Privacy · Cuddles Playground

Last updated: 14 October 2026

Controller and contact

The controller for the game is Projekt VielSeitig – Sieger GbR, Grund 3, 42653 Solingen, Germany, represented by Michael Sieger and Carola Sieger. Engamo Studio is the app brand of Sieger GbR.

Privacy enquiries: mail@projekt-vielseitig.de
Support: support@engamo.studio
Telephone: +49 (0)212 2531309-3

A short explanation – also for parents

Cuddles does not require its own user account. Game progress and settings are stored on your device. The game contains no advertising networks, gameplay tracking set up by us, or analytics or automatic error-reporting feature of its own. However, the Android store library processes technical diagnostics as described below. Graphics, music and sound effects are included with the app.

The optional full version is handled through the App Store or Google Play. Even without a purchase, the app may query the relevant store for product information and existing purchase entitlements when it starts. Local storage of game progress therefore does not mean that the app never uses an internet connection.

Game progress and settings on your device

Stored data includes Cuddles with their names and game attributes, dewdrops, unlocked items, game progress, coloured pictures, music and sound-effect volume, and the last confirmed full-version unlock status. The game does not send this progress to a game server of our own and does not provide its own cloud synchronisation.

This storage allows you to continue playing and retain your settings. Where personal data is processed, the legal basis for the requested game features is Article 6(1)(b) GDPR.

“Reset game” in the protected parent area resets game progress. It neither removes the purchase from the store nor automatically deletes the separately stored audio settings or unlock status. App data can be removed using the operating system’s features. Device or cloud backups may contain copies; their management depends on the device’s settings and services. We cannot remotely access game progress stored exclusively on your device.

Full version, restoring purchases and redemption codes

Purchases and restoration are handled through Apple or Google. To verify the unlock, the app processes product information, the localised price, purchase status and technical transaction data supplied by the store. For example, Google Play uses a purchase token for acknowledgement. The local unlock cache contains the unlock status, not your payment details.

The game does not ask for credit card or bank details. Redemption codes are checked through the official interfaces of the relevant store, not through a licensing server of our own. The legal basis for the necessary purchase processing and delivery is Article 6(1)(b) GDPR.

The store providers also process data as independent controllers, for example for account management, payment and fraud prevention. Information about recipients, retention and international processing is available from Apple and Google. Resetting or removing the app does not delete the purchase history held by those providers.

Android: technical diagnostics from the Google Play library

The Android version uses the Google Play Billing Library for full-version purchases and purchase restoration. This library transmits technical diagnostics to Google, particularly information about successful or failed library calls and connection problems. These may include device manufacturer and model, Android and app version, operating-system build, RAM size, language, region setting, time zone, network type and mobile network operator code (MCC/MNC). The region setting is not a GPS location; the operator code is not a telephone number or SIM serial number.

The library also generates a random identifier for each of its client instances. This can link multiple diagnostic events from that instance; it should not be equated with an advertising ID or permanent hardware identifier. Diagnostics may be queued for later transmission. The store connection is initialised when the app starts, even without a purchase or opening the parent area. The app does not provide its own switch to disable these SDK diagnostics.

Google describes the purpose as improving the Billing Library’s performance and providing support for errors. We do not operate our own analytics server for this purpose or receive this SDK diagnostic stream as our own event database. This processing is separate from locally stored game progress and from the optional purchase. It is not advertising or gameplay tracking set up by us.

Google processes this data as an independent controller for its own diagnostic purposes. Google’s privacy information explains the responsible Google entities, legal bases, international processing and safeguards, retention and individual rights. We do not promise a fixed deletion period for this SDK diagnostic stream. Data is encrypted in transit to Google’s services; this does not mean end-to-end encryption that prevents Google from reading it. Further information: Google Privacy Policy, Google retention practices and Billing logging documentation.

Apple reports for regular App Store distribution

Apple provides statistical reports through App Store Connect, for example on store product-page views, downloads and purchases. Some reports are only displayed once sufficient data is available. Usage and diagnostic data are subject to the relevant sharing and privacy settings at Apple. These Apple-provided reports are distinct from locally stored game progress and from an analytics feature within the game. Cuddles does not include an additional analytics SDK for these store reports.

Information about Apple’s processing is available in its App Store privacy information; details of the reports are available at Apple App Analytics.

Contacting support

If you contact us, we process your sender address, message and any information or files you voluntarily attach to handle your enquiry. Please do not send children’s names or photos, passwords or full payment details. For technical questions, your device, operating system, app version and a description of the problem will usually be sufficient.

Contract-related enquiries are handled under Article 6(1)(b) GDPR. Other enquiries are handled on the basis of our legitimate interest in responding to them under Article 6(1)(f) GDPR. Legally required retention is based on Article 6(1)(c) GDPR.

Hosting, technical support and backups

Our email and support systems, including our internally developed WaWi ticket system, run on a server provided by Hetzner Online GmbH in Falkenstein, Germany. SiMa Design – Michael Sieger provides technical administration. Data processing agreements are in place with SiMa Design and between SiMa Design and Hetzner. These providers process data within the scope of their contracted services.

Backups allow recovery after data loss or service disruption. We use a Hetzner Storage Box in Germany for this purpose; the backup schedule provides for retention of one week. Older backups also remain on Google Drive. Google Drive may involve processing outside the EU or EEA; information about Google’s processing is available in its privacy policy. Backup copies must be distinguished from deletion in the live systems.

Retention of support enquiries

Support enquiries are handled by email and in our internally developed WaWi ticket system. The following retention rules apply to both systems:

• Routine support: Resolved enquiries are deleted or reliably anonymised twelve months after closure, unless one of the exceptions below applies. This is our own retention policy, not a statutory minimum period.
• Business records subject to retention requirements: Records are archived for the applicable statutory period. Where the legal conditions apply, commercial or business correspondence is generally retained for six years and accounting vouchers for eight years, calculated from the end of the relevant calendar year. This classification does not automatically apply to the entire ticket, but only to records subject to the relevant retention requirement.
• Specific disputes: Deletion of necessary evidence is suspended for as long as it is needed to establish, exercise or defend legal claims. We regularly review whether retention remains necessary. The regular three-year limitation period is not a blanket obligation to retain all tickets; its start, exceptions and possible extensions must be considered case by case.

Children and the parent area

The game does not require registration or information about a child’s age. The arithmetic question protecting certain features is evaluated within the app. It is not identity or age verification. Purchases, purchase restoration, code redemption and resetting the game are intended for parents.

Requesting deletion of data

For Cuddles privacy and deletion requests, email mail@projekt-vielseitig.de with the subject “Cuddles – privacy/deletion”. Describe your request, but do not send payment details, purchase tokens or children’s data. We handle requests concerning data for which we are responsible and explain any necessary statutory retention.

Cuddles does not provide its own user account. Local game data can be removed using your operating system’s app-data controls; we cannot access it remotely. Google processes purchase and SDK diagnostic data as an independent controller. We cannot delete that data ourselves. Google’s privacy controls and request channels and its retention rules apply to that data; we can help you identify the appropriate recipient for your request. Removing or resetting the app does not delete Google’s purchase history or demonstrably erase diagnostics already sent to Google. Transaction records in particular may be subject to statutory retention requirements.

Your rights

Subject to the legal conditions, you may request access, rectification, erasure, restriction of processing and data portability. You may object to processing based on legitimate interests on grounds relating to your particular situation. Any consent you have given may be withdrawn with effect for the future. We can help with questions about deleting local data, but cannot access it remotely.

You may lodge a complaint with a data protection supervisory authority, in particular the State Commissioner for Data Protection and Freedom of Information of North Rhine-Westphalia. The game does not make automated decisions about individuals that produce legal or similarly significant effects.

Website logs

When you visit engamo.studio, the web server processes technical access data, in particular the IP address, time, requested address, HTTP status, amount of data transferred and, where available, referring page and browser or device information. This serves secure website delivery, troubleshooting and prevention of abuse. The legal basis is our legitimate interest in secure and reliable operation under Article 6(1)(f) GDPR.

Website logs are rotated daily; Plesk retains seven log files for each log. This is rotation-based retention, not deletion exactly seven days after each event. For specific security incidents, necessary evidence may be retained longer for that purpose, as long as needed for investigation or legal action. This rotation rule applies to website logs, not to all technical system and mail logs on the server.

Website and changes

This notice concerns the app, not all other Engamo products. When visiting this website, please also refer to the separate website privacy notice. Help is available from support.

We update this notice when our data processing changes. If new services are introduced, the privacy notice will be updated accordingly.