Legal · Games

Privacy policy for “Pawshift”

For all games

Last updated: October 11, 2026

Contents

1. Controller

Patrick Gruben
Rolandstraße 14
40476 Düsseldorf
Germany
E-mail: info@grubenhund.com
Phone: +49 160 94857908

Under the brand “grubenhund games” I develop and publish games for smartphones and tablets. I am not required to appoint a data protection officer; if you have questions, write to me directly.

2. Scope

This policy covers the game “Pawshift”. The version for all games is at games.grubenhund.com/en/privacy.

What happens when you visit this website (games.grubenhund.com) is described in the section “Visiting this website”. The dog training website grubenhund.com has its own privacy policy (in German).

3. In short

  • You don't need to register – no name, no password.
  • Your progress is stored on your device.
  • We use no analytics or tracking tools of our own.
  • Ads are served by Google AdMob – personalized only with your consent.
  • Purchases are handled by Apple and Google; we never see payment details.

4. Progress on your device

The game stores progress, settings, unlocked and purchased content locally on your device. This data does not reach us unless one of the backups described below is active. Legal basis: Art. 6(1)(b) GDPR (providing the game) and § 25(2) no. 2 TDDDG (storage on the device that is strictly necessary).

Note on device backups: if iCloud Backup on your iPhone or Android backup in your Google account is switched on, it may also back up the game data and restore it after a reinstall. Apple's or Google's privacy terms apply; we do not receive this data.

5. Feedback and bug report

The game keeps the last technical error messages (at most 30) on your device. Under Settings → “Feedback & bug report” you can share or copy a report yourself. It contains the game version, platform and the device identifier of the browser or system (e.g. “iPhone”, no model) with OS version, screen size, graphics level and renderer, language, time, the current chapter and the screen you are on, your progress as a number, your note and the last 15 error messages. The game never sends it on its own; we only receive it if you send it to us. Legal basis: Art. 6(1)(b) or (f) GDPR (helping with problems).

6. Cloud save in your iCloud (iPhone and iPad)

The app keeps a copy of your progress (without settings) in the iCloud key-value storage of your Apple ID so you can continue on your other devices. The provider is Apple; we have no access to it, there is no account with us and we run no servers. You can turn this off under Settings → “Cloud save” with the “iCloud save” switch; this deletes the iCloud copy. Android (later): your progress is part of the Android backup in your Google account if you have turned it on in Android's settings.

7. In-app purchases

Purchases are handled entirely by the Apple App Store or Google Play, who are separate controllers for this. We never receive payment details. The game only receives a purchase confirmation and records in your save which content you bought, so it stays unlocked. Legal basis: Art. 6(1)(b) GDPR.

Offered are “Ad-Free” (one-time), a starter pack (one-time) and packs of sparks. Sparks are an in-game currency for glow colors and collars only; hints and levels are always free. The app stores which purchases were credited on the device (and in the iCloud copy) so nothing is credited twice or lost.

8. Advertising (Google AdMob)

“Pawshift” shows ads – as optional ad videos with a reward or as ad breaks between levels. They are served by Google AdMob, a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google may process in particular the advertising ID (IDFA or Android advertising ID), the IP address and the approximate location derived from it, device and OS information, ad interactions and diagnostic data.

Consent: personalized ads and access to the advertising ID and device storage require your consent (Art. 6(1)(a) GDPR, § 25(1) TDDDG). We ask for it via Google's consent dialog before any ads are loaded; you can change or withdraw it any time in the game's settings under “Privacy & ad consent”. On iPhone and iPad we also ask via Apple's App Tracking Transparency prompt. If you do not consent, Google shows limited ads at most: not personalized and without access to the advertising ID or device storage. To deliver them, Google technically processes the IP address (Art. 6(1)(f) GDPR; our legitimate interest is funding the free game).

No Ads: where a game offers a “No Ads” purchase, you will no longer see ad breaks afterwards; optional ad videos remain available.

Transfers to the USA are based on the EU-US Data Privacy Framework or Standard Contractual Clauses. More: policies.google.com/technologies/partner-sites.

In Pawshift: interstitial ads appear at the earliest once you have solved ten puzzles – not during the first two app launches or the first ten minutes of play – and then at most on every third result card, when you leave it. Optional rewarded videos (double your sparks, sparks in the shop) are only loaded when you choose to watch one. The App Tracking Transparency prompt on iPhone and iPad is only shown to adults – where consent is required (e.g. in the EU), only after they agreed to personalized ads.

9. Children and teens

Age question: on first launch the app asks for your year of birth. The answer stays on your device and only decides which ads may be shown: under 16 there is no consent form and only non-personalized ads; under 13 ads are additionally requested as child-directed. For everyone, only ads rated for all ages are shown.

“Pawshift” is not specifically directed at children. Minors need their parents' permission for purchases. We recommend protecting purchases in the device settings (Screen Time or Google Family Link).

10. Visiting this website

This website (games.grubenhund.com) sets no cookies, uses no analytics or tracking tools and embeds no third-party content; fonts, images and videos come from the same server. Links to the App Store, Google Play or other websites only transfer data to those providers once you click them.

When you open a page, the host processes technically necessary data in server logs: IP address, date and time, requested address, amount of data transferred, browser and operating system. This is required to deliver the website, detect attacks and fix errors (Art. 6(1)(f) GDPR; legitimate interest in secure and reliable operation). The site is hosted by Vercel Inc., 650 California St, San Francisco, CA 94108, USA, as processor; transfers to the USA are covered by the EU Standard Contractual Clauses and Vercel's certification under the EU-US Data Privacy Framework. Logs are kept only as long as needed for operation, security and troubleshooting, usually no longer than 30 days.

If you send me an e-mail, I process your details in order to reply (Art. 6(1)(b) or (f) GDPR).

11. Recipients and service providers

  • Google Ireland Limited – advertising via AdMob (separate or joint controllership under Google's terms)
  • Apple and Google – app stores, payment processing, accounts and device backup (separate controllers)
  • Vercel Inc. (USA) – hosting of this website games.grubenhund.com (processor, see “Visiting this website”)

Beyond that we do not share personal data, and we never sell data.

12. Transfers outside the EU

Some service providers are based in the USA. Where data is transferred there, this is based on the EU-US Data Privacy Framework (adequacy decision of the European Commission) or EU Standard Contractual Clauses (Art. 46(2)(c) GDPR).

13. Your rights

You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and objection (Art. 21), and you may withdraw consent at any time with effect for the future (Art. 7(3)). Write to info@grubenhund.com.

Right to object

Where we process data on the basis of legitimate interests (Art. 6(1)(f) GDPR), you may object to this processing at any time on grounds relating to your particular situation (Art. 21 GDPR). Write to info@grubenhund.com.

How to delete data yourself is explained under Delete data.

You may also lodge a complaint with a supervisory authority, for example the data protection authority of North Rhine-Westphalia (LDI NRW), Kavalleriestraße 2–4, 40213 Düsseldorf, Germany.

14. Changes

When a game changes – for example with new features or service providers – I update this policy. The version published here applies. If this English version differs from the German one, the German version prevails.