NovaPuzzle
Photo puzzle: lay images, master stages, collect certificates
Privacy policy
Last updated: 5 September 2026
NovaPuzzle runs entirely on your device. There is no account, no server of ours and no advertising. Your progress, your best times and the name you enter for your certificate are stored locally only. The only point where data leaves the device is a purchase in the App Store — and Apple handles that.
1. Data controller
- Company
- Babala Özdemir (Einzelunternehmen)
- Address
- Unterer Rainweg 22
4414 Füllinsdorf
Schweiz - info@babala.ch
- Phone
- 076 222 45 99
- Company ID
- CHE-322.105.560
- App identifier
- iOS: ch.babala.novapuzzle
We have not appointed a data protection officer or an EU representative because we do not reach the relevant thresholds. Please address all requests to the contact above.
2. What data we process
| Data | Purpose | Stored where | Retention |
|---|---|---|---|
| Progress: solved levels, stars, best times, achievements seen, skip balance | Continuing on the next launch | Device only | Until you delete the app |
| Name on the certificate (optional, freely chosen) | Labelling the certificate | Device only | Until you change it or delete the app |
| For purchases: product and Apple transaction number | Unlocking the purchase and preventing double booking; Apple handles the payment itself | Device and Apple | On the device until the app is deleted; at Apple per their terms |
What we explicitly do not collect
- No account, no registration, no e-mail address
- No location, no contacts, no access to your photos
- No advertising, no tracking, no analytics services
- No server of ours: we receive no data from the app
3. Permissions on your device
The app requests only the following permissions. Each of them can be revoked at any time in your device settings; the app remains usable afterwards, with reduced functionality.
- Internet — Only for purchases through the App Store (Apple).
4. Legal bases
We process personal data under the Swiss Federal Act on Data Protection (revFADP). Where the GDPR applies, we rely on:
- Performance of a contract (Art. 6(1)(b) GDPR) — everything needed for the app to deliver the function you requested.
- Legitimate interests (Art. 6(1)(f) GDPR) — secure and stable operation, abuse prevention, troubleshooting.
- Consent (Art. 6(1)(a) GDPR) — this app requests no special system permissions, so no separate consent is required.
- Legal obligation (Art. 6(1)(c) GDPR) — in particular commercial and tax retention duties for payments.
5. Recipients and third parties
We do not sell data and do not disclose it for advertising purposes. Data is disclosed only to the following parties, and only where required for operation:
| Recipient | Location | Purpose |
|---|---|---|
| Apple Inc. / Apple Distribution International Ltd. | Cupertino (USA) / Cork (Ireland) | App Store distribution, processing of in-app purchases and subscriptions, and crash reports if you have enabled them with Apple. |
Authorities and courts receive data only where we are legally obliged to provide it.
Transfers abroad
Some of the recipients listed above process data outside Switzerland and the EEA, in particular in the United States. We base such transfers on the European Commission’s Standard Contractual Clauses with the Swiss adaptations recognised by the FDPIC and, where applicable, on the EU-US Data Privacy Framework. We will provide information on the safeguards in place on request.
6. Retention and deletion
All game data lives exclusively on your device and disappears when you delete the app. Purchase receipts are held by Apple in your Apple account.
Step-by-step instructions are available at Delete data.
7. Children and young people
This app is not directed at children. We do not knowingly collect personal data from children under 16. If we learn that such data has been submitted without parental consent, we delete it without delay.
8. Data security
Wherever the app transmits data at all, connections are encrypted via HTTPS/TLS. On the server side we use access restrictions, tenant separation and regular backups. Nobody can, however, guarantee absolute security for data transmission over the internet.
9. Your rights
- Access to the personal data we process
- Rectification of inaccurate data
- Erasure or destruction of your data
- Restriction of and objection to processing
- Receiving or porting your data in a common format
- Withdrawal of consent with effect for the future
An informal message to info@babala.ch or a call to 076 222 45 99. We normally respond within 30 days. To verify your identity we may request suitable proof. You may also lodge a complaint with a supervisory authority (Switzerland: FDPIC; EU: your competent authority).
10. Changes to this policy
We may adapt this policy when the app or the legal framework changes. The version published on this page, with the date shown above, is the applicable one. We announce material changes inside the app.
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