Privacy policy for “Pawshift”

Last updated: 25 September 2026

1. Controller

Patrick Gruben
Rolandstraße 14
40476 Düsseldorf
Germany
E-mail: info@grubenhund.com
Phone: +49 160 94857908

Under the brand “grubenhund” I develop and publish games for smartphones and tablets. I am not required to appoint a data protection officer; if you have questions, write to me directly.

2. Scope

This policy covers the game “Pawshift”. The version for all games is at grubenhund.com/en/games/privacy.

Visiting the website grubenhund.com (cookies, contact form, statistics) is covered by the website privacy policy (in German).

3. In short

• You don't need to register – no name, no password.
• Your progress is stored on your device.
• We use no analytics or tracking tools of our own.
• Ads are served by Google AdMob – personalised only with your consent.
• Purchases are handled by Apple and Google; we never see payment details.

4. Progress on your device

The games store progress, settings, unlocked and purchased content locally on your device. This data does not reach us unless one of the backups described below is active. Legal basis: Art. 6(1)(b) GDPR (providing the game) and § 25(2) no. 2 TDDDG (storage on the device that is strictly necessary).

Note on device backups: if iCloud Backup on your iPhone or Android backup in your Google account is switched on, it may also back up the game data and restore it after a reinstall. Apple's or Google's privacy terms apply; we do not receive this data.

5. In-app purchases

Purchases are handled entirely by the Apple App Store or Google Play, who are separate controllers for this. We never receive payment details. The game only receives a purchase confirmation and records in your save which content you bought, so it stays unlocked. Legal basis: Art. 6(1)(b) GDPR.

6. Advertising (Google AdMob)

Some games show ads – as optional ad videos with a reward or as ad breaks between levels. They are served by Google AdMob, a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google may process in particular the advertising ID (IDFA or Android advertising ID), the IP address and the approximate location derived from it, device and OS information, ad interactions and diagnostic data.

Consent: personalised ads and access to the advertising ID and device storage require your consent (Art. 6(1)(a) GDPR, § 25(1) TDDDG). We ask for it via Google's consent dialog before any ads are loaded; you can change or withdraw it any time in the game's settings. On iPhone and iPad we also ask via Apple's App Tracking Transparency prompt. If you do not consent, Google shows limited ads at most: not personalised and without access to the advertising ID or device storage. To deliver them, Google technically processes the IP address (Art. 6(1)(f) GDPR; our legitimate interest is funding the free game).

No Ads: where a game offers a “No Ads” purchase, you will no longer see ad breaks afterwards; optional ad videos remain available.

Transfers to the USA are based on the EU-US Data Privacy Framework or Standard Contractual Clauses. More: policies.google.com/technologies/partner-sites.

7. Children and teens

Our games are not specifically directed at children under 13. Minors need parental consent for purchases. We recommend protecting purchases in the device settings (Screen Time or Google Family Link).

8. Recipients and service providers

• Google Ireland Limited – advertising via AdMob (separate or joint controllership under Google's terms)
• Apple and Google – app stores, payment processing, accounts and device backup (separate controllers)

Beyond that we do not share personal data, and we never sell data.

9. Transfers outside the EU

Some service providers are based in the USA. Where data is transferred there, this is based on the EU-US Data Privacy Framework (adequacy decision of the European Commission) or EU Standard Contractual Clauses (Art. 46(2)(c) GDPR). Cloud saves and leaderboard entries are stored on servers in Frankfurt, Germany.

10. Your rights

You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and objection (Art. 21), and you may withdraw consent at any time with effect for the future (Art. 7(3)). Write to info@grubenhund.com.

Right to object

Where we process data on the basis of legitimate interests (Art. 6(1)(f) GDPR), you may object to this processing at any time on grounds relating to your particular situation (Art. 21 GDPR). Write to info@grubenhund.com.

How to delete data yourself is explained under Delete data.

You may also lodge a complaint with a supervisory authority, for example the data protection authority of North Rhine-Westphalia (LDI NRW), Kavalleriestraße 2–4, 40213 Düsseldorf, Germany.

11. Changes

When a game changes – for example with new features or service providers – I update this policy. The version published here applies. If this English version differs from the German one, the German version prevails.