ENIGMATA Privacy Policy

Last updated: January 23, 2026

Publisher: Filynx (EU)
Contact: support@filynx.eu
Website: https://filynx.eu

Introduction

Welcome to ENIGMATA. Your privacy matters to us.

This Privacy Policy explains how we collect, use, store, and protect your information when you use the ENIGMATA mobile application (the “App”). We are committed to transparency and giving you control over your data.

Our Privacy Principles:

Transparency – We’re clear about what we collect and why
Freemium Model – Free version with ads OR pay to remove ads permanently
Ad-Supported – We use Start.io advertising network in the free version
No Data Selling – We don’t sell your data to third parties or data brokers
No User Accounts – We don’t require registration or personal information
Your Control – You can opt out of personalized ads and analytics
Minimal Personal Data – We collect technical data, not personal identity information

1. Information We Collect

1.1 Anonymous Analytics Data (via Firebase Analytics)

We use Google Firebase Analytics to understand how players use ENIGMATA and to improve the game experience. Firebase automatically collects:

Usage Information:

App opens and session duration
Screen views and feature usage
Game completion rates (aggregated, not individual gameplay)
Settings preferences (language, sound settings, etc.)
Time spent on different screens

Technical Information:

Device model and manufacturer
Operating system and version
App version
Screen resolution and orientation
Network type (WiFi vs mobile data)
Crash reports and error logs
Performance metrics (load times, frame rates)

Instance ID:

Firebase generates a random instance identifier to distinguish between app installations
This ID is NOT linked to your personal identity
It resets if you reinstall the app

1.2 Advertising Data (via Start.io Ad Network)

IMPORTANT: The free version of ENIGMATA includes advertisements provided by Start.io. Start.io collects data to show you relevant ads and measure ad performance. You can remove ads permanently via in-app purchase.

What Start.io Collects:

Advertising ID (Google Ad ID): A unique identifier for advertising purposes (can be reset in Android settings)
Device Information: Device model, manufacturer, operating system, screen size
IP Address: Your approximate location based on IP address (city/region level, not precise GPS)
App Usage Data: Which screens you visit, how long you use the app
Ad Interaction Data: Which ads you view, click, or interact with
Network Information: Connection type (WiFi vs mobile data), carrier information
Inferred Interests: Categories of content you may be interested in based on app usage

Cross-App Tracking:

Start.io may track your activity across other apps that use their ad network
This helps show you more relevant ads based on your interests
You can opt out of personalized ads (see Section 6)

Third-Party Data Sharing:

Start.io may share anonymized data with advertisers and measurement partners
Advertisers learn if their ads were viewed or clicked (not your personal identity)
We do NOT control Start.io’s data practices beyond what’s in their privacy policy

How to Remove Ads:

Purchase the ad-free version via one-time in-app purchase
Once purchased, Start.io stops collecting data from your device
All ads are permanently removed across the entire app

Start.io Privacy Policy: https://www.start.io/privacy/

1.3 Purchase Information

When you purchase ad removal or DLC content:

Google Play processes your payment and purchase verification
We receive only a purchase token to verify you own the content
We do NOT receive your payment details, name, address, or email
Purchase data is handled by Google Play per their privacy policy

1.4 Information We Do NOT Collect

We want to be clear about what we DON’T collect:

❌ No Personal Information: No names, emails, phone numbers, or addresses
❌ No User Accounts: No registration, login, or user profiles
❌ No Precise Location: We don’t use GPS or precise location tracking
❌ No Gameplay Content: We don’t record your specific choices, roles, or strategies
❌ No Device Contacts: We don’t access your contacts, photos, or other personal files
❌ No Microphone or Camera: We never access these sensors

Note: While we don’t directly collect some of this data, Start.io (in the free version) does collect Advertising ID and approximate location for ad targeting. You can remove ads to stop this data collection.

2. How We Use Your Information

2.1 To Improve the Game

We use anonymous analytics data to:

Identify and fix bugs and crashes
Understand which features players enjoy most
Optimize game performance and loading times
Improve user interface and user experience
Plan future content updates and DLC
Ensure game balance and fairness

2.2 To Show You Advertisements (Free Version Only)

If you use the free version with ads:

Start.io uses your data to:

Show you advertisements in menu screens and between games
Display ads that may be relevant to your interests
Measure ad performance (impressions, clicks, conversions)
Prevent ad fraud and ensure ad quality
Optimize ad delivery and frequency

How Advertising Works:

Advertisers pay Start.io to show ads
Start.io shares a portion of revenue with us
This allows us to offer ENIGMATA for free
You can remove ads permanently via in-app purchase

We Do NOT:

Sell your data to advertisers or data brokers
Share your personal identity with advertisers
Use ads for anything other than supporting the free version

2.3 To Verify Purchases

We use purchase tokens to:

Verify you’ve purchased ad removal or DLC
Unlock content you’ve paid for
Remove advertisements permanently for ad removal purchasers
Prevent unauthorized access to premium content

2.4 Aggregated Statistics Only

All analytics are:

Aggregated: Combined with data from all players
Anonymous: Not linked to any individual person
Used internally: Only Filynx sees analytics data
Never sold: We don’t sell or share analytics data with third parties (except Firebase/Google for processing)

Note: Start.io ad data is separate and governed by their privacy policy. Advertisers receive aggregated metrics (not your personal data).

Example: We might see “80% of players use the Athens theme,” but we can’t see which specific person chose Athens.

3. How We Share Your Information

3.1 Service Providers

We share data with these service providers:

Start.io (Advertising Network – Free Version Only):

Delivers advertisements in the free version of ENIGMATA
Collects advertising data (see Section 1.2 for details)
Shares aggregated metrics with advertisers and measurement partners
Governed by Start.io Privacy Policy: https://www.start.io/privacy/
Governed by Start.io Terms: https://www.start.io/terms/
Data collection stops when you purchase ad removal

Google Firebase (Analytics & Hosting):

Processes analytics data on our behalf
Provides crash reporting and performance monitoring
Governed by Google Privacy Policy: https://policies.google.com/privacy
Firebase Terms: https://firebase.google.com/terms

Google Play (Payment Processing):

Processes in-app purchases (ad removal and DLC)
Handles payment information (we never see it)
Governed by Google Play Privacy Policy: https://policies.google.com/privacy

3.2 Legal Requirements

We may disclose information if required by law:

To comply with legal obligations or valid legal processes
To protect the rights, property, or safety of Filynx, our users, or others
To detect, prevent, or address fraud, security, or technical issues

3.3 What We (Filynx) DON’T Share

Filynx does NOT:

Sell your personal data to anyone
Sell your analytics data to data brokers
Share your gameplay choices or personal information with advertisers
Share data with social media platforms
Use your data beyond what’s described in this policy

Important Clarification About Start.io:

Start.io (our ad partner) does show targeted ads based on data they collect
Start.io may share anonymized data with their advertisers and measurement partners
We don’t control Start.io’s data practices (governed by their privacy policy)
You can remove ads permanently via in-app purchase to stop Start.io data collection
You can limit ad personalization in Android settings (see Section 6)

4. Data Retention

4.1 Analytics Data

Firebase retains analytics data for 14 months by default
After 14 months, data is automatically deleted
Aggregated reports may be retained longer but contain no identifiable information

4.2 Purchase Data

Purchase verification tokens are retained as long as you own the content
Required to verify your purchase if you reinstall the app
Stored securely and not linked to personal information

4.3 Local Game Data

All gameplay progress is stored only on your device
We cannot access your save data
Uninstalling the app deletes all local data
We recommend backing up your device to preserve game progress

5. Data Security

5.1 Technical Safeguards

We protect your data using:

Encryption in transit: HTTPS/TLS for all network communication
Secure storage: Firebase’s secure cloud infrastructure
Access controls: Limited employee access to analytics dashboards
Regular security reviews: Ongoing monitoring and updates

5.2 Third-Party Security

Firebase and Google Play maintain industry-standard security practices:

SOC 2/SOC 3 certified
ISO 27001 certified
Regular third-party security audits

5.3 No Absolute Security

No method of transmission or storage is 100% secure. While we use reasonable measures to protect your information, we cannot guarantee absolute security.

6. Your Rights & Choices

6.1 GDPR Rights (EU Users)

Under the General Data Protection Regulation (GDPR), you have the right to:

Right to Access:

Request what data we’ve collected about your app instance
Contact support@filynx.eu with your Firebase Instance ID

Right to Deletion (“Right to be Forgotten”):

Request deletion of your analytics data
We’ll work with Firebase to remove your instance data
Note: Aggregated statistics cannot be “unmerged” once anonymized

Right to Opt-Out:

Disable analytics collection entirely (see Section 6.3)

Right to Data Portability:

Request your data in a portable format
Limited data due to minimal collection

Right to Object:

Object to data processing for analytics purposes
Opt-out instructions below

Right to Rectification:

Not applicable (we don’t collect personal information to correct)

Right to Restrict Processing:

You can opt out of analytics to restrict processing

Right to Lodge a Complaint:

Contact your local data protection authority
EU list: https://edpb.europa.eu/about-edpb/board/members_en

6.2 CCPA Rights (California Users)

Under the California Consumer Privacy Act (CCPA), you have the right to:

Know what personal information is collected
Request deletion of personal information
Opt-out of the “sale” of personal information (we don’t sell data)
Non-discrimination for exercising your rights

6.3 How to Control Advertising and Analytics

Option 1: Remove Ads Permanently (Recommended)

Purchase ad removal via one-time in-app purchase
Permanently removes all advertisements
Stops Start.io data collection completely
Ad-free experience across entire app

Option 2: Limit Ad Personalization (Keep Free Version)

Open Android Settings
Go to Google > Ads
Enable “Opt out of Ads Personalization”

You’ll still see ads, but they won’t be personalized based on your interests
Ads will be generic/random instead of targeted
Start.io still collects some data for ad delivery

Option 3: Disable Firebase Analytics

Method A: Android Device Settings

Open Android Settings
Go to Google > Ads
Enable “Opt out of Ads Personalization” (this also limits analytics)

Method B: Request Opt-Out via Email

Email support@filynx.eu with subject “Opt Out of Analytics”
Include your Firebase Instance ID (we’ll provide instructions to find it)
We’ll disable analytics for your instance

Method C: Use a Firewall App

Block network access for ENIGMATA (game still works offline)
Analytics and ads won’t load without network access
Note: This may prevent ad loading (black screens where ads should be)

Impact of Different Options:

Option	Ads Removed	Personalized Ads	Analytics	Crash Reports
Purchase Ad Removal	✅ Yes	N/A	Still Active	✅ Yes
Limit Personalization	❌ No	❌ Generic Only	Still Active	✅ Yes
Opt Out Analytics	❌ No	✅ Personalized	❌ Disabled	❌ No
Firewall Block	⚠️ Blocked	⚠️ Blocked	❌ Disabled	❌ No

Our Recommendation:

Best experience: Purchase ad removal (one-time payment, no ads ever)
Free but less tracking: Limit ad personalization in Android settings
Maximum privacy: Purchase ad removal + opt out of analytics

7. Children’s Privacy

7.1 Age Requirements

ENIGMATA is rated for ages 13 and older.

We do NOT knowingly collect personal information from children under 13 without parental consent, as required by:

COPPA (USA): Children’s Online Privacy Protection Act
GDPR (EU): Parental consent required for children under 16 (varies by EU country)

7.2 Parental Controls

Parents and guardians can:

Review this Privacy Policy to understand data practices
Opt out of analytics on behalf of their child
Contact us to request deletion of any data
Monitor device permissions in Android settings

7.3 If We Learn of Underage Data Collection

If we learn we’ve collected data from a child under 13 without parental consent:

We will delete that data as soon as possible
We will take steps to prevent future collection
Parents can contact support@filynx.eu with concerns

7.4 Educational Use

If you’re an educator using ENIGMATA in a classroom:

Ensure you have proper consent from parents/guardians
Consider disabling analytics on school devices
Contact us for educational licensing options

8. International Data Transfers

8.1 EU to USA Data Transfers

Where Your Data is Processed:

Filynx is based in the European Union
Firebase servers are operated by Google in the United States and other countries
Your analytics data may be transferred outside the EU/EEA

Legal Basis for Transfers:

Google complies with the EU-US Data Privacy Framework
Google uses Standard Contractual Clauses (SCCs) approved by the EU Commission
Firebase maintains adequate data protection safeguards

More Information:

Google Privacy Shield/Data Privacy Framework: https://www.dataprivacyframework.gov/
Firebase Data Processing Terms: https://firebase.google.com/terms/data-processing-terms

8.2 Your Control

If you’re uncomfortable with international data transfers:

Opt out of analytics (Section 6.3)
Gameplay data stays on your device only
No international transfers occur for local game progress

9. Third-Party Links & Services

9.1 Google Services

ENIGMATA uses these Google services:

Firebase Analytics:

Privacy Policy: https://policies.google.com/privacy
Opt-out: https://tools.google.com/dlpage/gaoptout

Google Play (In-App Purchases):

Privacy Policy: https://policies.google.com/privacy
Purchase data handled per Google’s terms

9.2 External Links

The App may contain links to:

Our website (https://filynx.eu)
Educational resources about historical content
Third-party websites for additional information

We are not responsible for the privacy practices of external websites. Please review their privacy policies.

10. Data Breaches

10.1 Our Commitment

In the unlikely event of a data breach:

We will investigate immediately
We will notify affected users within 72 hours (GDPR requirement)
We will notify relevant data protection authorities
We will take steps to prevent future breaches

10.2 What Constitutes a Breach

Given our minimal data collection:

A breach would involve unauthorized access to Firebase analytics or purchase tokens
Since we collect no personal information, breach impact is minimal
Your gameplay data (stored locally) is not affected

11. Changes to This Privacy Policy

11.1 How We Update This Policy

We may update this Privacy Policy to reflect:

Changes in our data practices
New features or services
Legal or regulatory requirements
User feedback and best practices

11.2 Notice of Changes

When we make material changes:

We’ll update the “Last updated” date at the top
We’ll notify you via the App (in-app notice on next launch)
For significant changes, we may require re-acceptance
Continued use after changes means you accept the updated policy

11.3 Review Regularly

We encourage you to review this policy periodically:

Latest version always available at: https://filynx.eu/privacy
Check the “Last updated” date for recent changes

12. Contact Us

12.1 Privacy Questions or Requests

For any privacy-related questions, concerns, or requests:

Email: support@filynx.eu
Subject Line: “Privacy Request – ENIGMATA”

Include in Your Message:

Your Firebase Instance ID (if applicable – we’ll help you find it)
Nature of your request (access, deletion, opt-out, etc.)
Any relevant details

Response Time:

We aim to respond within 48-72 hours
GDPR requests will be fulfilled within 30 days (or we’ll explain any delays)

12.2 EU Data Protection Officer

For EU GDPR-specific inquiries:

Email: dpo@filynx.eu (if designated)
Or: support@filynx.eu with subject “GDPR Request”

12.3 Regulatory Authorities

If you’re not satisfied with our response, you have the right to lodge a complaint with:

Your local data protection authority (EU/EEA)
European Data Protection Board: https://edpb.europa.eu/

13. Summary (TL;DR)

Business Model:

💰 Freemium: FREE with ads OR pay to remove ads permanently
🎮 Full Athens gameplay available in free version
🚫 One-time purchase removes all ads forever

What we collect:

✅ Anonymous usage analytics (via Firebase)
✅ Technical data (device type, OS version, crash reports)
✅ Advertising data (via Start.io – free version only): Advertising ID, IP address, device info, ad interactions
✅ Purchase verification tokens (to unlock ad removal and DLC)

What we DON’T collect:

❌ Names, emails, or personal information
❌ Precise GPS location (only city/region via IP)
❌ Gameplay content or personal choices
❌ Contacts, photos, or other device data

How we use data:

🎮 Improve game quality and fix bugs
📊 Understand feature usage (aggregated only)
💰 Show ads in free version (via Start.io)
🔒 Verify purchases you’ve made

Advertising (Free Version Only):

📺 Ads appear in menu screens and between games
🎯 Start.io shows personalized ads based on your interests
🚫 Remove ads permanently via one-time purchase
⚙️ Limit ad personalization in Android settings

Your rights:

🛑 Remove ads permanently (one-time purchase)
🎯 Limit ad personalization (Android settings)
📧 Request data access or deletion
🇪🇺 Full GDPR rights for EU users
👶 Special protections for children under 13

Our promise:

🚫 We don’t sell your analytics data to third parties
🚫 We don’t share your personal information with advertisers
✅ Transparent about what Start.io collects for ads
✅ You can remove ads anytime via purchase
✅ Freemium model: free with ads OR pay to remove

Questions? Contact support@filynx.eu

Latest version: https://filynx.eu/privacy

ENIGMATA is committed to protecting your privacy while delivering a freemium cultural gaming experience.

Thank you for trusting us with your entertainment and education.