Privacy Policy

The level is zero, and the tank has no outlet

There is no registration step in Akvarij. No profile is built. No time you set is published anywhere. No advertisement is shown, no library counts anything, and nobody is on a list. Below that run of absences lies one more that turns the rest from assurance into something a reader can test: the published package requests no internet permission from Android. Android will not open a socket for an app that never declared the permission, no matter what that app's code would like to do, and the declared permissions are listed on the store page for anyone to read before installing.

Whatever the game keeps of you — puzzles finished, which packs are open, the half-filled wall you left standing — lives in the storage Android ring-fences for this app and nowhere beyond it. No copy reaches a machine of ours, which means there is nothing of yours in our hands to be leaked, sold, misplaced or handed over to anybody who asks.

Eleven levels follow. Between them they hold everything the General Data Protection Regulation requires such a notice to say, and the eleventh gives the address for disagreeing with any of it.

The controller

Article 4(7) attaches the word "controller" to whichever party decides what a processing operation is for and how it will be run. Attached to this page the title carries one duty that is not decorative: that what is written below was written truthfully, and that there is a person to hold to account if it was not.

There is no data protection officer here, and that is a conclusion rather than an oversight. Article 37 compels the appointment only where the controller is a public body, or where watching people closely and at scale is the main thing the business does, or where special-category data is handled on that same scale. A company whose one app transmits nothing meets none of those tests; appointing an officer regardless would protect nobody and look like it protected somebody.

Everything written down, in full

A puzzle with dozens of walls must remember something or every evening would begin at the first one. The complete contents:

• Walls completed, and in which pack, so the puzzle list can show where you have reached.
• Best times on those you have finished, kept so a later attempt has a figure to beat.
• The wall in progress — every tank's level, the cells you have marked as air, the undo history of this sitting — so closing the app does not pour away the reasoning.
• Hints remaining in the allowance.
• Settings: interface language, water colour, whether solved clues dim, the timer, haptics, reduced motion.

Now the absences, which matter more than the list. Nowhere is a name asked for. Nothing resembling an address — postal, electronic or network — is written down. Android offers an advertising identifier and the app never reads it. No combination of handset characteristics is assembled into a fingerprint. And the game issues itself no installation number, which is the omission that carries the rest: lacking one, there is no handle by which your copy of Akvarij could be told apart from the ten thousandth, whether by us or by anyone else. The operating system then seals that storage against every other app on the device.

Delete the game and the contents drain with it. To empty them and keep the game, there is a reset in the settings, and Android offers the same from its own application settings under "clear data".

Why Article 6 is nowhere on this page

Notices of this kind march down the page in pairs: a thing collected, the legal basis for collecting it, the next thing collected. No basis is given anywhere here, and a blank where a reader expects a pair deserves an explanation.

Every lawful basis is a reply to the same question — by what right is this in your hands? — and the question only makes sense if something is in somebody's hands. Here nothing is. What level 03 lists rests on equipment you own and we cannot reach, and it marks out nobody: strip away the identifiers, which were never there, and what remains is a record of how one telephone fared against some walls of glass. The Regulation engages where personal data is processed by a controller; the first element is missing, and without it the second cannot exist either.

All of which holds only while its premise does. Should a future build acquire any of the four — an account to sign into, an advertisement, instrumentation, or something to buy — the premise collapses — at which point this text has to be redrawn and published with the very release that introduces the change, each addition carrying its ground by name. A comment at the foot of this file sets out how.

Consent banners are missing for a related reason. The rules in question bite where something is placed on, or retrieved from, a user's device for a purpose beyond simply delivering what they asked for, and in practice such things arrive inside a web view, as a counting pixel, or as a token written by some outside library. This game contains no web view, no pixel and no outside library, and has no line over which any of them could speak, so the Croatian implementation of those rules has nothing in it to bite on.

One asked for, the rest left alone

That refusal on the right holds up the rest of the document. Take away an app's route out and claims about destinations cease to be assertions about our good intentions; they turn into facts about the published package, which anyone willing to open it can confirm for themselves.

Refuse any prompt you did not expect, and tell us about it: the version number, sent to plima@mortadela.site settles it. Only two things could account for it — the page has gone stale, or the package did not come from us — and we would want to know which before anyone else runs into it.

The store, which lies outside all of this

Every level so far describes Akvarij in use. How it reached the handset is a separate matter, settled beforehand between you and Google. The download, the updates that follow and a rating if you leave one are all entered against your Google account, in Google's own ledger, on whatever terms Google sets for its own services. We are outside that relationship entirely and have no influence over what it retains.

Our window onto all this is the Play Console, and it shows summaries only: how many copies went out, roughly where, which faults repeat, where the star rating sits. There is no view in it that resolves down to an individual. Your Google account — the email behind it, a saved payment method, the devices it has been used on — is simply not visible from where we sit, and the switches Google provides over its own retention are inside that account rather than in this app, so a question about them has to go there.

One caution about the listing. Reviews are published immediately and openly, carrying whatever name your account displays, and they remain on the page for every future visitor to read.

Nobody downstream, and no border crossed

Consigning work to a processor presupposes work being done. No server holds anything on this game's behalf; no analytics account is open against it; no crash service listens for it; no advertising exchange is wired into it; no mailing tool has its address list; no payment agent is appointed for it. These are not contracts turned down — they are contracts with nothing to be about. Article 13(1)(e) asks a controller to write out the categories of recipient; written out truthfully, there are none.

Transfer abroad resolves from the same fact. Every instrument in that area — an adequacy decision, the standard contractual clauses, one of the narrow exceptions in Article 49 — is a licence for data that travels, and nothing in this game travels. A best time recorded on your telephone was written there and has been nowhere since.

Set down as the edge of our responsibility rather than a gap in it: level 06 describes something carried out on Google's machines, under the agreement Google has with you, and finished and done with before anybody taps the icon.

For how long, and for whom

Duration. Retention clauses give a number of months because, usually, the data is being kept by somebody the reader has no hold over. The position here is the opposite, so what follows is a condition instead: what is stored lives as long as you want it to and not a moment longer, since the reset button and an uninstall both end it immediately. No nightly job duplicates it elsewhere, no archive retains an earlier state, and there is no machine of ours on which some remnant could survive you

Audience. Akvarij holds a general-audience rating, and watching numbers come true across a wall of tanks is a calm way for a child to spend half an hour. Four things usually make a parent read on — advertising pointed at the child, a purchase within reach of a careless tap, messages from strangers, material other users have uploaded — and none of the four was built in. Article 8 is the provision that sets an age below which a child's consent to an online service must be backed by a parent. It has no application here at all, because consent is never requested, from a child or from anybody else. Croatia sets that age at 16, set down now so the number is already in the text if advertising is ever introduced and the point abruptly matters.

Eight rights, and what each would really produce

You hold the complete set, in full strength. The unusual part is only where each is used: for this game that is nearly always on the handset itself rather than an exchange of letters with us. There would be little use in setting out an application procedure that could only ever end with us writing to say we hold nothing, so each line below states the outcome you would actually get.

Nothing here costs money, nothing requires a form to be filled in, and nobody will ask you for proof of who you are. The point of an identity check is to stop one person's file going to somebody else; with no files on this side there is nothing for it to protect, and carrying it out would mean collecting a document from you while assuring you that nothing is collected.

Taking it past us

Being registered in Croatia places the company under the General Data Protection Regulation alongside its Croatian implementing statute, the Zakon o provedbi Opće uredbe o zaštiti podataka. Supervision belongs to the Agencija za zaštitu osobnih podataka, the Croatian data protection agency, at Selska cesta 136 in 10000 Zagreb, whose forms and guidance are at azop.hr.

You are not confined to Zagreb. Article 77 offers a complainant three forums, and any of them will accept the matter: your country of residence, your country of employment, or wherever you believe the infringement took place. The choice is yours and may be made on nothing but convenience. A clause on this page cannot shrink it, and one that tried would be ineffective in law.

A word on order, which is advice and not a requirement. Mail sent here tends to be answered before the day is out; an agency must follow its process and work through what is in front of it. Try us by all means, but you owe us no first attempt, and a file open with the agency while we are still writing back is perfectly proper.

One address, and one rule about changes

A single mailbox takes all of it — plima@mortadela.site. Write about a right you want exercised, about a claim on this page you think is wrong, about a permission request that level 05 does not account for, or simply to ask how a part of it works. Both Croatian and English reach the same reader.

Slobodno nam pišite na hrvatskom — ista adresa, a odgovor stiže na hrvatskom.

The version under the heading moves whenever a word beneath it does. About timing there is a single rule, applied without exception. If a revision alters what the app really does — a class of information kept that was not kept before, an outsider admitted to the process, traffic leaving the country, a further purpose taken on — the rewritten text goes out inside the same release that makes the change, not two weeks afterwards once the behaviour has already reached everybody. That is why the version is worth a glance: it tells you whether the words you are reading belong to the build sitting on your telephone. Nothing older is destroyed, and a previous version will be sent on request.