Double Ten privacy policy

This policy covers Double Ten, our number puzzle game for iPhone, iPad and Android. It says what the app stores, what it sends and to whom, why, how long it is kept, and what you can ask us to do about it. The privacy notice for violabs.co.uk covers this website.

Double Ten is not released yet. This policy describes the app as it is built today. If a version of the app stores or sends anything new, we will update this policy before that version is released.

Who we are

Vio Labs LTD makes Double Ten and is the controller of the personal data described here. The company is registered in England and Wales, company number 17466165, with its registered office at 128 City Road, London EC1V 2NX.

To ask about your data or make a request, email contact@violabs.co.uk or write to us at the registered office.

In short

There are no accounts, no chat, no analytics and no crash reporting. We do not sell personal data.
Your progress, your coins and lives, your settings and a log of your play stay on your device.
The app sends nothing to us.
Adverts come from Google AdMob, and only when you choose to watch one. Every advert request asks for adverts suitable for children, and none is personalised.
This version has no purchases.

On your device

The app keeps these on your device only:

the levels you have finished, the level you are playing and the moves you have made in it, so that undo works and you can carry on later;
your daily puzzle in progress, the days on which you have earned a medal, the chapters you have finished and the colour palette you chose;
your settings: sound, haptics, motion, larger numbers and whether the game offers adverts;
your coins and lives, when your next life is due, the levels that have already paid coins, and how many adverts and advert offers there have been today and when, so that the daily limits work;
a log of your play, described below.

On Android, the progress is kept in the app's private settings and the log in a file in the app's private storage. On iPhone and iPad, they are kept in the app's own settings and documents folder. None of this is sent to us. Uninstalling the app deletes all of it.

Reset saved progress, in Settings, deletes your finished levels and the level in progress. It keeps your coins, lives, daily puzzle, medals, colours, settings and the log of your play.

On Android, the app keeps all of its data out of Android's backup to your Google account and out of the transfer of apps to a new phone. On iPhone and iPad, backups to iCloud or to a computer may include it, as they do for other apps. We cannot see these backups.

Google's software also keeps your advertising choices, and some files of its own, on your device, as described under "Advertising" below.

The log of your play

The app keeps a log of what happens as you play: when a level or the daily puzzle starts or resumes, each domino you select, flip or place and where, moves that are not allowed and why, undos, restarts, hints, levels finished, lives lost, advert offers and whether you chose to watch, and when you export the log or reset your progress. Each entry has the time, the version of the app, the level, counts such as the moves and clears so far, and how long you have been playing it. Random references tell one session or attempt from another. The log holds no name, contact details, device identifier, location or record of your touches on the screen. It keeps the newest 10,000 entries and deletes older ones.

The log stays on your device. In Settings you can export it as a JSON or CSV file. The file holds the log, the version of the app and the number of older entries deleted. The app writes it to its temporary storage and opens your device's share sheet. Nothing is sent unless you choose an app and send the file yourself.

If you send us an export, we use it only to improve the game, and we keep it only for as long as we need it for that. You can ask us to delete it at any time.

Advertising

Double Ten shows a video advert from Google AdMob only when you choose to watch one, for 50 coins or one life. Adverts become available after you have finished the first 10 levels, and there can be up to 12 a day. You can ask for one from the Rewards screen. The game sometimes offers one when you finish a level, at most four times a day and at least five minutes apart, and you can turn those offers off in Settings. AdMob is provided by Google Ireland Limited for people in the UK and the European Economic Area, and by Google LLC elsewhere.

Double Ten is for a general audience that includes children, so it asks for the same protections for everyone who plays. Every advert request tells Google that it is directed at children and that the user may be under the age of consent, asks for adverts rated suitable for general audiences, and asks for non-personalised adverts.

Before the first advert in a session, the app asks Google's consent tool whether consent is needed, also telling it that the user may be under the age of consent. If Google's consent message is needed, it is shown, and an advert is requested only if the choices allow it. Settings has Ad privacy, which opens Google's privacy options where they are available and also contacts Google.

To show, measure and protect adverts, Google's software in the app may still collect your IP address and the approximate location it shows, information about your device and the app, how the adverts perform, and how you interact with them. Google uses this under its own policies, and limits what it does with requests marked as directed at children: how Google uses information from sites or apps that use its services and the Google Privacy Policy. AdMob reports to us in totals, such as the number of adverts shown.

Google's software is built into the app. The app asks it to start, and to load an advert, only after you tap to watch one. On Android, part of it starts when the app opens, as it does in other apps that include it, and it may create files of its own in the app's storage. If you never watch an advert, the app makes no advert requests.

On iPhone and iPad, the app does not ask for permission to track you through Apple's App Tracking Transparency, so Google's software cannot read your device's advertising identifier.

On Android, the app removes the permission that Google's software uses to read your device's advertising ID, and the permissions for Android's own advertising services. On Android 13 and later, this means Google's software cannot read your advertising ID.

Where consent is needed, the legal basis for advertising is consent. Otherwise it is our legitimate interest in paying for the free game with optional adverts.

Purchases

This version of Double Ten has no purchases. The app contains code for a pack of coins, kept behind a question for a parent, but it is switched off. In this version the parent area says that coin packs are unavailable, and the app does not ask Apple or Google for a price, does not start a purchase and does not contact any service of ours. Because the code is in the app, the Android version declares Google Play's billing permission, but it does not use it.

Before any purchase or other online feature is switched on, we will update this policy to say what it stores and sends.

What the app does not do

The app has no accounts, no sign-in and no chat. It runs no analytics and no crash reporting, and sends nothing to us. It does not ask for your location, contacts, photos, camera or microphone. We do not sell personal data.

Children

Double Ten is for a general audience, including children. It does not ask for anyone's name, age or contact details, and it has no chat and nothing social. Its adverts are optional and requested as described under "Advertising": directed at children, for general audiences and not personalised. A parent can turn off the game's advert offers in Settings. If you have a question about a child's use of the app, email contact@violabs.co.uk, and if a child has sent us an export or an email, we will delete it.

How long it is kept

On your device: until you uninstall the app, or longer in your own iPhone or iPad backups. Resetting your progress deletes your finished levels and the level in progress.
The log of your play: the newest 10,000 entries, on your device only.
An exported file: in the app's temporary storage until your device clears it, and wherever you choose to send it.
An export you choose to send us: only for as long as we need it to improve the game.
Email you send us: only for as long as we need it to deal with what you asked.

Your rights

Under UK GDPR you can ask for a copy of the personal data we hold about you, and ask us to correct it, erase it, restrict how we use it or stop using it. Where it applies, you can also ask for your data in a portable format. Email contact@violabs.co.uk or write to us at the registered office above.

What Double Ten stores stays on your device and never reaches us unless you send it to us yourself, so you can delete it by uninstalling the app. For data that Google collects for adverts, use Google's own tools, or contact Google.

You can also complain to the Information Commissioner's Office: ico.org.uk/make-a-complaint.

Changes to this policy

If a new version of the app stores or sends anything new, we will update this policy before that version is released. The date of the last change is at the end of this page.