PRIVACY · 01

Privacy Policy

This Privacy Policy explains how Criminaler handles information when you use the mobile app, website, and related services. Criminaler does not require a named account, but it uses a pseudonymous device identifier to keep your game progress.

Effective: 29 July 2026

1. Who is responsible

Criminaler is operated by IT Sebastian Domagała, a Polish sole proprietorship. The operator is the controller of personal data processed for the Criminaler service.

For privacy requests—including access, deletion, correction, or objection—contact privacy@criminaler.com.

2. Information we process

  • A generated pseudonymous device identifier, game progress, attempts, scores, ticket balance, streaks, and quiz-session history.
  • AI Investigation messages and the replies generated for the quiz. Please do not enter personal or sensitive information.
  • Feedback you voluntarily send, including any text and contact details you choose to include.
  • Rewarded-ad verification and anti-fraud records.
  • Technical and security data in API, hosting, and infrastructure logs.
  • Cookieless website analytics and pseudonymous mobile product analytics, as described below.

3. Location

If you choose “my location” in the Case Atlas, the app asks the device for location access only to position the map. Criminaler does not intentionally include precise coordinates in product-analytics events. Device, network, infrastructure, analytics, and advertising providers may still process technical location signals such as an IP-derived approximate location under their own roles and policies.

4. Why we use information

Core gameplay and service records are processed because they are necessary to provide Criminaler. AI Investigation messages and optional mobile analytics are processed with your consent. Security, fraud prevention, support, and limited service-improvement records are processed for our legitimate interests in protecting and improving Criminaler, while records required by law are processed to meet legal obligations. You may object to processing based on legitimate interests and withdraw consent at any time.

Core device and gameplay data are required to save progress and operate the game. Analytics, feedback, and AI Investigation are optional. If you decline AI permission, AI Investigation is unavailable; other gameplay remains available.

  • To provide quizzes, save progress, calculate scores, operate tickets, and prevent duplicate or fraudulent rewards.
  • To answer AI Investigation messages and keep the investigation transcript available to you.
  • To provide support, review corrections, secure the service, diagnose faults, and meet legal obligations.
  • To understand product use and improve Criminaler through limited analytics.

5. Analytics

If website analytics are enabled, PostHog EU receives limited explicit page-view and App Store conversion events plus technical network data. Criminaler does not set persistent analytics cookies or store an analytics identifier in localStorage or sessionStorage, does not create named visitor profiles, respects Do Not Track, and disables automatic capture, session replay, surveys, heatmaps, dead-click capture, and feature flags.

The mobile app starts PostHog product analytics only after you explicitly allow it. It uses the generated pseudonymous identifier, not for cross-company advertising or Apple-defined Tracking. You can withdraw permission in Settings, which stops future capture and resets the local analytics identity; this does not itself erase historical events.

6. Advertising and AI recipients

Rewarded ads use Google AdMob with Google’s consent tools. Initial ads are requested as non-personalized and are available only when the current consent state permits an ad request. You can review applicable advertising choices in the Ticket Shop or Settings.

AI Investigation sends messages through OpenRouter to AI model providers only after the in-app disclosure is accepted. Criminaler requests routes that deny provider data collection and support Zero Data Retention; if no compliant endpoint is available, the AI feature may be unavailable. Operational metadata may still be handled under the providers’ documented policies.

7. Other recipients and transfers

We use Cloudflare for website and API edge delivery, Hetzner for EU hosting of the primary API and database, PostHog EU for optional analytics, Google AdMob and UMP for rewarded advertising and privacy choices, and OpenRouter plus the selected downstream model provider for AI Investigation. Some providers may process data outside the EEA. Where personal data leave the EEA, we rely on an applicable adequacy decision, Standard Contractual Clauses, or another lawful transfer safeguard. Contact us for information about the safeguard used for a particular transfer.

We do not sell personal data and do not use Criminaler analytics for cross-company advertising.

8. Retention

We apply these periods from the relevant activity or inactivity date. Deletion from providers and backups may complete within the stated cleanup windows.

  • Gameplay records and AI custom-quiz history: until deletion or 24 months after inactivity.
  • Feedback and PostHog analytics: 12 months.
  • API and infrastructure logs: 30 days.
  • Backups containing deleted or expired records: expire within 30 days.
  • Rewarded-ad anti-fraud records: 24 months, with the user link removed earlier where practical.

9. Your choices and rights

You may request access, correction, deletion, restriction, or portability; object to processing; withdraw consent without affecting earlier lawful processing; and request human review where applicable. We normally respond within one month. You may complain to the President of the Personal Data Protection Office in Poland or your local supervisory authority.

Delete My Data first requires PostHog to accept asynchronous deletion of the person and historical events. Criminaler then deletes gameplay, sessions, AI transcripts, feedback, and consent history, de-links the pseudonymous user and reward amount from retained rewarded-ad anti-fraud records, clears local app data, and creates a fresh ID. If PostHog does not accept the request, Criminaler records remain intact so you can retry. Provider processing and backup cleanup may take up to 30 days.

10. Children, security, and changes

Criminaler is intended only for adults aged 18 and over and is not directed to children. We use proportionate technical and organizational safeguards, but no online service can guarantee absolute security.

Material policy changes will appear in the change history. The app will provide a notice when a material change affects users and will request permission again if a consent-based purpose or recipient category materially changes.

Contact

IT Sebastian Domagałaul. Karola Goduli 36, 41-703 Ruda ŚląskaNIP 6272766908privacy@criminaler.com

Change history

29 July 2026 — Initial version for the first public release.