Nopeuspeli – Privacy Policy

Last updated: May 23, 2026

Data Controller

Arctic Kiwi Oy
Email: tietosuoja@arctickiwi.fi

Overview

Nopeuspeli ("Speed Game") is a reaction game published by Arctic Kiwi Oy. Your privacy is important to us. By default the app collects no data at all and works fully offline. The only feature that involves any network communication is the optional global leaderboard, which is strictly opt-in and described in detail below.

What data we process

1. Local-only data (always)

The app stores the following on your device only, using local storage. This data never leaves your device unless you opt in to the global leaderboard (and even then, only the items in section 2 are transmitted).

Your personal high score and your local top-5 score list.
Your interface preferences: language (Finnish/English), sound on/off, screen orientation preference.
Your global-leaderboard preferences: whether you have opted in, and the 3-letter initials you have chosen as your leaderboard handle.

This local data is not personal data under GDPR, never leaves your device, and is deleted when you uninstall the app or clear the app's storage.

2. Global leaderboard (opt-in only)

If — and only if — you explicitly enable the global leaderboard from Settings, the app will send your game result to our backend after each game over. Until you opt in, no network requests are made and no data is transmitted.

When the leaderboard is enabled, the following data is processed:

Data	Purpose	Retention	Stored?
Your score (integer)	Display on the public leaderboard	Until pruned out of the top 500 list, or until you request erasure	Yes, in our EU database
Your chosen 3-letter initials (e.g. "ABC")	Display on the public leaderboard next to your score	Same as above	Yes, in our EU database
Server-side timestamp of submission	Tie-breaker for equal scores and operational logging	Same as above	Yes, in our EU database
Your IP address	Used transiently for abuse prevention and rate-limiting. We immediately convert it to a salted SHA-256 hash with a one-hour expiry; the IP itself is not written to any persistent storage by us.	The hashed counter expires automatically within 1 hour.	No (IP is not stored; hash counter is short-lived)

The 3-letter initials are chosen by you and we recommend you do not use anything that personally identifies you. We treat the initials as user-provided content, not as a personal identifier.

We do not collect or process: your name, email address, phone number, device identifier (IDFA/IDFV), advertising ID, precise or coarse location, contacts, photos, microphone, camera, health data, biometric data, financial data, or browsing history.

Legal Basis for Processing (GDPR Article 6)

Local-only data (section 1): not personal data; no legal basis required.
Global leaderboard submissions (section 2): your explicit consent under GDPR Article 6(1)(a). You give consent by enabling the leaderboard in Settings; you can withdraw consent at any time by disabling it, with no effect on the lawfulness of processing before withdrawal.
Transient IP processing for rate-limiting: our legitimate interest in protecting the service from abuse (GDPR Article 6(1)(f)). The processing is minimal, the IP is never persisted in plaintext, and the hashed counter expires within 1 hour.

How to opt out

Open Settings → Global leaderboard and turn it off. From that moment, no further submissions are made. Previously submitted entries remain on the leaderboard until they fall out of the top 500 or you request erasure (see "Your Rights" below).

Third-Party Services and Hosting

The leaderboard backend is operated by Arctic Kiwi Oy and hosted on Cloudflare Workers with a Cloudflare D1 database pinned to a Western European region (the Netherlands / Germany). Cloudflare acts as our data processor under a GDPR-compliant Data Processing Addendum. See Cloudflare's privacy policy at cloudflare.com/privacypolicy.

The app does not use any analytics SDKs, advertising SDKs, crash reporters, social media SDKs, or other third-party trackers. There are no cookies. The app is not used for advertising or tracking in the sense of Apple's App Tracking Transparency framework.

International Data Transfers

All leaderboard data is stored on servers physically located in the European Union (Western Europe). No data is transferred outside the EU/EEA by us.

Data Retention

Local preferences and high scores: stored on your device until you uninstall the app or clear its storage.
Leaderboard entries (score, initials, timestamp): kept while the entry is within the top 500 globally. Older / lower entries are automatically pruned daily. You may also request earlier erasure (see below).
Rate-limit counters: automatically deleted within 1 hour.

Your Rights Under GDPR

As a user in the European Union you have the following rights under the General Data Protection Regulation (EU) 2016/679:

Right of access (Article 15) — If you have submitted to the leaderboard, you may request a copy of the entries associated with your initials. Because we deliberately do not collect any identifying information, the practical way to identify your entries is to tell us the initials you used and approximate submission times.
Right to rectification (Article 16) — You may request correction of an entry, although in practice it is usually easier to simply submit a new one.
Right to erasure (Article 17) — You may request deletion of leaderboard entries associated with your initials by emailing the address below. You can also delete all locally stored data by uninstalling the app.
Right to restriction of processing (Article 18).
Right to data portability (Article 20).
Right to object (Article 21).
Right to withdraw consent (Article 7) — Disable the leaderboard from Settings at any time.
Right to lodge a complaint — You have the right to lodge a complaint with a supervisory authority. In Finland, this is the Office of the Data Protection Ombudsman (tietosuoja.fi).

Children's Privacy

This app is suitable for users of all ages. We do not knowingly collect personal data from anyone, including children under 16 (GDPR Article 8). If you are a parent or guardian and believe your child has provided initials or score data you want removed, please contact us using the address below.

Apple App Store privacy disclosures

The following disclosures are aligned with Apple's App Store privacy ("nutrition label") requirements and Apple App Store Review Guidelines, in particular Guideline 5.1.1 (Data Collection and Storage) and Guideline 5.1.2 (Data Use and Sharing):

Data Used to Track You: None. The app does not use any data for tracking across apps or websites owned by other companies, and does not use Apple's App Tracking Transparency identifier.
Data Linked to You: None. We do not collect identifiers that could be used to link data back to a specific individual.
Data Not Linked to You (collected only when you opt in to the global leaderboard):
- User Content → Other User Content: the 3-letter initials you choose. Used for App Functionality.
- Usage Data → Product Interaction: your game score. Used for App Functionality.
- Diagnostics → Other Diagnostic Data: IP address (processed transiently for abuse prevention only, never stored in plaintext). Used for App Functionality / Fraud Prevention.

If you do not opt in to the global leaderboard, the app collects no data and the App Store privacy answer for your use is effectively "Data Not Collected".

Security

Communication with the leaderboard backend uses HTTPS. Score submissions are signed with an HMAC-SHA256 token to discourage casual abuse. The backend enforces rate-limiting and basic plausibility checks. The shared signing key is not a personal authentication credential.

Changes to This Policy

If we materially change this policy, we will update the "Last updated" date at the top and, where reasonable, surface a notice in the app. Because we do not collect contact information, we cannot notify users directly. We encourage you to review this page periodically.

Contact

If you have questions about this privacy policy or wish to exercise your rights, please contact us:

Arctic Kiwi Oy
Email: tietosuoja@arctickiwi.fi