01 Who is responsible
Daniel Piech, operating under the developer name Clevr Apps, based in Poland, is responsible for Twin Shadows and for personal information received in connection with support enquiries.
Privacy contact: premium53156@gmail.com.
Policy address: https://clevrapps.com/twinshadows/privacy-policy
02 Scope
This policy describes the current, ad-free Android version of Twin Shadows, including closed testing. It does not describe a future version containing advertising SDKs. We will update this policy and relevant disclosures before introducing advertising or other changes to personal-data processing.
03 Playing the game and information on your device
You do not need an account to play. The current game does not integrate advertising, analytics, or third-party crash-reporting SDKs, and does not automatically send gameplay information to us.
The game stores information locally to provide its features, including puzzle progress, saved constructions and drafts, gallery entries, challenge records, language preferences, and whether introductory instructions have been viewed. Feedback drafts, including an optional email address you enter, are also saved locally. These local files are not uploaded to us by the game.
Local information remains until removed by the app's available controls or by clearing the app's storage in Android settings or uninstalling the app. Clearing app storage removes saved progress as well as feedback drafts.
04 Optional email feedback
Feedback is optional and is not required to play. The feedback form prepares a message and opens your email application. You decide whether to send that message there; opening the email application does not itself send it to us.
If you send feedback, we receive your sender email address, any sender name supplied by your email service, the feedback category and message, any optional contact email entered in the form, the selected game language, and anything else you choose to include. Your email service may include ordinary message headers and other email metadata.
The current app addresses feedback to daniel.piech@outlook.com. Privacy enquiries can be sent to premium53156@gmail.com.
Please do not include passwords, sensitive personal information, or information about other people that is unnecessary for your request.
We use correspondence to answer enquiries, investigate reported problems, improve the game, and handle privacy requests. We do not use support correspondence for advertising or mailing lists.
For ordinary support correspondence, our GDPR legal basis is our legitimate interest in providing support and maintaining the game (Article 6(1)(f)), subject to your interests and fundamental rights, particularly where children are concerned. Where processing is necessary to meet a legal obligation, including applicable privacy obligations, the basis is Article 6(1)(c). We do not use correspondence for profiling or decisions based solely on automated processing that produce legal or similarly significant effects.
05 Service providers and disclosures
Email correspondence is handled through the sender's email provider and the recipient mailbox provider: Microsoft for the Outlook feedback address and Google for the Gmail privacy address. These providers process information under their applicable terms and privacy notices:
- Microsoft: https://privacy.microsoft.com/privacystatement
- Google: https://policies.google.com/privacy
We do not sell personal information. We disclose correspondence only as necessary to handle the enquiry through these services, comply with applicable law, or establish, exercise, or defend legal claims.
These email services may process information outside Poland and the European Economic Area, including in the United States. Google and Microsoft describe their reliance on adequacy decisions, the EU–US Data Privacy Framework for covered transfers, and standard contractual clauses where applicable in their published privacy information. Details of these mechanisms and ways to request further information are available in Google's transfer framework notice and the Storage and processing of personal data section of Microsoft's Privacy Statement. You may also contact us with questions about transfers associated with your enquiry.
06 Retention and security
We delete support correspondence within 12 months after resolving the enquiry, or sooner where it is no longer needed. We retain information longer only where necessary for a specific legal obligation or to establish, exercise, or defend a legal claim, and only for as long as that reason applies. Information from children is subject to any shorter retention period required by applicable law.
Local game data is retained as described above. Deleting correspondence from our mailbox does not delete copies held by the sender or independently retained by their provider.
We restrict access to support correspondence and use the security controls of the relevant email services. No electronic service can guarantee absolute security.
07 Children and parents
Twin Shadows is a general-audience puzzle game, rather than a service specifically directed at young children. No account or personal information is required to play the current offline game. Suitability for children does not mean that personal information is required from them.
Parents and guardians can contact premium53156@gmail.com about their child's privacy or to request deletion of information held by us, subject to proportionate verification and applicable law.
Children should ask a parent or guardian to contact us on their behalf and should not include personal details in feedback drafts or messages. If we learn that we have received personal information from a child in circumstances requiring parental consent that has not been obtained, we will delete that information unless retention is legally required, or obtain the required parental involvement before further processing. We do not use children's correspondence for marketing or profiling.
08 Your privacy rights
Where GDPR applies, you may request access to, correction of, or deletion of personal information we hold about you, and restriction of processing. You may object to processing based on legitimate interests. Data portability and withdrawal of consent apply where the relevant legal conditions are met. These rights have statutory conditions and exceptions.
Contact premium53156@gmail.com to make a request. We may ask for information reasonably necessary to verify your identity. We cannot access or delete game files stored only on your device; you can remove them through Android's app-storage settings.
You may complain to a competent data protection authority, including the President of Poland's Personal Data Protection Office (UODO): https://uodo.gov.pl/en. You do not need to contact us first to exercise that right.
09 External services and website scope
This notice covers the Twin Shadows app and support correspondence. It does not describe the separate operation of the Clevr Apps website, including its hosting, server logs, or cookies. Email applications, Google Play, and other external services process information under their respective privacy notices.
10 Changes and contact
We will update this notice when our data practices change and revise the date above. Where required, we will provide additional notice and obtain any necessary consent before the changed processing begins.
For questions about Twin Shadows privacy, contact Daniel Piech / Clevr Apps at premium53156@gmail.com.