Privacy Policy Partyfunk

Note on languages. This is the English version of the privacy policy. A German version (Datenschutzerklärung) is available as well. Both versions are meant to say the same. If you notice a difference, please write to hallo@mk-mc.eu.

This policy covers the iOS app Partyfunk (iPhone and iPad) from version 1.0 on, a party game app with the modes “Imposter/Spy”, “Would You Rather” and “Head Guessing”. It does not cover the website www.ki-agent.pro, which has its own privacy policy (in German).

1. Controller

The controller within the meaning of the GDPR and the publisher of the app (called “the publisher” below) is:

MKMC | marketing & consulting
Owner: Matthias Grevelding Kiesche
Zu den Birken 14a, 51515 Kürten
Germany
E-mail: hallo@mk-mc.eu

The app has no server of the publisher, no account and no network code of its own that sends data to the publisher. The publisher does not receive personal data from the app. What is exchanged between your device and Google or Apple is processed by those companies under their own terms (sections 4, 5 and 8).

When you write to the publisher

If you write to the publisher, for example by e-mail, the publisher processes your e-mail address and the content of your message to answer your request. The legal basis is Art. 6(1)(b) GDPR where your request concerns a purchase or a comparable contractual relationship, otherwise Art. 6(1)(f) GDPR. The publisher’s legitimate interest is answering requests about the app. The data is deleted once your request has been resolved and no statutory retention period applies.

2. Overview in plain language

• The app is a collection of party games played locally on your device, with three modes: “Imposter/Spy”, “Would You Rather” and “Head Guessing”.
• There is no account, no sign-up and no mandatory fields. The app asks for neither your real name, your e-mail address nor your location.
• Player names, round history and categories/terms you create stay exclusively on your device (stored locally via SwiftData). The publisher has no access to them.
• The publisher does not use their own analytics, their own crash reporting, or push notifications. Google’s components in the app may use the advertising identifier for tracking within the meaning of Apple’s App Tracking Transparency, if you allow it in iOS (sections 4 and 6).
• The free version shows a persistent banner ad and, after each round ends, a full-screen interstitial from Google AdMob — never at app launch. Where required, Google asks for your consent first, at the earliest after the first round (section 4). After that, iOS asks once whether the advertising identifier may be used (section 6).
• A subscription or the lifetime purchase removes advertising entirely and unlocks all categories and player counts (section 8).

3. Data stored on your device

The app stores the following content in the local app storage of your device (SwiftData):

• player names you enter for a round;
• round history and scores of games played;
• categories and terms you create yourself;
• a flag indicating whether the full version (subscription or lifetime) is active. It is only a local cache; the authoritative check happens with Apple (section 8);
• entries created by Google’s components, in particular your consent decision (section 4). The app itself does not read or write these entries.

The app does not transmit this content to the publisher or to third parties. It stays until you change or delete it in the app, or until you uninstall the app. If you back up your device, for example to iCloud or a computer, iOS may include app data in that backup. You control this in your iOS settings.

Because this data only lives on your device and the publisher has no access to it, the publisher does not process it themselves. To the extent that storing your player names, round history, categories and the full-version flag is still considered processing by the publisher, it relies on Art. 6(1)(b) GDPR (providing the app features you use).

Permissions

The app does not request access to the microphone, camera, location, photos, contacts, calendar, Bluetooth, motion data, notifications or health data. The only prompt is App Tracking Transparency, and it only appears in the free version (section 6).

4. Advertising (Google AdMob)

In the free version, the app shows a persistent banner ad at the bottom of the game hub and, after each round ends, a full-screen interstitial — never at app launch. Two components by Google are integrated for this:

• Google Mobile Ads SDK (Google AdMob): loads, displays and measures the banner and the interstitial.
• Google User Messaging Platform (UMP): determines whether a consent form is required for your region, displays it, and stores your decision.

The provider is Google (Google LLC, USA, or Google Ireland Limited, Ireland; which entity is responsible follows from Google’s own terms). These components connect your device directly to Google. The data does not pass through the publisher.

The app first checks whether a subscription or the lifetime purchase is active (section 8). If so, no Google components are called. Otherwise, at the earliest after the first round ends — never at app launch — the app asks Google’s consent service whether a form is required for your region. Only if Google’s consent service subsequently permits advertising does the app ask, where applicable, for permission to use the advertising identifier (section 6). Only then does the Google Mobile Ads SDK request the banner and the interstitial.

The app instructs the SDK to serve only ads up to content rating “G” (general audiences).

What data Google may process

Every request connects your device to Google’s servers. This technically and necessarily involves your IP address as well as device and connection information. According to Google’s own disclosures in its SDK’s privacy manifest, which Apple requires for apps, this includes in particular: a device identifier linked to you (also used for tracking, per Google), advertising data, product interaction and approximate location (each linked to you), as well as performance, crash and other diagnostic data (not linked to you). Google names third-party advertising, developer advertising and analytics as purposes. How long Google retains this data is set out in Google’s own, changing policies; current details are published by Google itself (links below). The app’s privacy information in the App Store (“App Privacy”) also covers data collected through the Google Mobile Ads SDK.

Legal bases

Where Google’s consent form appears, advertising is based on your consent: Art. 6(1)(a) GDPR for processing personal data, and §25(1) TDDDG (the German telecommunications-privacy act) for storing and accessing information on your device. Consent is voluntary. If you refuse or withdraw it, the app remains fully usable; Google may continue to serve limited advertising afterward.

To the extent Google processes data under its own responsibility, Google states the legal bases in its own privacy notices and in the form. Google’s information:

• Google Privacy Policy
• How Google uses data when you use the sites or apps of our partners

5. Consent management (Google UMP)

To obtain and manage advertising consent, the app uses the Google User Messaging Platform (UMP) SDK. It shows the consent dialog at the earliest after the first round ends, stores the choice you make locally on your device, and passes the consent status to AdMob before AdMob requests advertising.

6. App Tracking Transparency (ATT)

For personalized advertising, the app additionally asks, via Apple’s system-level App Tracking Transparency dialog, whether access to your device’s advertising identifier (IDFA) is permitted. This dialog appears only in the free version, independently of the UMP dialog, after it, and at the earliest shortly before the first ad is shown. If you decline, ads are served without cross-device tracking; the app works unchanged, and ads continue to be shown but are less personalized. The legal basis for using the advertising identifier is your permission in the dialog (Art. 6(1)(a) GDPR, §25(1) TDDDG).

7. Changing or withdrawing consent

You can change your decisions at any time. A withdrawal takes effect for the future. Processing up to that point remains lawful (Art. 7(3) GDPR). This is only possible in the app and in iOS:

• In the app: “Settings → Manage privacy options” opens Google’s form, where you can change or withdraw your choice. This entry only appears while no subscription and no lifetime purchase is active.
• In iOS: you change permission for the advertising identifier under Settings > Privacy & Security > Tracking.
• With a purchase: a subscription or the lifetime purchase removes advertising entirely. From the next launch on, there is no form, no ATT prompt, and no call to Google’s components (section 8). Data Google has already received, and the consent entries on your device, remain unaffected.
• By deleting the app: the locally stored consent data is removed.

8. Subscription and lifetime purchase (Apple App Store)

In the menu, you can unlock the full version — as a monthly subscription, an annual subscription (both in the same subscription group), or a one-time lifetime purchase. The full version removes advertising entirely and unlocks all categories and player counts. Apple handles the purchase through the App Store and StoreKit 2 and provides the price in localized form. Your payment and account data is processed solely by Apple; neither the app nor the publisher gets to see it. The publisher only receives signed transactions from Apple, which the app verifies on the device, without access to full payment data.

Automatic renewal and cancellation

Monthly and annual subscriptions renew automatically for the booked period unless cancelled at least 24 hours before the end of the current period, via your Apple Account settings. Cancellation happens exclusively through your Apple Account’s subscription management; cancelling directly with the publisher is not technically possible.

Family Sharing

The lifetime purchase can be shared with family members via Apple’s Family Sharing. The monthly and annual subscriptions are deliberately not shareable — they apply only to the Apple Account used to purchase them.

Restoring purchases

The purchase dialog offers a “Restore Purchases” function. It asks Apple for prior purchases and may require signing in with your Apple Account. The app itself sends nothing to the publisher in the process. The “full version active” flag on your device (section 3) only speeds up the display; the check with Apple is always authoritative.

Legal basis: Art. 6(1)(b) GDPR (performance of the purchase contract); Art. 6(1)(c) GDPR (German statutory retention rules, §147 AO, §257 HGB). Retention period: 10 years (statutory retention obligation). Third-country transfer: USA – adequacy decision EU-U.S. Data Privacy Framework (10 July 2023, C(2023) 4745) and standard contractual clauses (2021/914/EU).

9. Analytics services

Partyfunk uses no analytics or tracking SDKs of its own (no Firebase Analytics, no comparable service). Outside of the advertising-related processing by Google described above (sections 4 to 6), no usage analysis takes place. Push notifications are not built into this version.

10. Retention periods at a glance

• Player names, round history, categories and flags on your device: until you change them or delete the app.
• Consent decision and other entries from Google’s components: until you change them or delete the app. How long Google itself retains data is described in Google’s own privacy notices.
• Data at Apple (purchase, advertising-ID decision): per Apple’s own terms.
• E-mails to the publisher: until your request is resolved; for a contractual relationship, beyond that per statutory retention periods.

11. Recipients and third-country transfers

Google

The recipient of data arising from advertising and the consent request is Google (sections 4 to 6). The data goes directly from your device to Google, not through the publisher. Google LLC is based in the USA; processing there or in other countries outside the European Economic Area is possible.

Advertising partners

Further providers (advertising partners) may be involved in delivering and measuring ads through Google. Where Google shows a consent form, the partners are listed there under “Manage options”.

Apple

Apple is involved in distributing the app in the App Store, in the purchase (StoreKit), and in the ATT prompt. Apple processes the resulting data under its own privacy policy. Apple belongs to a group based in the USA; processing there or in other third countries is possible.

Reports from Apple

Apple provides developers with sales and download figures via App Store Connect. Aggregated app analytics and crash reports are only available for users who have allowed sharing diagnostic and usage data with app developers in their iOS settings. The publisher does not use their own analytics or crash-reporting software.

12. Your rights

You have the right to access (Art. 15 GDPR), rectification (Art. 16 GDPR), erasure (Art. 17 GDPR), restriction of processing (Art. 18 GDPR), data portability (Art. 20 GDPR), and the right to object to processing based on legitimate interests (Art. 21 GDPR). You can withdraw a given consent at any time with effect for the future (section 7).

Please contact hallo@mk-mc.eu for this. Since the publisher receives no personal data from the app and cannot identify you as a user of the app (Art. 11 GDPR), the publisher cannot provide information about, rectify, or erase data that only lives on your device, with Google, or with Apple. For data on your device, use the options in sections 3 and 7. For Google and Apple, contact those companies directly.

You also have the right to lodge a complaint with a supervisory authority (Art. 77 GDPR), including the authority at your habitual residence. The authority responsible for the publisher is the State Commissioner for Data Protection and Freedom of Information North Rhine-Westphalia (LDI NRW).

13. Changes and date

This policy is updated whenever the app, the services used, or the legal requirements change. The version in force at any time is the one published at this address. Last updated: October 12, 2026.