Privacy Policy

Engelbaher, LLC ("we," "us," or "our") operates the Panjpar Afghan Card Game mobile application (the "App").

This Privacy Policy explains how we collect, use, store, and protect your personal information when you use our App. We are committed to transparency and protecting your privacy.

1. Purpose and Scope

Panjpar is a traditional Afghan card game app that offers various gameplay modes and features, including:

• Single-player gameplay with AI opponents
• Online multiplayer connectivity
• Player progression and achievements
• Ad-supported experience with optional ad removal via in-app purchase

This policy covers all data processing activities within the App, including:

• Local data storage and processing
• iCloud synchronization of player profile data and preferences
• Online multiplayer via Firebase
• Advertising and tracking
• In-app purchases

2. Information We Collect

2.1 Data Stored Locally on Your Device

The App stores the following information on your device using iOS secure storage mechanisms. Some data may also sync via iCloud if enabled:

Game Progress (Local Only)

• Active single-player match state
• Recent game history stored on the device

In-Game Currency

• Virtual currency balance earned through gameplay and rewards
• Stored securely using iOS Keychain encryption

App Preferences and Settings

• Language and display preferences
• Game difficulty and customization settings
• Visual theme and design preferences
• These preferences can sync across your devices via iCloud

Purchase History

• Records of in-app purchases (such as ad removal)
• Managed by Apple's StoreKit framework

Note: Your iCloud account may also store synced profile data if iCloud is enabled.

All locally stored data:

• Remains on your device
• Is encrypted by iOS system-level security
• Is never transmitted to Engelbaher, LLC servers (we have no servers)
• Most local data can be removed by uninstalling the App

2.2 Data Synced via iCloud

By default, the App syncs player profile data through iCloud so it is available on your Apple devices.

Synced Profile Data

• Coins
• Unlocked items and customizations
• Player statistics and progression
• Default preferences (language, difficulty, and selection choices)

We cannot access your iCloud data, and it is encrypted and managed by Apple.

2.3 Data Collected for Online Multiplayer (Firebase)

When you use online multiplayer features, the App uses Firebase (operated by Google LLC) to facilitate matchmaking and game sessions. Multiplayer gameplay data is stored and synchronized through Firebase.

Firebase Authentication Data

• Anonymous Sign-In: Firebase generates a unique anonymous user ID. No personal information is required.
• Apple Sign-In (Optional): If you choose to sign in with Apple, we collect:
  • Apple-provided unique user ID
  • Display name (optional, you control this)
  • Email address (optional, may be Apple's private relay email)
• Authentication tokens for session management

Firebase Realtime Database Data

• User profile information (display name, user ID, activity timestamps)
• Active game session data (game state, player identifiers, turn data)
• Matchmaking and lobby information (available games, host data, status)

Data Retention and Deletion

• Game sessions are automatically deleted when games end or players disconnect
• Lobby entries are removed when you stop hosting
• User profiles persist until you delete your account or sign out
• You can request deletion of your Firebase data by contacting us

Firebase data is governed by Google's privacy practices. See Firebase Privacy and Security.

2.4 Data Collected for Advertising (Google AdMob)

Unless you purchase ad removal, the App displays advertisements using Google AdMob.

Automatic Data Collection by AdMob

When ads are displayed, Google AdMob may automatically collect:

• Device information (model, operating system version, screen size)
• IP address (for approximate location and fraud prevention)
• Ad interaction data (impressions, clicks, video completions)
• App usage data (session duration, in-app events related to ads)

Identifier for Advertisers (IDFA) and Tracking

If you grant tracking permission through App Tracking Transparency (ATT), Google may collect:

• Your device's Advertising Identifier (IDFA)
• Cross-app tracking data to serve personalized ads
• Ad attribution data via SKAdNetwork (Apple's privacy-preserving framework)

You can control tracking:

• When you first launch the App, we show a pre-alert explaining why we request tracking
• iOS then shows the system tracking permission prompt
• You can change this setting anytime: Settings → Privacy & Security → Tracking → Panjpar
• If you deny tracking, you will still see ads, but they will be less personalized

Consent Management for GDPR (User Messaging Platform)

If you are in the European Economic Area (EEA), UK, or Switzerland, we use Google's User Messaging Platform (UMP) to:

• Collect your consent for personalized ads and data processing
• Allow you to manage your privacy choices
• Comply with GDPR requirements

You can update your consent choices anytime in the App's Settings.

Google's use of advertising data is governed by Google's policies:

• Google Privacy Policy
• Google Advertising Privacy & Terms
• AdMob Data Use

2.5 Data We Do NOT Collect

We do not collect:

• Precise geolocation data
• Contact information (email, phone number, address) unless you provide it via Apple Sign-In
• Photos, camera, or microphone data
• Calendar or reminder data
• Health or fitness data
• Financial information (payment handled by Apple)
• Browsing history or other app usage
• Social media account data

3. How We Use Your Information

3.1 Game Functionality

• Track your progress, achievements, and statistics
• Save your profile data and preferences and sync them across devices
• Enable online multiplayer gameplay
• Provide rewards and incentives for gameplay activities

3.2 Advertising (If You Haven't Purchased Ad Removal)

• Display advertisements via Google AdMob
• Personalize ads based on your interests (if you grant tracking permission)
• Measure ad performance and prevent fraud

3.3 App Improvement

• Understand app stability through Apple's anonymized crash reports (if you enable "Share iPhone Analytics" in iOS settings)
• We do NOT use custom analytics SDKs beyond what Apple and Google provide

3.4 Legal Compliance

• Comply with applicable laws and regulations
• Respond to legal requests and prevent abuse

4. Data Sharing and Third Parties

4.1 Third-Party Services

We integrate the following third-party services, each with their own privacy practices:

Google LLC

• Service: AdMob (advertising), Firebase Authentication, Firebase Realtime Database
• Data Shared: Device identifiers, IP address, ad interaction data, user IDs, game session data
• Purpose: Ad serving, user authentication, online multiplayer matchmaking
• Privacy Policy: https://policies.google.com/privacy
• Data Processing Location: Google data centers worldwide (compliant with GDPR for EEA users)

Apple Inc.

• Service: iCloud (CloudKit), StoreKit (in-app purchases), Apple Sign-In, SKAdNetwork
• Data Shared: Player profile data and preferences (via iCloud), purchase receipts, Apple ID authentication tokens
• Purpose: Profile sync, purchase management, authentication, privacy-preserving ad attribution
• Privacy Policy: https://www.apple.com/legal/privacy/

4.2 No Data Sales

We do not sell your personal information to third parties. Google AdMob may use your data for targeted advertising as described in their privacy policy, but we do not directly sell data.

4.3 Service Providers

We do not employ additional service providers beyond Google and Apple.

4.4 Legal Disclosures

We may disclose information if required by law, court order, or government regulation, or to protect our rights and safety.

5. iCloud Synchronization

By default, the App uses iCloud to sync player profile data across your Apple devices. You can turn this off in iOS Settings.

• Coins
• Unlocked items and customizations
• Player statistics and progression
• Default preferences (language, difficulty, and selection choices)

How iCloud Sync Works:

• Profile data is stored in Apple's iCloud servers, encrypted by Apple
• Accessible only to you via your Apple ID
• We cannot access your iCloud data
• You can disable iCloud sync: Settings → [Your Name] → iCloud → Panjpar → Toggle Off

iCloud synchronization is governed by Apple's Privacy Policy.

6. Data Security

6.1 On-Device Security

• All local data is protected by iOS Data Protection (encryption at rest)
• Keychain storage uses hardware-backed encryption
• App sandbox prevents access by other apps

6.2 Transmission Security

• Firebase communication uses HTTPS/TLS encryption
• AdMob ad requests use HTTPS

6.3 Your Responsibility

To protect your data:

• Use a strong device passcode and enable Face ID/Touch ID
• Keep iOS up to date
• Do not jailbreak your device
• Enable "Find My iPhone" for remote wipe capability
• Protect your Apple ID credentials

6.4 Data Breach Notification

In the unlikely event of a data breach affecting your personal information, we will notify you and relevant authorities as required by law.

6.5 Reporting Security Issues

If you discover a security vulnerability, please contact us at privacy@engelbaher.com.

7. Data Retention and Deletion

7.1 Local Data

• Stored on your device until you delete the App
• Single-player match state is stored locally and is not synced
• You can delete individual game history entries within the App

7.2 iCloud Data

• Profile data remains in iCloud until you disable iCloud for the App or delete your iCloud account
• Coins are also stored locally to help restore your balance across installs
• Managed by Apple, not by us

7.3 Firebase Data

• Game sessions are deleted automatically when games end or players disconnect
• User profiles persist while you remain signed in
• To delete your Firebase account data, contact us at privacy@engelbaher.com

7.4 Advertising Data

• Managed by Google AdMob according to their retention policies
• You can reset your advertising identifier: Settings → Privacy & Security → Apple Advertising → Reset Advertising Identifier

7.5 Backup Data

• If you enable iCloud Backup or local iTunes/Finder backup, app data may be included
• Backups are managed by Apple or your backup software, not by us

8. Children's Privacy

Panjpar is a general-audience game suitable for all ages. We do not knowingly collect personal information from children under 13 (or under 16 in the EEA) without parental consent.

How We Protect Children:

• No account creation required for single-player mode
• Online multiplayer supports anonymous sign-in (no personal info required)
• Ads comply with COPPA and are age-appropriate
• We do not knowingly track children for advertising purposes

Parental Controls:

• Parents can disable in-app purchases: Settings → Screen Time → Content & Privacy Restrictions → iTunes & App Store Purchases
• Parents can limit ad tracking: Settings → Privacy & Security → Tracking → Disallow apps to request tracking
• Parents can restrict multiplayer: Monitor device internet access

If we learn that we have collected personal information from a child without parental consent, we will delete it promptly. Contact us at privacy@engelbaher.com if you believe this has occurred.

9. Your Privacy Rights

9.1 European Union (GDPR)

If you are in the EEA, UK, or Switzerland, you have the following rights:

• Access: Request a copy of your data
• Rectification: Correct inaccurate data
• Erasure: Request deletion of your data ("right to be forgotten")
• Restriction: Limit processing of your data
• Portability: Receive your data in a structured, machine-readable format
• Object: Object to processing based on legitimate interests
• Withdraw Consent: Withdraw consent for data processing (e.g., ad personalization)

To exercise these rights:

• Local data: Manage directly on your device or delete the App
• Firebase data: Contact us at privacy@engelbaher.com
• AdMob data: Manage consent via the App's privacy settings or Google's My Ad Center
• iCloud data: Contact Apple Privacy

Legal Basis for Processing (GDPR):

• Contract Performance: Game functionality, multiplayer features
• Consent: Personalized advertising, tracking
• Legitimate Interests: App improvement, fraud prevention

You have the right to lodge a complaint with your local data protection authority.

9.2 California (CCPA/CPRA)

If you are a California resident, you have the following rights:

• Know: What personal information we collect and how it's used
• Delete: Request deletion of your personal information
• Opt-Out: Opt out of the "sale" or "sharing" of personal information
• Correct: Correct inaccurate personal information
• Limit: Limit use of sensitive personal information
• Non-Discrimination: We will not discriminate against you for exercising your rights

Categories of Personal Information We Collect (CCPA):

• Identifiers (device ID, IP address, advertising ID if tracking enabled)
• Commercial information (in-app purchase history)
• Internet activity (ad interactions, app usage)
• Inferences (ad preferences, game skill level)

Do We "Sell" or "Share" Personal Information?

• We do not directly sell personal information
• Google AdMob may "share" data for targeted advertising purposes (if tracking enabled)
• You can opt out by denying tracking permission or purchasing ad removal

To exercise your CCPA rights, contact us at privacy@engelbaher.com.

9.3 Other Regions

We respect privacy rights under applicable laws in Canada (PIPEDA), Australia (Privacy Act 1988), Brazil (LGPD), and other jurisdictions. Contact us to exercise your rights.

10. In-App Purchases and Payment

The App may offer optional in-app purchases, which may include:

• One-time purchases to remove advertisements
• Premium content, features, or customizations
• Virtual currency or other digital goods

Payment Processing:

• All purchases are processed by Apple's App Store via StoreKit
• We do NOT collect or store payment information (credit cards, billing addresses, etc.)
• Apple provides us with a purchase receipt to verify your transaction
• Purchase status is cached locally on your device for quick access

Restoring Purchases:

• You can restore purchases on new devices or after reinstalling
• Uses Apple's purchase verification system
• No personal or payment data is transmitted to us

Refunds and Support:

• Refund requests must be made through Apple: Request a refund
• We cannot process refunds directly

Apple's handling of payment data is governed by Apple's Privacy Policy.

11. International Data Transfers

Your data may be transferred to and processed in countries other than your own:

• Firebase/Google: Data may be stored in Google data centers worldwide. Google complies with GDPR for EEA users via Standard Contractual Clauses and EU-US Data Privacy Framework.
• Apple/iCloud: Data is stored in Apple data centers globally. Apple complies with GDPR and uses Standard Contractual Clauses.

These transfers are necessary to provide the App's functionality. By using the App, you consent to these transfers.

12. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices, legal requirements, or App features.

How We Notify You:

• We will update the "Last Updated" date at the top
• The updated policy will be posted in the App and on our website
• For material changes, we may display an in-app notification

Your Continued Use:

Your continued use of the App after changes take effect constitutes acceptance of the updated policy.

We encourage you to review this policy periodically.

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us:

Email: privacy@engelbaher.com
Website: https://engelbaher.com

Data Controller:
Engelbaher, LLC
United States

We will respond to inquiries within 30 days (or sooner as required by applicable law).

14. Governing Law and Jurisdiction

This Privacy Policy is governed by the laws of the State of Washington, United States, without regard to its conflict-of-law provisions.

Subject to mandatory local consumer-protection laws in your jurisdiction, disputes arising under this Privacy Policy may be resolved in the state or federal courts located in King County, Washington, USA.

Nothing in this section limits your statutory rights under the laws of your country of residence, including rights under the GDPR, CCPA, or other applicable privacy regulations.