Privacy Policy: Escalero
Who is responsible
This privacy policy explains how personal data is processed in connection with Escalero.
The controller within the meaning of the General Data Protection Regulation (GDPR) is:
Xinger Solutions GmbH
Seefeldgasse 5, 3462 Absdorf, Austria
E-mail: office@xinger.org
x4apps is a brand of Xinger Solutions GmbH.
Our approach
We process personal data only where it is needed to provide Escalero, where we have a legitimate interest, or where you have given your consent. The following sections describe each processing activity, its legal basis under Art. 6 GDPR and how long data is kept. We do not sell personal data.
Data stored on your device
Content and settings you create in Escalero, such as scores, lists or preferences, are stored locally on your device. This data is not transmitted to us. You can delete it at any time by clearing the app data or uninstalling the app.
If you use the backup function of your operating system, Google or Apple process this data according to their own privacy policies.
Download through app stores
Escalero is distributed through Google Play and the Apple App Store. When you download the app, the store operator processes data such as your account, device and payment information under its own responsibility. We have no influence on this processing. Please refer to the privacy policies of Google and Apple.
The store operators provide us with aggregated statistics, for example on downloads, ratings and app stability, which do not allow us to identify you.
Advertising with Google AdMob
Escalero is financed by advertising. Ads are delivered by Google AdMob, a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google").
We use AppLovin MAX to serve advertisements. AppLovin may collect the following data:
- Device identifiers (e.g., Advertising ID / IDFA)
- IP address
- Device type, operating system, screen size
- Ad interaction data (impressions, clicks)
- Approximate location (based on IP address) Legal basis: Art. 6(1)(a) GDPR (consent) or Art. 6(1)(f) GDPR (legitimate interest).
Opt-out on iOS: When you first open the App, you will be asked for permission via the App Tracking Transparency (ATT) dialog. You can revoke this permission at any time under Settings → Privacy → Tracking. Opt-out on Android: You can disable personalized ads under Settings → Google → Ads. AppLovin Privacy Policy: https://www.applovin.com/privacy/
Data processed: advertising identifier of your device (Android advertising ID or Apple IDFA), IP address, device and operating system information, app usage and interactions with ads.
Purposes: delivering ads, measuring their performance, preventing fraud and, only with your consent, showing personalised ads based on your interests.
Consent: When you first open the app, a consent dialog (Google User Messaging Platform) asks whether Google and its partners may store and access information on your device and use it for personalised ads. The legal basis is your consent (Art. 6(1)(a) GDPR, § 165(3) TKG 2021). You can change your choice at any time via the privacy settings in the app. Without consent, Google shows non-personalised or limited ads; processing that is strictly necessary for delivering them, limiting how often they appear and preventing fraud is based on our legitimate interest in financing the app (Art. 6(1)(f) GDPR).
iPhone and iPad: The app only accesses the advertising identifier (IDFA) if you allow tracking in the App Tracking Transparency dialog.
Transfers to third countries: Google may process data in the USA. Google LLC is certified under the EU–US Data Privacy Framework, for which the European Commission has adopted an adequacy decision (Art. 45 GDPR).
You can reset or delete the advertising identifier in your device settings. More information: How Google uses information from apps that use its services and the Google privacy policy.
In-app purchases
Escalero offers optional in-app purchases. Payments are processed exclusively by Google Play or the Apple App Store; we do not receive your payment details.
To unlock purchased features, the app receives a purchase confirmation from the store. It is stored on your device and checked with the store when you restore purchases. The legal basis is the performance of a contract (Art. 6(1)(b) GDPR).
In-app purchases and subscriptions are managed through the service RevenueCat (RevenueCat, Inc., USA). RevenueCat helps us verify purchases, provide unlocked content, and restore purchases across multiple devices. The following data may be processed in this context:
- a randomly generated app user ID (anonymous identifier)
- purchase information (product purchased, price, time, status, receipts or transaction IDs from Apple/Google)
- device and app information (e.g. operating system and version, app version, country or region of the app store, language)
- IP address (technically required for communication with RevenueCat's servers)
Neither we nor RevenueCat receive your payment data (e.g. credit card number). Payment is processed exclusively by Apple or Google.
More information: https://www.revenuecat.com/privacy
Children
Escalero is intended for a general audience. We do not knowingly process personal data of children under 14 beyond what is described in this policy. If you believe that a child has provided us with personal data, please contact us so that we can delete it.
Contacting us
If you contact us by e-mail, we process your e-mail address, the content of your message and any information you provide in order to answer your request. The legal basis is the handling of your request (Art. 6(1)(b) GDPR) or our legitimate interest in communicating with you (Art. 6(1)(f) GDPR).
Questions about Escalero: office@xinger.org
Storage period
We keep personal data only as long as necessary for the purposes described above. E-mail correspondence is deleted once your request has been fully handled, unless statutory retention obligations, for example under Austrian commercial and tax law, require us to keep it longer.
Your rights
You have the right to access your data (Art. 15 GDPR), to rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18) and data portability (Art. 20), and the right to object to processing based on legitimate interests (Art. 21). You can withdraw consent at any time with effect for the future (Art. 7(3)).
To exercise your rights, write to office@xinger.org.
You also have the right to lodge a complaint with a supervisory authority. In Austria, this is the Datenschutzbehörde, Barichgasse 40–42, 1030 Vienna, dsb.gv.at.
Changes to this policy
We update this privacy policy when Escalero or the legal requirements change. Each update is published as a new version with the date from which it applies. Earlier versions remain available in the version history.