Privacy Policy

Privacy Policy ("Policy") of the Mobile App "Jigsaw Drop Solitaire" ("App").

Last updated: October 15, 2026

We, Riseforward Ltd., limited liability company, registered office at Level 1, Blue Harbour Business Centre, Ix-Xatt Ta' Xbiex, Ta' Xbiex XBX 1027, Malta, Registration number: C110851, VAT: MT31634902 (the "Company", "we", "us"), publish the App on Google Play under the package name com.alex.picturesolitaire and set forth this Policy.

We are committed to protecting the privacy of the people who play our App. This Policy explains which Personal Data we collect when you play, why and on which legal basis we collect it, with whom we share it, how we protect it and which rights you have over it. Please take the time to read this Policy thoroughly. By installing or using the App you, the end user, agree to this Policy. If you do not agree with it, please do not install the App, or uninstall it.

The Policy applies to the App and to every feature, content pack, advertisement and service delivered through it (collectively, our "Services"). The Company is the controller of the Personal Data collected via the App according to Art. 4(7) GDPR.

Which data is collected?

Information that identifies you or can be used to identify or contact you is defined as "Personal Data". In the context of the App this is mostly technical information about your device and about the way you play, and above all the advertising identifier of your device. We never ask for your name, email address, telephone number, date of birth or payment details to play: the App has no account, no registration, no in-app purchases and no social features.

We only collect and handle Personal Data that is automatically collected from your device as outlined in this Policy, and Personal Data that you provide directly when you contact us.

We collect the following categories of Personal Data:

  • "Automatically Collected Information": information about how you use the App and the actions you take in it (levels started and completed, hints and shuffles used, virtual coins earned and spent, session start and length, screens visited, App version, time of first launch); device and network connection information (manufacturer and model, operating system version, screen size, language and region, time zone, network type, free memory); identifiers such as the Google Advertising ID of your device, random installation and app-instance identifiers created by our measurement components, and your Internet Protocol (IP) address, from which an approximate location (country, region or city, never a precise GPS position) may be derived; advertising information (which ads were requested and shown, impressions, clicks, completion of rewarded videos, the estimated revenue of an impression); install attribution information (the Google Play install referrer and the campaign or link that led you to the App); crash reports and performance diagnostics; and the record of your consent choices and of your acceptance of the Terms of Use.
  • "Information You Provide": information you provide when you contact us by email, such as your email address, the content of your message and any attachment.

Your game progress, settings and consent choices are stored on your device only. They are excluded from Android cloud backup and from device-to-device transfer, and they are deleted when you uninstall the App. Measurement and crash data is stored on secure servers provided to us by Google (Firebase) and by the other service providers named in this Policy under the relevant service and data processing agreements.

Minors

The App is not directed to children. By using the App you confirm that you are at least 13 years old, or older where the law of your country sets a higher age for consenting to data processing without a parent (16 in several EU Member States), and that you use the App in accordance with the age restrictions set by Google Play. The App does not take part in Google Play's "Designed for Families" program. We do not knowingly collect Personal Data from minors below the applicable age. If you are the parent or legal guardian of such a minor who has used the App, please contact us at info@riseforward.biz: we will delete the minor's Personal Data from our systems and ask our service providers to do the same.

How is your Personal Data used?

In this section we outline exactly how and why your Personal Data is collected and processed and the legal basis for this collection and processing.

The legal basis of processing will be one of the following:

  • Your explicit consent (Art. 6(1)(a) GDPR).
  • Legitimate interests (Art. 6(1)(f) GDPR), which may include but are not limited to our commercial interest in offering the App free of charge, the protection and security of the App, and the interests of the players.
  • Our legal obligation to comply with applicable laws and regulations (Art. 6(1)(c) GDPR).

You can contact us using the contact details below if you require more information on the collection and legal basis for processing your Personal Data.

If You Play the App:

When you play the App, we use Automatically Collected Information to deliver the Services to you: to download level packs and pictures, to apply the App's remote configuration, to show the App in your language and to keep your progress on your device.

Some of this data is aggregated, and such aggregated data cannot be used to identify you. We use it to monitor trends, to understand which levels are too hard or too easy, to administer the App and to collect general information about how the App is used.

The legal basis for such processing of your Personal Data is our legitimate interest (Art. 6(1)(f) GDPR) in operating and improving the App and in offering it free of charge.

Showing you Advertisements:

The App is free to play and is financed by advertising. Banner, interstitial and rewarded video advertisements are delivered through the AppLovin MAX mediation platform and the advertising networks listed in the section "Third-party advertising networks and other third-party features" below. To request and display an advertisement, and to grant you the in-game reward after a rewarded video, those networks receive your Advertising ID, IP address, device information and information about the advertisement you saw or tapped.

Advertisements may be non-personalized, i.e. selected from the context of the App, your language and your approximate location only. The legal basis for such processing is our legitimate interest (Art. 6(1)(f) GDPR) in financing a free App.

Advertisements may be personalized, i.e. selected on the basis of an interest profile that the advertising networks build from your Advertising ID and your activity across apps and websites. The legal basis for such processing is your consent (Art. 6(1)(a) GDPR), which we ask for in the consent form described in the section "Consent, the Advertising Identifier and SDK storage" below. You are not required to give it; without it you will still be able to play and will see non-personalized advertisements instead.

Measuring the App and Attributing Installs:

We use Google Analytics for Firebase to count installs, sessions and gameplay events, Firebase Crashlytics to receive crash reports and performance diagnostics, and Adjust to learn which marketing campaign or store link brought you to the App and how much advertising revenue an installation generates. This information lets us fix bugs, compare versions of a feature and run our marketing responsibly.

The legal basis for such processing is your consent (Art. 6(1)(a) GDPR) where the applicable law requires consent for analytics and attribution, and otherwise our legitimate interest (Art. 6(1)(f) GDPR) in understanding and improving the App. Until you have answered the consent form, where one is shown, analytics collection stays switched off.

Reminding you to Play:

On Android 13 and later the App asks once, on its first start, for permission to show notifications. If you allow it, the App schedules reminder notifications locally on your device; they are not sent from a server and no Personal Data leaves your device for them. The legal basis is the permission you give in the Android system dialog; you can withdraw it at any time in the App's settings or in the Android notification settings.

Contacting our Customer Service:

Should you contact us with a question or a request, we will respond to it and manage it. The communication channel is email at info@riseforward.biz or post at the address above. The legal basis for processing the Personal Data in your message is our legitimate interest (Art. 6(1)(f) GDPR) in supporting the players of the App and, where you exercise a legal right, our legal obligation (Art. 6(1)(c) GDPR) to respond. We will be unable to answer you without the Personal Data contained in your message.

Protect the security and integrity of our business:

We may be required to process your Personal Data to protect our company, our players and our business; for the purpose of complying with laws, regulations, court orders and other legal obligations; to assist in an investigation; to enforce this Policy and the applicable Terms of Use, or any other agreements with third parties; to promote the safety and security of the App; to detect or prevent fraud, invalid advertising traffic, emulators and other harmful practices; or for any other reason permitted by law.

The legal basis for such processing is the compliance with our legal obligations (Art. 6(1)(c) GDPR), our legitimate interest in the security of the App (Art. 6(1)(f) GDPR) and the protection of your and/or other persons' vital interests.

Special categories of Personal Data:

The App does not collect information that falls under the special categories of Personal Data, including but not limited to health-related information, sexual orientation and ethnic origin information. Should such data ever be needed, we would only process it with your prior explicit consent, according to Art. 9(2)(a) GDPR, except where permitted or required by applicable law.

Consent, the Advertising Identifier and SDK storage

The App is a native Android application and does not use browser cookies. Its software components (SDKs) nonetheless use comparable mechanisms: the Google Advertising ID, a resettable identifier that Android assigns to your device, random identifiers that the advertising and measurement SDKs create for your installation, and small files in the App's private storage in which those SDKs keep your preferences and the state of your consent.

On the first start the App shows a welcome window that links to the Terms of Use and to this Policy. Immediately after, where the law requires it, the App shows a consent form provided by Google's User Messaging Platform:

  • In the European Economic Area, the United Kingdom and Switzerland the form follows the IAB Transparency & Consent Framework. It lists the purposes and the advertising partners and lets you accept, refuse or choose purpose by purpose. Until you have answered, the App does not initialize its advertising SDKs.
  • In the United States the form lets you opt out of the "sale" or "sharing" of your personal information for targeted advertising, where state law gives you that right.
  • Elsewhere advertisements may be shown without a form, in which case they may be personalized according to the advertising networks' own policies and your device settings.

Your choice is stored on your device and passed to each advertising and measurement SDK as a technical signal (the consent string). Meta Audience Network is kept in its "Limited Data Use" mode unless you have expressly allowed it.

You have the ability to change your choices at any time:

  • open Settings → Privacy options inside the App to review, change or withdraw the consent you gave; the change applies to the next advertisement request;
  • go to Android Settings → Google → Ads (or Settings → Privacy → Ads) to reset your Advertising ID or to delete it, after which the advertising SDKs receive a string of zeros instead of an identifier;
  • switch reminder notifications off in the App's settings or in the Android notification settings;
  • uninstall the App or clear its storage in the Android settings to delete every preference, identifier and record the SDKs keep on your device.

If you wish to opt out of tracking by the Company beyond these settings, you can contact us at info@riseforward.biz.

Third-party advertising networks and other third-party features

While the App may contain advertisements and links leading to third-party apps and websites (for example the "Rate the game" button, which opens Google Play), third-party apps and websites are not covered by this Policy, which only covers the practices regarding the Company's use of your Personal Data. We are not responsible for third parties' privacy policies and/or procedures. You are strongly advised to read the privacy policy of third-party apps and websites when linking to them.

To the extent advertising features of third parties are embedded in the App, the following terms apply:

Advertising in the App is mediated by AppLovin MAX (AppLovin Corporation). Whenever an advertisement placement is shown, your device establishes a direct connection to the servers of AppLovin and of the advertising network that wins the placement. This means the advertisement is transferred by the network directly to your device, and the network receives your Advertising ID, IP address, device information and information about the advertisement at that moment, whether or not you interact with it. Each network acts as an independent controller of the data it collects through its SDK and processes it under its own privacy policy.

Please bear in mind that the Right to erasure and all other rights apply also to your data held by these advertising networks. Please contact us at info@riseforward.biz in case you wish to delete your data, including data held by the advertising networks, and we will forward your request and tell you how to contact them directly.

How we share and disclose personal data

We will not sell your Personal Data to third parties and we will not share, transfer or otherwise distribute your Personal Data to third parties, unless required by law, unless the third party acts as a data processor on our behalf, unless the third party is an advertising network delivering advertisements in the App as described above, or you have given us express consent to do so.

The sharing of Personal Data with other entities or service providers will be done in accordance with the applicable and relevant laws on data protection and is limited to the extent necessary. These companies have been selected carefully, and we regularly monitor how they comply with our instructions. These companies are prohibited from using your Personal Data for any other purposes than those described in this Policy. The sharing of your Personal Data with such companies is based on our legal entitlement to engage third-party processors to carry out the processing on our behalf, on the condition that we only use processors that provide sufficient guarantees to implement appropriate technical and organisational measures in such a manner that processing will meet the requirements of the applicable law and ensure the protection of the rights of users.

International transfers:

Some of the companies with which we may share your Personal Data are located outside of the European Economic Area, in particular in the United States. In order to maintain sufficient protection of your Personal Data in this context, we ensure that the said companies are located in third countries that offer an adequate level of protection based on a European Commission adequacy decision (including the EU-US Data Privacy Framework for certified companies), or we implement additional safeguards, e.g. the standard data protection clauses adopted by the European Commission. You can request further details by contacting us at the contact details below.

Law enforcement/Legal requests:

We may be required to disclose your Personal Data to government or law enforcement officials, in response to a lawful request by a public authority or when we have to comply with a legal obligation, including the need to meet national security requirements according to Art. 6(1)(c) GDPR.

We may also disclose your information in order to respond to any claims, to protect our rights or the rights of a third party, to ensure the safety of any person, to prevent any illegal activity, or to pursue our legitimate interest in applying or enforcing our Terms of Use (including for the purposes of fraud protection), according to Art. 6(1)(f) GDPR.

Should the Company be involved in a merger, acquisition, reorganization or sale of assets, your Personal Data may be transferred as part of that transaction; we will require the recipient to honour this Policy.

We will obtain your consent prior to sharing your Personal Data with other companies if required under applicable data protection laws. In such instances, the legal basis is Art. 6(1)(a) GDPR.

Is my Personal Data used for other purposes?

Your Personal Data will only be used for the purposes laid out in this Policy or otherwise explicitly disclosed purposes at the time of requesting such Personal Data. We will provide you with the relevant information about using your Personal Data if handled outside of this Policy's scope.

You have the following rights:

  • Right of access - You have the right to request confirmation as to whether we handle your Personal Data and, where that is the case, to request access to the Personal Data we have about you.
  • Right to rectification - You have the right to request the correction of incorrect Personal Data.
  • Right to erasure - You have the right to request the erasure of Personal Data without undue delay under certain circumstances, e.g., if your Personal Data is no longer necessary for the purposes for which it was collected or if you withdraw consent on which our processing is based according to Art. 6(1)(a) GDPR and there is no other legal ground for the processing.
  • Right to restriction of processing - You have the right to request us to restrict the handling of your Personal Data under certain circumstances, e.g., if you think that the Personal Data we handle about you is unlawful or incorrect.
  • Right to data portability - You have the right to receive the Personal Data you have provided us in a structured, commonly used, and machine-readable format, and you have the right to transmit that information to another controller without hindrance or ask us to do so under certain circumstances.
  • Right to object - You have the right to object to the handling of your Personal Data under certain circumstances, in particular, if we process your Personal Data on the legal basis of legitimate interests (Art. 6(1)(f) GDPR) or if we use your Personal Data for advertising purposes.
  • Right to withdraw consent - You have the right to withdraw your consent for the processing of your Personal Data, where processing is based on your consent, without affecting the lawfulness of processing based on consent before its withdrawal. In the App you can do so at any time under Settings → Privacy options.
  • Right to non-discrimination for the exercise of your rights - We will not discriminate against you because you have exercised any of your rights under this Policy.

Please note that, since the App has no account, we do not hold your name or email address and may not have sufficient information to identify you. To let us and our service providers locate the records that belong to your device, please include your Google Advertising ID (visible under Android Settings → Google → Ads) in your request. Additionally, in some cases, in order to adequately verify your identity or your authorization to make the request, we may require you to provide additional information. We respond within one month, which may be extended by two further months for complex requests as the GDPR allows, and free of charge unless a request is manifestly unfounded or excessive.

If you live in California or in another US state with a comprehensive privacy law, you additionally have the right to know what personal information we collect, use and share, to delete and correct it, and to opt out of its "sale" or "sharing" for cross-context behavioural advertising. We do not sell personal information for money; personalized advertising through the networks named above may count as "sharing", and you can opt out of it through the consent form and the device settings described in this Policy. We do not knowingly sell or share the personal information of anyone under 16.

You can execute your abovementioned rights by contacting us on the contact details mentioned below.

Right to lodge a complaint before the data protection authority

You have the right to lodge a complaint with a supervisory authority, particularly in the EU Member State of your habitual residence, place of work, or place of the alleged infringement, if you consider that our processing of your Personal Data infringes the applicable data protection laws. The supervisory authority competent for the Company is the Information and Data Protection Commissioner of Malta (https://idpc.org.mt). Please contact us at the contact details mentioned below, and we will assist you in identifying the respective competent supervisory authority.

Data security

We have implemented technical and organizational measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. All traffic between the App and any server travels over encrypted connections (TLS), and the App refuses unencrypted connections. Data stored on your device is kept in the App's private storage, which other apps cannot read. Access to data on our servers and in our measurement tools is restricted to the people who need it to operate the App. However, no security measures can be completely secure. We cannot ensure or warrant the security of any information transmitted through the App, and you do so at your own risk. Should a breach affecting your Personal Data ever occur, we will notify the competent authority and, where the law requires it, you.

Data retention

Your Personal Data is stored along with other information for as long as it is needed to ensure you can use the App, to comply with relevant laws (including those regarding document retention) and to provide the Services to you. Your Personal Data is also stored in order to resolve any disputes that may arise with any parties, which are otherwise deemed necessary for us to conduct our business.

To determine the appropriate retention period for Personal Data, we consider a number of factors, including what Personal Data we are processing, the risk of harm from any unauthorized disclosure, why we are processing your Personal Data and whether we can achieve this outcome by another means without having to process it. In particular:

  • your progress, settings and consent record stay on your device until you uninstall the App or clear its storage;
  • analytics and crash data linked to an identifier is kept for no longer than 14 months from your last activity, after which it is deleted or reduced to aggregated statistics;
  • attribution data is kept for the period needed to measure and pay for a campaign;
  • server access logs are deleted or anonymized within 90 days;
  • consent records are kept for as long as needed to demonstrate that consent was given;
  • email correspondence is kept for as long as needed to resolve your request and to defend legal claims;
  • data collected by the advertising networks is retained by each network for the period set in its own privacy policy.

When we no longer need to process your Personal Data for the purposes set out in this Policy, we will delete it from our systems.

Please contact us at the contact details listed below if you have any questions regarding the specific retention times for certain types of Personal Data.

Automated decision making

We do not use your Personal Data to make decisions by automated means with legal or similar effects for you. The selection of a personalized advertisement according to your consent choices is automated profiling for advertising purposes only, and you can refuse it as described in this Policy.

Whom do I contact if I have any privacy questions?

If you have any concerns, queries, or questions regarding this Policy, please contact us at info@riseforward.biz or by post at Riseforward Ltd., Level 1, Blue Harbour Business Centre, Ix-Xatt Ta' Xbiex, Ta' Xbiex XBX 1027, Malta. Please mention "Jigsaw Drop Solitaire" in the subject line so that your message reaches the right person.

Updates to this Policy

This Policy may be amended occasionally, for example when the App, its software components or the law change. Any such changes will be made available through updates of this page, which will show a new "Last updated" date at the top; for material changes we will also inform you inside the App. Therefore, please refer back to this Policy regularly.

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