RUDEEN

Privacy Policy

Last updated: 18 October 2026

Scope: This policy applies to the app (Android/iOS), its web version (at "/play/") and this website ushanka-hat.com with all its pages.

Note: This policy also describes planned features. Sections marked "applies only if ads are switched on on the website" apply only once ads on the website and in the web version are switched on.

Ads on the website at present: not switched on.

1. Controller

The controllers within the meaning of the General Data Protection Regulation (GDPR, Art. 4(7)) are:

Stanislav Britanishskii, Böblinger Straße 189, 70199 Stuttgart, Germany

Dmitrii Kovalenko, Oppenhoffallee 83, 52066 Aachen, Germany

E-mail: britanishskii.games@gmail.com

No data protection officer has been appointed; none is required (fewer than 20 persons regularly process personal data, Section 38 BDSG).

2. Offline game (no account)

The single-device game works without an account and without an internet connection. Only the following is stored on your device: language, theme, sound/vibration and your player name. This data is not transmitted to us.

Legal basis for local storage: Section 25(2) no. 2 TDDDG (strictly necessary to provide the service you requested).

3. Optional sign-in and account (Firebase Authentication)

Signing in is optional. The game works offline and online as a guest without an account. An account is only needed for features tied to a person, such as future purchases, and a single account works in the app and on the web. You can sign in with Google, with Apple, or with e-mail and password. We use Firebase Authentication (Google Ireland Limited / Google LLC) for this.

In the web version the app loads Firebase Authentication (program files from www.gstatic.com, then connections to Google servers such as googleapis.com and firebaseapp.com) only when you open the sign-in screen, or at start if you are signed in in this browser. Merely opening the web version makes no connection to Google for sign-in.

Data processed: user ID (UID); e-mail address; name (provided by Google or Apple, if you use them); for e-mail sign-in, a hash of your password (never the password itself; if you sign in with Google, we do not receive your Google password); whether the e-mail address has been confirmed; technical data such as IP address and device/app identifier during sign-in. For e-mail accounts, Firebase Authentication sends you a confirmation e-mail after registration and, on request, a password reset e-mail.

Purpose: creating and securing your account, sign-in, confirming your e-mail address, password reset, abuse prevention.

Legal basis: Art. 6(1)(b) GDPR (providing the account you requested) and (f) GDPR (security and abuse prevention).

Retention: until you delete your account.

In addition, our own server (Hetzner, see section 4) keeps a small account record so that purchases can be linked to your account in the app and on the web. It contains only: your user ID (UID), the date the record was created, the date of last use (the last time the app or the web version asked the server for your account data) and, later, the word packs you bought (pack, store or source, date). It does not contain your e-mail address, password or name. Purpose: linking purchases to your account in the app and on the web. Legal basis: Art. 6(1)(b) GDPR. Retention: as long as the account exists; when you delete your account in the app or on the web, this record is deleted immediately. Backup copies of the database are kept for at most 14 days, so the deleted data also disappears from the backups after 14 days at the latest.

Profile photo in online rooms. If you sign in with Google and the setting "Show my photo to other players" is on (Settings > Account; on by default), the other participants of your online room see your Google profile photo next to your name. Their devices load the photo directly from Google's servers (googleusercontent.com); Google therefore sees their IP address. You can turn this off at any time in Settings > Account; then the others see only the first letter of your name. Our server does not store the photo: it only passes its address (the link from your Google account) on to the room only while the room exists and you are online in it; when you drop offline, and on a seat taken over by someone else, no photo is shown. Legal basis: Art. 6(1)(f) GDPR (legitimate interest: players of a room recognise each other); you can object at any time by turning the setting off.

4. Lobby server (Hetzner)

Online games run on our own WebSocket server in Germany. The hosting provider is Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany. A data processing agreement with Hetzner under Art. 28 GDPR has been concluded.

Data processed: IP address, lobby ID, game state (e.g. player name, game progress), error messages in the system journal (see section 5). If you have an account, the server also keeps the account record described in section 3 (UID, dates, purchased word packs).

Purpose: providing the online lobby, troubleshooting, security.

Legal basis: Art. 6(1)(b) and (f) GDPR.

Retention: game state until the lobby ends; error messages of the server in the system journal 7 days (see section 5).

5. Website and web version: hosting and server logs

This website and the web version run on the same server at Hetzner Online GmbH (Industriestr. 25, 91710 Gunzenhausen, Germany). The web server Caddy, which provides the HTTPS connection, sits in front of our game server. A data processing agreement with Hetzner under Art. 28 GDPR has been concluded (see section 4).

When you open a page, the server technically sees your IP address, the time and the requested page. The web server writes no access log (no logging of individual requests). Error messages of Caddy, of the TURN server (coturn) and of the game server go to the system journal of the server. They can contain your IP address, the time and the failed connection. Journal entries are deleted after 7 days.

Purpose: security and troubleshooting. Legal basis: Art. 6(1)(f) GDPR (legitimate interest in a secure and working service).

Our website itself sets no cookies; on Google's consent window and ad code see below.

Google's consent window and ad code: every page of the website loads Google's consent tool (fundingchoicesmessages.google.com, see section 11), also while ads are not switched on; with it you make your choice and can change it later. When it loads, Google receives your IP address, browser and device information and the address of the page and may transfer data to Google LLC in the USA (see section 14). The website loads Google's ad code (AdSense, adsbygoogle.js from pagead2.googlesyndication.com) only if ads are switched on, and only after you have consented in the consent window or the consent tool has found that no consent is needed for you (a visit from outside the EEA, the United Kingdom and Switzerland). Before that the website makes no connection to Google's ad servers (googlesyndication.com, doubleclick.net, adtrafficquality.google). For Google as the consent tool, the legal basis of section 11 applies. Google's information on data use on partner sites: https://policies.google.com/technologies/partner-sites

6. Local storage in the web version

The web version stores data in the local storage (localStorage) of your browser. It holds the settings of the app:

If you sign in in the web version, Firebase Authentication keeps the sign-in session in the storage of your browser (IndexedDB).

This data is not passed on to third parties and is used only for the game. Legal basis: Section 25(2) no. 2 TDDDG (strictly necessary to provide the service you requested). You can delete it at any time in your browser settings ("Delete website data").

7. Voice chat in online games (peer-to-peer)

Voice chat runs directly between players' phones (WebRTC). As a result, your IP address is technically visible to the other participants in the lobby. The server only helps set up the connection (signaling). Audio is neither recorded nor stored.

To establish the connection we use our own STUN/TURN server (coturn) on our server at Hetzner in Germany. No external STUN/TURN service is used. With TURN, encrypted media traffic passes through that server; it is not recorded. Error messages of the TURN server can contain your IP address and are deleted after 7 days (see section 5).

Microphone access is requested only after your permission in the operating system; legal basis Art. 6(1)(a) GDPR and Section 25(1) TDDDG. You can turn voice chat off at any time.

8. Speech recognition

The app and the web version do not use speech recognition. No audio is recorded or transmitted for this purpose.

9. Advertising in the app (own house ads and Google AdMob)

The app fetches its own ads (texts and images) from our server (/api/ads, /ads/...). The server technically sees your IP address (error messages in the system journal, see section 5); no personal data, advertising IDs or usage profiles are sent or stored. Without a connection no ad is shown. Ads can be switched off in Settings ("No ads").

During the game, on the screen of the explainer (below the word card, above the buttons), and, taking turns with our own ads, at the bottom of the home screen, the app shows a small banner ad from Google AdMob (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland). When an ad is requested, Google may process your advertising ID, IP address, device and app information (e.g. model, operating system, app ID) and your interactions with the ad, also on its own responsibility. In the EEA, the UK and Switzerland a consent form from Google (User Messaging Platform, IAB TCF) appears at the first start; ads are requested only after you have made your choice there (elsewhere no form is required). If you do not consent, Google may still show non-personalised or limited ads that follow your choice. For ads on the website and in the web version, section 10 applies. Google's information on how it uses data from partner apps: https://policies.google.com/technologies/partner-sites

You can change or withdraw your choice at any time: Settings → "Ad privacy settings" (shown wherever the form is required). You can also reset the advertising ID in your device settings, or switch ads off in Settings ("No ads").

Legal basis: Art. 6(1)(a) GDPR and Section 25(1) TDDDG (access to advertising ID/terminal equipment); for non-personalised or limited ads without consent, Art. 6(1)(f) GDPR (legitimate interest in financing the free game and in preventing fraud).

10. Advertising on the website and in the web version (Google AdSense) – applies only if ads are switched on on the website

If ads are switched on, we show ads from Google AdSense on the pages of the games portal, on the game pages and between the rounds of the web game. The provider in the EU is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Google LLC (USA) is involved.

Third-party vendors, including Google, use cookies to serve ads based on a user's prior visits to this website or other websites. Google's use of advertising cookies enables it and its partners to serve ads to users based on their visit to this and/or other sites on the Internet. Users may opt out of personalised advertising by visiting Google's Ads Settings: https://adssettings.google.com (Google now calls it "My Ad Center": https://myadcenter.google.com). Google's information on data use on partner sites: https://policies.google.com/technologies/partner-sites

There are three kinds of ads:

Data processed: cookies and device identifiers, IP address, browser and device information, URL of the page, interactions with ads. Google may also process this on its own responsibility. Further advertising partners and their purposes are listed in the consent window (see section 11).

Without your consent: no ads are shown.

Legal basis: Art. 6(1)(a) GDPR and Section 25(1) TDDDG (consent). You can withdraw it at any time (see section 11).

Transfer to the USA: see section 14.

11. Consent management (privacy settings)

A consent window asks for your choice; you can open it again at any time with the "Privacy settings" link at the bottom of every page. For this we use Google's "Privacy & messaging" tool (IAB TCF); the provider is Google Ireland Limited. Your choice (TC string) is stored in a cookie or in the local storage of your browser, so that we do not ask again on your next visit and can prove your consent. Legal basis: Art. 6(1)(c) GDPR in conjunction with Art. 7(1) GDPR (proof of consent); for storing your choice in the browser, Section 25(2) no. 2 TDDDG.

Withdrawal: you can change or withdraw your choice at any time, as easily as you gave it. Click the link "Datenschutz-Einstellungen" (privacy settings) at the bottom of every page of the website (page "/datenschutz-einstellungen") or, in the web version, under "About the app". Withdrawal takes effect for the future (Art. 7(3) GDPR); the lawfulness of the earlier processing is not affected.

As long as ads are not switched on, no ads are shown and Google's ad code (AdSense) is not loaded, even after your consent; the consent window may still appear (see section 5).

12. Crash reports and statistics

The app, the web version and the website use no crash reporting and no analytics (no Firebase Crashlytics, no Firebase Analytics, no other tracking tools).

13. Recipients

14. Transfers to third countries

Google LLC and Apple Inc. are based in the USA. This also applies to the consent management on the website and, if ads are switched on, to AdSense; further advertising partners from the consent window may also transfer data to third countries. For users in the EU, Sign in with Apple is provided by Apple Distribution International Ltd. (Hollyhill Industrial Estate, Hollyhill, Cork, Ireland); Apple may transfer data to Apple Inc. in the USA. On 10 July 2023 the European Commission adopted an adequacy decision for the EU-US Data Privacy Framework. Transfers to certified companies rely on it (Art. 45 GDPR). Google LLC is certified under the EU-US Data Privacy Framework (list of certified companies: https://www.dataprivacyframework.gov). Otherwise standard contractual clauses (Art. 46 GDPR) are used.

15. Retention

16. Deleting your account

In the app and in the web version: Settings → Delete account. Your account and associated data will be deleted, including the account record on our server (UID, dates, purchased word packs); copies of it in database backups disappear after 14 days at the latest. If you signed in with Apple, the app also revokes the Apple token (in the web version this is not possible; you can remove the app from your Apple ID settings under "Sign in with Apple"). If you signed in with e-mail and password, you must enter your password again to delete the account.

On the web: page "Konto löschen" (delete account), linked at the bottom of every page of the website (path "/delete-account").

Alternatively by e-mail to the address above.

17. Your rights

Under the GDPR you have the right to:

You may lodge a complaint with a supervisory authority (Art. 77 GDPR): The competent authority for the controllers is Der Landesbeauftragte für den Datenschutz und die Informationsfreiheit Baden-Württemberg (LfDI BW), Lautenschlagerstraße 20, 70173 Stuttgart, Germany.

18. Age

The app, the web version and this website are intended for persons aged 16 and over and are not directed at children. Under Art. 8 GDPR, in Germany children can consent on their own to the processing of their data by online services only from the age of 16. We do not knowingly process personal data of children under 16.

19. Obligation to provide data

For the offline game you do not have to provide any data. Online lobbies can be used as a guest without signing in. An account (and the data in section 3) is only needed for features tied to a person, such as future purchases. You do not have to consent to ads: the website and the web version work without consent; without consent, no ads are shown on the website.