Pingvino — Privacy Policy

This policy explains how the Pingvino iOS app handles your information. The short version: Pingvino does not collect, store, transmit, or share any personal data.

1. Data we collect

None. Pingvino does not collect any personal data, usage data, analytics, device identifiers, location, contacts, photos, or any other information about you or your device.

2. Data stored on your device

Your in-game progress — coins earned, decorations purchased with in-game coins, the nickname you choose, and any redeemed promotional codes — is stored locally on your device only, using the standard iOS UserDefaults mechanism. This information never leaves your device and is removed when you delete the app.

3. Third parties

Pingvino does not use any of the following:

• No third-party analytics SDKs
• No advertising or ad networks
• No tracking technologies
• No social-network SDKs
• No crash-reporting services
• No cloud backend or server of any kind

No data is shared with, sold to, or disclosed to any third party, because no data is collected in the first place.

4. Network use

Pingvino's only network feature is an optional on-device, peer-to-peer "visit a friend's house" mode built on Apple's MultipeerConnectivity framework. When two players are physically near each other and both explicitly choose to connect, their devices exchange a small message containing:

• The nickname the player chose inside the app
• The list of in-game decoration IDs the player has purchased

This exchange happens directly between the two devices over the local network or Bluetooth. Nothing is sent to any server. Pingvino has no backend, no cloud storage, and makes no outbound internet requests.

The iOS permissions Local Network and Bluetooth are requested only to enable this opt-in feature.

5. Children's privacy

Pingvino is suitable for children and is offered in the App Store's Kids category. We take children's privacy seriously and comply with Apple's Kids category requirements and applicable laws including the Children's Online Privacy Protection Act (COPPA) and the EU General Data Protection Regulation (GDPR).

Specifically, in Pingvino:

• We do not knowingly collect any personal information from children of any age.
• There is no behavioural advertising and no advertising of any kind.
• There are no third-party analytics or tracking.
• There are no in-app purchases, no subscriptions, and no payment of any kind.
• There are no links out of the app to external websites, social media, or other apps.
• The optional peer-to-peer "visit a friend" feature requires explicit confirmation on both devices before any data is exchanged, and only nicknames and in-game cosmetic IDs are shared between the two nearby devices.

If you are a parent or guardian and have any concerns, please contact us using the email address below and we will respond promptly.

6. Promotional codes

Pingvino includes an in-app "CODE" feature that lets players enter promotional codes to receive in-game coins. Entered codes are checked locally against a list inside the app and stored locally on the device only. Codes are not transmitted anywhere and are not associated with any user account.

7. Your rights

Because Pingvino does not collect any personal data, there is no personal data for us to access, correct, export, or delete on your behalf. To remove all data the app has stored on your device, uninstall the app from iOS.

8. Security

Data that stays on your device is protected by the same security mechanisms that iOS provides to every app. Peer-to-peer connections use the encryption provided by Apple's MultipeerConnectivity framework (encryptionPreference: .required).

9. Changes to this policy

If this policy changes, the updated version will be posted at this URL with a new effective date. Material changes will be reflected in the app's App Store listing.

10. Contact

Questions about this policy or about Pingvino can be sent to jarle@jarlehansen.net.