This policy explains what information the Milogram game ("the app") uses, why, who else handles it, and the choices you have. Milogram is made by Mala ("we", "us").
The short version: Milogram has no accounts. You play without giving us your name, email or phone number, and your games stay on your device. Usage data and crash reports are sent with a random install ID, with no name or contact details and none of your words or games, and you can switch them off. Words you appeal are sent without anything that identifies you.
Who we are
The controller of your information is Mala, the studio behind mala-lab.com.
- Website: mala-lab.com
- Email: support@mala-lab.com
- Representative and data protection officer: we haven't appointed a representative in the EU or UK (GDPR and UK GDPR Article 27) or a data protection officer. Send any privacy question or request to support@mala-lab.com.
What stays on your device
The game plays fully offline against the computer. Your saved games, the moves in them, your settings, statistics, the words you accepted with an appeal and your choices in this policy are stored on your device only. We don't receive them. Deleting the app deletes them.
Information we collect
Usage figures (Firebase Analytics)
To learn how the game is played and improve it, the app sends these events to Google Firebase Analytics: a game finished (mode, preset, topic, level, result, game length and the share of turns that had a valid move), the tutorial finished, the subscription screen was seen, and a subscription started. Firebase also counts sessions, time played and returning players by itself.
These events carry Firebase's random app-instance identifier and basic device information (such as the device model, operating system, app version, language and approximate country derived from the IP address). They don't carry your name, email, the words you play or your saved games. We have switched off the collection of the advertising ID by Firebase Analytics. Google Analytics keeps this event data for 2 months.
Crash reports (Firebase Crashlytics)
If the app crashes or hits an error, a report is sent to Google Firebase Crashlytics: the technical error and where it happened in the code, the device model, operating system and app version, and the same app-instance identifier. Reports don't include your games or the words you play. Firebase keeps crash reports for 90 days.
Usage figures and crash reports follow one switch in the app's settings, and where the law requires consent they start only after you agree (see "Your choices").
Word appeals (Mala's word service)
When the game doesn't know a word and you appeal, the app sends only the word to our word service, which judges it and may add it to the dictionary for all players. The appeal carries no identifier: no install ID, account or advertising ID. The service stores no player data (no IDs, devices or IP addresses) and keeps no request logs. It uses your IP address only in passing, to deliver the answer and to limit how many appeals one address can send a minute. For words it doesn't know yet, it keeps a count of appeals and the days they were first and last seen. The word service runs on Cloudflare, and a spelling checker it uses runs on Google Cloud and receives only the word. You can switch sending appeals off with "שליחת ערעורים לבדיקה" (send appeals for checking) in Settings; the appealed word then counts in your game only.
Please appeal only words you played. Don't type personal information into the game.
Dictionary and document updates
When it's online, the app checks for a new list of accepted words and for new versions of these legal documents, and downloads them. These are ordinary downloads of public files from Cloudflare; they don't carry any identifier.
Advertising (Google AdMob)
If you don't have the ad-free subscription, the app may show one ad when it opens (at most once every few hours, never during a game) and offers an optional rewarded ad when you tap Hint. Ads are provided by Google AdMob. AdMob receives information from your device such as the IP address, device type, operating system, app identity, ad interactions and, if you allow it, the advertising identifier, and uses it to deliver ads, limit how often you see them, measure them and prevent fraud.
- In the EU, EEA, UK and Switzerland, Google's consent message is shown before ads that need consent. You choose whether ads may be personalised, and you can change your choice later in the app's settings.
- Elsewhere, ads may be personalised. You can opt out of personalised ads through your device's ad settings.
- On iPhone and iPad, the app asks for your permission through Apple's App Tracking Transparency prompt before the advertising identifier (IDFA) can be used. If you decline, it isn't used, and the game works the same.
- On Android, you can reset or delete your advertising ID in your device settings.
Purchases (ad-free subscription, through RevenueCat)
The ad-free subscription is sold and billed by Apple (App Store) or Google (Google Play). We use RevenueCat to check and restore subscriptions without a Milogram account. RevenueCat receives the purchase receipt and transaction details from the store (product, dates, price, country or currency and subscription status) and a random identifier it creates for the app on your device. We never receive your card or bank details.
What we never collect
- Your name, email address, phone number, address or photo. The app has no accounts and no sign-in.
- Your contacts, photos, microphone, camera or location.
- The words you play and your saved games (except a word you choose to appeal, sent without an identifier).
- Payment card or bank details.
We don't sell your personal information.
Why we use it (legal bases)
| Purpose | Legal basis (GDPR / UK GDPR) |
|---|---|
| Judging word appeals and improving the dictionary | Our legitimate interest in an accurate word list; you can switch appeals off |
| Usage figures and crash reports | Your consent in the EU, EEA, UK and Switzerland; elsewhere our legitimate interest in a working, improving game, with an opt-out at any time |
| The ad-free subscription | Performance of our contract with you (the Terms of Use); legal obligations for tax and accounting records kept by the stores |
| Ads | Your consent for personalised ads or use of the advertising identifier; otherwise our legitimate interest in funding the free game |
| Downloading dictionary and document updates | Performance of our contract with you |
Who we share information with
We use these service providers. They process information for us, or as independent controllers where their own terms say so:
- Google (Firebase Analytics, Firebase Crashlytics, AdMob, Google Cloud for the word service's spelling checker, and Google Play billing). Google privacy policy
- Cloudflare (the word service, its database, and delivery of dictionary and document updates). Cloudflare privacy policy
- Apple (App Store billing and App Tracking Transparency). Apple privacy policy
- RevenueCat (subscription management). RevenueCat privacy policy
Words accepted through appeals become part of the dictionary, which is published to all players and, as the word lists' licence allows, may be shared publicly. They aren't linked to anyone.
We may disclose information if the law requires it, to protect players or the service, or as part of a merger or sale of the business, in which case this policy continues to apply.
How long we keep it
- On your device: until you delete the app or its data.
- Appealed words: kept as part of the dictionary's records: the word, the service's verdict, the number of appeals and the days it was first and last seen, without any identifier.
- Firebase Analytics: 2 months for event data linked to the app-instance identifier (our Google Analytics retention setting).
- Firebase Crashlytics: 90 days, Firebase's default.
- AdMob and RevenueCat: according to each provider's own retention policy.
- Request logs: the word service keeps none.
Your choices
- Usage figures and crash reports: one switch in the app's settings. In the EU, EEA, UK and Switzerland, nothing is collected until you agree; elsewhere it's on until you switch it off.
- Word appeals: the "שליחת ערעורים לבדיקה" (send appeals for checking) switch in Settings.
- Ads: the consent settings in the app in the EU, EEA, UK and Switzerland; elsewhere your device's ad settings (Apple's tracking prompt and setting on iPhone and iPad, the advertising ID on Android); or the ad-free subscription, which removes ads.
- Everything on your device: delete the app, or clear its data.
Your rights
Depending on where you live, you may have the right to access, correct, delete or receive a copy of your information, to object to or restrict its use, and to withdraw consent at any time (this doesn't affect what happened before). Because the app has no accounts and appeals carry no identifier, we usually can't link any information to you; for Firebase data, tell us your request and we'll explain how we can help. You can also complain to your local data protection authority (in Israel, the Privacy Protection Authority).
California and other US states: we don't sell personal information. You can opt out of personalised ads as described under "Advertising" and "Your choices". We don't use sensitive personal information. You won't be treated differently for exercising your rights.
To exercise a right, email support@mala-lab.com. We'll answer within the time the law requires.
Children
Milogram is made for a general audience of players 13 and older (16 in EU and EEA countries whose law requires a parent's consent below that age). It isn't directed at children. We don't knowingly collect information from children under that age; the app asks for no personal details, and a parent can switch usage figures and appeals off in the settings. If you think a child under that age has sent us information, write to support@mala-lab.com.
International transfers
Our providers may process information outside your country, including in the United States. Where the law requires it, transfers rely on the safeguards in each provider's data processing terms, including the European Commission's Standard Contractual Clauses.
Security
Connections to our services are encrypted (HTTPS), and downloaded word lists are checked against a hash before the app uses them. No system is perfectly secure, so we can't guarantee absolute security.
Changes to this policy
When we change this policy we update its version and effective date at the top. If the change is significant, the app will tell you before it applies. Previous versions are available on request.
Language
This policy is available in Hebrew and English. If the two versions differ, the Hebrew version prevails.
Contact
Mala (mala-lab.com), support@mala-lab.com