Privacy Policy

This privacy policy explains how we collect, use, and protect your personal data in connection with our app "Whistle1" (Anpfiff1) and related websites.

1. Data Controller

2. Data Processing in the App

2.1 Local Save Games

Whistle1 stores save games and settings locally on your device. This data is not transmitted to our servers unless you use optional cloud features.

2.2 Online Leaderboard

When you upload your career results to the online leaderboard, the following data is processed:

• Your chosen player name (pseudonym)
• Game statistics (points, titles, seasons)
• Difficulty level
• Timestamp

Legal basis: Art. 6(1)(a) GDPR (consent)

3. Google Play Games Services (Android)

The Android version of Whistle1 uses Google Play Games Services for the following features:

• Sign-in: Automatic sign-in with your Google account
• Achievements: Unlocking achievements
• Cloud Save: Optional – save games to Google Cloud

By using Google Play Games Services, data is transmitted to Google (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA). For more information, see the Google Privacy Policy.

Legal basis: Art. 6(1)(a) GDPR (consent upon sign-in); Art. 6(1)(b) GDPR for purchase verification.

4. Apple App Store, Game Center & iOS

The iOS version of Whistle1 is distributed via the Apple App Store (for EU users: Apple Distribution International Ltd., Hollyhill Industrial Estate, Hollyhill, Cork, Ireland; worldwide: Apple Inc., One Apple Park Way, Cupertino, CA 95014, USA). Apple is the independent controller (Art. 4(7) GDPR) for personal data processed in connection with your Apple ID, the App Store, Game Center and iOS.

4.1 App Store – Download, Update, Payment

When downloading, updating or purchasing, Apple processes under its own responsibility your Apple ID, purchase and download history, device and network information (including IP address and device identifiers) and payment information. As the developer we do not receive any direct identifying data (no Apple ID, no email address, no payment data), only aggregated statistics (e.g. App Store analytics, downloads per region) and revenue reports via App Store Connect.

Details: Apple App Store & Privacy.

4.2 Apple Game Center

Whistle1 integrates Apple Game Center for achievements, leaderboards and optional friend networking. When you use Game Center, Apple processes under its own responsibility in particular:

• Nickname, avatar, Game Center ID and, if applicable, Apple Arcade status
• Games played, timestamps and duration, scores, achievements, challenges
• List of Game Center friends and recent co-players, joint play times
• Device and software version, game controller usage
• Approximate location (derived from IP address)
• Interactions with Game Center UI (views, clicks)

As the developer we only receive from Apple your Game Center nickname, avatar and pseudonymous Game Center ID to display in in-game leaderboards and – only if you explicitly allow it – a list of related players (likewise pseudonymous). We receive no Apple ID, no email address and no payment data.

Details: Apple Game Center & Privacy.

Legal basis: Art. 6(1)(b) GDPR (contract fulfillment) for achievements and leaderboards; Art. 6(1)(a) GDPR (consent) for friend networking.

4.3 In-App Purchases via Apple StoreKit 2

See section 6 – In-App Purchases.

4.4 Crash Reports & Apple Diagnostic Data

iOS only transmits crash and diagnostic data to Apple and to us if you have enabled this in Settings → Privacy & Security → Analytics & Improvements. The data is pseudonymized and does not contain directly identifying content. We use it for bug fixing and product improvement.

Legal basis: Art. 6(1)(f) GDPR (legitimate interest in bug fixing); additionally Art. 6(1)(a) GDPR upon your voluntary opt-in.

4.5 TestFlight (Beta Program)

If you participate in the TestFlight beta program, Apple processes your TestFlight name or email address, your participation status and any feedback you send (including screenshots and crash logs). We receive pseudonymous tester IDs and the submitted feedback.

Legal basis: Art. 6(1)(a) GDPR (consent via TestFlight participation).

5. Steam (Valve Corporation)

The PC version of Whistle1 is distributed via Steam, operated by Valve Corporation, P.O. Box 1688, Bellevue, WA 98009, USA. Valve is the independent controller (Art. 4(7) GDPR) for personal data processed in connection with your Steam account, downloads, purchases, community features and gameplay via Steam.

5.1 Data processed by Valve

When you purchase, download or play Whistle1 via Steam, Valve processes under its own responsibility:

• Account data: email address, country of residence, Steam username, password, Steam ID
• Payment information (e.g. name, address, credit card or other payment data)
• Gameplay: playtime, progress, achievements, Steam leaderboards
• Device and connection data: IP address, operating system, hardware/device identifiers
• Crash reports and telemetry
• Community content: forum posts, Steam chat messages, reviews, user-generated content
• Cookies, pixels and advertising tags on the Steam websites

Details and rights (including data download via the Steam Privacy Dashboard): Valve/Steam Privacy Policy.

5.2 Data we receive as the developer

Via Steamworks we only receive from Valve:

• Your Steam ID and persona name (pseudonyms) when you use Steam leaderboards or achievements
• Achievement and leaderboard data from your playthrough
• Aggregated statistics and anonymized crash reports
• Purchase and license verifications (product ID, transaction token) – no payment data

We receive no direct identifying data (name, email, address) and no payment data.

5.3 Steam Cloud (optional)

If you enable Steam Cloud, your save games are stored encrypted on Valve's servers. This is optional and can be disabled in your Steam settings.

5.4 Steam Community features

If you publish screenshots, reviews, guides, forum posts or Workshop content for Whistle1 via Steam, processing is carried out solely by Valve. Such content is publicly visible to other users.

Legal basis: Art. 6(1)(b) GDPR (contract fulfillment) for purchase and provision of the game; Art. 6(1)(a) GDPR (consent) for optional community and cloud features.

6. In-App Purchases

Whistle1 offers optional in-app purchases. Payment processing is handled exclusively by the respective platform. We do not receive any payment data (no credit card numbers, no PayPal account, no bank details). Our servers only receive server-verifiable purchase tokens to prevent duplicate rewards and manipulation (hardened IAP system with transaction tracking and audit log).

6.1 Google Play Billing (Android)

• Purchase confirmation (product ID, timestamp)
• Transaction ID / purchase token for verification

Provider: Google Ireland Limited / Google LLC (see section 3).

6.2 Apple StoreKit 2 (iOS)

On iOS, in-app purchases and subscriptions are handled exclusively via Apple's StoreKit 2 interface. From Apple we receive:

• Product ID and purchase timestamp
• Signed transaction/receipt ID (JWS) for server-side purchase verification

Provider: Apple Inc. / Apple Distribution International Ltd. (see section 4).

6.3 Steam (Valve)

Purchases of the PC version and any DLC/additional content are billed exclusively by Valve. We only receive the purchase and license verification via Steamworks.

Legal basis (all platforms): Art. 6(1)(b) GDPR (contract fulfillment).

7. Advertising (Google AdMob)

The free Android version of Whistle1 displays ads via Google AdMob. No advertising is shown on iOS or in the Steam version. When AdMob is used, the following data may be processed:

• Your device's advertising ID
• Approximate location (based on IP address)
• Device and app information
• Interactions with advertisements

You can disable personalized advertising in your device's Google settings. With the "Ad-Free" purchase, no ads will be displayed.

More information: Google Advertising & Privacy

Legal basis: Art. 6(1)(a) GDPR (consent via consent dialog).

8. Analytics & Crash Reports

We use anonymized or pseudonymized crash reports and basic usage statistics to fix bugs and improve the app. Depending on the platform, this data is collected through the following services:

• Android: Google Play Console / Android Vitals (anonymized)
• iOS: Apple Analytics & crash logs – only if you enabled this in iOS settings
• PC (Steam): Steamworks crash reports (anonymized)

No directly identifying data is collected. IP addresses – where captured at all – are processed in truncated form.

Legal basis: Art. 6(1)(f) GDPR (legitimate interest in app stability and improvement).

9. International Data Transfers

Where data is transferred to providers in the United States (Apple Inc., Google LLC, Valve Corporation), the transfer is based on appropriate safeguards under Chapter V GDPR:

• EU–US Data Privacy Framework (Commission adequacy decision of 10 July 2023) for self-certified companies.
• Standard Contractual Clauses of the European Commission (Art. 46(2)(c) GDPR), supplemented by additional safeguards where necessary.

Apple Inc. and Google LLC are certified under the EU–US Data Privacy Framework. For Valve Corporation, Standard Contractual Clauses apply; further information is available in Valve's privacy policy.

10. Your Rights

You have the following rights regarding your personal data:

• Access (Art. 15 GDPR)
• Rectification (Art. 16 GDPR)
• Erasure (Art. 17 GDPR)
• Restriction of processing (Art. 18 GDPR)
• Data portability (Art. 20 GDPR)
• Objection (Art. 21 GDPR)
• Withdrawal of consent (Art. 7(3) GDPR)

You also have the right to lodge a complaint with a supervisory authority.

11. Contact

For privacy-related questions, contact us at:

Last updated: April 2026
Version: 2.0 (Android, iOS & Steam)