Privacy Policy

1. Introduction and contact details of the controller

1.1 We are pleased that you are visiting our website and thank you for your interest. Below we inform you about how we handle your personal data when you use our website. Personal data here means all data with which you can be personally identified.

1.2 The controller responsible for data processing on this website within the meaning of the General Data Protection Regulation (GDPR) is:

The controller responsible for the processing of personal data is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data.

2. Compono app (iPad & iPhone)

This section applies specifically to the app Compono, distributed via Apple's App Store / TestFlight.

2.1 What data does Compono collect?

Compono does not collect, store or transmit any personal data whatsoever. There is:

• no user account, no login, no registration
• no analytics, no tracking, no advertising
• no crash or diagnostic reports sent to us
• no transmission to Gnoseo servers

In Apple's App Store privacy label, this corresponds to the category “Data Not Collected”.

2.2 Access to the photo library

If you would like to use one of your own photos as a puzzle in Compono, iOS will ask you for access to the photo library. This access:

• is optional — the app works without it
• can be revoked at any time in the iOS settings
• takes place exclusively locally on your device
• does not transmit any image data to Gnoseo or third parties

2.3 Game Center (optional)

Compono uses Apple's Game Center for leaderboards. If you are signed in to Game Center, scores are transmitted to Apple — exclusively to Apple, not to us. Data processing by Apple is governed by Apple's privacy policy. Game Center can be disabled in the iOS settings.

2.4 Local storage on the device

Compono stores data exclusively on your device and never elsewhere:

• game progress and personal best times
• settings (sound, difficulty, switch control etc.)
• chosen favourite images from the gallery

This data never leaves your iPad/iPhone. When the app is uninstalled, it is automatically deleted.

2.5 Children & families

Compono is also intended for children and is fully compliant with the Children's Online Privacy Protection Act (COPPA) as well as Apple's Kids Category guidelines: since Compono collects no personal data, no protection of children's data is required — it is simply never recorded. There is no advertising, no external links, no in-app purchases.

2.6 Third parties in the app

Compono uses exclusively Apple's own frameworks (SwiftUI, GameKit, PhotosUI, AudioToolbox). No third-party SDKs, no external analytics tools, no Firebase, no Crashlytics and no advertising network are integrated.

3. Data collection when visiting our website

3.1 When using our website for information purposes only, i.e. if you do not register or otherwise transmit information to us, we only collect the data that your browser transmits to the site server (so-called “server log files”). When you access our website, we collect the following data, which is technically necessary for us to display the website to you:

• the website visited on our site
• date and time of access
• amount of data sent in bytes
• source/reference from which you reached the page
• browser used
• operating system used
• IP address used (where applicable, in anonymised form)

The processing is carried out in accordance with Art. 6 (1) (f) GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. The data is not passed on or used in any other way. However, we reserve the right to subsequently check the server log files if there are concrete indications of unlawful use.

3.2 For security reasons and to protect the transmission of personal data and other confidential content (e.g. enquiries to the controller), this website uses SSL or TLS encryption. You can recognise an encrypted connection by the character string “https://” and the lock symbol in your browser bar.

4. Hosting

For the hosting of our website we use STRATO AG (Pascalstraße 10, 10587 Berlin, Germany), which provides its services exclusively on servers within the Federal Republic of Germany.

All data collected on our website is processed on these servers. We have concluded a data processing agreement pursuant to Art. 28 GDPR with STRATO, which ensures the protection of our site visitors' data and prohibits unauthorised disclosure to third parties.

More information on data processing at STRATO: https://www.strato.de/datenschutz/

5. Cookies & browser storage

This website sets no cookies. It only uses local browser storage (localStorage) to remember your preference for light or dark mode. This information remains exclusively on your device and is not transmitted to us or third parties. No processing of personal data takes place here.

This website also does not load any fonts, images or scripts from external servers. All content is delivered directly from the hosting server.

6. Contacting us

When you contact us (e.g. by email), personal data is collected. This data is stored and used exclusively for the purpose of answering your enquiry or for contacting you and the associated technical administration.

The legal basis for processing this data is our legitimate interest in answering your enquiry pursuant to Art. 6 (1) (f) GDPR. If your contact is aimed at concluding a contract, the additional legal basis for processing is Art. 6 (1) (b) GDPR. Your data will be deleted after your enquiry has been conclusively processed; this is the case if it can be inferred from the circumstances that the matter in question has been conclusively clarified and provided that there are no statutory retention obligations to the contrary.

6.1 Email hosting (Microsoft 365)

Our email address info@gnoseo.de is operated via Microsoft 365, a service of Microsoft Ireland Operations Limited (One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland). Incoming and outgoing messages and attachments are processed and stored on Microsoft servers.

Microsoft processes data of European customers primarily within the EU under the EU Data Boundary. In individual cases, data may be transferred to Microsoft Corporation (USA); for this purpose, the EU Standard Contractual Clauses and certification under the EU-U.S. Data Privacy Framework are in place. A data processing agreement pursuant to Art. 28 GDPR exists with Microsoft.

Microsoft's privacy statement: https://privacy.microsoft.com/en-us/privacystatement

7. Rights of the data subject

7.1 Applicable data protection law grants you the following data subject rights (rights to information and intervention) vis-à-vis the controller with regard to the processing of your personal data, whereby reference is made to the legal basis cited for the respective exercise conditions:

• right of access pursuant to Art. 15 GDPR
• right to rectification pursuant to Art. 16 GDPR
• right to erasure pursuant to Art. 17 GDPR
• right to restriction of processing pursuant to Art. 18 GDPR
• right to notification pursuant to Art. 19 GDPR
• right to data portability pursuant to Art. 20 GDPR
• right to withdraw consent given pursuant to Art. 7 (3) GDPR
• right to lodge a complaint pursuant to Art. 77 GDPR with a supervisory authority — for us the responsible authority is the Bavarian State Office for Data Protection Supervision (BayLDA), Promenade 18, 91522 Ansbach, Germany

To exercise your rights, simply write to us at info@gnoseo.de.

7.2 RIGHT TO OBJECT

IF WE PROCESS YOUR PERSONAL DATA AS PART OF A BALANCING OF INTERESTS ON THE BASIS OF OUR OVERRIDING LEGITIMATE INTEREST, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THIS PROCESSING WITH EFFECT FOR THE FUTURE ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION.

IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL CEASE PROCESSING THE DATA CONCERNED. HOWEVER, FURTHER PROCESSING REMAINS RESERVED IF WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING THAT OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR IF THE PROCESSING SERVES TO ASSERT, EXERCISE OR DEFEND LEGAL CLAIMS.

IF YOUR PERSONAL DATA IS PROCESSED BY US FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH MARKETING. YOU CAN EXERCISE THE OBJECTION AS DESCRIBED ABOVE.

IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL CEASE PROCESSING THE DATA CONCERNED FOR DIRECT MARKETING PURPOSES.

8. Duration of storage of personal data

The duration of storage of personal data is determined on the basis of the respective legal basis, the purpose of processing and — where relevant — additionally on the basis of the respective statutory retention period (e.g. commercial and tax retention periods).

When processing personal data on the basis of express consent pursuant to Art. 6 (1) (a) GDPR, the data concerned is stored until you withdraw your consent.

If statutory retention periods exist for data processed within the framework of legal or quasi-legal obligations on the basis of Art. 6 (1) (b) GDPR, this data is routinely deleted after the retention periods have expired, provided it is no longer required for the fulfilment of the contract or the initiation of the contract and/or there is no longer a legitimate interest on our part in continued storage.

When processing personal data on the basis of Art. 6 (1) (f) GDPR, this data is stored until you exercise your right to object pursuant to Art. 21 (1) GDPR, unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

Unless otherwise stated in the other information in this declaration on specific processing situations, stored personal data is otherwise deleted when it is no longer necessary for the purposes for which it was collected or otherwise processed.

Last updated: 12 May 2026 · Version 2.0 · Template: IT-Recht Kanzlei (Munich), individually adapted for Gnoseo