Privacy Policy

Talking Blocks: Tiny Opinions ("Talking Blocks" or the "App")

Effective date: TODO(release)

The short version. Talking Blocks is for players 13 and older, and it never asks your age. There are no accounts and no sign-in of our own. Your game progress stays on your device and, if you use iCloud, in your own iCloud account, where the save is encrypted and we can't read it. If you're signed in to Apple's Game Center, your scores and achievements go to Game Center, under Apple's privacy policy. The free version shows ads from Google (and from a few ad partners that compete to show them), which collect some device and usage data, with your consent in the European Economic Area (EEA), the UK and Switzerland. Payments for No Ads and Premium are handled by Apple; we never see your payment details. To fix crashes and tune the game, the App sends crash reports and game statistics to Google, not linked to your name or any account and not used to target ads, with your consent in the EEA, the UK and Switzerland (elsewhere they are on by default), and you can turn them off in Settings. We don't run servers for the App.

1. Who we are

The App is published by Dam Tran ("we", "us", "our"). We are responsible (the "controller") for the processing of personal data described in this policy. You can reach us at contact@talkingblocksgame.com or through https://talkingblocksgame.com/support.

2. Summary of data

Data	Who receives it	Why	More
Game progress, coins, boosters, settings, your privacy choices	Stays on your device (and, with iCloud, a copy of the save in your own iCloud account that we can't read)	To run the game; to let you load your save on your other devices	Sections 4, 15
Scores, Journey star total and achievements, only if you're signed in to Game Center	Apple (Game Center)	Leaderboards and achievements	Section 7
Crash reports, errors, slowdowns and game events (levels played, ads watched, purchases), with random identifiers created for the App, your device model and approximate location (city, from IP address)	Google, on our behalf	To fix crashes and improve the game; not to target ads	Section 6
Device identifiers, approximate location (from IP address), ad and app interaction data, diagnostics	Google, and the ad partners AppLovin, Unity, Liftoff and Meta	To show, measure and protect ads; the ad companies' analytics and fraud prevention	Section 5
Purchases (No Ads, Premium) and their status	Apple (payment); the App, on your device; Google gets purchase details if game statistics are on	To sell and unlock No Ads and Premium; statistics	Sections 6, 7
Your email and message, if you contact us	Us	To answer you	Section 8

3. What we don't collect

We don't offer or require accounts, logins or profiles (Game Center is Apple's own, optional sign-in, Section 7). We don't ask for your name, email address, phone number, contacts, microphone, precise location or health data, and the App never reads your photos. Apart from the crash reports and game statistics in Section 6, the App sends nothing to us, and we don't operate servers that receive data from the App.

4. Information stored on your device and in your iCloud

Your game progress (levels, stars, scores, Daily Mood streaks), coins, boosters, settings (such as sound, music and haptics) and your ad-consent choices are saved locally on your device using standard iOS storage. This information is not sent to us or to anyone else, except your own iCloud copy (below), the Game Center scores and achievements described in Section 7 (only if you sign in to Game Center) and the game statistics described in Section 6 (counts and results, not your save). It may be included in backups of your device (iCloud or a computer), which Apple or you control.

iCloud saves. If you're signed in to iCloud, the App also keeps a copy of each device's save in your own private iCloud storage, so you can load it on your other devices or after reinstalling. The save in that copy is encrypted with keys protected by your iCloud account, and we can't read it. Nothing loads by itself: you choose a save in Settings › iCloud saves, where you can also delete the copies of your other devices. To remove every copy, delete the App from all your devices and then delete its data in your device's iCloud storage settings.

Daily reminder. If you turn on the daily reminder, iOS shows it from your own device. To pick a good time, the App uses the times you usually start playing, kept in your save (on your device and in your iCloud copy). None of it is sent to us.

Because there are no accounts, we cannot recover, restore or transfer your game progress or coins ourselves. Without an iCloud copy, they are lost if you delete the App, reset your device or switch devices. Your No Ads purchase and Premium subscription are tied to your Apple Account and can be restored at any time with Restore Purchases (Section 7).

5. Advertising by Google

The free version of the App shows ads served by Google's ad service, provided by Google LLC (Google Ireland Limited for users in the European Economic Area (EEA) and Switzerland). Google's consent tools ask for your privacy choices in the EEA, the UK, Switzerland and US states with privacy laws.

What Google may collect automatically. According to Google's disclosures, Google's ad service may collect:

Device identifiers: the Apple advertising identifier (IDFA), only if you allow tracking in Apple's prompt, and identifiers limited to this App or its developer on your device.
Approximate location: your IP address, which may be used to estimate your general location (for example, country or city). It does not use GPS or Location Services.
Advertising data: for example, which ads you have seen or tapped.
Product interactions: for example, app launches, taps and video views.
Diagnostics: crash logs, performance data (such as launch time, hang rate and energy use) and other technical diagnostics.

How it is used. Google uses this information to deliver ads, to limit how often you see the same ad, to measure ad performance, for analytics, and to detect and prevent fraud and abuse. Where you have allowed it, ads may be personalized. Google uses information it receives as described in its own policies:

Your choices about ads:

Tracking permission (all regions). The App asks for permission through Apple's App Tracking Transparency prompt before the IDFA can be used. If you choose "Ask App Not to Track", the IDFA is not available to the App or to Google. You will still see ads, but they may be less relevant. You can change this at any time in iOS Settings › Privacy & Security › Tracking.
Consent in the EEA, UK and Switzerland. Before ads use your data, a consent message from Google's certified consent platform asks for your choices (if you are under the age of digital consent in your country, a parent or guardian should answer it, Section 13). If you don't consent to personalized ads, Google may show non-personalized or limited ads. These are based on context such as the app and your approximate location rather than your profile, and may still use data for frequency capping, aggregated reporting and fraud prevention, as allowed by law.
US state privacy rights. Showing personalized ads may count as "selling" or "sharing" personal information, or "targeted advertising", under some US state laws. You can opt out as described in Section 12.
Change your mind any time from the Privacy Choices option in the App's Settings screen (shown where your region requires it), or with the iOS tracking setting above.

Other ad partners. Google also lets a few other ad companies compete to show the ad ("mediation"): AppLovin (AppLovin Corp.), Unity Ads (Unity Technologies), Liftoff Monetize (Liftoff Mobile) and Meta Audience Network (Meta Platforms). Each runs its own code in the App, which starts only once Google's does, and may collect similar data under its own policy. Where Google's consent message applies, your choices are passed to them through Google's ad service where each supports it, and where a US state privacy law applies, the App tells them not to sell or share your data. Their policies: AppLovin, Unity, Liftoff, Meta.

Ad content. We ask for ads suitable for general audiences and set blocks on sensitive ad categories in our ad account, but we can't guarantee that every ad meets this. If you see an ad that seems inappropriate, please report it with Report an Ad in Settings or email us. Include the time, a screenshot and the advertiser if you can.

Younger players. If Apple's Game Center tells the App that the signed-in account is one Apple marks as underage, then from that moment, and for as long as it is the last account signed in to Game Center in the App, the App protects that player in three ways. It asks Google to treat ad requests as coming from a child. It turns on each ad partner's own setting for younger or opted-out users, which limits ad personalization. And it doesn't show the tracking prompt if it hasn't been shown yet. This only works for players signed in to Game Center, and it can't undo a tracking answer already given; a parent can turn tracking off at any time (Section 13).

Premium subscribers don't see ads. No Ads owners see no banner or ads between levels; rewarded videos they choose to watch are still served as described above. For both, the ad services' code, including the ad partners', may still start in the App and collect the data described in this section.

No automated decisions. We don't make decisions about you based solely on automated processing that have legal or similarly significant effects. Ad personalization, where you allow it, is done by Google and the ad partners under their policies.

6. Crash reports and game statistics (Google)

The App uses Google Analytics and Google's crash reporting service, provided by Google, to learn what crashes and how the game is played, so we can fix bugs and tune levels. Google processes this data on our behalf.

What is sent:

Crash reports: where the App's code failed, device model, iOS version, free memory and storage, the App's version, and the screen and level you were on.
Errors and slowdowns: some problems that don't crash the App (for example a purchase or an ad that didn't work as expected), and slowdowns reported by iOS.
Game events: how levels go (for example the result, stars, score and boosters used), screens opened, iCloud save actions, ads watched, the store screen and purchase details (such as the product, price and whether it was a free trial), coins earned and spent, and time played.
Device: the device model, screen size, iOS version and language, so we can see how the game plays on small and large iPhones.
Identifiers: random identifiers created for the App when it is installed. They don't show your name, but they still count as personal data. Your approximate location (country and city) is derived from your IP address; Google says Google Analytics doesn't store or log IP addresses.

What isn't: your name, email, contacts, Game Center identity or the advertising identifier (IDFA). We never set a user ID. We don't use these statistics to target or personalize ads, and we don't share them with the other ad partners. We may link them to our Google ad account, so that we can see reports such as session counts and ad revenue together.

Your choices. Once Google's consent message has run, it decides whether you are treated as in the EEA, the UK or Switzerland; until then, your App Store country does. There, nothing is sent until you agree in that message (shown after a few levels, Section 5): crash reports need storing information on your device; game statistics also need measuring content performance by Google. Elsewhere, sending is on from the start. You can turn it off at any time in the App's Settings › Share stats; crash reports kept on your device are then deleted.

Google's handling is described in the Google Privacy Policy and in How Google uses information from sites or apps that use its services.

7. Purchases and other Apple services

No Ads and Talking Blocks Premium are sold through Apple's In-App Purchase system. Apple processes the payment. We never receive your payment card details, billing address or Apple Account credentials. On your device, the App receives a transaction record from Apple confirming what you own (No Ads) and which subscription is active. The App uses it to unlock No Ads and Premium; if game statistics are on (Section 6), purchase details are also sent to Google Analytics. We see only those statistics, not your payment details or who you are.

Sharing and ratings. If you choose to share a result card, the App hands a picture and a short text to iOS's share sheet, and you pick where it goes; nothing is sent to us. If you pick Save Image there, iOS asks your permission to add that picture to your Photos; the App can only add it and never reads your library. The App may ask iOS to show Apple's rating prompt now and then; Apple handles your answer. Apple's handling of your data is described in the Apple Privacy Policy.

Game Center (optional). If you're signed in to Apple's Game Center, the App sends Game Center your best Endless score, your best Endless score this week, your Journey star total and the achievements you earn (trophies' gold tiers and the secret trophies). They appear on Game Center's leaderboards and in your Game Center profile, where other players may see them according to your Game Center settings. Apple handles this data under the Apple Privacy Policy; it isn't sent to us or to Google. So that nothing is sent twice, the App keeps a note on your device of what it already sent, filed under the player identifier Game Center gives the App; that note stays on your device. Game Center is never used for an account Apple marks as underage, and the App remembers on your device that such an account signed in, for the ad protections in Section 5. You can sign out of Game Center in iOS Settings at any time.

8. If you contact us

If you email us, we receive your email address and whatever you choose to include, such as device model or screenshots. We use it only to respond to you and to improve the App. We keep support conversations for up to 12 months after the conversation ends, unless we need to keep them longer to comply with the law, and then delete them.

10. Legal bases (EEA, UK and Switzerland)

Consent: personalized ads, any other ads or ad measurement that store or read information on your device, and crash reports and game statistics. You can withdraw consent at any time (Sections 5 and 6).
Legitimate interests: limited ads that don't store or read information on your device, security and fraud prevention, the ad protections for younger players (Section 5) and answering support requests. These are balanced against your rights.
Contract: providing No Ads or Premium after you buy it.
Legal obligation: keeping records the law requires.

12. Your choices and rights

Choices you control directly:

Delete the game data stored on your device: delete the App (a random ID that labels this device's iCloud copy stays on the device until you reset it). Deleting it doesn't remove your iCloud copies: delete those in your device's iCloud storage settings (Section 4). Game Center scores are kept by Apple (Section 7).
Tracking: iOS Settings › Privacy & Security › Tracking.
Ad consent and US state opt-outs: Privacy Choices in the App's Settings screen, where shown for your region.
Crash reports and game statistics: Share stats in the App's Settings screen.
Ad personalization across Google: My Ad Center. The other ad partners' own choices are in their policies (Section 5).

EEA, UK and Swiss residents have the right to access, correct, delete, restrict or object to processing of their personal data, to data portability, and to withdraw consent at any time. You can complain to us by email (Section 18), and you also have the right to complain to your local data protection authority.

US residents in California and other states with consumer privacy laws (such as Colorado, Connecticut, Virginia, Texas, Oregon and others) may have the right to know or access, correct, and delete personal information; to opt out of the sale or sharing of personal information and of targeted advertising; and not to be discriminated against for exercising these rights. We do not use or disclose sensitive personal information.

California disclosures (last 12 months):

Categories collected: identifiers (device identifiers, IP address, random identifiers created for the App, and your email address and message if you email us), commercial information (purchase details, if game statistics are on), internet or other electronic network activity (ad and app interactions, game events, crash reports), approximate geolocation derived from IP (not precise geolocation), and inferences the ad companies may draw for ad personalization where allowed.
Sources: you, if you email us; your device, through the ad services and the crash report and statistics service in the App.
Purposes: advertising and ad measurement, analytics, security and fraud prevention, debugging.
Disclosed for a business purpose to: Google, as our service provider for crash reports and game statistics. We don't sell them or share them for cross-context behavioral advertising, and we have turned off Analytics' ad personalization.
Sold or shared for cross-context behavioral advertising: identifiers, internet or other electronic network activity and approximate geolocation may be treated as "sold" or "shared" when Google and the ad partners named in Section 5 (AppLovin, Unity, Liftoff and Meta) show personalized ads. You can opt out as described above.
Minors: we do not knowingly sell or share personal information of consumers under 16. Where Game Center tells the App an account is underage, the App asks the ad companies to limit personalized ads (Section 5).

How to make a request. We handle requests about data we control and work with our providers where needed. Most data about your use of ads is held by Google and the ad partners, not by us. Crash reports and game statistics are held by Google for us under random identifiers, which we can't link to you. We don't hold any other personal data about you unless you have emailed us, and we can't link the ad companies' data to you. To make a request, email contact@talkingblocksgame.com. We will respond within one month in the EEA, the UK and Switzerland, or within 45 days under US state laws (either can be extended where the law allows, and we'll tell you if it is), and help you use the ad companies' own tools for the data they hold. We may need to verify your request. You may use an authorized agent where the law allows. If we decline your request, you may appeal by replying to our answer. If the appeal is denied, you may contact your state Attorney General.

Do Not Track. The App does not respond to web browser "Do Not Track" signals. On iOS, we follow Apple's tracking setting: if you choose "Ask App Not to Track", or turn off "Allow Apps to Request to Track", the App treats that as a request not to track you.

13. Children's privacy

Talking Blocks is a general-audience game for players 13 and older (Terms of Use, section 2), and it is rated 13+ on the App Store. It is not part of the App Store's Kids category.

The App doesn't ask your age and doesn't collect it. We do not knowingly collect personal information from children under 13 or, without a parent's or guardian's consent, from anyone under the age of digital consent in your country. The App has no accounts, no chat and no way to share personal information. The App does show ads, so Google and the ad partners in Section 5 collect the device data described there, and we take these steps:

we ask for ads suitable for general audiences and set blocks on sensitive ad categories;
the IDFA is used only if you allow tracking through Apple's prompt, and on a child's device a parent can turn tracking requests off (see below);
if Game Center tells the App that an account is underage, the App asks for child treatment of ads and limits ad personalization from then on (Section 5);
if you are under the age at which you can consent to data processing in your country (such as 16 in Germany and the Netherlands), a parent or guardian should make the App's privacy choices for you.

Parents and guardians can turn off Settings › Privacy & Security › Tracking › Allow Apps to Request to Track on a child's device, lock it with Screen Time › Content & Privacy Restrictions, and use Ask to Buy in Family Sharing to approve purchases.

If you believe a child under 13 has given us personal information, for example by emailing us, contact contact@talkingblocksgame.com and we will delete it. If we learn that we have collected personal information from a child under 13 without verifiable parental consent, we will delete it promptly.

14. International transfers

We are based in Vietnam, so if you email us, your message is handled there. Google and the ad partners may process data in the United States and other countries. If you agree to crash reports and game statistics, you also agree that Google may transfer, store and use them in the United States and other countries, whose privacy laws may differ from yours. For data from the EEA, UK and Switzerland, they say they rely on legally recognized transfer mechanisms such as the European Commission's Standard Contractual Clauses and the EU-U.S. Data Privacy Framework.

15. Retention

On your device: until you delete the App.
iCloud saves: in your iCloud account until you delete them (Section 4).
Game Center: kept by Apple under Apple's privacy policy (Section 7).
Support emails: up to 12 months after the conversation ends (Section 8).
Crash reports: up to 90 days. Game statistics: up to 14 months (then only totals remain). These follow Google's service and our current settings.
Google and the ad partners (ads): according to their own retention policies, such as Google's.

16. Security

The App never sends your save to us or to Google; the only game data that leaves your device is your own iCloud copy (Section 4), the statistics in Section 6 (if allowed) and what goes to Game Center if you sign in (Section 7). Data shared with Google, the ad partners and Apple is designed to travel over encrypted connections. No method of storage or transmission is completely secure, but we keep the data we handle to a minimum.

17. Changes to this policy

If we change this policy, we will post the new version at https://talkingblocksgame.com/privacy and update the effective date. If a change materially affects how your data is used, we will also tell you in the App or ask for your consent where required.

18. Contact

Dam Tran
Email: contact@talkingblocksgame.com
Support: https://talkingblocksgame.com/support

Related: Terms of Use