Privacy Policy

1. Who we are

Glee Games is GLEE GAMES LTD (formerly FIT FOOD AI LTD), a company registered in England and Wales (company number 16542151), registered office 4 Purcells Avenue, Edgware, London HA8 8DT, United Kingdom. We are the data controller for the information described in this policy. You can reach us at privacy@gleerewards.com.

2. What this policy covers

This policy applies to the Solitaire Secret app for Android ("the app") and to this website. It explains what information we collect, why, who we share it with, and the choices and rights you have. By installing and using the app you are asking us to provide it, and this policy describes how we handle information in doing so.

3. What we collect

The app works without an account. We do not ask for, and do not collect, your name, email address, phone number, contacts, photos, precise location or payment details.

Collected automatically when you use the app

Information you give us

If you email us, we keep your email address and what you wrote so we can reply and keep a record of the conversation.

Information we deliberately do not collect

We do not collect special-category data (health, religion, ethnicity, sexuality, political opinions and the like), government identifiers, or financial account details.

4. How we use it, and why we're allowed to

Data protection law requires a lawful basis for each use. Ours are set out below.

Where we rely on legitimate interests we have considered the impact on you and concluded that our use is proportionate and within your reasonable expectations. You can ask us for details of that assessment.

5. Advertising

The app is free and funded by ads served through Google AdMob, which may in turn work with other advertising networks. To serve, cap and measure ads, these partners receive your advertising identifier, IP address and device information, and record which ads were shown and whether they were completed.

Personalised ads. Where the law requires it, the app asks for your consent before showing personalised ads, using Google's consent tool. If you decline, you still see ads, but they are not based on your interests.

Your controls. On Android, open Settings → Google → Ads (on some phones Settings → Privacy → Ads). There you can delete or reset your advertising ID and opt out of ads personalisation. These are device-level settings and apply to every app on the phone. Opting out does not reduce the number of ads, only how they are chosen.

Google's own practices are described at policies.google.com/technologies/partner-sites.

6. Who we share information with

• Advertising partners — Google AdMob and the networks that bid through it, for the purposes in section 5.
• Analytics and crash reporting — PostHog (product analytics and crash diagnostics), which processes usage and diagnostic data on our behalf.
• Google Play — the store through which the app is distributed provides us with aggregated install and crash statistics.
• Hosting and infrastructure — the providers that host this website and our services.
• Authorities and advisers — where the law requires it, to protect our rights or the safety of our users, or in connection with a merger, acquisition or sale of our business.

We do not sell personal information. Sharing an advertising identifier with ad networks for personalised advertising may count as "sharing" or a "sale" under some laws, such as California's; section 12 explains how to opt out.

7. International transfers

We are based in the United Kingdom. Our advertising, analytics and hosting providers process data in the United States and other countries. When information leaves the UK or the European Economic Area we rely on safeguards recognised under UK and EU law — adequacy decisions where they exist, and otherwise the UK International Data Transfer Agreement or the EU Standard Contractual Clauses built into our providers' terms.

8. How long we keep it

• Game settings and progress stay on your device and are deleted when you uninstall the app.
• Analytics and crash data are kept in identifiable form for up to 14 months, after which only aggregated statistics remain.
• Advertising data is retained by our advertising partners according to their own policies.
• Emails you send us are kept for as long as needed to deal with your request and for up to two years afterwards, unless we need them longer to resolve a dispute or meet a legal obligation.

9. Security

We use industry-standard measures to protect information in transit and at rest, including encrypted connections and access controls, and we choose providers that do the same. No method of transmission or storage is completely secure, so we cannot guarantee absolute security, but we take the protection of your information seriously and will act promptly on any incident.

10. Children

The app is intended for adults and is not directed at children. We do not knowingly collect personal information from anyone under 18. If you believe a child has used the app and information about them has been collected, contact us and we will delete it.

11. Your rights (UK and EU)

If you are in the United Kingdom or the European Economic Area you have the right to:

• access the personal data we hold about you and receive a copy;
• correct inaccurate data;
• erase your data in certain circumstances;
• restrict or object to our processing, including objecting at any time to direct marketing and profiling for it;
• port data you provided to us to another service, in a machine-readable format;
• withdraw consent at any time where consent is the basis for processing, without affecting processing that happened before;
• complain to a supervisory authority. In the UK that is the Information Commissioner's Office — ico.org.uk/make-a-complaint, 0303 123 1113. We would appreciate the chance to address your concern first.

Because the app has no accounts, most of the data we hold is keyed to an advertising identifier rather than to you by name. To act on a request we may need you to tell us that identifier, which you can find in your Android ads settings.

12. Your rights (California)

If you are a California resident, the California Consumer Privacy Act gives you the right to know what personal information we collect and how it is used and shared, to request its deletion or correction, to opt out of the sale or sharing of personal information, to limit the use of sensitive personal information (we do not collect any), and not to be discriminated against for exercising these rights.

Categories collected in the last 12 months: identifiers (advertising ID, IP address); device and internet activity information (device details, app interactions, ad interactions); approximate geolocation inferred from IP address; and inferences our advertising partners may draw for ad selection. Sources: you and your device, and our advertising and analytics partners. Purposes: those in section 4. Disclosed to: advertising networks and analytics providers, as described in section 6.

Do Not Sell or Share My Personal Information. The only "sale" or "sharing" we engage in is providing your advertising identifier to ad networks for personalised advertising. To opt out, turn off ads personalisation or delete your advertising ID in your Android settings (section 5), or email us at privacy@gleerewards.com with the subject "Do not sell or share". We also honour Global Privacy Control signals where our systems can detect them.

13. How to exercise your rights

Email privacy@gleerewards.com and tell us which right you want to exercise. We will respond within one month (UK and EU) or 45 days (California), and may ask for information that lets us match your request to the data we hold — usually your advertising identifier. We use anything you send us to verify a request only for that purpose. You can also authorise someone to act for you; we may ask them for evidence of that authority.

14. Features we may add

We plan to add features over time, such as player accounts and a shared coin balance across Glee games. Those features will need more information than the app collects today — for example an email address. We will update this policy and, where required, ask for your consent before any such feature collects new information. Until then, the descriptions in this policy are complete.

15. Changes to this policy

When we change this policy we will update the date at the top and, for significant changes, tell you inside the app. The current version is always at gleerewards.com/privacy.

16. Contact

GLEE GAMES LTD (Glee Games)
4 Purcells Avenue, Edgware, London HA8 8DT, United Kingdom
privacy@gleerewards.com