Effective date: September 13, 2026
Ing. Oliver Herklotz ("I", "me", or "my"), operating under the name "hrkltz" as the provider of Lucky Bubble for iPhone, iPad, and Mac ("App"), is committed to protecting your privacy. This Privacy Policy explains how I handle information for the App. Lucky Bubble has no website of its own; it is listed on hrkltz.io, which is covered by my shared Website Privacy Policy.
I have not appointed a Data Protection Officer; none of the thresholds requiring one is met. I am based in Switzerland, so the Swiss FADP applies, and the GDPR applies in parallel under its Art. 3(2) for users in the EU/EEA.
My App does not collect, store, or share personal data through my own analytics, advertising, or tracking systems. I do not operate a backend for this App at all — there is no account, no sign-in, no online multiplayer, and no server of mine for the App to send anything to. The App works entirely offline; it does not need an internet connection and does not make network requests of its own.
Because no personal data reaches me, there is no processing of yours for me to name a legal basis or a retention period for. The sections below describe what happens on your device, so that the picture is complete.
The only thing the App keeps is your last match — it is saved after every move so you can continue where you stopped, and it includes the player names you type for the seats at the table — plus a handful of settings such as the theme. All of this lives only on the device you play on. It is not synced to any server of mine and I never see it. Starting a new match replaces the saved one; finishing a match clears it.
iOS, iPadOS, and macOS may collect analytics, diagnostic, and usage information at the operating-system level. Depending on your device settings (for example, "Share iPhone & Watch Analytics", "Share Mac Analytics", and "Share With App Developers"), Apple may receive diagnostic data and may share certain diagnostic information with developers. This data handling is controlled by Apple and governed by Apple's own privacy terms. Where I receive such reports they are aggregated crash and performance statistics from Apple, not identifiable information about you, and you can switch the sharing off in your device settings at any time.
My App is designed to keep your data local to your device. However, Apple's operating systems and frameworks may generate technical logs (for example, crash logs and performance diagnostics), and those logs may be transmitted to Apple when Apple analytics sharing is enabled on your device. I do not use third-party analytics, advertising, or tracking SDKs in my App.
On iPhone, the optional Motion Roll & Burst setting lets you shake the phone to rattle the dice and tap the back of the phone to pop the bubble. When it is enabled, the App reads the device's motion sensors (accelerometer and gyroscope) for this purpose only, while the App is in the foreground. Sensor readings are used on the device as the App runs and are not collected, stored, or transmitted by me — there is nowhere for them to be sent. The setting is off unless you turn it on, and you can turn it off again at any time in the App's settings.
Because everything the App stores is on your device, deleting the App deletes it. There is nothing held by me to request the deletion of.
I do not integrate third-party analytics, advertising, or tracking services in my code.
There is none, and no profiling (GDPR Art. 22). The bot players make their moves from the state of the dice and the score sheet in front of them, and nothing about you. On devices with Apple Intelligence, the bots may use Apple's on-device model to play their characters; that model runs entirely on your device, and the App sends it nothing but the state of the game.
Where I process personal data about you, you have the rights of access, rectification, erasure, restriction, data portability, and objection, as set out in full in my Website Privacy Policy. For this App specifically, the honest answer to an access request is that I hold nothing about you to disclose. You may also lodge a complaint with a supervisory authority: within the EU/EEA, the authority of your habitual residence, place of work, or the place of the alleged infringement (GDPR Art. 77); in Switzerland, the Federal Data Protection and Information Commissioner (FDPIC), Feldeggweg 1, 3003 Bern.
The App is a family-friendly dice game and may be played by children, but it collects nothing from anyone, children included. There are no accounts, no chat, no advertising, and no in-app purchases.
I may update this Privacy Policy from time to time. If I make changes, I will update the effective date at the top of this page. Your continued use of my App after an updated policy is posted means you accept the updated policy.
Questions about this Privacy Policy, or any request under the rights above: gruezi@hrkltz.io. See also my Imprint.