The whole of it
Relicart gathers nothing, and there is nowhere for it to send anything
No account. No server. No outward connection of any kind. Half-finished boards, and the times you set on the ones you do finish, live in a folder that belongs to the app on the handset in your hand.
Everything further down is that sentence broken into parts you can check. A privacy policy gets long when a company has a lot of collecting to account for; this one is short for the opposite reason.
On your device
What the app writes down, and who can reach it
Inside its private storage Relicart keeps the board you are part way through — which artwork, how many pieces, and where each piece currently sits — so a large puzzle waits exactly as you left it. It also keeps the gallery of pictures you have finished together with your best time on each, the piece count and difficulty you tend to choose, and whether the interface is in English or another language it ships with.
Android reserves that folder to the application that created it, so other software installed on the handset is not shown what is inside. The company cannot see it either: nothing in the build listens for an instruction from outside, because nothing in the build opens a connection in the first place.
There is one movement of files we do not control and will not pretend otherwise. Android operates an automatic backup attached to a Google account; where a person has left it switched on, the system may copy an application's files into that person's own Google Drive so that a replacement handset can restore them. That copying is performed by Android under the account holder's settings. We are not a party to it, cannot read what it carries, and cannot disable it for anyone — the control is per application, inside Android's settings.
Uninstalling takes the folder with it. Clearing the app's data from Android settings empties the folder and leaves the app installed, which is how to wipe a gallery of best times without losing the app itself.
Not in the build
The things that were never compiled in
No advertising framework. No analytics or attribution package, no crash reporting service, no sign-in provider, no billing component. Those are absences from the package rather than switches inside it, which is the stronger promise: nothing waits to be turned off, and no server anywhere has the standing to turn it back on. Item by item, none of the following is ever read, worked out or sent:
- any detail that would let somebody write to you, telephone you or find your door;
- whatever string Android is currently using for advertising, along with the Android ID, the serial on the handset and its hardware addresses;
- where in the world the handset is, by whatever method one might try;
- anything from the address book, the diary, the message history or the call log, and nothing from the microphone or camera;
- how long you took, how often you play, or which artworks you return to;
- photographs or any other file already stored on the device.
Every artwork in the app arrives inside the installer; none is fetched afterwards. That is why the app is complete the moment installation ends, and why it behaves the same way with the device entirely offline.
Who is responsible
The company, and where a letter arrives
LAKE (W.A.) PTY LTD
Director: Nolan Combs
3948 Caves Rd, Wilyabrup WA 6280
Australia
Mail: [email protected]
That address is read by a person. It is the only channel for privacy questions about Relicart, and a question sent to it gets an answer rather than an acknowledgement.
European and British readers will know the term controller; for anything Relicart might process, that role belongs to the company named above. No processor acts on our instructions, no second party shares the decisions, and no representative has been appointed anywhere, since there is no processing for such an arrangement to govern.
Permissions and the store
What the app asks Android for, and what Google handles separately
The manifest is close to empty. Saving a finished picture goes through Android's own document and media pickers, which grant one write to the single destination you choose and no continuing sight of your photo library. Camera, microphone, location, contacts and telephone permissions do not appear, so the prompt asking you to grant them never has occasion to appear either.
Obtaining or updating the app through Google Play is a transaction between you and Google, conducted under Google's terms rather than ours, and none of the account or device data involved passes through this company. What the developer console gives us is already aggregated — installs counted by country, crash rates, star ratings — and there is no way back from any of it to a person.
Children
Suitable, and nothing is taken from a child either
A jigsaw is about as safe a thing as software gets. Relicart has no advertising, no chat, no links out, no contact between users and no screen that asks for money, and since the collecting is nil for everybody it is nil for a child. There is therefore nothing for a parent to ask us to delete, though a parent is welcome to write and have that confirmed in plain words.
The law
Australian rules first, and the others where they reach
Being an Australian company puts us under the Privacy Act 1988 (Cth) to begin with, and under the thirteen Australian Privacy Principles that Schedule 1 of that Act sets out.
Said plainly, because it is the sort of thing a reader deserves to hear from the company rather than discover later: the Act exempts most small business operators, broadly those turning over three million Australian dollars or less a year without doing anything that removes the exemption, such as trading in personal information. A company of this size very probably sits inside that exemption and is therefore not obliged to follow the Principles at all.
We follow them anyway. That is a decision rather than a legal duty we are claiming to be under, and it costs us nothing to keep, since the Principles mostly govern information we do not hold. APP 1 is this page. APP 3 and APP 5 are answered by not collecting. APP 6 and APP 8 have no subject matter. APP 11 is served by the operating system's own separation of app storage.
Part IIIC of the Act sets up the Notifiable Data Breaches scheme, under which an entity must tell both the people affected and the Commissioner when a breach looks likely to do serious harm. A store that does not exist is difficult to breach; if a future version of Relicart ever holds personal information and that information is compromised, the people affected and the Commissioner will be told, and told plainly what went wrong.
The app is listed worldwide, so it is installed in Europe and in Britain as well, and the General Data Protection Regulation and the UK GDPR reach us there through their extraterritorial scope.
| Where you are | What applies | Who hears a complaint |
|---|---|---|
| Australia | The Privacy Act and its thirteen Principles, plus Part IIIC on breach notification | The Australian Information Commissioner — oaic.gov.au |
| European Union | The Regulation of 2016, principally Articles 15 to 21, with Article 77 behind them | The data protection authority of the country you live in |
| United Kingdom | UK GDPR together with the Data Protection Act 2018 | Information Commissioner's Office — ico.org.uk |
Relicart ships in more than one language, and a question written in any of them will be answered. If plain English is easier, ask for it and you will get it; if another language would help, say which and a translation will be arranged rather than the question being turned away.
What you can ask
Your rights, and the answer they will meet
Access to whatever personal information an entity holds about you is APP 12's business, and having it corrected is APP 13's. The European and British rules add erasure, restriction, portability and objection, along with the right to complain to a supervisory authority.
Write to [email protected] and the reply will come inside thirty days, which is the Australian expectation and well within the month the European rules allow. It will be brief, because nothing is filed under your name to show you, correct, delete, suspend or forward anywhere. No proof of identity will be asked for first: there is no record for such a check to protect, and requesting a scan of a passport in order to report an empty drawer would be the only moment in the exchange at which anybody's data was genuinely at risk.
An answer you are not satisfied with is worth one more letter, which will be read properly rather than filed. Beyond that, complaints in Australia go to the Information Commissioner through oaic.gov.au, which ordinarily expects the organisation to have been approached first; readers elsewhere will find their venue in the table above.
Changes
This page is rewritten before the release, never after it
If a later build of Relicart takes on anything that touches personal information — a gallery that syncs between devices, a crash reporter, artwork packs offered for sale, advertising in any form — then this text is redrawn and goes up before the build does, not after. The date and issue line under the title moves at the same time, and a plain summary goes into the Play release notes so the change is visible from the store without anyone coming here.
The address stays put for as long as the app is listed. That issue line is the quickest way to see whether the wording has moved since you last read it.