Paeki Privacy Policy

1. Overview

Paeki ("the App") is developed and published by Kynoss Studios ("we," "us," or "our"). Paeki is a daily image puzzle game for iPhone (iOS 26 and later) where players reveal a hidden image tile by tile and guess what it depicts.

This Privacy Policy explains what data Paeki accesses, how that data is processed, and your rights regarding your information. We are committed to transparency and to protecting your privacy.

Paeki operates entirely on your device. We do not operate servers, databases, or cloud services. We do not create user accounts. We have no mechanism to collect, receive, view, or store your personal data. The data Paeki works with exists solely on your iPhone, under your control.

2. Game Data

What Paeki Stores Locally

3. Game Center

Paeki integrates with Apple's Game Center for leaderboards and achievements. Game Center is managed entirely by Apple and is subject to Apple's Privacy Policy.

• What Paeki sends to Game Center: Your daily puzzle score (number of tiles revealed) and achievement completions. Nothing else.
• Game Center is optional. You can play Paeki without signing into Game Center. If you choose not to sign in, no data is sent to Game Center.
• Game Center data is managed by Apple. Kynoss Studios does not have access to your Game Center profile, friends list, or any data Apple stores in connection with Game Center.

4. On-Device Language Processing

Paeki uses Apple's Natural Language framework (NLEmbedding) to validate guesses semantically — so that synonyms, related words, and natural phrasing are accepted.

• All language processing runs entirely on your device.
• No text you type is transmitted to any server, including Apple's.
• The Natural Language framework is a built-in iOS component that requires no network connection.

On devices that support Apple Intelligence, Paeki may optionally use Apple's Foundation Models framework to generate contextual hints. This processing also occurs entirely on-device — no data is sent to any server.

5. Data Storage & On-Device Processing

Game data is stored locally on your device using Apple's SwiftData framework. This data is protected by:

• iOS Data Protection (encrypted at rest, tied to your device passcode)
• App sandboxing (only Paeki can access its own data store)
• Standard iOS security architecture

Paeki does not use:

• iCloud or any cloud storage
• Any third-party SDKs, frameworks, or libraries
• Analytics services (no Firebase, no Mixpanel, no Amplitude, etc.)
• Advertising SDKs or ad networks
• Crash reporting services
• Any form of user tracking or fingerprinting

6. Data Retention & Deletion

Retention Policy

• Game data (scores, streaks, statistics, puzzle history) is retained on your device until you delete the app.
• Game Center data (leaderboard scores, achievements) is retained by Apple according to Apple's data retention policies.

Deletion

• Delete the app: Deleting Paeki from your device permanently removes all local game data. Game Center achievements and leaderboard entries are retained by Apple in your Game Center profile.
• There is no server-side data to delete, no account to close, and no request process needed. You have full and immediate control.

7. Data Sharing & Third Parties

• We do not sell your data.
• We do not share your data with third parties.
• We do not transmit your data off your device (except scores to Game Center, if you opt in).
• We do not use third-party SDKs that could collect data.
• We do not serve advertisements.
• We do not engage in data mining or user profiling.
• We do not share data with parent companies, subsidiaries, or related entities (Kynoss Studios is an independent sole developer).

8. Data Security

Paeki relies on Apple's built-in security infrastructure to protect your data:

• Encryption at rest: All local data is protected by iOS Data Protection, which encrypts data using keys tied to your device passcode.
• App sandboxing: iOS prevents other apps from accessing Paeki's data store.
• No network exposure: Because Paeki does not transmit personal data over any network, there is no risk of data interception, server breaches, or unauthorized remote access.
• No accounts: There are no credentials to steal, no passwords to breach, and no accounts to compromise.

9. Children's Privacy (COPPA)

Paeki is a puzzle game rated 4+ and is suitable for all ages. We do not knowingly collect personal information from children under 13.

Because Paeki does not collect, transmit, or store personal information on any server, and because all data remains solely on the user's device, Paeki does not create the data collection risks that COPPA is designed to address. Nonetheless:

• Paeki does not collect personal information from any user, including children.
• Paeki does not require or support account creation.
• Paeki contains no advertising, social features, or in-app communication.
• Paeki does not transmit any data to Kynoss Studios or any third party.

If you are a parent or guardian and have questions about this policy, please contact us at kynossstudios@gmail.com.

10. Your Rights Under GDPR (European Economic Area)

If you are located in the European Economic Area (EEA), the General Data Protection Regulation (GDPR) provides you with specific rights regarding your personal data. We respect these rights, even though Paeki's on-device architecture means we do not act as a data controller or processor of your personal data in the traditional sense — because your data never reaches us.

Legal Basis for Processing

To the extent any on-device processing constitutes "processing" under the GDPR, the legal basis is:

• Legitimate interest: Processing your data on your own device to provide the app's gameplay functionality directly to you.
• Consent: Game Center integration is opt-in. You may decline Game Center sign-in and still use all core features.

Your Rights

• Right of access: All data is stored on your device and accessible to you at all times within the app.
• Right to erasure: You can delete all data by deleting the app.
• Right to restrict processing: You can decline Game Center sign-in to prevent any score data from leaving your device.
• Right to data portability: Your data is stored locally on your device and is accessible to you.
• Right to object: You can stop all data processing by deleting the app.

Data Transfers

Paeki does not transfer personal data outside your device (except optional Game Center score submission, which is managed by Apple under Apple's own GDPR compliance). No cross-border data transfers by Kynoss Studios occur.

Data Protection Officer

Due to the nature of our data processing (entirely on-device, no data collection), we are not required to appoint a Data Protection Officer. For any privacy-related inquiries, please contact us at kynossstudios@gmail.com.

11. Your Rights Under CCPA/CPRA (California)

If you are a California resident, the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) provides you with specific rights.

Information We Collect

Under CCPA/CPRA definitions, Paeki processes the following categories of information on your device only:

• Game activity data (scores, streaks, puzzle completion status)

However, because all processing occurs on your device and we never collect, receive, or access this information, Kynoss Studios does not "collect" personal information as defined by the CCPA/CPRA.

Your Rights

• Right to know: This Privacy Policy describes all data the app processes. We do not collect additional data beyond what is described here.
• Right to delete: Delete the app to remove all local game data.
• Right to opt out of sale: We do not sell your personal information. We never have and never will.
• Right to opt out of sharing: We do not share your personal information with third parties for cross-context behavioral advertising or any other purpose.
• Right to non-discrimination: We will not discriminate against you for exercising any of your privacy rights.

"Do Not Sell or Share My Personal Information"

Paeki does not sell or share personal information. Because no data is transmitted from your device to us or any third party, there is no sale or sharing to opt out of. We fully comply with the CCPA/CPRA without requiring any user action.

12. Apple Platform Disclosures

In compliance with Apple's App Store Review Guidelines and platform requirements:

Game Center

• Paeki uses GameKit to submit scores to leaderboards and report achievement progress, only when the user is signed into Game Center.
• Game Center is optional. Core gameplay does not require it.
• Game Center data is managed by Apple under Apple's Privacy Policy.

StoreKit 2 (In-App Purchases)

• Paeki uses StoreKit 2 to offer a one-time "Paeki Pro" in-app purchase.
• All transaction processing is handled by Apple. Kynoss Studios does not receive, store, or have access to payment information.
• Purchase status is verified locally using Apple's on-device Transaction API.

Required Reason APIs

Paeki uses only Apple's first-party frameworks and does not access any APIs that require declared reasons beyond those already disclosed in this policy and in the app's App Store privacy nutrition label.

App Tracking Transparency

Paeki does not track users across apps or websites owned by other companies. The App Tracking Transparency framework is not used because no tracking occurs.

App Privacy Nutrition Label

Paeki's App Store privacy nutrition label accurately reflects that the app does not collect data linked to user identity and does not track users.

13. Changes to This Policy

We may update this Privacy Policy to reflect changes in the app's functionality or legal requirements. When we make changes:

• The "Last Updated" date at the top of this page will be revised.
• Material changes will be communicated through the app or its App Store listing.
• Continued use of Paeki after changes constitutes acceptance of the updated policy.

We encourage you to review this policy periodically.

14. Contact Us

If you have questions about this Privacy Policy, your privacy rights, or Paeki's data practices, please contact us:

• Email: kynossstudios@gmail.com
• Developer: Kynoss Studios
• Support Page: Paeki Support

We will respond to privacy inquiries within 30 days.