Privacy Policy

1. Controller

The controller responsible for data processing in MyPictureQuiz is STG Ventures GmbH. You can contact us by email at info@stgventures.de.

2. Local Processing of Your Photos

MyPictureQuiz creates quiz rounds from photos and photo metadata that are available on your device. In particular, the app processes local photo data, capture dates and location metadata, depending on the photo library access you grant to the app.

Photos, videos, GPS coordinates, specific place names and your answers in the onboarding quiz are not transmitted to us, PostHog or other analytics providers. The app uses this information only locally on your device to create quiz rounds and show places in the game. The only exception is an error report that you send yourself; it contains the coordinates of the affected photo (see Section 4).

3. Anonymous Usage Analytics with PostHog

We use PostHog Cloud EU, an analytics service provided by PostHog Inc., to understand how the app is used and where users drop off during onboarding or gameplay. Processing takes place on servers in the EU, currently in Frankfurt am Main, Germany.

The legal basis is our legitimate interest in improving and stabilizing the app pursuant to Art. 6(1)(f) GDPR.

We only collect sparse, abstract usage data, for example:

• app starts and basic status information
• onboarding and onboarding quiz steps, but not selected answers
• quiz starts, round results and scores only as broad categories
• photo access status, for example full access, limited access or denied
• the number of playable or prepared photos only as broad ranges, not as an exact list
• paywall, purchase and restore events without payment data
• technical diagnostic and crash data, to the extent provided by the SDK we use

PostHog uses an anonymous installation identifier for this purpose. We do not link this identifier to names, email addresses, Apple IDs, accounts or other directly identifying information.

4. Error Reports from the App

After each photo in a round you can use “Report an error” to tell us that an answer was wrong. Sending a report is always your own explicit action: nothing is transmitted when you cancel the dialog, and the dialog shows you beforehand exactly which details will be sent.

A report contains the text you enter, the four answer options shown, the correct answer, the answer you chose, and the capture date and GPS coordinates of the affected photo, together with basic technical data such as the app version, iOS version and device language. The photo itself is never transmitted.

Reports are sent to PostHog Cloud EU (see Section 3) under your anonymous installation identifier and are used solely to find and fix wrong answers and photo assignments. They are sent regardless of the analytics setting described in Section 6, because they are only ever sent at your request. The legal basis is the consent you give by sending the report (Art. 6(1)(a) GDPR).

5. What We Do Not Collect

In particular, we do not collect the following for usage analytics:

• photos or videos from your photo library
• GPS coordinates or specific location data from your photos (except in an error report you explicitly send, see Section 4)
• specific cities, countries or place names from your photo library
• answer text from the onboarding quiz
• name, email address, phone number or Apple ID
• advertising IDs or data for personalized advertising

We do not use the usage analytics data collected via PostHog for advertising or retargeting, and we do not share it with data brokers. For ad measurement with Meta, which exclusively affects users with a US, Canadian or Australian App Store account, see Section 7.

6. Opt-out in the App

Anonymous usage analytics is enabled by default. You can disable it at any time in the app under Settings > Privacy > Anonymous usage analytics. When you disable this feature, the app will not send any further analytics events; this also stops all transmissions to Meta described in Section 7. Error reports (Section 4) are not affected by this setting, because they are only sent when you tap “Send” yourself.

7. Ad Measurement with Meta

We run ads for MyPictureQuiz on Meta platforms such as Facebook and Instagram. To measure how effective these ads are, we use the Meta SDK provided by Meta Platforms, Inc. — exclusively when your App Store account is assigned to the United States, Canadian or Australian storefront. For all other users, in particular in the EU, this feature is fully disabled and no data is transmitted to Meta.

The data transmitted consists of app events such as installation, app launches, paywall views and completed purchases, together with technical device data. Only if you consent in the iOS tracking dialog (App Tracking Transparency) is your device's advertising identifier (IDFA) additionally used to attribute installs and purchases to individual ad campaigns. Without this consent, Meta only receives aggregated measurements that cannot be traced back to you, including via Apple's SKAdNetwork.

Legal bases: We base the transmission of app events on our legitimate interest in measuring and managing our advertising campaigns (Art. 6(1)(f) GDPR); the advertising identifier is used only based on your consent given in the iOS tracking dialog (Art. 6(1)(a) GDPR). You can withdraw this consent at any time in the iOS Settings under Privacy & Security > Tracking; disabling usage analytics in the app (Section 6) additionally stops all transmissions to Meta.

The recipient is Meta Platforms, Inc. (USA). Meta is certified under the EU-U.S. Data Privacy Framework; due to the storefront restriction (United States, Canada, Australia), however, no data is transferred out of the EU.

8. Purchases, Payment Data and RevenueCat

Subscriptions and in-app purchases are processed by Apple. We do not receive payment data such as credit card numbers or bank details.

To validate purchases and manage subscription status, we use RevenueCat, a service provided by RevenueCat, Inc. (USA). For this purpose, RevenueCat processes an anonymous installation identifier, transaction data for your purchases (product, price, currency, time, subscription status) and basic device data. RevenueCat does not receive names, email addresses or payment data from us. We have concluded a data processing agreement with RevenueCat; transfers to the USA are based on the EU Standard Contractual Clauses and the EU-U.S. Data Privacy Framework respectively. The legal bases are the performance of the contract (Art. 6(1)(b) GDPR) and our legitimate interest in reliable purchase processing and subscription analytics (Art. 6(1)(f) GDPR).

For users with a US, Canadian or Australian App Store account, RevenueCat additionally forwards purchase events to Meta for ad measurement (see Section 7).

9. Retention and Deletion

Analytics data is stored only for as long as it is needed for product analytics and app improvement. You can request access to or deletion of data stored for your anonymous installation identifier, to the extent that assignment is technically possible. Error reports are kept until the reported problem has been reviewed and fixed, and for no longer than twelve months.

10. Your Rights

Subject to the legal requirements, you have the right to access, rectification, deletion, restriction of processing, data portability and objection to processing. You may also lodge a complaint with a data protection supervisory authority.

For privacy requests, contact us at info@stgventures.de.