EARWORM

Privacy Policy

Last updated: 2 June 2026

1. Data Controller

The controller of your personal data within the meaning of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR") is Robert Ratajczak, a sole trader operating under the business name ROBERT RATAJCZAK, Tax ID (NIP) 6972389419.

For matters related to the processing of personal data, contact: contact@earworm.page.

2. Scope of Processed Data

In connection with using the EarWorm game (available as mobile apps for Android, Android TV and iOS, and in party mode via a web browser), we may process the following categories of data:

• Device identifier (an anonymous UUID generated locally on the first launch of the app) — used to identify the player and to power the song repeat-avoidance mechanism between games.
• Google account identifier (optional, only if you sign in with a Google account) — a pseudonymous identifier that lets us link games across devices.
• Player nickname in party mode — the name you enter when joining a game, visible to other participants in the same session.
• Gameplay data — the history of shown songs, results (guessed / skipped / not guessed), and the number of rounds.
• IP address and technical request data (User-Agent, HTTP method, URL path) — in server logs, for the purposes of security, abuse detection and rate limiting.
• Advertising identifier (AAID on Android, IDFA on iOS) — a pseudonymous device identifier used by the Google AdMob advertising network to serve in-app ads. Details in section 7 "In-app advertising".

We do not collect your name, home address, phone number or payment data. The EarWorm app does not use its own cookies. In connection with serving ads, your device's advertising identifier may be processed (see section 7).

3. Purposes and Legal Bases for Processing

• Providing the game service (delivering songs to guess, saving results, running party mode) — necessary for the performance of a contract for the provision of electronic services (Art. 6(1)(b) GDPR).
• Ensuring the security of the service (server logs, protection against abuse, rate limiting) — the legitimate interest of the controller (Art. 6(1)(f) GDPR).
• Repeat-avoidance mechanism (remembering a player's recent games to vary subsequent rounds) — the legitimate interest of the controller in ensuring entertainment quality (Art. 6(1)(f) GDPR).
• Serving in-app advertising — displaying ads (personalised or non-personalised) via the Google AdMob advertising network. Legal basis: your consent expressed in the in-app ad privacy choice dialog (Art. 6(1)(a) GDPR) — for personalised ads; the legitimate interest of the controller in funding a free-to-play app (Art. 6(1)(f) GDPR) — for non-personalised ads.

4. Data Retention Period

• Player and gameplay data — for the period you use the app and for the time necessary to operate the repeat-avoidance mechanism (typically: the most recent games of a given device).
• Server logs (including IP addresses) — for a period of 30 days, after which they are automatically deleted.
• Party sessions — deleted when the game ends or during periodic cleanup of inactive data.

5. Data Recipients

Your data may be disclosed to the following categories of recipients:

• providers of hosting and server infrastructure services on which EarWorm runs;
• the Google authentication service provider (only to the extent necessary to perform sign-in, when you use that option);
• Google LLC and Google group entities as the operator of the AdMob advertising network — in respect of the advertising identifier, IP address, technical request data and information about ad interactions (details in section 7);
• state authorities entitled to receive data under applicable law.

We do not sell or share your data with third parties for marketing purposes.

6. Transfers of Data Outside the EEA

As a rule, your data is processed on servers located within the European Economic Area. If you use Google sign-in, some data may be processed by Google LLC under the terms described in Google's privacy policy.

Data processed in connection with serving ads (Google AdMob) may be transferred to Google LLC in the United States. The transfer is based on the European Commission's adequacy decision of 10 July 2023 regarding the EU-US Data Privacy Framework, to which Google LLC has adhered.

7. In-App Advertising

We display ads via the Google AdMob advertising network, which lets us offer the EarWorm app free of charge.

On first launch, we show a Google User Messaging Platform ("UMP") consent dialog where you decide whether you accept personalised ads. You can change your choice at any time in the app's settings under Ad privacy.

Regardless of your choice, AdMob processes a limited set of data necessary to serve ads:

• the device's advertising identifier (AAID on Android, IDFA on iOS);
• IP address and technical device and request data (model, operating system, language, app category);
• information about ad interactions (impressions, clicks, exposure time).

Personalised ads are shown only after you grant your consent in the UMP dialog. They may involve profiling based on your activity in other apps and services of Google's advertising partners (Art. 6(1)(a) GDPR in conjunction with Art. 22 GDPR — with the right to withdraw consent at any time).

Non-personalised ads are shown based on context (e.g. language, game category, country) and do not require your consent; in this case AdMob does not build a marketing profile of you.

The retention period for advertising data on Google's side is set by Google's policies; as a rule, the advertising identifier is used until you reset it in your device settings.

For details on how Google processes advertising data, see:

• Google Privacy Policy;
• AdMob Ads Policy.

8. Your Rights

In connection with the processing of your personal data, you have the following rights under the GDPR:

• the right of access to your data (Art. 15 GDPR);
• the right to rectification of your data (Art. 16 GDPR);
• the right to erasure of your data ("the right to be forgotten", Art. 17 GDPR);
• the right to restriction of processing (Art. 18 GDPR);
• the right to data portability (Art. 20 GDPR);
• the right to object to processing based on a legitimate interest (Art. 21 GDPR);
• the right to withdraw consent to processing (including consent to personalised ads) at any time, without affecting the lawfulness of processing carried out before its withdrawal (Art. 7(3) GDPR) — via the app's Ad privacy settings;
• the right to lodge a complaint with the supervisory authority — the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warsaw, Poland).

To exercise the above rights, write to contact@earworm.page. We will respond within 30 days of receiving the request.

9. Automated Decision-Making

Your data is not subject to automated decision-making that produces legal effects concerning you, nor to profiling within the meaning of Art. 22 GDPR.

10. Voluntary Provision of Data

Providing data is voluntary but necessary to use the EarWorm game. Failure to provide device-identifying data makes it impossible to provide the service.

11. Changes to the Privacy Policy

We reserve the right to amend this privacy policy. We will announce significant changes in the app and on the earworm.page website. The current version is always available at earworm.page/privacy.

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