This Privacy Policy explains how UIXLY AS handles information when you use the Pawy Memo mobile application (the App).
Pawy Memo has no account or cloud game profile. Game results are not retained as a history or uploaded to UIXLY servers. The App includes Firebase Analytics, Firebase Crashlytics, Google AdMob advertising in the free version, and an optional store purchase that removes ads.
1. Who is responsible for your data?
UIXLY AS is the data controller for the processing described in this policy.
UIXLY ASOrganisation number: 937 658 397
Vollsveien 104
1358 Jar
Norway
Email: hello@uixly.io
2. Information handled by the App
Information stored only on your device
The App stores game preferences and ad-removal status locally. Game results are not saved as a history. Pawy Memo does not require your name, email address, phone number, or an account.
You can clear local App data. Copies may remain in device backups controlled by you or your platform provider.
Analytics information
Google Analytics for Firebase (Analytics) may automatically collect generic App lifecycle, screen, session, and interaction information, together with App version, device model, operating system, language, approximate region derived from technical connection information, and pseudonymous app-instance, Firebase installation, device, or session identifiers.
Pawy Memo does not assign an Analytics user ID or connect Analytics to a Pawy Memo account, name, or email address. The current App does not send custom named gameplay events. Because installation and device identifiers may still be used, this information is pseudonymous rather than strictly anonymous.
Crash diagnostic information
Firebase Crashlytics (Crash Diagnostics) may receive native crashes, Android application-not-responding events, uncaught Flutter-framework and asynchronous errors, and other serious failures. Reports may contain the original exception, stack trace, timestamps, App version and bundle identifier, foreground or background state, device model, operating-system version, architecture, available memory and storage, and pseudonymous Crashlytics, Firebase installation, and session identifiers.
Pawy Memo does not set a Crashlytics user ID or deliberately attach your name, email address, account information, or saved gameplay history to crash reports. A crash report may still include technical application state relevant to the failure.
Advertising information — free version
The free version may show banner and interstitial ads supplied by Google AdMob when consent, entitlement, network, and ad-availability conditions allow. Google and its advertising partners may automatically process:
- IP address and an approximate area, such as a city or region, inferred from it;
- ad requests, impressions, taps, App launches, and other product interactions;
- device, App, network, performance, crash, and diagnostic information; and
- device, app-set, installation, advertising, attribution, or similar identifiers where available and permitted.
This information is used to deliver ads, select or limit personalisation, measure performance, prevent invalid activity and fraud, and maintain the advertising SDK. Non-personalized ads use contextual information such as the App's content and a coarse area and may use consented mobile identifiers for functions such as frequency capping and reporting. Limited ads are used when consent for local identifiers or storage is unavailable; they disable personalization and identifier-dependent functions such as standard frequency capping, although Google may still process IP address, contextual signals, basic delivery information, and limited invalid-traffic data. Pawy Memo does not add gameplay results or custom targeting parameters to its ad requests.
Purchase information
The app store through which you obtain the App processes the optional permanent ad-removal purchase, restoration, billing, and payment. The App receives store-provided product and entitlement information and keeps a local ad-removal status. UIXLY does not receive your full payment-card or bank-account details. Removing ads stops Pawy Memo's ad surfaces after the entitlement is active, but it does not disable Analytics or Crash Diagnostics.
Information you send us
If you contact UIXLY, we receive the contact details and message content you choose to provide. We use that information to answer your request, provide support, and meet applicable legal obligations.
3. Why we process information and our legal bases
Under the General Data Protection Regulation (GDPR), we rely on the following legal bases where it applies:
| Purpose | Information | Legal basis |
|---|---|---|
| Run the game, remember settings, and restore ad removal | Local preferences and store entitlement status | Performance of a contract or steps requested before entering one — GDPR Article 6(1)(b) |
| Understand broad App usage and improve the product | Analytics information | UIXLY's legitimate interests in understanding and improving the App — GDPR Article 6(1)(f) |
| Detect and fix crashes and protect reliability | Crash diagnostic information | UIXLY's legitimate interests in maintaining a stable and secure App — GDPR Article 6(1)(f) |
| Personalize ads and use advertising identifiers where permitted | Consent choices, advertising identifiers, and advertising information | Your consent — GDPR Article 6(1)(a) |
| Fund the free version through contextual or limited ads, measure basic delivery, and prevent fraud | Contextual ad requests, delivery, diagnostic, and fraud-prevention information | UIXLY's legitimate interests in funding and protecting the free App — GDPR Article 6(1)(f), subject to consent requirements for device access or storage. Google determines and explains its own legal bases in its privacy notices. |
| Respond to support or privacy enquiries | Contact details and message content | UIXLY's legitimate interests in supporting users — GDPR Article 6(1)(f); or legal obligation — GDPR Article 6(1)(c) |
| Keep records required by law and respond to lawful requests | Relevant records | Compliance with a legal obligation — GDPR Article 6(1)(c) |
4. Advertising and privacy choices
Google consent and ad choices
Pawy Memo uses Google's User Messaging Platform (UMP) to request updated consent information and show a privacy message where required. Ads are requested only after UMP reports that ads may be requested. Depending on your location, consent choices, platform settings, and Google's configuration, you may receive personalized, non-personalized, or limited ads.
You can opt out of personalized advertising or withdraw advertising consent through privacy controls made available by the App, Google, or your device. You can also manage Google advertising preferences through Google My Ad Center. Opting out does not affect processing already performed and may not stop contextual or limited ads, basic measurement, security, or fraud prevention.
Analytics and Crash Diagnostics
Advertising choices and the ad-removal purchase do not control Analytics or Crash Diagnostics. You may object to this processing or ask about available opt-out controls by emailing hello@uixly.io.
5. Service providers and sharing
We do not sell your locally stored game settings or gameplay results. UIXLY uses Google Analytics for Firebase and Firebase Crashlytics for analytics and diagnostics. Google generally acts as a processor for covered Firebase customer data under the Firebase Data Processing and Security Terms.
For AdMob advertising data, Google, UIXLY, and in some cases Google's advertising partners may act as separate or independent controllers for their own processing. Learn how Google uses information from partner apps, review the Google Privacy Policy, and see the Mobile Ads SDK disclosures for Android and iOS.
Your store provider independently processes App download, purchase, restoration, and payment information under its own terms and privacy policy. We may also disclose relevant information where required by law, valid legal process, or to establish, exercise, or defend legal claims.
6. International data transfers
Google and its subprocessors operate global infrastructure, so Analytics, Crash Diagnostics, consent, and advertising information may be processed outside Norway and the European Economic Area (EEA), including in the United States.
Where European data-protection law applies, transfers are covered as applicable by an adequacy decision, a recognised data-transfer framework, the European Commission's Standard Contractual Clauses, and supplementary safeguards. See the Firebase Data Processing and Security Terms and Google's Ads international-transfer information.
7. Retention
- Local App data: retained on your device until you clear it, subject to store restoration and device backups.
- Analytics: user-level and event-level information is retained for up to 14 months. Aggregated reports may remain after user-level or event-level data expires.
- Crash Diagnostics: Google states that standard Crashlytics crash data and associated identifiers are kept for 90 days before removal from live and backup systems begins.
- Advertising and consent: retained by Google and applicable advertising partners according to their purposes, consent records, legal obligations, and published retention practices.
- Support and legal records: retained only as long as reasonably necessary to answer the request, resolve disputes, or comply with law.
See Google's Analytics retention documentation and Firebase privacy and retention information.
8. Security
We use reasonable technical and organisational safeguards appropriate to the information and risks involved. Game settings remain on your device. Firebase services use encryption in transit and access controls, and Firebase states that Crashlytics data is encrypted at rest. No method of storage or transmission is completely secure.
9. Your data-protection rights
Depending on the circumstances and applicable law, you may have the right to access, correct, delete, restrict, or receive certain personal data; withdraw consent; object to processing based on legitimate interests; and lodge a complaint with a supervisory authority.
To exercise a right, email hello@uixly.io. Because Pawy Memo has no account and provider records use pseudonymous identifiers, UIXLY may be unable to connect a specific provider record to you without enough identifying technical information. We will assess each request and use the tools reasonably available to us.
You may complain to the Norwegian Data Protection Authority (Datatilsynet). See How to complain to Datatilsynet. These rights are described in the official text of the GDPR.
10. Children's privacy
Pawy Memo is a general-audience game and is not directed to children under 13. If you are not old enough to provide valid consent under the law that applies to you, a parent or guardian should make any advertising or privacy choice for you.
If you believe a child's personal data has been handled inappropriately, contact hello@uixly.io so that we can investigate. A policy statement does not replace any child-audience configuration required by an app store or advertising platform.
11. Automated decisions
UIXLY does not use the information described in this policy to make decisions based solely on automated processing that produce legal or similarly significant effects about you. Advertising systems may automatically select which ad to show, but that selection does not produce such an effect.
12. Changes to this policy
We may update this policy when the App, advertising or analytics providers, or legal requirements change. We will update the date above and make the revised policy available on this webpage. If a change materially affects processing based on consent, we will request new consent where required.
13. Contact
Questions, objections, or data-rights requests may be sent to:
UIXLY ASOrganisation number: 937 658 397
Vollsveien 104
1358 Jar
Norway
hello@uixly.io