LEGAL DOCUMENT
Privacy Policy
ATONI App Privacy Policy
Version 1.0, 11 August 2026 Effective date: 11 August 2026
1. Data controller
The controller of data related to ATONI is Marek Oczkowski, a sole trader operating at ul. Dolnej Wsi 88, 44-100 Gliwice, Poland, Polish tax identification number (NIP): 9691596950 (the “Controller”, “we”, “us”).
Privacy and general enquiries: contact@atoni.app.
2. Key principles
- ATONI does not require an account, name, email address or phone number.
- Player names entered before a game remain on the device and are not sent to us, Google, Apple or other parties.
- We do not send the selected word, the impostor hint or player names to analytics.
- We do not collect precise location, contacts, photos, recordings, health data or content from other apps.
- We do not sell personal data. At launch, we do not use personal data for behavioural advertising or advertising profiling.
3. Information that may be processed
3.1 Information stored on the device
| Information | Purpose | Does it leave the device? |
|---|---|---|
| Player names | running a local game | no |
| language, free games used and round settings | remembering preferences and limits | no, except for aggregated events described below |
| local installation UUID | privacy settings and optional notifications | only after notifications are voluntarily enabled and their delivery is activated |
| analytics and notification choices | remembering the user’s choice | the notification setting may be transmitted to the delivery provider |
| local Premium entitlement | restoring purchase status efficiently | the purchase confirmation is verified by the relevant store |
Uninstalling the App or using “Delete local data” removes information stored only on the device. A Premium purchase remains connected to the store account and may be restored.
3.2 Product analytics
Version 1.0 does not send usage events to an external analytics service. The analytics setting available in the App stores only the user’s choice and does not start data transmission.
If analytics is enabled in a future release, we will update this Policy, the store declarations and the user choice mechanism before collection begins. We do not plan to send player names, game words, hints, full payment details or precise location to analytics.
3.3 Optional notifications
If a user voluntarily enables notifications, the operating system and Expo, Apple or Google services may create and process a notification token, installation identifier, platform, language, Premium status and consent status. These details are used only to deliver messages to the correct device and select the relevant language or audience.
Notifications may concern new features, new words, ATONI news and special offers. They can be disabled in ATONI or in the device settings.
3.4 App Store and Google Play purchases
Apple or Google processes store account, payment, tax and payment method information under its own terms and privacy policy. We may receive limited transaction information, such as the store, order or transaction identifier, product, price, currency, store country and purchase, refund or restoration status. We do not receive the full payment card number.
3.5 Support contact
If a user contacts us, we process the email address, message, attachments and information needed to reply, handle a complaint or exercise user rights.
4. Purposes and legal bases
For users in the European Economic Area, the United Kingdom and Switzerland, processing may rely on the following bases:
| Purpose | Legal basis |
|---|---|
| providing the App, Premium and purchase restoration | performance of a contract or steps before entering into a contract |
| complaints, accounting, tax and legal duties | performance of a contract and legal obligation |
| security, fraud prevention and legal claims | our legitimate interests |
| storing the local analytics choice | our legitimate interest in operating App settings |
| marketing push notifications | consent, which may be withdrawn at any time |
| responding to voluntary contact | contract, legitimate interests or consent, depending on the message |
Withdrawing consent does not affect processing carried out lawfully before withdrawal.
5. Recipients
Where necessary for the App to operate, information may be processed by or disclosed to:
- 650 Industries, Inc. (Expo), Google and Apple for optional notification delivery;
- Apple Distribution International Ltd. and relevant Apple entities for App Store distribution, purchases and store diagnostics;
- Google Commerce Limited, Google Ireland Limited and relevant Google entities for Google Play distribution and purchases;
- providers hosting atoni.app and contact@atoni.app, to the extent needed to maintain the website and correspondence;
- accountants, legal advisers, public authorities or courts where lawful and necessary.
Apple and Google may act as independent controllers for their accounts, stores, payments and legal obligations. Other providers operate according to the scope of their services and applicable data processing terms.
6. International transfers
Google, Apple and their service providers may process information outside the user’s country, including outside the EEA, United Kingdom or Switzerland. Transfers use legally recognised safeguards, such as adequacy decisions, the Data Privacy Framework where applicable, or standard contractual clauses.
Expo, Apple and Google use global infrastructure and may not allow all processing to be restricted to Europe.
7. Retention
- local data: until deleted in the App, cleared from the device or removed with the App;
- external analytics data: not collected in version 1.0;
- notification data: while the installation and consent remain active; after consent is withdrawn, the token is removed locally and deregistered from our delivery list if it was previously stored there;
- purchase and accounting data: for periods required by tax, accounting and consumer law and limitation periods;
- correspondence and complaints: while handled and then until the relevant limitation period expires;
- consent or objection records: for as long as needed to honour the choice and demonstrate compliance.
After the relevant period, information is deleted, anonymised or retained only where required by law.
8. User rights
Depending on residence and applicable law, a user may have rights to information, access, correction, deletion, restriction, portability, objection to processing based on legitimate interests, withdrawal of consent, complaint to a supervisory authority and non-discrimination for exercising privacy rights.
Requests may be sent to contact@atoni.app. Because ATONI does not operate user accounts and normally does not know a user’s identity, we may request only the information necessary to locate relevant data. Device-only data can be removed with “Delete local data”.
9. California and other US states
Where applicable law applies, users may request information about data categories, sources, purposes and recipients, access, correction or deletion, and may exercise any right to opt out of sale or sharing for cross-context behavioural advertising.
We do not sell personal information and, at launch, do not share it for cross-context behavioural advertising. We do not discriminate against users for exercising privacy rights. Requests may be sent to contact@atoni.app.
10. Brazil
Where the LGPD applies, users may request confirmation of processing, access, correction, anonymisation, blocking or deletion, information about sharing, portability within the limits of law and withdrawal of consent. Requests may be sent to contact@atoni.app. Users may also contact the Brazilian National Data Protection Authority (ANPD).
Distribution in Brazil may be subject to additional rules protecting children and adolescents in digital environments, including age assurance and parental control requirements. Store-level or device-level safeguards may apply, and availability may be limited until the applicable compliance route is confirmed.
11. Minors
ATONI is intended for users aged 13 and over and is not directed to children under 13. We do not knowingly collect personal data from a child under 13. A parent or guardian who believes such processing occurred should contact contact@atoni.app.
Where local law requires parental or guardian consent for processing or a purchase by a user aged 13 to 17, the user must obtain it. Optional marketing notifications should not be enabled by a minor without any consent required in that minor’s country.
12. Security
We use measures appropriate to the limited data involved, including data minimisation, HTTPS encryption in transit, restricted administrative access, multi-factor authentication where available and periodic review of permissions and third-party libraries. No security method provides an absolute guarantee.
13. Changes
We may update this Policy when the App, law or providers change. The current version will be available in the App and at https://atoni.app/en/privacy. Material changes will be communicated where required by law.
14. Contact and complaints
Questions and requests: contact@atoni.app.
Users in the EEA may complain to the data protection authority in their country of residence, place of work or alleged infringement. In Poland, the authority is the President of the Personal Data Protection Office. Users in the United Kingdom may contact the Information Commissioner’s Office. Users in Brazil may contact the ANPD.