Girostella – Documentazione legale
Privacy Policy e Termini di utilizzo dell'app Girostella
Girostella Privacy Policy
Last updated: August 14, 2026
This Privacy Policy describes how personal data is processed through the Girostella mobile application (“App”), in accordance with Regulation (EU) 2016/679 (“GDPR”) and applicable Italian law.
1. Data Controller
The Data Controller is Girostella. Email: alessandro_penna@icloud.com
2. Data Processed by the App
Girostella is designed in accordance with the principle of data minimization.
The App does not use advertising platforms, profiling tools, cross-app or cross-site tracking technologies, analytics SDKs, or third-party crash reporting services.
The App does not request access to the user’s location, camera, microphone, contacts, photos, calendar, or health data, and does not require users to provide their name, address, phone number, or email address in order to play the game.
During use, certain information required for the operation of the game is stored locally on the device, including scores, personal records, attempts, progress, gameplay streaks, unlocked or selected cosmetic items, audio and haptic preferences, information relating to any purchased attempts, technical identifiers of transactions already processed, and scores awaiting synchronization with Game Center.
This data remains within the App’s private storage area on the device and is not transmitted to servers operated by the Data Controller. It is normally deleted when the App is removed, except for information that may be independently retained by Apple services.
The Data Controller does not receive or store the user’s IP address and does not collect geolocation data. Apple services used by the App may, however, independently process technical and network information in accordance with their respective privacy policies.
3. Game Center
Girostella uses Apple Game Center for player authentication, leaderboard management, score submission and synchronization, and validation of certain daily game features.
Through GameKit, the App may temporarily receive technical information required for the operation of the service, including a Game Center identifier associated with the player and information necessary to display leaderboards.
Nicknames, avatars, and other Game Center profile information may be displayed according to the user’s settings and the features provided by Apple, but they are not stored on servers operated by the Data Controller.
Scores obtained while offline may be temporarily stored on the device until the next synchronization.
Apple independently processes data collected through Game Center in accordance with its own privacy policies and applicable terms.
Use of Game Center is optional. Without authentication, certain features, such as leaderboards, score synchronization, or validation of specific daily activities, may not be available.
4. In-App Purchases
Any in-app purchases are processed through StoreKit and the App Store.
The Data Controller does not receive or store credit or debit card numbers, banking details, Apple Account credentials, or complete payment method information.
The App receives only the technical information necessary to verify and manage a purchase, such as the product identifier, transaction result, and technical transaction identifier.
Identifiers of transactions that have already been processed may be stored locally to prevent duplicate credits.
Payments, billing, refunds, and purchase history are handled by Apple in accordance with its own terms and privacy policies.
5. Support
If a user voluntarily contacts the Data Controller by email, the information processed may include the user’s email address, any name provided, the content of the request, any attachments, and technical information voluntarily supplied by the user.
This information is used solely to respond to the request, provide support, handle disputes, or comply with legal obligations.
Users are encouraged not to provide personal data that is not necessary for handling their request.
6. Purposes and Legal Bases for Processing
| Purpose | Legal basis |
|---|---|
| Operation of the App and storage of game progress | Performance of the requested service, Art. 6(1)(b) GDPR |
| Game Center, leaderboards, and synchronization | Performance of the requested service, Art. 6(1)(b) GDPR |
| Management of in-app purchases | Performance of a contract, Art. 6(1)(b) GDPR |
| Prevention of errors, duplicate transactions, and abuse | Legitimate interest of the Data Controller in the security and proper operation of the service, Art. 6(1)(f) GDPR |
| User support | Performance of the service or legitimate interest in handling user requests, Arts. 6(1)(b) and 6(1)(f) GDPR |
| Compliance with legal obligations | Legal obligation, Art. 6(1)(c) GDPR |
| Establishment, exercise, or defense of legal claims | Legitimate interest, Art. 6(1)(f) GDPR |
The App does not rely on consent for advertising, profiling, or tracking activities, as no such activities are carried out.
7. Recipients of Personal Data
The Data Controller does not sell or disclose personal data to advertisers, data brokers, or marketing platforms.
Where necessary, data may be processed by Apple in connection with Game Center, the App Store, and StoreKit, by the email service provider used for support, by professional advisers, or by public authorities where required by law.
8. International Data Transfers
The Data Controller does not operate its own servers and does not transfer App data to systems or infrastructure operated by the Data Controller outside the European Economic Area.
Data transmitted through Apple services, including Game Center, the App Store, and StoreKit, is processed by Apple in accordance with its own privacy policies and the safeguards required under applicable law.
9. Data Retention
Game progress, preferences, and other locally stored data are retained until the App is deleted.
Scores awaiting synchronization are retained until synchronization, any applicable expiration, or deletion of the App.
Support requests are retained for as long as necessary to handle the request and, as a general rule, for no longer than 24 months, unless a longer retention period is required by law or necessary to protect the rights of the Data Controller.
Any administrative or accounting records are retained for the periods required under applicable law.
Data independently processed by Apple is retained in accordance with Apple’s own retention policies.
10. Data Subject Rights
Where provided for under Articles 15–22 of the GDPR, users may exercise their rights of access, rectification, erasure, restriction of processing, objection, and data portability.
Requests may be sent to the email address provided in the Data Controller section.
Since all game-related data is stored exclusively on the device and is not accessible to the Data Controller, it can be deleted directly by removing the App.
For data retained by Game Center, the App Store, or other Apple services, users must use the tools made available by Apple.
Users also have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) pursuant to Article 77 of the GDPR.
11. Children
Girostella does not require users to provide personal identification information and does not offer chat, messaging, or features that allow users to freely publish content.
The use of Game Center, the App Store, and purchases by minors is subject to Apple Account settings, family features, and restrictions provided by Apple.
If the Data Controller receives personal data relating to a minor through a support request that is not necessary to handle the request, such data will be deleted unless there is another legitimate reason to retain it.
12. Security
Data stored locally by the App is kept within the sandbox environment provided by iOS.
Communications with Game Center and the App Store use the frameworks and security systems provided by Apple.
The Data Controller adopts reasonable and proportionate measures to protect personal data against unauthorized access, loss, or alteration.
13. Profiling and Automated Decision-Making
Girostella does not carry out advertising profiling and does not use automated decision-making that produces legal or similarly significant effects on users.
Leaderboards, scores, and the availability of attempts depend solely on the rules and mechanics of the game.
14. Changes to This Privacy Policy
This Privacy Policy may be updated to reflect changes to the App, the services used, or applicable law.
The updated version will be published at the same location and will indicate the relevant date of the latest update. In the event of material changes, a notice may also be provided within the App.
15. Contact
For information or requests relating to privacy: