Effective: · Last updated: · Applies to: Pandle for iOS
Pandle is designed to work without an account, advertising, analytics, or developer-operated servers. This policy explains what stays on your device, what Apple processes when you make a purchase, and what happens if you contact us.
This Privacy Policy describes how SIRT6APPS, the developer of Pandle (referred to as “Pandle,” “we,” “us,” or “our”), handles information in connection with the Pandle iOS application (the “App”) and this Privacy Policy webpage.
It does not govern Apple Inc. or other services that operate under their own terms and privacy notices. Apple distributes the App, provides StoreKit and the App Store, processes in-app payments, and controls the associated Apple Account and billing systems. Apple’s handling of that information is described in App Store & Privacy and Apple’s Privacy Policy.
The App creates limited gameplay and transaction-delivery data on your device, but it does not transmit that data to us. Apple separately processes information needed to distribute the App and complete purchases.
The current version of the App does not require an account and does not include advertising, analytics, social features, a developer-operated backend, or third-party software development kits. It does not request access to your location, contacts, photos, camera, microphone, health data, or advertising identifier.
| Category | Source and use | Location and disclosure |
|---|---|---|
| On-device gameplay data (not sent to us) | Coin and gold-bar balances, an in-flight item count, a game-world state flag, and identifiers of StoreKit transactions already delivered. Pandle creates and updates these records to run the game, preserve purchased items, recover interrupted play, and prevent duplicate purchase delivery. | Stored in the App’s private container on your device. The App does not send this data to us or to advertising or analytics companies. Your operating-system backup settings may cause Apple to include app data in a device or iCloud backup. |
| StoreKit purchase data (Apple processed) | Apple makes limited transaction details available to the App, such as product identifier, transaction identifier, verification result, status, and revocation information. The App uses these details only to verify and deliver the item and prevent duplicate delivery. | Payment and Apple Account information are processed by Apple. The limited details used by the App remain on device. Apple may also provide us sales, proceeds, tax, and transaction reports through App Store Connect for support, accounting, fraud prevention, legal compliance, and store administration. |
| Messages you send us (only if you choose) | Your email address, name (if supplied), message, attachments, and any device, diagnostic, or purchase information you choose to include. We use them to respond, troubleshoot, protect users and the App, and comply with law. | Processed through our communications service providers. We do not require you to send information in order to play. Please do not send passwords, full payment-card numbers, government identifiers, or other unnecessary sensitive information. |
| Web request data (standard delivery logs) | When you visit this page, the hosting provider may automatically process an IP address, browser and device information, requested URL, and request time to deliver and secure the page. | This page sets no cookies, uses no analytics, contains no advertising, and does not use browser storage. Standard hosting logs may be retained under the provider’s operational and security schedule. |
Pandle does not collect, receive, or process any of the following, and we do not ask you to provide them:
If you volunteer sensitive information inside a support message, we use it only to answer you and delete it once the matter is resolved, subject to the retention criteria in Retention and deletion.
Where we actually receive information—principally a message you send or limited App Store reporting—we use it only to provide support; administer, secure, debug, and improve Pandle; deliver and reconcile purchases; prevent fraud or misuse; maintain financial and business records; comply with legal obligations; and establish, exercise, or defend legal claims. We do not use personal information for targeted advertising or profiling.
We collect and keep only what is reasonably necessary and proportionate for these purposes. We do not use information for a materially different purpose without first providing notice and, where required, obtaining your consent.
Pandle offers one-time purchases of consumable digital game items: coin packs and individual gold bars. There are no subscriptions. The items have no cash value, are not currency outside the App, cannot be redeemed for money, and are consumed through gameplay.
Removing on-device gameplay records does not delete Apple’s purchase, billing, tax, or fraud-prevention records. Requests concerning Apple-held information must be directed to Apple through its Data and Privacy portal.
On-device gameplay and transaction-delivery records remain in the App’s private container for as long as the App remains installed, unless the operating system or you remove them. Deleting Pandle normally deletes its local container from that device. Copies may remain in Apple-managed backups until those backups are deleted or expire under your Apple settings. Because we do not receive this local data, we cannot view, export, alter, or remotely delete it.
We retain support communications, limited App Store reports, and related records only for as long as reasonably necessary for the purpose described in this policy. The retention period depends on whether a support matter remains open, whether the record is needed for security or fraud prevention, and applicable tax, accounting, consumer-protection, recordkeeping, limitation-period, and legal-hold requirements. We then delete or anonymize the information where reasonably practicable.
Apple controls retention and deletion of Apple Account, payment, App Store, backup, and purchase-history information under Apple’s policies and applicable law. Deleting Pandle does not instruct Apple to delete those records.
We minimize the information handled by Pandle and keep gameplay records within the App’s iOS sandbox. We use Apple’s signed transaction verification before delivering purchased items and avoid embedding advertising, tracking, or analytics code. We also limit access to communications and business records to what is reasonably necessary.
No device, storage system, email service, or internet transmission can be guaranteed completely secure. You are responsible for maintaining appropriate security for your device and Apple Account, including device passcode and account security settings. If you believe information you sent us has been compromised, contact us promptly.
If a security incident affects personal information we hold and applicable law requires notification, we will notify affected individuals and the relevant regulators within the timeframes that law sets, and describe what happened and what you can do about it. Incidents affecting Apple Account, payment, or App Store systems are Apple’s to assess and report under Apple’s own obligations.
You can play without creating an account or sending personal information to us. You may delete local App data by deleting Pandle from the device, subject to any Apple-managed backups. You can control backups, purchase approvals, diagnostics, and other platform features in your Apple device and account settings.
Depending on where you live and subject to applicable exceptions, you may have rights to request access to, correction of, deletion of, or a copy of personal information we hold; to object to or restrict certain processing; to withdraw consent where processing relies on consent; and to appeal or complain to a privacy regulator. We will not discriminate against you for exercising a privacy right.
To submit a request, email us using the address in Contact and describe the request and the context in which you communicated with us. We may need to verify the request in a proportionate way. Because Pandle has no developer-operated account or server database, we ordinarily cannot identify you from App use or retrieve on-device data, and we cannot provide or delete data we do not possess. We will explain if that is the case.
We acknowledge requests promptly and respond within the period applicable law allows—generally 45 days in US states with comprehensive privacy laws and one month under the GDPR and UK GDPR—and we will tell you if we need a permitted extension and why. There is no charge for a request unless it is manifestly unfounded or excessive, in which case we will say so before doing anything.
Appeals. If we decline a request in whole or in part, we will explain why and how to appeal. To appeal, reply to our decision with the word “Appeal” and your reasons. We will respond to the appeal in writing within the period applicable law requires, and if we again decline we will provide a way to contact your state attorney general or data-protection authority.
During the preceding 12 months, the categories of personal information we may have collected are identifiers and contact information, internet or similar network activity associated with visits to this page, commercial information contained in Apple reports or voluntarily supplied for support, and the contents of support communications. The sources, purposes, retention criteria, and recipient categories are described above.
We have not sold personal information or shared it for cross-context behavioral advertising, including personal information of consumers under 16. We do not offer a financial incentive for personal information, and we do not use or disclose sensitive personal information for purposes that would require a right to limit under California law. If California law applies to your request, you may exercise applicable rights to know, access, correct, delete, and obtain information about disclosure without discriminatory treatment. An authorized agent may submit a request where permitted by law, subject to verification of authority and identity.
We do not use automated decision-making technology to make decisions about you, do not conduct behavioral advertising, and therefore do not conduct processing that presents a significant risk to consumer privacy or security requiring a risk assessment.
Comprehensive state privacy laws—including those of Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, Rhode Island, Indiana, and Kentucky—give residents rights that broadly track those described above: to confirm processing and access personal data, to correct it, to delete it, to obtain a portable copy, and to opt out of targeted advertising, sale, and profiling with legal or similarly significant effects. We honor these rights for any resident of a state with such a law, whether or not we meet that state’s applicability thresholds, and we apply the same appeal process described above.
We do not engage in targeted advertising, sale of personal data, or profiling, so there is nothing for those particular opt-outs to act on. We do not process sensitive data, so no sensitive-data consent is sought or required. We do not knowingly process the personal data of minors, and Pandle is not offered to them. Consistent with data-minimization requirements such as Maryland’s, we limit what we collect to what is reasonably necessary to provide the support or transaction you asked for.
Washington’s My Health My Data Act, Nevada’s consumer health data law, and comparable statutes: Pandle collects no consumer health data of any kind, so no separate consumer health data privacy notice, consent, or authorization applies. Illinois’ Biometric Information Privacy Act and Texas’ CUBI: Pandle collects no biometric identifiers or biometric information, and we operate no retention or destruction schedule for such data because none exists.
Nevada residents may submit a verified request that we not sell covered information; we do not sell covered information.
Pandle is intended only for people who are at least 18 years old and is not directed to children. People under 18 must not use the App or send personal information to us.
The App does not knowingly collect personal information from anyone under 18. If we learn that we received personal information from a person under 18, we will delete it as required by applicable law. A parent or legal guardian may contact us using the information below to raise a concern.
We are based in the United States. If you send us a message, your information may be processed in the United States and in other countries where communications providers operate. Privacy protections can differ from those in your home jurisdiction. Where a transfer of personal data out of the European Economic Area, the United Kingdom, or Switzerland requires a safeguard, we rely on the European Commission’s Standard Contractual Clauses, the UK International Data Transfer Addendum, or another mechanism permitted under applicable law, together with reasonable technical and organizational measures. You can ask us for information about the mechanism used for a specific transfer.
For people in the European Economic Area, United Kingdom, or Switzerland, the legal bases for processing information we actually receive are: taking steps at your request and providing requested support (Article 6(1)(b)); our legitimate interests in operating, securing, supporting, and improving Pandle and protecting legal rights (Article 6(1)(f)); compliance with legal obligations, including financial and recordkeeping duties (Article 6(1)(c)); and consent where the law requires it (Article 6(1)(a)), which you may withdraw at any time without affecting processing already carried out. Providing information is never a statutory or contractual requirement of playing Pandle; you simply cannot receive an emailed reply if you do not send us an email.
You have the rights of access, rectification, erasure, restriction, objection, and data portability, and you may lodge a complaint with your local supervisory authority—for example the UK Information Commissioner’s Office or the Swiss Federal Data Protection and Information Commissioner. Please contact us first if you would like us to try to resolve a concern.
Other jurisdictions. Residents of Canada, Brazil, Australia, Japan, South Korea, and other countries with comprehensive privacy laws may have comparable rights under those laws. We honor them on the same basis and through the same contact address, subject to verification and to the limits described above on data we do not possess.
We may update this policy to reflect changes to Pandle, StoreKit, our practices, or applicable requirements. We will post the revised policy at this location and change the “Last updated” date. If a change materially affects how the App handles personal information, we will provide additional notice or obtain consent when required by applicable law. Earlier versions remain applicable to practices occurring before the revised policy’s effective date unless the revised policy or law states otherwise.
This policy does not waive or limit any privacy or consumer right that cannot lawfully be waived or limited.
Questions, privacy requests, parental inquiries, or concerns about Pandle can be sent to:
SIRT6APPS
Pandle developer and privacy contact
contact.sirt6apps@gmail.com
Please put “Pandle Privacy” in the subject line. Do not include passwords, complete payment-card numbers, or unnecessary sensitive information.