Flippy Walls

Flippy Walls Privacy Policy

Version 1.0. Effective date: 23 September 2026.

This document explains what the Flippy Walls game and its website do with your data. The contract of use — what you can do with the game, what is paid for and what is not guaranteed — is a separate document: the Terms of Use.

In three sentences

Flippy Walls is played with no account and no sign-up, and it does not ask you for any personal data: high scores, coins and preferences are stored only on your device. The only things that can leave the game are anonymous analytics if you give your consent, the validation of any purchases you make and the score you send to Game Center. There is no advertising, no cross-app tracking and no data is sold to anyone.

1. Who the controller is

The controller is Somia Digital. You can write to us at hola@somia.digital about any privacy matter. The complete identification details are in the legal notice.

2. The principle: everything stays on your device

Flippy Walls has no accounts, no server of its own and no database of ours with player data. All of this lives on your device and is not copied anywhere:

  • your high scores;
  • your coins and what you have unlocked;
  • your game preferences, including your answer about analytics.

If you delete the game, all of this is deleted with it. We have no copy of it and cannot restore it for you. Character pack purchases can be recovered with the restore purchases option (section 4); coins cannot.

3. Analytics: only if you give your consent

To understand how the game is played and to improve it, we use GameAnalytics. By default nothing is sent: the game asks whether you consent and, unless you say yes, no analytics data leaves it.

If you consent:

  • the game creates a random, anonymous identifier (a UUID) on your device, which we do not link to any name, email or account;
  • your game sessions and a few events are sent: game start, death (with the cause and the height you reached), new high score and continuing the game;
  • technical data is added: the platform, the iOS version, the device model and manufacturer and the game build.

No personal data, no advertising identifier (IDFA) and no cross-app tracking are involved. The game does not use Apple’s App Tracking Transparency because it tracks no one, and it shows no ads.

You can withdraw your consent whenever you like in the game’s Settings. From that moment on, nothing more is sent.

Who receives the data. GameAnalytics ApS (Pilestræde 58, Copenhagen, Denmark) acts as a processor (article 28 of the General Data Protection Regulation, GDPR) under its Developer Policy. Under its Data Processing Addendum (updated on 6 July 2023), the data is stored in the United States (Amazon Web Services, us-east-1 region), with the sub-processors AWS, Google Cloud and Imply, also in the United States. The transfer relies on the European Commission’s standard contractual clauses.

4. In-game purchases

Flippy Walls is free and has optional purchases (coin packs and character packs). They are charged by Apple through your App Store account: we do not see your card, your name or your address.

To validate purchases and keep their history we use RevenueCat (RevenueCat, Inc., United States). What is sent there is an anonymous identifier of the app and the purchase data; your name and email are not sent. The transfer to the United States relies on standard contractual clauses.

In the game you can restore your purchases of character packs. Coins are consumable and are not restored. Refunds are handled by Apple, not by us, at reportaproblem.apple.com.

5. Game Center

Leaderboards and achievements run on Game Center, Apple’s service, and on your Game Center profile. The game sends it your score and the achievements you unlock. Your Game Center profile data is processed by Apple under its own privacy policy; we neither receive nor store it.

6. Notifications

The game’s reminders are local notifications: they are scheduled by your device, they do not go through any server and we do not use push notifications. You can turn them off whenever you like in iOS Settings.

7. Gameplay clips

If you record a clip of your game (with Apple’s ReplayKit), the clip stays on your device. It only leaves it if you decide to share it, and wherever you choose.

8. The website and the support form

The flippywalls.somia.digital site is static HTML and CSS, with no JavaScript: it sets no cookies, does not use browser storage, loads no third-party scripts or fonts and does no analytics. It is hosted by Netlify, Inc. (United States), which acts as a processor and logs technical access data to operate and protect the service.

On the home page there is a support form. It is the only thing on the site that collects data, and only if you fill it in.

  • What you enter: your email and your message (required) and, if you wish, your name. The form adds the language of the page you send it from, so that we can reply in the same language. You do not need to include any sensitive data.
  • What for: to read your query and reply to it. Nothing else: we do not build mailing lists, we do not send newsletters and we do not use these addresses for anything else.
  • Who stores it: Netlify (Netlify Forms) receives and stores the submission so that we can read it. The transfer to the United States relies on standard contractual clauses.
  • How long: until the query is resolved, and a reasonable time afterwards in case there is a follow-up. Then it is deleted.
  • Legal basis: your consent (article 6(1)(a) GDPR), which you give by sending the form, and our legitimate interest (article 6(1)(f)) in attending to people who write to us and in preventing spam.
  • The form includes a hidden honeypot field for bots, which nobody should fill in.

If you would rather not use the form, you can write to app-support@somiadigital.com with questions about the game. To exercise your privacy rights, write to hola@somia.digital.

9. How long data is kept

  • On your device: for as long as you have the game installed. That is up to you.
  • At GameAnalytics: its policy does not set a specific retention period. When the service ends, it deletes or returns the data if we ask it to.
  • At RevenueCat: the purchase history, associated with the anonymous identifier, for as long as necessary to validate purchases and be able to restore them.
  • In the support form: until the query is resolved and a reasonable time afterwards.

10. Legal basis and where the data is processed

  • The data that stays on your device is not processed by us: it does not leave your phone or tablet.
  • Analytics is based on your consent (article 6(1)(a) GDPR), which also covers the access to your device required by article 22(2) of Law 34/2002 on information society services and e-commerce (LSSI-CE). You give it and withdraw it within the game.
  • Purchases and their validation are based on the performance of the contract (article 6(1)(b)).
  • The support form is based on your consent (article 6(1)(a)) and on our legitimate interest (article 6(1)(f)).

Some data is processed outside the European Economic Area, in the United States: analytics data (GameAnalytics and its sub-processors), purchase data (RevenueCat) and website and form data (Netlify). In all three cases, with the safeguards of Chapter V of the GDPR (standard contractual clauses). Apple processes App Store and Game Center profile data under its own privacy policy.

11. Your rights

You have the right to access your data, rectify it, erase it, restrict its processing or object to it, the right to data portability and the right to withdraw your consent at any time. To exercise these rights, write to hola@somia.digital. You can also lodge a complaint with the Spanish Data Protection Agency (AEPD) at aepd.es.

In practice, and because it is quicker than writing to us:

  • Stop analytics: withdraw your consent in the game’s Settings.
  • Delete what is on your device: delete the game.
  • Turn off notifications: in iOS Settings.

One thing, in all honesty: because the analytics identifier is anonymous and we do not link it to any name or email, we will usually be unable to tell which data is yours. If you have any question or request, write to us anyway and we will do what we can, without asking you for personal data to find out.

12. Minors

Flippy Walls is rated 4+ on the App Store. That is a rating of the game’s content, not an age requirement for the contract.

The Terms of Use set a minimum age of 14 to accept them on your own behalf, which is the age from which Spanish law (article 7 of Organic Law 3/2018, the LOPDGDD) allows a person to consent to the processing of their data. Under 14, the game can be played with the permission and supervision of the person who holds parental authority or guardianship over the minor, who is the one who decides whether to give consent to analytics. Purchases are always made by the Apple account holder, who can use Apple’s tools such as “Family Sharing” and “Ask to Buy”.

13. Security

We do what is reasonable to protect the little that leaves your device: we store no identity, analytics is anonymous and optional, and payments do not go through us. No system is infallible, and to the fullest extent permitted by applicable law we are not liable for unauthorised access that is not attributable to us.

14. Changes to this policy

If what the game or the website does changes, this document changes before, not after, and the version and date at the top are updated.

15. Contact

Write to us at hola@somia.digital. The Catalan version of this document prevails; the other two are translations.