SolitairePlace

1. Introduction

GreatGamesNetwork ApS ("we", "us", "our") operates SolitairePlace.com ("the Service").

We are committed to protecting your privacy in compliance with the General Data Protection Regulation (GDPR) and applicable data protection laws.

This Privacy Policy describes what data we collect, how we use it, and your rights regarding your personal data.

2. Data Controller

GreatGamesNetwork ApS
CVR: DK46157885
Registered in Denmark
Email: support@greatgamesnetwork.com

3. Data We Collect

3a. Game Data (Local Only)

Game progress, scores, and high scores are stored exclusively in your browser's localStorage. We do not transmit or store your game data on our servers.

This data is entirely under your control and can be cleared at any time through your browser settings.

3b. Technical Data

Our web servers automatically collect standard log data, including: IP address, browser type and version, operating system, referring page, pages visited, and timestamps.

Legal basis: Legitimate interest (security and service improvement).

3c. Analytics Data

We use Google Analytics 4 (GA4) for website analytics. GA4 uses cookies and similar technologies to collect usage data.

GA4 collects: page views, session data, referrer URLs, browser and operating system type, device type, approximate location (derived from IP address), and user interactions with the site.

IP addresses are anonymized by Google Analytics. For details on Google's data practices, see Google's Privacy Policy and Google Analytics data practices.

Legal basis: Consent (obtained via our cookie consent mechanism before analytics cookies are set).

We also use Umami, a cookieless analytics tool that we run on our own server (umami.infessa.com). Umami records page views and game events: which game you open, when a game starts and ends and how it ended, hints, shares, ad breaks, and whether the play-reminder card was shown and what you chose. Umami sets no cookies and stores no IP address; it counts visitors with a salted hash that changes every month, so you cannot be recognised from one month to the next.

One exception: if you first came to the site by clicking one of our Google ads, we remember which ad it was (see Section 4c) and Umami records it with your later visits, so we can tell whether our advertising pays for itself. The record holds a random identifier for your browser, the day of the click and the campaign, ad and keyword or website the ad ran on. It holds no name, no IP address and no Google click identifier.

Legal basis: Legitimate interest (understanding how the games are played so we can improve them).

3d. Advertising Data

Google AdSense serves advertisements on our site. Google may collect: IP address, device identifiers, cookie data, browsing behavior, and ad interaction data.

Google uses this data to serve personalized ads, measure ad performance, and limit ad frequency.

For details on Google's data practices, see Google's Privacy Policy.

Legal basis: Consent (obtained via cookie consent mechanism for personalized ads).

3e. Play Reminders (Optional Push Notifications)

After a few visits we may ask whether you would like an occasional reminder to play. If you say yes and your browser grants permission, we send at most one notification per day, timed around when you usually play. Reminders are delivered through Amptune (amptune.com), our notification service.

To time reminders, Amptune receives: a random identifier for your browser, your time zone, when you are playing and which game, and your browser's push subscription. No name, email address, or account is involved.

Legal basis: Consent (you enable notifications explicitly). You can stop reminders at any time by blocking notifications for solitaireplace.com in your browser settings.

3f. App Install Reward

When you install SolitairePlace as an app, the app gives you 10 free hints the first time it opens, once per device. To make sure the reward is given only once, the app sends our server a random identifier for your browser and a short description of your device (screen size, time zone, language, number of processor cores, memory and graphics chip), and the server sees your IP address and browser type. The server stores only two one-way coded values made from these (they cannot be turned back into the data) and the time of the claim, for 2 years. The free hints themselves are kept in your browser's localStorage.

Legal basis: Performance of the service you ask for (claiming the reward) and our legitimate interest in giving it only once per device.

4. Cookies and Local Storage

4a. Local Storage (No consent required)

Browser localStorage is used to store game progress, including scores and high scores. This storage is strictly necessary for functionality you request and is entirely under your control. You can clear it at any time through your browser settings.

4b. Analytics Cookies (Consent required)

Google Analytics 4 uses cookies (such as _ga and _ga_<container-id>) to distinguish users and sessions. These cookies are set only after you provide consent via our cookie consent mechanism.

Analytics cookies are used to understand how visitors interact with the site, including page views, session duration, and navigation paths.

4c. Advertising Source Record (Consent required where the consent message applies)

If you arrive by clicking one of our Google ads, we store a small record in your browser's localStorage, named sp-ft: a random identifier, the day of the click and which campaign and ad it was. In the EEA, the UK and Switzerland it is stored only if you allow storage on your device in our consent message, and it is removed if you withdraw that. It stays until you clear your browser's site data.

4d. Reminder Cookie (Consent required)

If you accept analytics cookies, Amptune sets a first-party cookie named _reach_uid (a random identifier, expires after 2 years) so your play pattern can be recognised across visits. Without that consent, the identifier lives only in memory for the current visit.

4e. Advertising Cookies (Consent required)

Google AdSense places cookies to serve and measure advertisements. These cookies may track browsing activity across websites.

Types of advertising cookies include: ad personalization, ad measurement, and frequency capping.

Consent is obtained before non-essential advertising cookies are set.

You can manage Google ad personalization at adssettings.google.com. You can also opt out of personalized advertising via aboutads.info/choices.

5. How We Use Your Data

• Providing and maintaining the game service
• Storing game progress locally in your browser
• Serving advertisements to support the free service
• Analyzing site usage to improve the Service (via Google Analytics and Umami)
• Sending play reminders you have opted in to (via Amptune)
• Ensuring security and preventing abuse
• Complying with legal obligations

6. Data Sharing and Third Parties

We do not sell your personal data.

• Google AdSense: Receives data for ad serving as described in Section 3d, governed by Google's privacy policy.
• Google Analytics: Receives analytics data for usage analysis, governed by Google's privacy policy and our data processing agreement with Google.
• Umami: Receives the cookieless usage data described in Section 3c. Umami runs on our own server (umami.infessa.com), so this data is not shared with a third party.
• Amptune: Receives the reminder data described in Section 3e, only if you enable notifications. Amptune is operated by MB Alpha, the group SolitairePlace belongs to, and uses the data solely to send your reminders.
• Law enforcement: We may disclose data if required by law or to protect our rights and safety.

We do not share your data with any other third parties.

7. Data Retention

• Server logs: Retained for 90 days, then deleted.
• Local storage data: Persists until cleared by you through your browser settings.
• Advertising data: Governed by Google's data retention policies.
• Umami data: Aggregated page view and event counts, kept on our own server for as long as we need them to understand site usage.
• Google Analytics data: User and event data retained for 14 months, then automatically deleted. Aggregated reports are retained indefinitely. Governed by Google Analytics data retention settings.

8. Your Rights Under GDPR

As a data subject, you have the following rights:

• Right of access: Request a copy of the data we hold about you.
• Right to rectification: Request correction of inaccurate data.
• Right to erasure: Request deletion of your data.
• Right to restriction: Request that we limit the processing of your data.
• Right to data portability: Receive your data in a structured, machine-readable format.
• Right to object: Object to processing based on legitimate interest.
• Right to withdraw consent: Withdraw your consent for advertising and analytics cookies at any time via the "Cookie Settings" link in the footer.

To exercise your rights, contact us at support@greatgamesnetwork.com. We will respond within 30 days.

For locally stored game data, you can exercise your own rights by clearing your browser data at any time.

You also have the right to lodge a complaint with Datatilsynet, the Danish Data Protection Authority.

9. International Data Transfers

Our website is hosted within the EU/EEA.

Google AdSense may transfer data outside the EEA. These transfers are protected by Standard Contractual Clauses and Google's data processing terms.

Google Analytics may transfer analytics data outside the EEA. These transfers are protected by Standard Contractual Clauses and Google's data processing terms.

10. Data Security

We take appropriate measures to protect your data, including:

• HTTPS encryption for all connections
• Regular security updates and vulnerability monitoring
• Access controls for server infrastructure

The security of locally stored game data depends on the security of your own device.

11. Children's Privacy

The Service is not intended for children under 13 years of age. Children between 13 and 15 require parental consent to use the Service.

We do not knowingly collect personal data from children under 13. We configure advertising to comply with applicable children's privacy regulations.

If we become aware that we have collected data from a child under 13, we will delete it promptly.

Parents or guardians may contact us at support@greatgamesnetwork.com.

12. Data Breach Notification

In the event of a data breach, we will notify Datatilsynet (the Danish Data Protection Authority) within 72 hours of becoming aware of a qualifying breach.

Affected users will be notified without undue delay if the breach poses a high risk to their rights and freedoms.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via a prominent notice on the Service.

Your continued use of the Service after changes are posted constitutes your acceptance of the updated Privacy Policy.

14. Contact Us

GreatGamesNetwork ApS
CVR: DK46157885
Email: support@greatgamesnetwork.com
Website: greatgamesnetwork.com

Danish Data Protection Authority (Datatilsynet): datatilsynet.dk