Last updated: February 11, 2026
LEXICODE (the “App”) is a free word puzzle game by FILYNX (EU), supported by advertisements.
We aim to collect as little data as possible. No account is required. No tracking across other apps or websites.
- Who We Are Publisher/Data Controller: FILYNX (EU)
Contact: support@filynx.eu
Website: https://filynx.eu - What We Collect (and What We Don’t) We do NOT ask for or require:
Your name, email, phone number, or address A user account or profile Contacts, photos, microphone recordings, or precise location Any personally identifiable information beyond what is described below
However, the App uses Firebase Analytics for app improvement and Start.io for advertising, which may process limited device and usage data (see Sections 4 and 5).
- Data Processed Automatically The App operates entirely offline for gameplay. Analytics and advertising data are collected only to improve app quality and support the free experience.
Firebase Analytics may process:
App activity: Screen views, button taps, session duration, feature usage, puzzle completion rates Device information: Device model, OS version, app version, language/region settings Technical data: Crash reports, error logs, performance metrics, load times Identifiers: App-instance identifiers (anonymous tokens that identify app installations)
Start.io Advertising SDK may process (with your consent):
Device information: Device model, operating system version, screen size Advertising identifiers: Android Advertising ID or iOS IDFA (with your permission) General location: Country and region (not precise GPS location) App usage data: Session information used for ad relevance
Important:
We do not try to identify you as a person We do not track you across other apps or websites Analytics data never includes your puzzle solutions or specific gameplay content Advertising data is only collected for ad personalization if you consent
- Third-Party Services We Use
A. Firebase Analytics (Google) We use Firebase Analytics to understand how the App is used (in aggregate) and improve stability, performance, and user experience.
What Firebase collects:
App installation and session data General feature usage patterns (which screens are viewed, which difficulty levels are popular) Technical performance data (crash reports, load times) Device characteristics (model, OS version, language settings)
What Firebase does NOT collect:
Personal identification information Your specific puzzle solutions or word selections Precise location data Any data that identifies you personally
Provider policies:
Google Privacy Policy: https://policies.google.com/privacy Firebase Terms: https://firebase.google.com/terms
B. Start.io Advertising We use Start.io to display advertisements in the App. Start.io helps us keep the App free by connecting us with advertisers.
What Start.io collects (with your consent):
Device identifiers: Advertising ID (Android) or IDFA (iOS, with your permission) Device information: Model, operating system, screen size General location: Country and region derived from IP address (not precise GPS) App usage patterns: Session data used to determine ad relevance
What Start.io does NOT collect:
Your name, email, or contact information Your specific puzzle solutions or gameplay content Precise GPS location Data from other apps on your device
How Start.io uses this data:
To display relevant advertisements within the App To measure ad performance (impressions, clicks) To prevent ad fraud To improve ad quality and relevance (if you consent to personalization)
If you decline personalized ads:
Start.io will still show advertisements, but they will be generic and not tailored to your interests Start.io will not collect or use your advertising identifier for personalization You will still see the same number of ads, but they may be less relevant to you
Provider policies:
Start.io Privacy Policy: https://start.io/policy/privacy-policy-site
- Advertising and Your Consent LEXICODE displays advertisements to support the free experience. We respect your right to choose how your data is used for advertising.
A. Your Consent Choice On first launch, the App will ask whether you consent to personalized advertisements. You have two options:
Accept: Start.io may collect device and usage data to show you ads tailored to your interests. This results in higher-quality, more relevant advertisements.
Decline: Start.io will show generic, non-personalized advertisements. No personal data will be collected for ad targeting purposes. The App functions identically in all other respects.
B. Changing Your Choice You can change your advertising preference at any time:
In the App: Settings > Privacy > Personalized Ads toggle This change takes effect immediately No penalty or loss of functionality for changing your preference
C. Types of Advertisements The App may display the following ad formats:
Banner ads: Small advertisements shown on menu and information screens (not during active gameplay) Interstitial ads: Full-screen advertisements shown between games (limited frequency, with cooldown periods) Rewarded video ads: Optional advertisements you can choose to watch in exchange for in-game hints
Important: No advertisements are shown during active puzzle gameplay. You will never be interrupted while solving a puzzle.
D. iOS App Tracking Transparency On iOS devices, if you consent to personalized ads, the App may request Apple’s App Tracking Transparency (ATT) permission. This allows Start.io to use your IDFA for better ad personalization. You can accept or deny this separately from the in-app consent. Denying ATT permission does not affect app functionality.
- Legal Bases (EEA/UK/GDPR) Where GDPR/UK GDPR applies, we rely on:
Consent: For personalized advertising data collection via Start.io. You are asked for explicit consent on first launch and can withdraw it at any time via Settings > Privacy > Personalized Ads.
Legitimate Interests: For basic app analytics (Firebase), security, crash reporting, fraud prevention, and service improvement. This processing is minimal, non-intrusive, and does not override your privacy rights.
Legitimate Interests: For displaying non-personalized advertisements, which is necessary to support the free app model. No personal data is used for non-personalized ads.
- Data Retention FILYNX:
We do not maintain a user database for LEXICODE We do not store gameplay data on our servers All your game progress, statistics, and settings are stored locally on your device only Your advertising consent preference is stored locally on your device
Firebase Analytics:
Analytics data is retained by Google according to Firebase’s retention controls We have configured Firebase to retain analytics data for the minimum necessary period User-level analytics data can be automatically deleted per Firebase’s retention settings
Start.io:
Advertising data is managed by Start.io according to their data retention policies If you withdraw consent, Start.io will no longer collect personalization data going forward For details on Start.io’s data retention, see: https://start.io/policy/privacy-policy-site
Customer Support:
If you email support@filynx.eu, we keep that correspondence as long as needed to handle your request and basic recordkeeping (typically up to 12 months)
- Your Choices and Controls
A. Manage Ad Personalization In the App: Settings > Privacy > Personalized Ads Toggle on for personalized ads (Start.io collects ad-relevant data) Toggle off for non-personalized ads (no ad-targeting data collected) This setting takes effect immediately
B. Opt Out of Analytics You can disable analytics collection through your device settings:
iOS: Settings > Privacy & Security > Analytics & Improvements Toggle off “Share iPhone Analytics” or “Share iPad Analytics”
Android: Settings > Google > Ads Toggle on “Opt out of Ads Personalization” Or: Settings > Google > Usage & diagnostics (varies by device)
C. iOS Tracking Permission If you previously granted ATT (App Tracking Transparency) permission on iOS: Settings > Privacy & Security > Tracking > LEXICODE Toggle off to revoke tracking permission
Important: Changing any of these settings does not affect gameplay. The App functions fully offline with all features available regardless of your privacy choices.
D. Reset App Data To clear all local data (statistics, progress, settings, consent preferences):
iOS: Delete and reinstall the App Android: Settings > Apps > LEXICODE > Storage > Clear Data
Note: Reinstalling the App will reset your consent preference, and you will be asked again on first launch.
E. Delete Your Data To request deletion of any data we or our partners may have:
Email support@filynx.eu with your request We will coordinate with Google Firebase and Start.io to delete your data We will provide instructions for any device-level identifiers needed
- Your Rights Under GDPR If you are in the European Economic Area (EEA), United Kingdom, or Switzerland, you have the following rights:
Right to Access: Request what data we’ve collected about you Right to Rectification: Request correction of inaccurate data Right to Erasure: Request deletion of your data Right to Restrict Processing: Request limitation of data processing Right to Data Portability: Request your data in a portable format Right to Object: Object to processing based on legitimate interests Right to Withdraw Consent: Withdraw consent at any time via Settings > Privacy > Personalized Ads, or by contacting us
To exercise these rights, contact: support@filynx.eu
We will respond to requests within 30 days as required by GDPR.
- Children’s Privacy LEXICODE is suitable for all ages (4+) and is family-friendly.
We do not knowingly collect personal data from children No user accounts or profiles are required All gameplay is local and offline Advertisements shown are age-appropriate and filtered by Start.io Parents can disable ad personalization and analytics via the in-app Settings or device settings We comply with COPPA (U.S.), GDPR-K (EU), and other children’s privacy laws
Parental Control:
Parents may want to supervise young children’s device usage time Ad personalization and analytics can be disabled with no impact on gameplay No social features, chat, or user-generated content Parents can set the Personalized Ads toggle to off in Settings > Privacy
- International Data Transfers Firebase Analytics is operated by Google and Start.io is operated by Start.io Inc. (New York, USA). Both may process data on servers outside your country, including in the United States.
Safeguards:
Google complies with EU-U.S. Data Privacy Framework Start.io maintains appropriate safeguards for international data transfers Standard Contractual Clauses (SCCs) are in place for EEA data transfers where required Both providers maintain appropriate technical and organizational security measures
For more information: Google: https://policies.google.com/privacy/frameworks Start.io: https://start.io/policy/privacy-policy-site
- Data Security We implement reasonable technical and organizational safeguards to protect data:
Local Data Security: All game progress, statistics, settings, and consent preferences are stored locally on your device We use standard secure storage APIs provided by iOS/Android No sensitive personal information is stored
Network Security: Analytics and advertising data are transmitted using encrypted connections (HTTPS/TLS) Minimal data transmission (analytics and ad requests only, no gameplay data)
Limitations: No system is perfectly secure We cannot guarantee absolute security You are responsible for device security (passcodes, biometric locks, etc.)
- Changes to This Privacy Policy We may update this Privacy Policy from time to time to reflect:
Changes in our data practices Updates to legal requirements New features or services Changes to advertising partners or third-party services
When we update:
The “Last updated” date at the top will change Continued use of the App after changes means you accept the updated policy Material changes will be communicated via App Store update notes If we add new advertising partners or significantly change data collection, we will reset your consent preference and ask again
Your options:
If you don’t agree with changes, you may stop using the App Your local game progress remains on your device You can request data deletion at any time
- Third-Party Links The App may contain links to third-party websites (e.g., our website, support pages, advertiser landing pages).
We are not responsible for the privacy practices of third-party sites We encourage you to review their privacy policies Third-party sites are governed by their own terms and policies Clicking on an advertisement may take you to an advertiser’s website, which is not controlled by FILYNX
- Do Not Track (DNT) Some browsers support “Do Not Track” signals. The App respects your privacy choices through the in-app consent mechanism described in Section 5 rather than DNT signals, because:
The App uses a dedicated consent system for advertising preferences You can control ad personalization directly in Settings > Privacy We do not track you across websites or other apps
- California Privacy Rights (CCPA) If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):
Right to Know: What personal information we collect, use, and share Right to Delete: Request deletion of your personal information Right to Opt-Out: Opt out of “sale” of personal information Right to Non-Discrimination: No discrimination for exercising your rights
To exercise these rights, contact: support@filynx.eu
Note: We do not sell personal information. Start.io’s use of advertising data for ad serving is not considered a “sale” under CCPA, but you can opt out of personalized advertising at any time via Settings > Privacy > Personalized Ads.
- Contact & Questions If you have questions about this Privacy Policy or your data:
Email: support@filynx.eu
Website: https://filynx.eu
We respond to:
Privacy questions and concerns Data access, deletion, or portability requests Advertising and consent-related questions GDPR and privacy rights inquiries General feedback about our privacy practices
We aim to respond within 48-72 hours and resolve requests within 30 days as required by law.
- Summary: Your Privacy at a Glance
- ✓ Free app with respectful advertising – ads support the free experience
- ✓ Your choice on ad personalization – accept or decline on first launch, change anytime in Settings
- ✓ No ads during gameplay – advertisements never interrupt active puzzles
- ✓ Minimal data collection – only anonymous analytics and consented ad data
- ✓ Offline-first – all gameplay is local; no server-side game data
- ✓ No accounts required – no email, no passwords, no profiles
- ✓ No cross-app tracking – we do not track you across other apps or websites
- ✓ You control your data – manage preferences in Settings > Privacy
- ✓ GDPR compliant – full data rights for EU users with explicit consent
- ✓ Family-friendly – safe for all ages with parental controls
- ✓ Transparent – clear about what we collect and why
- ✓ We never sell your data to third parties
Thank you for trusting FILYNX with LEXICODE. Your privacy matters to us.