This Privacy Policy explains how Circle Architect ("we," "our," or "us") collects, uses, and protects your information when you use our mobile application. We are committed to protecting your privacy and complying with applicable data protection laws, including the General Data Protection Regulation (GDPR).
If you are located in the European Union, you have specific rights regarding your personal data, including the right to access, rectify, erase, restrict processing, data portability, and object to processing.
Legal Entity: Zeelworks (sole proprietorship registered in the Netherlands)
Registered Address: PO Box C6124, Kwikstaartlaan 42, 3704 GS Zeist, Netherlands
Support & Privacy Email: zeelworksmail@gmail.com
Phone: +31 6 5128 0682
EU Establishment & Representative: Zeelworks operates from the Netherlands and serves as its own EU representative for GDPR and DSA compliance.
Data Protection Officer: No Data Protection Officer is appointed; Circle Architect is operated by a sole developer and current data processing activities do not require a DPO under GDPR.
DSA Point of Contact: zeelworksmail@gmail.com
| Data Type | Purpose | Legal Basis (GDPR) | Retention Period |
|---|---|---|---|
| Game Progress & Statistics | Save game state, track achievements | Legitimate Interest | Until app deletion |
| Purchase Information | Process premium subscriptions | Contract Performance | 7 years (tax requirements) |
| Device Information | App optimization, crash reports | Legitimate Interest | 12 months |
| Advertising ID | Serve relevant advertisements | Consent | Until consent withdrawn |
| User-Generated Content (Art) | Display and store created artwork | Contract Performance | Until deletion by user |
We process your personal data based on the following legal grounds:
Google AdMob: Serves advertisements in the free version of our app. AdMob may collect device information and advertising identifiers to provide personalized ads.
Privacy Policy: https://policies.google.com/privacy
We may use analytics services to understand app usage patterns. All analytics data is anonymized and aggregated.
We do not sell your personal data to third parties.
We implement appropriate technical and organizational security measures to protect your personal data:
If you are located in the European Union, you have the following rights:
To exercise these rights, contact us at: zeelworksmail@gmail.com
We retain personal data only as long as necessary for the purposes outlined in this policy:
Your data may be transferred to and processed in countries outside your residence. When we transfer data outside the EU/EEA, we ensure adequate protection through:
Our app is suitable for users aged 13 and above. We do not knowingly collect personal information from children under 13. If we become aware that we have collected such information, we will delete it promptly.
Our app may use cookies and similar tracking technologies for:
You can manage tracking preferences through your device settings.
Circle Architect is considered a digital service under the EU Digital Services Act. We provide the following transparency information:
We may update this Privacy Policy periodically. We will notify you of material changes through the app or by email. Continued use of the app after changes constitutes acceptance of the updated policy.
If you believe we have not handled your personal data properly, you have the right to lodge a complaint with your local data protection supervisory authority.
For any questions about this Privacy Policy or our data practices, please contact us:
Email: zeelworksmail@gmail.com
Phone: +31 6 5128 0682
Postal Address: PO Box C6124, Kwikstaartlaan 42, 3704 GS Zeist, Netherlands
Subject: Circle Architect - Privacy Inquiry
Response Time: We aim to respond within 30 days (GDPR requirement)
For GDPR-related requests (access, deletion, portability), please email us with "GDPR Request" in the subject line. Include your device information and specify which rights you wish to exercise.