billing data reaches the app or any FREEDOM LLP server.

No purchases or financial-data category appears in the App Store declaration for this app. That absence is not by itself evidence that no purchase record is handled. To confirm: what purchase information does the app, or any server FREEDOM LLP operates, receive and store — transaction identifiers, restore-purchase state, entitlement status — and is any of it linked to an identifier or to an account?

Data stored on your device

UK rules on storing information on your device, or reading information from it, apply to this app whether or not that information is personal data. What the app keeps in its own storage has not been confirmed. To confirm: what does the app store locally — game progress, settings, advertising frequency limits, consent choices — and is any of it copied off the device?

Deleting the app removes what it has stored in its own storage on your device. It does not delete data that has already been sent to other companies. To confirm: is any app data stored outside the app's own storage, for example in a device backup or a shared keychain?

This policy makes no claim about how data is protected in transit or at rest. No security measure has been confirmed for this app, and none will be stated here until it is. To confirm: do transmissions from this app use TLS, and what other security measures can FREEDOM LLP stand behind, so a short statement on how data is protected can be added here?

Why we may process data

UK data protection law requires a lawful basis for every use of personal data. The bases below follow from what was declared to the App Store. They are provisional, and several depend on facts the studio has still to confirm.

Where consent is the basis, you can withdraw it at any time. Withdrawing consent does not affect anything done before you withdrew it.

• Consent — for tracking and for use of the device advertising identifier. Location, identifiers, usage data and diagnostics are all declared as used to track you, so consent is the basis for those uses. To confirm: is consent actually collected inside the app, by what mechanism, and how does a user withdraw it for each company involved?
• Location — declared as used to track you, so consent is the basis relied on for it. To confirm: is location used for any purpose other than tracking? If so, state that purpose and its lawful basis before this policy is published.
• Performance of a contract — only if FREEDOM LLP itself processes something to deliver an in-app purchase you have paid for. To confirm: does the app offer purchase restore, and does FREEDOM LLP process anything to deliver purchases, or is entitlement handled entirely by the app store? If FREEDOM LLP processes nothing, this basis does not apply and this bullet must be removed.
• Legitimate interests — To confirm: not available on the record as it stands. The App Store declaration lists usage data and diagnostics entirely as data used to track you, with no carve-out, so both sit under consent. This basis may only be added if the studio confirms usage or diagnostics processing that happens outside the tracking components, and states the interest relied on.
• To confirm: can the app still be used normally if a user declines tracking and declines advertising consent?

Sharing

Because the app is declared as tracking you, data about you is shared with, or matched against data held by, other companies. That is what the tracking declaration means in practice: your data is combined with data collected about you elsewhere for advertising purposes, or passed to a data broker. The categories of recipient that follow from that declaration are listed below.

No individual company is named. The app was not available to inspect, so the recipients are known only as categories. Nothing may be copied across from FREEDOM LLP's other titles, whose components differ from title to title. To confirm: list every company that receives data from this app — advertising networks, attribution providers, analytics providers and any data broker — and the country in which each one processes it.

Tracking of this kind normally involves companies based outside the United Kingdom. Where personal data is transferred outside the UK, it may only go to a country covered by UK adequacy regulations, or under the UK International Data Transfer Agreement or the UK Addendum to the EU standard contractual clauses. To ask for a copy of the safeguard relied on for a particular transfer, email [email protected]. To confirm: which recipients process data outside the UK, in which countries, which of those safeguards applies to each, and confirm that a copy of each safeguard can be supplied on request. To confirm: does FREEDOM LLP have a stated practice for handling legal and law-enforcement requests, and does it hold any data from this app that such a request could reach?

• Advertising networks
• Attribution and advertising measurement providers
• Analytics providers
• Any data broker to which tracking data is passed

Retention

No retention period and no retention criterion has been confirmed for any category of data from this app, either at FREEDOM LLP or at any company that receives data from it. Nothing will be published here that FREEDOM LLP cannot stand behind. To confirm: state the retention rule actually applied to each category — location, identifiers, usage data and diagnostics — by FREEDOM LLP and by each company that receives them, and add any purchase record only if it is first confirmed that FREEDOM LLP receives one.

Data held in the app's own storage on your device stays there until you clear it or delete the app.

Your rights

If UK data protection law applies to your data, you have the rights listed below, and they are free to use. To exercise one, email [email protected]. To confirm: confirm who handles rights requests at FREEDOM LLP, and that the statutory response deadline can be met, before any response time is stated in this policy. The app is declared as collecting identifiers rather than account details, so a request may need a device identifier before it can be matched to your data. To confirm: does the app use accounts or profiles? If not, which identifier must a person supply so a request can be matched, and how do they obtain it — from inside the app, or from device settings? To confirm: once the recipients are known, confirm whether corrections and erasures can be passed on to each of them, before any such commitment is stated here.

Separately from the rights below, you have the right to object at any time to your personal data being used for direct marketing, including profiling connected to direct marketing. If you object, that use must stop. To object, email [email protected].

If you are unhappy with how your data has been handled, you can complain to the Information Commissioner's Office, the UK supervisory authority, at ico.org.uk. You can complain to the ICO without contacting us first.

• Access — ask what data is held about you and get a copy
• Rectification — have inaccurate data corrected
• Erasure — ask for data to be deleted
• Restriction — ask for a limit on how data is used
• Objection — object to processing based on legitimate interests
• Portability — receive certain data in a portable form
• Withdraw consent — for anything done on the basis of consent, including tracking

Children

The App Store age rating for this app is 4+, so children can download and play it. The same declaration records that the app offers in-app purchases. Payment for those is taken by Apple, and purchases can be restricted through the device's parental controls.

That declaration also records that the app tracks users. In the UK, a child under 13 cannot give valid consent for an online service, and the ICO's Age Appropriate Design Code expects profiling and behavioural advertising to be off by default for children. The declaration records tracking for all users of this app, and no age gate or child-directed setting has been confirmed. Nothing on record shows that tracking or personalised advertising is switched off for children. To confirm: is there an age gate in the app, and are tracking and personalised advertising switched off for children? Is the app placed in the App Store Kids Category? In the two titles whose source was available, no child-directed or age-restricted setting was applied to their advertising components, and the position here is unknown. If tracking cannot be switched off for children, either the tracking declaration or the app must change before this policy is published.

The superseded document said the service is not aimed at anyone under 13. That does not match a 4+ rating, so it is not repeated. If you are a parent or guardian with a question about your child's data, email [email protected].

Changes

This policy may be updated. The current version is published at To confirm: confirm the URL at which FREEDOM LLP will host this policy, and that the App Store listing's privacy policy link will point to it before this policy goes live.

This version replaces the document dated 1 March 2022 that was hosted at a third-party address under a different app name and a different developer name, on a hosting page that injects a third-party sponsored advert. Until the privacy policy link in App Store Connect is changed, the store listing still points at that old document and at that advert. To confirm: confirm the App Store Connect privacy policy URL has been changed to the new address. This policy must not be published before that change lands. To confirm: what date does this version go live? It is shown on the page as the effective date.

If a change materially affects how your data is used, that will be said on the page.

Contact

For any question about this policy or about your data, email [email protected].

FREEDOM LLP, 101 King's Cross Road, London WC1X 9LP, United Kingdom — the address for correspondence about this policy. Registered in England and Wales, company number OC407608.