PRIVACY POLICY

Privacy Policy – PopUp Flex

Effective Date: 11th of April, 2025

Pop Up Flex is a service provided by Pink Frog Games GmbH (hereinafter also “Pinkfrog” or “Provider”), acting as Controller in accordance with relevant data protection provisions. Please find full company and contact details on the App. This Privacy Policy informs you about which data we collect when, and how we process your personal data in the context of the PopUp Flex Quiz App ("App").

I. Controller, Scope

Pinkfrog is the controller responsible for the processing of your personal data under applicable data protection laws, including the General Data Protection Regulation (GDPR).

II. General Information About Data Processing

Purposes of Processing We process personal data to provide a functional and engaging app experience, offer content and progression features, and support monetization activities including ads and in-app purchases.
Legal Basis The processing of personal data is primarily based on:
- Art. 6(1)(b) GDPR for contract performance (e.g., providing core app functionality)
- Art. 6(1)(a) GDPR for consent-based processing (e.g., personalized ads, third-party tracking)
- Art. 6(1)(f) GDPR for legitimate interests (e.g., analytics and fraud prevention)
Retention Time Personal data is retained only as long as necessary to fulfill the intended purpose. If based on consent, data is stored until consent is withdrawn. Further storage may be required due to legal obligations. Data will be deleted or blocked after expiration of the retention period unless further storage is required for legal claims.
Processors We may use selected third-party providers as processors (e.g., hosting providers, analytics platforms, app stores). These processors are bound by data processing agreements pursuant to Art. 28 GDPR.
Transfer to Third Countries Some services may process data outside the EU/EEA. Data transfer will occur only under an adequacy decision by the European Commission or subject to appropriate safeguards, such as Standard Contractual Clauses.

III. Services We Use

Offer Wall Service We use Adjoe to provide an offer wall, allowing users to earn in-game currency by completing tasks. These services may collect device identifiers, usage data, and performance metrics.
Ad Mediation Service We use AppLovin (and similar partners) to manage rewarded and interstitial ads. Ad networks may collect data such as IP address, device ID, ad engagement metrics, and interactions.
Mobile Measurement Partner (MMP) We use MMP services such as AppsFlyer or Adjust to measure marketing performance and app usage. These partners may process installation data, attribution events, and revenue metrics.
In-App Purchases Transactions are processed through platform providers (Google Play, Apple App Store). We do not store payment information, but we may access anonymized purchase histories to manage your in-game progression.
Rewarded Ads We serve rewarded video ads that offer in-game benefits. Watching ads is optional. Advertisers may collect anonymized device and behavior data for targeting and reporting.

IV. Data We Collect

App store credentials
Nickname and optional profile picture
Device information (e.g., model, OS version, IP address)
App usage data (e.g., quiz completion, category unlocks, ad views)
In-game currency activity (e.g., Brain$ balance, boosters used)

This information is used to provide core app functionality, personalize the experience, and deliver ads and rewards.

V. Your Rights (GDPR) Under GDPR, you have the following rights:

Right of access
Right to rectification
Right to erasure
Right to restriction of processing
Right to notification
Right to object
Right to withdraw consent
Right to data portability

You are not required to pay any fee for exercising your rights. We will respond within one month.

Please contact us at [Insert Contact Email] for data access or any privacy-related inquiries.

Right to Object You may object to the processing of your personal data under Art. 6(1)(e) or (f) GDPR at any time for reasons arising from your particular situation. We will no longer process the data unless we demonstrate compelling legitimate grounds.

Right to Lodge a Complaint You have the right to lodge a complaint with a supervisory authority if you believe your data is being unlawfully processed.

VI. Children’s Privacy

Our App is not directed to children under the age of 13. We do not knowingly collect personal information from children.

VII. Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy when introducing new services or features. The updated policy will be published within the App and/or store listings.