1. Who is responsible
DOROBANTI NETWORK S.R.L. (Dorobanți Media), tax identifier CUI 51010254, is the controller of data it receives for the website, support and commercial administration of Bluff Artist.
Registered office: Aleea Tomești nr. 9, bl. 15, sc. 2, et. 7, ap. 63, Sector 4, București, 042144, Romania.
For support and data requests: support@dorobantimedia.com. Telephone: +40 730 000 064.
2. The offline app
Player names, the selected word, roles and rounds stay in device memory. They are not sent to the publisher, saved to files or logged. You can use nicknames. The app has no accounts, ads or usage analytics.
Fully closing the app removes the session. Backgrounding the app or hiding a card does not delete the round. Replay retains players and options; the last word is kept in the same session to avoid repetition when alternatives exist. During setup, you can remove a player and add them under another name. The app locally saves the appearance (System by default, Light or Dark) and language (System, Romanian or English) preferences, timer duration and, if you create them, custom category titles and lists.
Custom categories are stored only on the device where you create them, in system-protected files excluded from app backups. There is no contacts import, account, cloud sync or list publishing. The app does not send these titles or lists to the publisher. You can view, edit and delete them in ‘My categories’, including after Bluff Artist + expires. Deletion removes the list from the app’s library.
There is no account to delete or copy of a round held by the publisher. The app does not offer cloud sync or round backups. Device backups and system diagnostics are managed separately by Apple according to your settings.
Card protection does not prevent screen photography or the device reading aloud. In-app links open the website only at your request. Apple services have their own privacy policy.
3. Purchases and Apple records
Bluff Artist + uses StoreKit for products, prices, offer eligibility, purchasing, restoration and subscription management. Verified transaction evidence, such as product and transaction identifiers and purchase, expiry or revocation dates, is used in app memory to decide access. The game creates no subscription database of its own. Apple manages payment and the Apple Account; the app does not receive full card details.
Apple may make sales, subscription and refund reports available to the publisher. We access or export only information needed for accounting, revenue/refund reconciliation or a billing request. We prefer aggregate information and do not use subscriber identifiers for marketing or profiling. Evidence voluntarily sent for support follows the support period; a document included in mandatory accounting records follows the statutory period below.
Apple separately processes data for its own services under its privacy policy.
4. Website and browser choices
These pages are hosted on the Dorobanți Media website, separately from the app. A visit sends the server your IP address, requested page, headers and browser technical information for delivering and protecting the website. A link opened from the app includes no game-session data.
Necessary website preferences and optional measurement are explained in the website privacy policy and cookie policy. Optional measurement is enabled only according to your consent choice; a website choice does not introduce analytics into the game.
Support correspondence for this app follows this policy’s 90 days after resolution. The separate website period of 30 days after last contact for general business enquiries does not replace the app-support period.
5. When you contact us
We use your email address, supplied name, message and necessary attachments to respond. Contact is voluntary, but we need a way to reply and the details needed for the issue. Do not send player names, private answers, personal lists or full payment-card details. We do not ask for your Apple Account password. For a billing issue we may ask for a relevant transaction reference.
The app operator personally handles support and data requests. Only that person accesses the support mailbox and the devices receiving messages. Messages are not forwarded; support mail and downloaded support files are excluded from local and device backups. Details are used to resolve the request, without marketing, tracking or profiling.
If you call us, we may use your number, call details and necessary notes to respond. We do not record calls. Telecommunications providers and your device separately manage their own technical records.
6. Purposes and lawful bases
- Providing Plus access and handling billing or support requests necessary to perform our contract with you: GDPR Article 6(1)(b). This basis covers only data objectively necessary for that contract or steps you request before entering it.
- General correspondence not necessary to perform a contract, and delivering or protecting the website: legitimate interests in answering enquiries and maintaining a working, secure website, Article 6(1)(f).
- Rights requests and mandatory accounting records: compliance with applicable legal obligations, Article 6(1)(c).
- Limited records of a specific complaint or dispute: legitimate interests in establishing, exercising or defending a claim, Article 6(1)(f), or an applicable legal obligation.
- Optional website measurement: consent, Article 6(1)(a), under the cookie policy. It can be withdrawn through the website choices.
In-app StoreKit verification does not automatically send transaction evidence to the publisher. Correspondence you send and Apple reports accessed separately are handled according to their purpose and category, as described above.
You do not need to send us game data to play. We do not use correspondence for solely automated decisions with legal or similarly significant effects or make your rights conditional on marketing consent.
7. Providers, recipients and transfers
Vercel hosts the website. Its processing agreement governs customer data processed on our instructions; Vercel separately controls contact and service-generated data for its own service. Apple iCloud Mail handles messages to our addresses under the iCloud terms and Apple privacy policy. Purchases are handled separately through Apple services. Using iCloud Mail does not mean that all Apple processing is performed as our processor.
Vercel describes primary infrastructure in the United States and subprocessors in several countries; its agreement includes Standard Contractual Clauses for relevant EEA transfers. Apple identifies Apple Distribution International Limited in Ireland for EEA individuals’ data in its policy and describes international processing, including US storage and Standard Contractual Clauses. These services do not imply EEA-only storage.
We may disclose only necessary data to professional advisers or authorities for a legal obligation or a specific claim. We do not sell personal data or send gameplay data to these providers. Contact us for information about recipients and safeguards relevant to a request.
Vercel processing agreement · Vercel subprocessors · iCloud terms · Apple privacy policy
8. How long data is kept
- Game-session data: in app memory, with no saved history for a new launch. Local preferences remain until changed or the app’s data is removed.
- Categories or themes you create remain in the local library until you delete them or remove the app’s data; files are system-protected and excluded from app backups.
- Routine support: messages, attachments and necessary notes are deleted 90 days after resolution, including Trash and downloaded or exported files we control.
- Rights requests: we keep the request, response and minimal explanation of the outcome for 90 days after closure. Additional identity-document copies are deleted immediately after verification unless a distinct legal obligation requires them. An active complaint follows the legal-hold rule below.
- Private test reports and evidence: personal data needed for an issue is deleted 90 days after resolution; for an acceptance check without an open issue, the period starts on the check date. We remove personal details unnecessary for diagnosis.
- Accounting records: where a document is a mandatory accounting record or supports an accounting entry, Article 25 of Law 82/1991 requires 5 years, calculated from 1 July of the year following the end of the financial year in which the document was drawn up. Annual, consolidated annual and interim financial statements have a separate 10-year period under Article 35(3). These periods do not automatically apply to every Apple report or support message.
- A specific legal hold: we isolate only relevant records until final resolution and expiry of the applicable legal appeal or enforcement periods. We review necessity every 90 days and delete within 30 days after the hold ends unless a separate statutory period still applies.
Vercel documents 30 days for Observability Plus data and runtime logs, with at most 14 consecutive days selected per query. This does not set the lifetime of every build log, account record, export or recovery copy. Our support period is not a promise of immediate deletion from every provider copy. Apple describes a default 30 days in Trash with manual emptying available; this concerns user recovery of messages.
Romanian Accounting Law · Observability Plus · iCloud Mail deletion
9. Private testing and data minimisation
For future operations we do not download or separately archive TestFlight feedback or crash reports or begin public-user measurement through App Analytics or developer diagnostic feeds. Apple manages data in its own services. An issue voluntarily sent directly to support follows the support rules above.
Within 30 days after this policy takes effect, we inventory existing retained private test material and delete personal data past its applicable period or unnecessary for the issue. We keep only the technical result and device class/OS version where sufficient. A legal exception is documented separately; a new policy version does not establish that old copies have already been deleted.
10. Your rights
Subject to GDPR conditions, you may request access, correction, deletion, restriction and, where applicable, portability. You may object to processing based on legitimate interests. You may withdraw consent for consent-based processing without affecting earlier lawful processing. Rights depend on the purpose and basis; a legal obligation or defence of a claim may limit deletion of particular records.
Write to support@dorobantimedia.com. We request only proportionate identity verification where needed; do not send identity documents unsolicited. We respond within one month of receipt. If a lawful extension of up to two further months is necessary, we explain the reason within the first month. Requests are normally free; lawful exceptions for manifestly unfounded or excessive requests are explained individually.
You may complain to ANSPDCP or the competent authority where you live or work and use available judicial remedies.
11. Changes
If purposes, recipients or relevant processing change, we update this information and inform you before the change applies, as required by law. The applicable date and version accompany the policy. Legal rights apply regardless of an update to this document.