Privacy Policy — Cruciverba

# Privacy Policy — Cruciverba 

_Last updated: 8/9/2026_

This Privacy Policy describes how **Giovanni Emanuele Spina** ("we", "Data Controller") processes personal data collected through the application **Cruciverba ** (`app.cruciverbait.app`), distributed on **Android** and classified as **AI / Assistant**.

## 1. Data Controller
- **Developer / Company:** Giovanni Emanuele Spina
- **Contact email:** creo.app.app@gmail.com
- **Website:** https://appcodeengine.com/

## 2. Access to content
The app does not require registration and does not provide user account creation. All content is accessible to every user without authentication.

## 3. Content loaded via WebView
The app loads web content via WebView from **https://cruci-italia-daily.lovable.app/**. Any data processed during browsing is handled directly by the website and is subject to its own Privacy Policy. The app does not modify or intercept data transmitted between the user and the site.

## 12. Sharing data with third parties
We do not share data with third parties.

## 13. No sale of personal data
We do not sell users' personal data. Any data processed is used exclusively for the purposes described in this Privacy Policy.

## 14. Children
This application is intended for a general audience and is not directed to children under 13. We do not knowingly collect data from minors without parental consent.

## 15. Legal basis and GDPR rights
Data processing takes place to provide the service, ensure the security of the application, comply with legal obligations and, where required, with the user's consent. In accordance with the **GDPR Regulation (EU 2016/679)**, the user has the right to access, rectify, erase, restrict, object to and port their personal data. You can exercise your rights by writing to: creo.app.app@gmail.com.

## 16. Data retention
Data collected by third-party providers (e.g., Google AdMob, Firebase, RevenueCat, payment stores) is retained according to their respective privacy policies and retention periods. Data managed directly by the app is retained only for as long as necessary for the purposes for which it was collected.

## 17. Security
We adopt appropriate technical and organizational measures to protect personal data against unauthorized access, loss or disclosure, including encrypted connections (HTTPS/TLS) and secure storage of any credentials used.

## 18. Changes to this Privacy Policy
We may update this Privacy Policy in case of changes to the app's features, applicable regulations or service providers used. The date shown at the top of the document represents the latest revision.

## 19. Contacts
For any privacy-related requests, please write to **creo.app.app@gmail.com**.