Privacy Policy

In short

LingoHunters is a word-search game for learning vocabulary. We collect four kinds of thing: what you give us when you sign in, what you create by playing, a little technical information from your device, and records of anything you buy. We use it to run the game, keep your progress, rank you in seasons, show ads in the free version, and stop people cheating.

The part most likely to surprise you: the username you choose is public. It appears on leaderboards alongside your rank, your level and the avatar you picked from our own set. Anyone who opens the app can see it. Your real name and your email address are never shown to other players.

You have rights over your information — to see it, correct it, delete it, take a copy elsewhere, object to some uses of it, and withdraw any consent you gave. Your rights explains how, and you do not need a working account to ask.

Three annexes add what applies specifically in the EEA or the UK (Annex A), the United States (Annex B) and Peru (Annex C).

Who we are

LingoHunters is the game described in this policy. Our website is lingohunters.app and you can reach us at [email protected]. That address goes to the people who run the service, and it is the right place for every question, request or complaint in this document.

We are the controller of the information described here: we decide why it is collected and what happens to it.

LingoHunters is published by TRAVELERS CONNECTORS S.A.C., RUC 20612183695, of Jr. San Ramón 253, Urb. San Carlos 2da. Etapa, Comas, Lima, Peru. We are a Peruvian company, which is why this policy is written to Peruvian law as well as to the European rules — see Annex C.

Our representatives in the European Union and the United Kingdom will be named on this page, with their addresses, before the app is released.

We have not appointed a data protection officer. If we appoint one, we will name them here with their contact details.

What this policy covers

This policy covers:

• the LingoHunters mobile app on iOS and Android;
• this website, including the Spanish and French versions;
• the staff admin panel at /admin, which only our own team can sign in to.

It does not cover:

• Apple and Google. When you sign in with them, or buy through the App Store or Google Play, they handle your information under their own policies, as controllers in their own right. We cannot change what they do.
• Sites we link to, which have their own policies.
• Ads you tap through. What happens next is between you and the advertiser.

The information we collect

Each item is marked obligatory — that part of the service does not work without it — or optional.

What you give us

Information	Obligatory or optional
Username. Yours to choose, at least three characters. Public — see Your public profile and the leaderboards.	Obligatory
Avatar. One picture you choose from the set we made for the game — never a photo of you. Public, like your username.	Optional
Email address. You never type one: a guest gets a placeholder we generate, and a Google or Apple account uses the address that provider gives us (see below). The service cannot send email, so we never write to it.	Obligatory
Referral code, if someone gave you one and you enter it. Every account also gets a code of its own to share.	Optional
The languages you choose to learn.	Obligatory if you play
Settings you choose — sound, pronunciation, slide sensitivity, word difficulty, daily reminder time, colour-blind mode and reduced animations — saved to your account so they follow you between devices.	Optional
Anything you write to us, including the address you write from.	Optional

What you create by playing

Information	Obligatory or optional
Game sessions — the words you found, how long each took, moves made, hints used, your score.	Obligatory if you play
Your Worddex — the state of every word for you (unknown, watched, discovered, learning, mastered) and how often you have met it.	Obligatory if you play
Tokens and experience — what you earned and spent, achievements, streaks, daily-challenge results.	Obligatory if you play
Season and leaderboard position, calculated from the above.	Obligatory if you play

What your device tells us

Information	Obligatory or optional
Push notification token — a unique identifier for your installation, issued by Google’s Firebase Cloud Messaging (on iOS, layered over Apple’s push service) when you allow notifications.	Optional
Platform (iOS or Android), app version and device language, sent together with the push token. The device language your phone reports may carry a region code, such as es-PE; we do not use it to work out where you are.	Optional — sent only when you allow notifications
Last active time, refreshed about once an hour while the app is open.	Obligatory

We do not collect your location. There is no GPS in the app and we do not look up where an IP address is. We do not use the microphone, we do not record audio, and we do not read your contacts. We do not collect any photo of you: there is no photo upload, the app does not use your camera or your photo library, and your picture in the game is always one of the avatars we made. We do not use an analytics product, a crash-reporting product or an advertising attribution kit — none is installed.

What we get from Apple or Google when you sign in

Information	Obligatory or optional
Google: your account identifier, your email address (only if Google says it is verified), your display name. Google also offers the address of your profile photo; we do not keep it.	Obligatory if you choose Google sign-in
Apple: your Apple user identifier, and your name and email only if you choose to share them when you first authorise the app. If you hide your address, we get a relay address and nothing else.	Obligatory if you choose Apple sign-in

A name arriving this way is stored but never shown to other players. You never type it yourself.

What we get from purchases

Information	Obligatory or optional
Purchase records from RevenueCat: transaction, event and customer identifiers, which store you bought from, the price, currency, date, and whether the purchase was real or a test. We keep the full record RevenueCat sends us.	Obligatory if you buy something
Subscription tier, status and billing period.	Obligatory if you subscribe

We never see or hold your card number. Apple and Google are the merchants and they take the payment.

What we collect when ads are shown

For each rewarded ad we record its type, the provider, the ad unit it appeared in, Google’s transaction identifier for that view — so a reward is paid once and only once — and the tokens granted. Watching a rewarded ad is optional; the record exists only if you watch one.

The one place we store network identifiers

When somebody redeems a referral code, we store the IP address and the user-agent of the person redeeming it, with their email address, username and any campaign parameters in the link. This is only to stop one person collecting referral rewards over and over, which is why we pay out at most five redemptions per IP address. It is the only place in our own database where an IP address is stored. Like every online service, our hosting and content-delivery providers see the address of each connection and keep ordinary access logs for a short period; we do not read them to identify you.

There is no date of birth, no age, no country and no gender field anywhere in LingoHunters. We do not ask for any of them.

Why we use it, and our legal basis

If you are in the EEA or the UK, the legal basis in the third column is the one we rely on. Peru has a different framework and no equivalent of “legitimate interests” — Annex C sets out the basis for each of these purposes under Peruvian law.

Purpose	Information used	Legal basis
Creating your account and signing you in	Username, email, Google or Apple identifier	Performance of our contract with you (Art 6(1)(b))
Running the game and keeping your progress: drawing words, building grids, validating results, awarding tokens and experience, and remembering all of it	Game sessions, Worddex, ledgers, achievements, streaks	Performance of our contract (Art 6(1)(b))
Showing seasons and public leaderboards, and paying out prize pools	Username, avatar, words discovered, experience	Performance of our contract (Art 6(1)(b)) — the leaderboard is an advertised part of the game
Selling and managing token packs and subscriptions	Purchase records, subscription status, RevenueCat customer id	Performance of our contract (Art 6(1)(b))
Keeping tax and accounting records of what was sold	Purchase records	Legal obligation (Art 6(1)(c))
Sending push notifications about your game — streaks, seasons, rewards	Push token, platform, gameplay state	Performance of our contract (Art 6(1)(b)); you can switch them off at any time
Showing non-personalised ads in the free app	The ad request: your IP address, basic device information and, where your device provides one, the advertising identifier — used by Google only to cap how often you see an ad and for aggregated reporting	Our legitimate interest in funding a free version of the game through advertising that does not profile you (Art 6(1)(f)); where the identifier is stored or read for this, the consent the ePrivacy rules require, asked for through Google’s consent form
Showing personalised ads — choosing ads from a profile built across apps	Advertising identifier (IDFA or Android Advertising ID)	Your consent (Art 6(1)(a)), asked for through App Tracking Transparency and Google’s consent form — see Advertising for what happens where neither prompt appears
Verifying that a rewarded ad was genuinely watched before granting tokens	Our internal user id, ad view record	Performance of our contract (Art 6(1)(b))
Detecting cheating and referral abuse	Game session results, referral records, IP address and user-agent at redemption	Our legitimate interest in detecting and preventing cheating and referral abuse that would undermine fair play for everyone else (Art 6(1)(f))
Answering support messages and handling rights requests	Whatever you send us, plus your account record	Performance of our contract (Art 6(1)(b)); legal obligation for rights requests (Art 6(1)(c))
Keeping the service working: fixing faults, restoring data, protecting against loss	Whatever is affected	Our legitimate interest in keeping the service available, correct and recoverable (Art 6(1)(f))

Where we rely on a legitimate interest, we have weighed it against your interests and rights. You can object to any of it — see Your rights.

What happens if you do not provide it

• Username and email. Without them there is no account, so there is no game. If you play as a guest, both are generated for you; if you sign in with Google or Apple, the email comes from them. Either way you never type one.
• Google or Apple identifier. Only needed if you choose to sign in that way, and it is what makes an account permanent. Without one you stay a guest, and a guest account that never bought anything is deleted after 30 days of inactivity; a guest account with a purchase is kept like a registered one (see How long we keep it).
• Gameplay records. They are produced by playing. Without them we cannot count your score, keep your Worddex or place you on a leaderboard.
• Push token. Refuse notification permission and the app works normally; you simply get no notifications.
• Advertising identifier. Decline and any ad you choose to watch is non-personalised. Nothing else changes, and no feature is withheld. On Android outside Europe there is no prompt to decline today; the device setting described in Advertising does the same job.
• Purchase records. Only created when you buy. Refusing means not buying; everything free stays available.
• Referral IP address and user-agent. Recorded automatically when a code is redeemed. If you would rather it were not, do not redeem a referral code.

Nothing here is a statutory requirement. Everything above is either needed to give you the service you asked for, or optional in the sense described.

Your public profile and the leaderboards

This is the section we most want you to read.

Public to anyone using the app:

• your username, exactly as you chose it;
• the avatar you picked from our set, if you picked one;
• your rank, your level, your experience points and your number of words discovered;
• your position in weekly and seasonal leaderboards, and any prize you won;
• if you invite friends, your place on the referral leaderboard and how many people you brought in;
• an internal account identifier that means nothing outside the game.

Leaderboards are not limited to friends and there is no private mode. Anyone who opens the app can see the list. Treat your username as something the world can read, and do not use your real name, your email address or anything else you would not put on a public page. We do not filter usernames for offensive content, so please choose sensibly.

Never shown to other players:

• your email address;
• your real name, even when Google or Apple gave it to us;
• your purchases, your subscription, your tokens, the ads you saw, or anything from your game sessions beyond the ranking figures above.

Changing your username. You can change it in the app’s settings, and the new one replaces the old one on the leaderboards. Copies may persist briefly in caches used to build the rankings. If you cannot reach the setting, write to [email protected] and we will change it for you.

Who we share information with

We do not sell your information. Nobody pays us for it, and we do not pass it to anyone for their own marketing. What leaves the app for advertising purposes is the ad request itself — your IP address, basic device information and, where your device provides one, its advertising identifier — and that identifier is used to personalise ads only with your permission; Advertising explains that in full. Everything else goes to the providers below. Those acting for us do so under a contract that limits them to our instructions and requires protection at least equal to this policy; Apple, Google Play and Google AdMob act as controllers under their own policies, as the table says.

Recipient	What they receive	Why
Railway	Everything — they host the application and the database	Hosting and the database
Upstash	User ids and usernames	Caching leaderboards and reward calculations so they load quickly
Cloudflare R2 and Cloudflare Stream	No stored player data. They hold the game’s own word images, pronunciation audio, video and avatar artwork — though, like any content-delivery network, they see your device’s IP address when it fetches a file	Storage and delivery of game content
Google Firebase Cloud Messaging	Your device push token and the text of the notification	Delivering push notifications
RevenueCat	Our internal user id, and your purchase and subscription records	Managing purchases and subscription status
Apple and Google (App Store, Google Play)	Purchase data, and account identifiers if you use their sign-in	Distributing the app and taking payment, as controllers under their own policies
Google AdMob	The ad request — IP address, basic device information and, where the device provides one, the advertising identifier; that identifier is used to personalise ads only with your permission; our internal user id when verifying a rewarded ad	Serving ads in the free version and confirming a reward was earned, as a controller under Google’s own policies
Google Sign-In and Sign in with Apple	The sign-in exchange itself	Letting you sign in without a password

We also disclose information where the law requires it — to a court, a regulator or a law-enforcement body acting under proper authority — and to our professional advisers where necessary. If the business is ever sold or reorganised, information may pass to the buyer, who stays bound by this policy until they give you notice of a different one.

About the AI providers

We use OpenAI, Google Gemini, RunPod and Google Cloud Text-to-Speech to build the game’s word library — the definitions, illustrations and pronunciation audio every player sees. This happens in an internal content tool, before anybody plays.

These providers never receive information about players. The prompts we send them contain the word being generated and nothing else. No username, no email address, no gameplay record and no device identifier is sent to any AI provider.

Advertising

The free version of LingoHunters is paid for by advertising, through Google AdMob.

How the ads work. Today the only ads in LingoHunters are rewarded ads: you choose to watch a video and receive 5 tokens for it. There are no banners and no ads between rounds — if you never tap “watch an ad”, you never see one. You can watch at most 40 rewarded ads in any 24-hour period, so 200 tokens, with a one-minute wait between them. A Plus or Pro subscription does not change any of this; it buys the things listed in the Terms, not the removal of ads that only appear when you ask for them.

What Google receives. Every ad request carries your device’s IP address — from which Google infers a rough, city-level location — and basic device information. Where your device provides an advertising identifier (IDFA on iOS, Advertising ID on Android), the request carries that too. For a non-personalised ad Google uses the identifier only to cap how often you see the same ad and for aggregated reporting, not to build a profile. A personalised ad is one chosen from a profile Google has built across apps using that identifier, and that only happens with your permission. On iOS, if you decline tracking, the identifier is all zeros and Google never sees a real one. Separately, when you finish a rewarded ad, Google tells our server that our internal user id has earned a reward, so we grant the tokens once and only once.

How you are asked. It depends on your platform and where you are:

1. On iOS, the app asks for App Tracking Transparency permission before any ad is loaded. This is Apple’s own prompt, and it controls whether the advertising identifier can be read at all. Decline it and every ad is non-personalised.
2. In the EEA, the UK and Switzerland, on both platforms, Google’s consent form is shown before the first ad, asking separately about storing information on your device and about personalised advertising. Decline and any ad you choose to watch is non-personalised.
3. On Android outside those regions, no prompt is shown today, and the app requests personalised ads by default. We are not going to describe this as a choice you made: it is the app’s current default, the opt-out is the device setting below, and we are changing the app so that everyone is asked before the first personalised ad. This paragraph will be rewritten when that ships.

The app holds back ad measurement until the tracking prompt has been answered, so on iOS no advertising identifier is touched before you have had your say.

How to change your mind. The app has no settings screen that reopens the consent form, so you cannot change an ad-consent answer from inside the app today. Until that screen ships, here is what works:

• On iOS: Settings → Privacy & Security → Tracking, and turn LingoHunters off (or on). Turning it off withdraws permission for the advertising identifier immediately.
• On Android: Settings → Google → Ads, where you can delete your advertising ID or opt out of ad personalisation across all apps. This is also the opt-out where the app showed you no prompt.
• Write to us at [email protected]. Tell us you want to withdraw your consent to personalised advertising and we will confirm within 10 working days — the maximum Peruvian law allows — and walk you through the device setting above if that is what it takes. We know this is harder than the one tap it took to say yes; that is why the screen is being built.

We are wiring that screen up, and this section will be updated when it ships.

Sending information to other countries

Our providers operate internationally, so your information may be processed outside your own country, including in the United States.

Where information leaves the EEA or the UK, our transfer mechanism is the European Commission’s Standard Contractual Clauses (Decision (EU) 2021/914), with the UK Addendum for transfers from the United Kingdom. Because those clauses only work if the destination country’s law lets them, we assess each provider’s country before relying on them and add technical measures where needed, as the European Data Protection Board’s Recommendations 01/2020 require. Some providers are additionally certified under the EU–US Data Privacy Framework; that framework is currently being challenged before the EU courts, which is why we treat it as extra assurance, not as the mechanism we depend on. You can ask us for a copy of the clauses at [email protected], and we will send it with commercially confidential terms removed.

The region our servers run in is not finally settled. We will name it on this page once it is, rather than guess at it now.

How long we keep it

We do not use the phrase “as long as necessary” without saying what decides it. Here is what actually happens.

What	How long	What decides it
Guest accounts and everything attached to them	Deleted automatically 30 days after your last activity	A nightly job removes guest accounts inactive for 30 days that never made a purchase. Permanent, across every related record.
Referral records that were refused as fraudulent, or that expired unused — including the IP address and user-agent	Deleted about 3 months after they were created	A monthly clean-up on the first of the month. Three months is long enough to spot a pattern of abuse and short enough not to keep network identifiers around.
Referral records for a successful referral — including the IP address and user-agent recorded at redemption	While either account exists. If you delete yours, the record of the referral you redeemed stays, scrubbed of your username, email address, IP address and user-agent	The record is what proves the reward was earned once. We are shortening this so that the network identifiers are dropped after 3 months in every case, and will update this row when that ships.
Registered accounts and their gameplay history	Until the account is deleted	There is no automatic purge for a registered account; it stays while the account exists. Ask us to delete it and we will, subject to the records below.
Purchase and subscription records	Kept after deletion for as long as tax and accounting law requires	Statutory retention periods for financial records, and the need to handle refunds, chargebacks and disputes.
Ad view records	Kept while the account exists	Used for reward accounting and to check ad revenue against what our provider reports. No fixed period is currently set.
Support correspondence	Kept while it is needed to deal with your request and any follow-up	Resolving the matter, and being able to show how a rights request was handled.
The word library and its generation logs	Kept indefinitely	It is the game’s content and contains nothing about you.
Website theme preference	Until you clear your browser storage	It never leaves your device. See the Cookie Policy.

A registered account has no automatic expiry today. If you want yours gone, ask, and see Your rights.

How we protect it

What is actually in place:

• Players have no password to steal. A permanent account signs in through Google or Apple, so we store no password for it.
• Data on your device is stored encrypted, and your sign-in tokens are kept in the device keychain — the operating system’s protected credential store — rather than in ordinary app storage.
• Everything in transit is encrypted between the app, this website and our servers.
• Leaderboard queries are written to a strict boundary: they return only the ranking fields — username, avatar, rank, level, experience, words discovered — and cannot reach an email address, a purchase or a session record, even by mistake.
• The staff admin panel is separate. Staff sign in against a session held in cookies the browser’s own JavaScript cannot read, and the panel reaches our API through a server-side proxy, so no access token is ever handed to a browser.
• Sign-ins are short-lived and can be ended. The app holds two tokens: an access token that expires on its own after 15 minutes, and a refresh token that lasts up to 60 days and is recorded on our servers. Signing out cancels that refresh token on our servers, and Settings → Sign out on every device cancels all of them at once. Plainly: an access token already issued keeps working until its 15 minutes are up.

We deliberately claim no more than that: we hold no ISO 27001, SOC 2 or comparable certification, we run no bug bounty, and we claim no encryption at rest beyond what our hosting provider does by default. If that changes, we will say so here.

If something goes wrong. If a security breach puts your information at risk, we will notify the relevant supervisory authority within 72 hours of becoming aware of it where the GDPR applies, and — where Peruvian law applies — the authority and the people affected within 48 hours. We will tell you directly whenever a breach is likely to put your rights at high risk, describing what happened, what it means for you and what to do about it.

Your rights

You have all of the following. They are free, and asking does not affect your account.

• Access. Ask what we hold about you and get a copy.
• Rectification. Have anything wrong corrected and anything incomplete completed.
• Erasure. Have your account and its data deleted.
• Restriction. Have us pause processing while a dispute about accuracy or lawfulness is settled.
• Objection. Object to anything we do on the basis of a legitimate interest. We stop unless we can show compelling grounds that override your interests. This right is set out on its own below, because the law says it should be.
• Portability. Get the information you gave us, and the data your play produced, in a structured, machine-readable format, or have it sent to another service where that is technically possible.
• Withdraw consent. Where we rely on your consent — which today means personalised advertising — you can withdraw it at any time. Withdrawing consent does not make what we did before it unlawful; it stops the processing from that point on.
• Not to be subject to a purely automated decision that has a legal or similarly significant effect on you. See Automated decisions.
• Complain to a supervisory authority. See How to contact us, and how to complain.

Your right to object. You can object at any time to anything we do on the basis of a legitimate interest. Today that means three things: the anti-cheat and anti-abuse checks, keeping the service working and recoverable, and showing non-personalised ads. Write to [email protected] and say what you object to. We stop unless we can show compelling legitimate grounds that override your interests, rights and freedoms, and we tell you which it is.

Peru’s ARCO+ rights — acceso, rectificación, cancelación, oposición, plus impedir el suministro (stopping us passing your data to third parties), tratamiento objetivo (the Peruvian form of the automated-decisions right), portability, information and withdrawal of consent — are covered by the list above; Annex C gives the deadlines that apply there.

Two ways to exercise them, and one needs no account:

1. Write to [email protected]. This works whether or not you can sign in, and whether or not you still have the app. Tell us what you want, and enough to find your record — your username, or the email address on the account. We may ask one follow-up question to be sure it is really you, and never more identification than the request needs.
2. In the app. You can correct your username, change your notification settings, sign out, and delete your account — Settings → Delete account. Deletion is immediate and permanent, it works for guest accounts too, and it needs nothing from us. Delete your account explains exactly what is erased, what we must keep, and what happens to tokens you paid for; it is also the route to use if you have already uninstalled the app. Data export is still handled by email: you write, we check it is really you, and we send it.

We answer within one month where the GDPR applies, and can extend that by two further months for a complex request, telling you why. Peru’s deadlines are shorter for some rights and are set out in Annex C.

If we ever refuse a request, we will tell you why and how to challenge it.

Marketing

We do not send marketing email. The service has no email capability at all, so there is no newsletter, no promotional message and no re-engagement campaign. If that ever changes, we will ask for your consent first, and this section will be rewritten before a single message goes out.

Push notifications are about your own game: streaks, seasons, rewards and daily challenges. The sure way to stop them is your device’s notification settings for LingoHunters, which takes effect immediately. The app’s own notification switch saves your preference to your account; we are finishing the work that makes our servers honour it, so until then the device setting is the one to use.

You have the right to object to processing for direct marketing at any time, including any profiling connected to it. If we ever do direct marketing, you can object by writing to [email protected], and we will stop. There is no balancing test for this — an objection to direct marketing is absolute.

Automated decisions

Some things happen automatically, without a person looking:

• Game validation. When you finish a session, the server checks the result against the grid and the words it drew, and rejects results that could not have happened. The logic is a straightforward comparison of your submitted result with the puzzle the server generated. The consequence is that the tokens and experience for that session are not awarded.
• Ad reward throttling. Rewards from ads are capped at 40 ads in any 24-hour period, with a one-minute gap between ads. The logic is a count and a timer. The consequence is that you wait, or come back later.
• Referral limits. At most five referral redemptions from the same IP address are paid out. A sixth is recorded, marked as suspected abuse and never rewarded; marked records are later deleted. The logic is a count per IP address. The consequence is that the reward is withheld.

None of these produces a legal effect or anything similarly significant for you. They affect in-game rewards only: nothing about your money, your legal position or your access to anything outside the game turns on them. We do not build advertising or behavioural profiles about you, and we do not score you.

Our commitment. If we ever restrict, suspend or delete an account for suspected cheating or abuse, a person will review that decision before it becomes permanent, and you can contest it by writing to [email protected] and asking for a human to look again. You have the right to state your case and to be told the reason.

Children

LingoHunters is not directed at young children, and we do not want their information.

You must be at least 13 to use LingoHunters. Where the law where you live sets a higher age for agreeing to an online service on your own, that higher age applies instead: in the European Union the threshold is set nationally and ranges from 13 to 16, and in Peru and Spain it is 14. Below the applicable age, a parent or guardian must set the account up and consent on your behalf. This is also a requirement of our Terms.

Today, the app does not ask your age when you create an account. We will not describe an age screen we have not shipped. One will be added before the app is released, and it will ask neutrally, without steering the answer.

If you are a parent or guardian and believe your child has created an account, write to [email protected] with the username or the email address on it. We will delete the account and the data attached to it, and confirm when it is done. You need only show enough for us to see that the account is your child’s. If we find out ourselves that an account belongs to a child below the applicable age, we delete it.

We do not knowingly show personalised ads to a child, sell children’s information, or share it for advertising.

Cookies and device storage

This website sets no cookies for visitors. It loads no analytics, no tag manager, no advertising pixel and no third-party fonts. It stores at most one thing in your browser — whether you prefer the light or the dark theme, and only once you have used the theme switch — and that value never leaves your device. That is why you do not see a cookie banner here.

The only cookies in the whole product are the two session cookies for the staff admin panel, which are set only when a member of our team signs in, and never for a player or a visitor.

The full explanation of what this website stores is in the Cookie Policy. What the app keeps on your device is described in this policy, under How we protect it.

Changes to this policy

This policy was last updated on 15 September 2026 and takes effect on 15 September 2026. Both dates appear at the top of the page, and we keep them accurate.

Several things are marked here as still to come: our EU and UK representatives, the hosting region, the registration of our bank of personal data, an in-app advertising-consent screen and an age screen. Filling those in will change this page, and that is the point.

If we make a change that materially affects you — a new purpose, a new category of recipient, a different legal basis, or a new use of your information — we will tell you before it takes effect, in the app and on this page, and where the change needs your consent we will ask for it rather than assume it. Smaller corrections take effect when published. The previous version stays available on request.

How to contact us, and how to complain

Start with us. Write to [email protected]. It reaches a person, and we would much rather fix something than have you take it elsewhere first. Tell us what happened and what you want done.

If we do not resolve it, you can complain to a data protection authority:

• In the EEA: the supervisory authority of the country where you live, where you work, or where the problem happened. The list is published by the European Data Protection Board.
• In the United Kingdom: the Information Commissioner’s Office, at ico.org.uk.
• In Peru: the Autoridad Nacional de Protección de Datos Personales, part of the Ministerio de Justicia y Derechos Humanos. See Annex C for the tutela procedure.
• Elsewhere: your national privacy or consumer authority.

You can also go to the courts. In the EEA and the UK, complaining to us first is not a precondition for either. In Peru it is: the tutela procedure before the ANPD, and the hábeas data action, are open to you once we have refused your request or let the deadline pass without answering — see Annex C.

Annex A — If you are in the EEA or the UK

This annex adds to the rest of the policy for people in the European Economic Area and the United Kingdom.

Who is responsible. TRAVELERS CONNECTORS S.A.C. is the controller. We are established in Peru, not in the EEA or the UK, so the GDPR applies to us under Article 3(2) because we offer the service to people here — and there is no lead supervisory authority or one-stop-shop for us. You may complain to your own national authority. We will appoint EU and UK representatives and name them on this page, with their addresses, before the app is released, as Article 27 of the EU and UK GDPR requires. We have appointed no data protection officer; if we do, they will be named here.

Legal bases. Why we use it, and our legal basis gives the basis for each purpose. Three rest on legitimate interests, named in full: detecting and preventing cheating and referral abuse that would undermine fair play for everyone else, keeping the service available, correct and recoverable, and funding a free version of the game through advertising that does not profile you. You may object to any of them. The processing based on consent is personalised advertising and the use of your advertising identifier for it; withdraw it as described in Advertising, and doing so does not affect what was lawful beforehand. Where Google’s consent form asks about storing information on your device, that is the consent the ePrivacy rules require, and it is separate from the GDPR bases above.

Transfers. Standard Contractual Clauses, with the UK International Data Transfer Addendum where relevant, backed by a transfer assessment of each destination. Ask and we will send you a copy of the clauses.

Automated decision-making. We carry out none that produces legal effects concerning you or similarly significantly affects you. Automated decisions describes the automatic checks the game does run.

Your rights are those in Articles 15 to 22 — access, rectification, erasure, restriction, portability, objection, and not to be subject to solely automated decisions with legal or similarly significant effects — plus the right to complain to your supervisory authority and to an effective judicial remedy.

Is providing information a requirement? Nothing here is a statutory requirement. Your username and email are a contractual one: without them we cannot give you an account. What happens if you do not provide it covers the rest.

Annex B — If you are in the United States

This annex adds to the rest of the policy for residents of US states with comprehensive privacy laws, including California, Colorado, Connecticut, Virginia, Texas and others with similar statutes.

Categories we have collected in the preceding 12 months, in California’s terms: identifiers (username, email address, account identifiers, device push token, advertising identifier, and an IP address when a referral code is redeemed); commercial information (purchases and subscriptions); internet or other electronic network activity (how you use the app and interact with ads); and inferences drawn only for the game itself, such as which words you have mastered. We get them from you, from your device, from Apple and Google at sign-in, and from RevenueCat when you buy. Why we collect each, who receives it and how long we keep it are in The information we collect, Why we use it, and our legal basis, Who we share information with and How long we keep it. In the same period we have disclosed those categories to the service providers listed there for the business purposes stated, and shared one category — the advertising identifier — with one category of third party, an advertising network.

Sensitive personal information. We collect none: no government identifier, no financial account number, no precise geolocation, no racial or ethnic origin, no religious beliefs, no health data, no biometrics, no contents of your messages. So there is no use or disclosure of it for you to limit.

Do Not Sell or Share My Personal Information. We do not sell your personal information, and we never have — no one pays us for it. We do share information in one context: showing personalised ads in the free app passes your device’s advertising identifier to Google, which California treats as “sharing” for cross-context behavioural advertising, and other states treat as targeted advertising. On iOS this happens only if you have allowed tracking; on Android in the United States it is the app’s current default, as Advertising explains. To opt out: on iOS, decline the App Tracking Transparency prompt or turn LingoHunters off under Settings → Privacy & Security → Tracking; on Android, opt out of ad personalisation or delete your advertising ID under Settings → Google → Ads. A switch with the name Do Not Sell or Share My Personal Information will sit in the app’s Settings and make every ad request non-personalised regardless of the device setting; until it ships, write to [email protected] and we will apply your opt-out and help you set it on your device within 15 business days. This website itself has no ads, no analytics and no trackers, so nothing is sold or shared here, and there is nothing for a Global Privacy Control signal to switch off; we will honour that signal if that ever changes.

Minors. We do not knowingly sell or share the personal information of anyone under 16, and in states that protect minors up to 18 we do not use a known minor’s information for targeted advertising without the consent the law requires. Once the app asks your age, any answer under 18 will turn personalised ads off for that account.

Your rights in states with comprehensive privacy laws: to know what we collect and why, to access a copy, to correct it, to delete it, to get it in a portable form, to opt out of targeted advertising, and not to be discriminated against for asking. We offer no financial incentives for your data, so price and service are the same either way. Write to [email protected]; we confirm receipt within 10 business days, respond within 45 days, and may extend once by another 45 days for a complex request, telling you why.

Appeals. If we refuse a request, you may appeal by replying to our decision. We will review it and tell you the outcome in writing, with our reasons. Residents of states that provide it may then contact their state Attorney General.

Authorised agents may make a request on your behalf with written permission that we can verify.

Children under 13. See Children. We do not knowingly collect personal information from children under 13. A parent or guardian who tells us about an account will have it and its data deleted, and may refuse any further collection.

Annex C — If you are in Peru

This annex adds to the rest of the policy for people in Peru. It reflects Ley N° 29733 and its regulation, D.S. 016-2024-JUS, in force since 30 March 2025.

Who is responsible, and where. The titular del banco de datos is TRAVELERS CONNECTORS S.A.C., RUC 20612183695, domiciled at Jr. San Ramón 253, Urb. San Carlos 2da. Etapa, Comas, Lima, Peru. Our contact address is [email protected]. Article 6.1(1) of the Reglamento requires our identity and our domicile, and both are stated here.

The bank of personal data. Your information will be stored in a bank of personal data covering LingoHunters’ registered users and their gameplay, which we will register with the Autoridad Nacional de Protección de Datos Personales (ANPD) before launch, as the law requires. That registration will also declare each international transfer listed in Who we share information with — the recipient and the country — as Article 21 of the Reglamento requires. We will publish its name and registration code here once registered. We are not claiming it has been registered yet.

Legal basis. Peruvian law has no “legitimate interests” basis for the controller; the exceptions in Article 14 are exhaustive. So, for people in Peru:

Purpose	Basis under Ley 29733
Account, sign-in and running the game	Art 14.5 — the data are necessary to perform our contract with you: the account and the game you asked for
Gameplay progress, Worddex, seasons, leaderboards	Art 14.5
Purchases and subscriptions	Art 14.5, and legal obligation for tax and accounting records
Transactional push notifications	Art 14.5
Verifying that a rewarded ad was watched before granting tokens	Art 14.5
Answering support messages and handling your rights	Art 14.5, and the duties the Law imposes on us
Keeping the service working, secure and recoverable	Art 14.5, and our security duties under Article 16 of the Law and the Reglamento
Anti-cheat and referral-fraud checks, including the IP address stored at redemption	Art 14.5 — necessary to deliver the service correctly
Advertising, personalised or not — the ad request described in Advertising	Your consent (Reglamento Art 26.1), which you may withdraw at any time as easily as you gave it. Today, on Android, the app shows no consent prompt outside Europe; that is a gap we are closing, and until it is closed the device setting in Advertising is your opt-out

Obligatory and optional fields. Every item in The information we collect is marked, as Peruvian law requires. What happens if you do not provide it explains what follows from providing it and from refusing.

Transfers. Yes, there is an international transfer: our providers are outside Peru, including in the United States, as listed in Who we share information with. We use contractual clauses that impose protection equivalent to Peruvian law on each recipient, and each transfer will be declared to the ANPD with the bank’s registration. The region our servers run in will be named on this page once it is settled.

Retention. How long we keep it sets out what we keep and what decides how long.

Automated decisions. Automated decisions describes them and their consequences. None of them has a legal effect on you, and any account restriction is reviewed by a person. This is also how we honour your right to tratamiento objetivo under Article 23 of the Law.

Your ARCO+ rights and our deadlines, counted in días hábiles (working days) from when we receive your request:

Right	Our deadline
Information (información)	8 working days
Access (acceso)	20 working days
Rectification, updating or deletion (rectificación, actualización, supresión)	10 working days
Objection (oposición)	10 working days
Stopping disclosure to third parties (impedir el suministro)	10 working days
Portability, and withdrawal of consent	Treated on the same terms; we act as soon as we can and within 10 working days

Each period except the 8-day one for information may be extended once, by an equal period, where the circumstances justify it — we will tell you before the first period runs out. Exercising these rights is free. Write to [email protected].

If we do not answer. Silence counts as refusal. A refusal, or an unsatisfactory answer, is what opens the next step: you may then bring a procedimiento de tutela de derechos before the ANPD at the Ministerio de Justicia y Derechos Humanos, or a hábeas data action before the courts, and you may also complain to INDECOPI in matters of consumer protection.

Minors. In Peru the threshold is 14. Someone aged 14 to 17 may consent for themselves to a digital service, and we will explain what we do in language they can understand. Below 14, a parent or guardian must consent. When the age screen ships, we will make the reasonable efforts the Reglamento requires (Art 25.4) to check who is consenting before treating a consent as valid, and we will use the age answer for nothing else. See Children, and write to us if a child’s account needs deleting.

Sensitive data. Peruvian law treats more categories as sensitive than the GDPR does, including information about your income. We do not collect any of them. We never ask about your income, your health, your beliefs, your origin or your biometrics, and nothing in the game produces that information.

Breach notification. Where Peruvian law applies, we notify the ANPD and the people affected within 48 hours of becoming aware of a breach that puts personal data at risk.