Privacy Policy
Version 1.0 | Last Updated: January 5, 2026
1. Introduction
Welcome to Olhoten Apps ("we," "our," or "us"). We are committed to protecting your privacy and ensuring you have a positive experience when using our mobile applications. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use any of our applications ("Apps").
Developer: Olhoten Apps
Contact Email: olhoten.apps@gmail.com
We act as the Data Controller for personal data collected through our Apps. This means we determine the purposes and means of processing your personal data.
1.1 Applications Covered
This Privacy Policy applies to all mobile applications published by Olhoten Apps, including but not limited to:
- Ten Twins - Number Puzzle Game
...and any other applications published under the Olhoten Apps developer account on Google Play Store and Apple App Store.
1.2 Age Restriction
All Olhoten Apps applications are intended for users aged 13 and older. We do not knowingly collect personal information from children under 13. Our Apps are not directed to children under 13 and are not designed for use by children under 13.
1.3 Consent and Legal Basis
When you first launch any of our Apps, you will be presented with a consent screen to choose your privacy preferences. All users worldwide receive this consent prompt, regardless of location.
Your choices include:
- Analytics (help us improve the app)
- Personalized advertising (see relevant ads)
- Attribution tracking (understand how you found us)
You can use our Apps regardless of your choices, and you can change your preferences at any time in Settings > Privacy.
Legal Basis for Processing (GDPR):
| Processing Activity | Legal Basis | Can You Object? |
|---|---|---|
| Core app functionality | Contract (necessary to provide service) | No |
| Saving app progress | Contract | No |
| Processing purchases | Contract | No |
| Crash reporting | Legitimate Interest (app stability) | Yes* |
| Security and fraud prevention | Legitimate Interest | Yes* |
| Analytics | Consent | Yes |
| Personalized advertising | Consent | Yes |
| Attribution tracking | Consent | Yes |
| Push notifications | Consent | Yes |
*For legitimate interest processing, you may object, but we may continue processing if we demonstrate compelling legitimate grounds.
2. Information We Collect
We collect information automatically when you use our Apps and through third-party services integrated into our Apps. We do not collect sensitive personal information such as precise geolocation, racial/ethnic origin, religious beliefs, health data, sexual orientation, or biometric data.
2.1 Information Collected Automatically
| Data Type | Examples | Purpose | Legal Basis |
|---|---|---|---|
| Device Information | Device model, OS version, unique device identifiers | App functionality, crash reporting | Contract / Legitimate Interest |
| App Usage Data | Scores, progress, features used, session duration | Analytics, app improvement | Consent |
| App Progress | Achievements, in-app currency balance, preferences | Core functionality, cloud sync | Contract |
| Crash Data | Crash logs, error reports, diagnostic data | Bug fixing, stability improvement | Legitimate Interest |
| Advertising Data | Ad interactions, ad views, advertising identifiers | Displaying relevant ads | Consent |
| Attribution Data | Install source, campaign data, conversion events | Marketing analytics | Consent |
| Purchase Data | Transaction history, purchase timestamps | Processing in-app purchases | Contract |
2.2 Information We Do NOT Collect
- Precise location data (GPS coordinates)
- Contact lists or address books
- Camera or microphone data
- Health or fitness data
- Financial account information (handled by Apple/Google)
- Social Security numbers or government IDs
- Biometric data
- Contents of messages or communications
3. How We Use Your Information
3.1 Core App Functionality (Legal Basis: Contract)
- Providing app features and functionality
- Saving and synchronizing your progress
- Processing in-app purchases
- Managing your preferences
3.2 Analytics and Improvement (Legal Basis: Consent)
- Understanding how users interact with our Apps
- Identifying popular features and areas for improvement
- Measuring the effectiveness of updates
- A/B testing new features
3.3 Security and Stability (Legal Basis: Legitimate Interest)
- Identifying and fixing bugs and crashes
- Preventing fraud and abuse
- Ensuring app security and integrity
3.4 Advertising (Legal Basis: Consent)
- Displaying advertisements (for non-premium users)
- Measuring ad performance
- Providing personalized ads based on your interests (with your consent)
- Serving contextual (non-personalized) ads (without consent)
3.5 Communications (Legal Basis: Consent)
- Sending push notifications (with your permission)
- Notifying you about rewards, events, and updates
- Responding to your inquiries
4. Third-Party Services and Data Sharing
We use trusted third-party services to provide certain features. These services act as Data Processors on our behalf and process data according to our instructions and their own privacy policies.
4.1 Firebase (Google)
| Service | Data Collected | Purpose |
|---|---|---|
| Firebase Analytics | App usage events, device info, user properties | Analytics |
| Firebase Crashlytics | Crash reports, device info, app state | Crash reporting |
| Cloud Firestore | App progress data | Cloud save sync |
| Firebase Cloud Messaging | Push notification tokens | Push notifications |
| Firebase Remote Config | App configuration data | Feature management |
Firebase Privacy Policy: firebase.google.com/support/privacy
4.2 RevenueCat
Handles in-app purchase processing and subscription management.
RevenueCat Privacy Policy: revenuecat.com/privacy
4.3 AppLovin MAX (Advertising)
Ad mediation platform that may serve ads from multiple advertising networks. We request your consent before collecting data for personalized advertising.
AppLovin Privacy Policy: applovin.com/privacy
4.4 AppsFlyer (Attribution & Analytics)
Helps us understand how users discover our Apps and measure the effectiveness of marketing campaigns.
AppsFlyer Privacy Policy: appsflyer.com/legal/privacy-policy
4.5 Data Sharing Summary
We do NOT sell your personal information.
We share data with third parties only:
- To provide services described above (Data Processors)
- When required by law or legal process
- To protect our rights, safety, and property
- With your explicit consent
- In connection with a merger, acquisition, or sale of assets (with notice)
5. Data Retention
| Data Type | Retention Period | Deletion Method |
|---|---|---|
| App progress (local) | Until you delete the App or clear data | Device settings or uninstall |
| App progress (cloud) | Until you delete your account or request deletion | In-app account deletion |
| Analytics data | 14 months (Firebase default) | Automatic expiration |
| Crash reports | 90 days | Automatic expiration |
| Purchase records | As required by law (typically 7 years) | Legal retention requirement |
| Push notification tokens | Until you disable notifications or delete the App | Device settings |
| Attribution data | 24 months maximum | Automatic expiration |
6. Your Rights and Choices
6.1 Universal Rights (All Users)
| Right | How to Exercise |
|---|---|
| Access your data | Settings > Privacy or contact us |
| Delete local data | Device Settings > Apps > Clear Data or uninstall |
| Delete cloud data | Settings > Account > Delete Account and Data |
| Opt-out of analytics | Settings > Privacy > toggle off Analytics |
| Opt-out of attribution | Settings > Privacy > toggle off Attribution |
| Opt-out of personalized ads | Settings > Privacy > toggle off Personalized Ads |
| Disable push notifications | Device Settings > Apps > Notifications |
| Change consent preferences | Settings > Privacy (at any time) |
6.2 European Union Users (GDPR)
If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have additional rights under GDPR:
- Right to Access - Request a copy of your personal data (30 days)
- Right to Rectification - Request correction of inaccurate data (30 days)
- Right to Erasure - Request deletion of your personal data (30 days)
- Right to Restrict Processing - Request limitation of data processing (30 days)
- Right to Data Portability - Receive your data in a portable format (30 days)
- Right to Object - Object to processing based on legitimate interests (30 days)
- Right to Withdraw Consent - Withdraw consent at any time (Immediate)
To exercise your GDPR rights: Email us at olhoten.apps@gmail.com with "GDPR Request" in the subject line.
6.3 California Residents (CCPA/CPRA)
California residents have rights under CCPA/CPRA including: Right to Know, Right to Delete, Right to Correct, Right to Opt-Out, Right to Non-Discrimination.
We do NOT sell your personal information.
To submit a CCPA/CPRA request: Email us at olhoten.apps@gmail.com with "CCPA Request" in the subject line.
7. Children's Privacy
All Olhoten Apps applications are NOT intended for children under 13 years of age.
We do not knowingly collect, use, or disclose personal information from children under 13. Our Apps are rated:
- Google Play: Rated for Everyone 10+ or Teen
- App Store: Rated 12+ or higher
Parents and Guardians: If you believe your child under 13 has accessed any of our Apps and provided personal information, please contact us immediately at olhoten.apps@gmail.com. We will investigate and delete any children's data within 48 hours.
8. Data Security
We implement appropriate technical and organizational measures to protect your information:
- Encryption in Transit: All data transmitted using TLS 1.2+ encryption
- Encryption at Rest: Cloud data stored in encrypted Firebase databases (AES-256)
- Secure APIs: API calls authenticated and encrypted
- Access Controls: Limited access to user data on need-to-know basis
Important: No method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.
9. International Data Transfers
Your information may be transferred to and processed in countries other than your country of residence, including the United States.
We ensure appropriate safeguards for international transfers through Standard Contractual Clauses (SCCs), EU-US Data Privacy Framework, and Data Processing Agreements with all service providers.
10. Advertising and Tracking
Non-premium users see advertisements in our Apps served through AppLovin MAX.
Ad personalization:
- With consent: We show personalized ads based on your interests
- Without consent: You will see contextual (non-personalized) ads
Premium subscribers do not see any advertisements.
Opt-out of personalized ads:
iOS: Settings > Privacy & Security > Tracking
Android: Settings > Google > Ads > Opt out of Ads Personalization
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of material changes by posting a prominent in-app notice. We encourage you to review this Privacy Policy periodically.
12. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy, please contact us:
Email: olhoten.apps@gmail.com
Subject Line Guidelines:
- General questions: "Privacy Question"
- GDPR requests: "GDPR Request - [Your Request Type]"
- CCPA requests: "CCPA Request - [Your Request Type]"
- Data deletion: "Data Deletion Request"
- Children's data concerns: "URGENT: Children's Data"
| Request Type | Response Time |
|---|---|
| General questions | 14 days |
| GDPR requests | 30 days |
| CCPA requests | 45 days |
| CCPA opt-out | 15 business days |
| Children's data | 48 hours |
By using any Olhoten Apps application, you acknowledge that you have read and understood this Privacy Policy.
This Privacy Policy complies with GDPR, CCPA/CPRA, COPPA, LGPD, and other applicable privacy regulations.
Version: 1.0 | Effective Date: January 5, 2026