Privacy Policy
Effective date: August 6, 2026 · Last updated: August 6, 2026This Privacy Policy explains how Minigamr LLC ("Minigamr," "we," "us," or "our"), a limited liability company organized under the laws of the State of Utah, United States, collects, uses, shares, and protects personal information. It applies to:
- our website at minigamr.com (the "Site"); and
- the mobile applications we publish on the Apple App Store (the "Apps," and together with the Site, the "Services").
For the purposes of the EU and UK General Data Protection Regulation ("GDPR"), Minigamr LLC is the data controller of personal information processed through the Services. You can reach us using the details in the Contact Us section.
- Our Website
- Information Our Apps Collect
- How We Use Information
- Who We Share Information With
- Advertising and Tracking Choices
- International Data Transfers
- Data Retention
- Your Rights (EEA, UK & Switzerland)
- Your Rights (US States)
- Account and Data Deletion
- Children's Privacy
- Security
- Changes to This Policy
- Contact Us
1. Our Website
The Site is a simple informational website. It does not use cookies, does not run analytics, does not show advertising, and does not ask you to create an account. We designed it this way on purpose.
The Site is hosted by Cloudflare, Inc. (Cloudflare Pages). To deliver the Site and protect it against attacks, Cloudflare processes technical data about your visit — such as your IP address, browser type, and the pages you request — in server logs for a limited period. Cloudflare acts as our service provider (processor) and does not sell this data. See the Cloudflare Privacy Policy for details.
If you email us, we receive your email address and whatever you include in your message. We use it only to respond to you.
2. Information Our Apps Collect
Our first Apps are currently in development. When they are released, they may collect the categories of information below. Each App's App Store listing will describe exactly what that App collects in its Apple "App Privacy" label, and we keep those labels consistent with this policy. Not every App will collect every category — many of our Apps will collect far less.
Information you provide
- Account information. If an App offers accounts, we collect what you provide when signing up — typically an email address and a display name — plus the content you choose to sync (for example, saved progress or documents).
- Messages to us. Support requests and feedback you send, including your email address.
Information collected automatically
- Device and app information. Device model, operating system version, app version, language, region, and identifiers such as a randomly generated installation ID or, with your consent, the Apple advertising identifier (IDFA).
- Usage information. How the App is used — screens viewed, features used, session length — collected through analytics tools.
- Crash and diagnostic information. Crash logs and performance data (such as crash stack traces, device state, and app version at the time of a crash).
- Purchase information. If an App offers in-app purchases or subscriptions, Apple processes the payment. We never receive your payment card details; we receive purchase records (such as the product purchased and subscription status) needed to unlock what you paid for.
- Cloud sync information. If an App syncs data through iCloud, that data is handled by Apple under your iCloud account. If an App syncs through our own servers, the synced content is stored by us as described in this policy.
Our Apps do not collect precise location, contacts, photos, health data, or similar sensitive information unless a specific App clearly asks for the related system permission for a feature you choose to use — and never without the corresponding iOS permission prompt.
3. How We Use Information
We use personal information for the purposes below. Where GDPR applies, the legal basis for each purpose is listed alongside it.
| Purpose | Legal basis (GDPR Art. 6) |
|---|---|
| Providing the Services — running the Apps, creating and maintaining your account, syncing your data, delivering purchases you have made | Performance of a contract (Art. 6(1)(b)) |
| Fixing crashes and keeping the Services reliable and secure, including fraud and abuse prevention | Legitimate interests (Art. 6(1)(f)) — keeping our Services working and safe |
| Understanding how our Apps are used so we can improve them (analytics) | Consent (Art. 6(1)(a)) where required; otherwise legitimate interests (Art. 6(1)(f)) |
| Showing personalized advertising in Apps that contain ads | Consent (Art. 6(1)(a)) |
| Responding to your messages and support requests | Legitimate interests (Art. 6(1)(f)) — answering the people who contact us |
| Complying with law — tax, accounting, and responding to lawful requests | Legal obligation (Art. 6(1)(c)) |
Where we rely on consent, you can withdraw it at any time (for example, in the App's settings or your device settings) without affecting the lawfulness of processing that happened before you withdrew it.
We do not use your personal information to make automated decisions that produce legal or similarly significant effects about you.
4. Who We Share Information With
We do not sell your personal information for money, and we never will. We share personal information only with the service providers and partners below, or as required by law.
| Recipient | What they do |
|---|---|
| Apple Inc. | Distributes our Apps, processes all in-app purchases and subscriptions, and provides iCloud sync and opt-in crash and analytics reporting. See Apple's Privacy Policy. |
| Google LLC — Firebase | Provides analytics, crash reporting, and related app infrastructure for Apps that use it. See Firebase Privacy and Security. |
| Google LLC — AdMob | Serves advertising in Apps that contain ads, using device identifiers as described in Section 5. See Google's Privacy Policy. |
| Cloudflare, Inc. | Hosts the Site and processes visitor IP addresses to deliver it securely. See Cloudflare's Privacy Policy. |
We may also disclose personal information if required to do so by law or valid legal process, to protect the rights, safety, or property of Minigamr, our users, or others, or as part of a merger, acquisition, or sale of assets — in which case this policy will continue to apply to your information until you are told otherwise.
5. Advertising and Tracking Choices
Some of our Apps may show ads to keep them free. For those Apps:
- Tracking requires your permission. On iOS, we use Apple's App Tracking Transparency framework. An App will only access your device's advertising identifier (IDFA) to track your activity across other companies' apps and websites for personalized ads if you tap "Allow" on the iOS prompt.
- You can say no. If you decline, you will still see ads, but they will not be personalized based on cross-app tracking. Apps remain fully functional either way — we never lock features behind tracking consent.
- You can change your mind. Withdraw permission at any time in iOS Settings → Privacy & Security → Tracking, and manage Apple's own ad personalization in iOS Settings → Privacy & Security → Apple Advertising.
- In the EEA, UK, and Switzerland, personalized ads are only shown with your consent, which the App will ask for separately and which you can withdraw in the App's settings.
The Site shows no ads and contains no tracking of any kind.
6. International Data Transfers
We are based in the United States, and the service providers named in this policy process data in the United States and other countries. If you use the Services from the European Economic Area, United Kingdom, or Switzerland, your personal information is transferred to the United States.
Where such transfers occur, we rely on appropriate safeguards recognized under GDPR: the service providers we use (including Apple, Google, and Cloudflare) participate in the EU-U.S. Data Privacy Framework (and its UK and Swiss extensions) and/or enter into the European Commission's Standard Contractual Clauses as part of their data processing terms. You can request more information about these safeguards using the details in the Contact Us section.
7. Data Retention
We keep personal information only as long as needed for the purposes described in this policy:
- Account and synced data: kept while your account is active, and deleted within 30 days after you delete your account (allowing for removal from backups).
- Analytics data: retained for up to 14 months, after which it is deleted or aggregated.
- Crash and diagnostic data: retained for up to 90 days.
- Purchase records: kept as long as needed to provide what you purchased and to meet tax and accounting obligations.
- Email correspondence: kept as long as needed to handle your request and for a reasonable period afterward in case of follow-up.
When retention periods end, we delete or irreversibly anonymize the data.
8. Your Rights (EEA, UK & Switzerland)
If you are in the European Economic Area, the United Kingdom, or Switzerland, you have the right to:
- Access the personal information we hold about you and receive a copy;
- Rectify inaccurate or incomplete information;
- Erase your personal information ("right to be forgotten");
- Restrict processing in certain circumstances;
- Receive your data in a structured, commonly used, machine-readable format and have it transmitted to another controller (data portability);
- Object to processing based on legitimate interests, and to direct marketing at any time;
- Withdraw consent at any time where processing is based on consent, without affecting the lawfulness of prior processing.
To exercise any of these rights, contact us using the details in the Contact Us section. We will respond within one month. We may need to verify your identity before acting on a request.
You also have the right to lodge a complaint with your national data protection authority. A list of EEA authorities is available from the European Data Protection Board; in the UK, the authority is the Information Commissioner's Office.
9. Your Rights (US States)
Depending on where you live (including California, Colorado, Connecticut, Utah, Virginia, and other states with consumer privacy laws), you may have the right to know what personal information we collect, to access it, to correct it, to delete it, and to opt out of "sales" of personal information, "sharing" for cross-context behavioral advertising, or targeted advertising.
We do not sell personal information for money. In Apps that show personalized ads, the use of device identifiers by advertising partners may count as "sharing" or "targeted advertising" under some state laws — you can opt out at any time through the App's ad settings and the iOS controls described in Section 5, or by contacting us.
To exercise any right, contact us using the details in the Contact Us section. We will respond within 45 days, we will not discriminate against you for exercising your rights, and you may use an authorized agent to submit a request on your behalf.
10. Account and Data Deletion
Every App we publish that offers account creation also offers account deletion from inside the App (in the App's settings). Deleting your account removes your account information and synced content from our systems within 30 days, except for records we are legally required to keep (such as purchase records for tax purposes).
You can also request deletion of any personal information we hold — whether or not you have an account — by contacting us. See the Contact Us section.
11. Children's Privacy
Our Services are not directed to children under 13, and we do not knowingly collect personal information from children under 13. If you are under 13, please do not use the Services or send us any personal information. If you are a parent or guardian and believe a child under 13 has provided us personal information, contact us and we will delete it promptly.
If you are in the EEA or UK, you must be at least the age of digital consent in your country (between 13 and 16, depending on the country) to consent to data processing yourself; below that age, a parent or guardian must consent for you.
If we ever release an App designed for children, it will comply with the Children's Online Privacy Protection Act (COPPA) and Apple's Kids Category rules, including no behavioral advertising, and will have its own clearly-marked privacy disclosures.
12. Security
We take reasonable technical and organizational measures to protect personal information, including encryption in transit (HTTPS/TLS for all Services), access controls, and reliance on established infrastructure providers. No method of transmission or storage is completely secure, but we work to protect your information and will notify you and the relevant authorities of a data breach where the law requires it.
13. Changes to This Policy
We may update this policy from time to time — for example, when we release a new App or change providers. When we do, we will update the "Last updated" date at the top of this page, and if the changes are material we will provide more prominent notice (such as an in-App notice). The current version will always be available at minigamr.com/privacy.
14. Contact Us
Minigamr LLC is a Utah limited liability company located in Davis County, Utah, United States. Our mailing address is 830 Oxford Dr, North Salt Lake, UT 84054, United States.
For any questions about this policy, or to exercise any privacy right described above, email us.