comitis

Legal

Privacy policy

Last updated: October 2026

This privacy policy applies to the website www.comitis.de and to all Comitis apps. Part A covers the website, Part B the individual apps, Part C your rights. Each app has its own section; we add new apps there.

1. Controller

The controller within the meaning of the General Data Protection Regulation (GDPR) is:

Comitis, Daniel Baier (sole proprietorship)
Reitbergstr. 12, 94124 Büchlberg, Germany
Email: support@comitis.de

We have not appointed a data protection officer as we are not legally required to do so. For privacy questions, please use the email address above.

2. Summary

Part A – Website www.comitis.de

3. Hosting and server log files

The website is hosted by IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany. We have concluded a data processing agreement with the provider under Art. 28 GDPR.

Each time a page is requested, the server automatically processes: IP address (stored by IONOS in anonymised form only), date and time of access, requested page or file, amount of data transferred, status code, referrer URL, browser type and operating system. This data is technically necessary to deliver the website and to keep it secure and stable (e.g. to fend off attacks).

The legal basis is Art. 6(1)(f) GDPR; our legitimate interest is the secure and error-free operation of the website. IONOS keeps log files for a maximum of eight weeks; they are then deleted unless they are needed longer to investigate a specific security incident.

4. No cookies, no tracking, no external content

The website sets no cookies and stores no information on your device. We use no analytics, tracking or advertising services and embed no third-party content (such as Google Fonts, videos or maps). A cookie banner is therefore not required.

5. Contact by email

If you email us, for example for app support, we process your email address, your name (if provided) and the content of your message, including any details you choose to send such as your device model or copied game statistics, in order to handle your request.

The legal basis is Art. 6(1)(b) GDPR where your request concerns a contract (e.g. an in-app purchase), otherwise Art. 6(1)(f) GDPR (legitimate interest in answering enquiries). We delete messages once your request has been resolved, at the latest after two years, unless statutory retention obligations apply. Our mailbox is also operated by IONOS SE (address see section 3) as a processor.

Part B – Apps

The following sections each apply to the app named. Data generated when you download an app from Apple’s App Store or Google Play (such as your store account and the download time) is processed by Apple or Google under their own responsibility; their privacy policies apply: Apple, Google.

6. Driftlet

Driftlet is a skill game for Android and iOS. The app works without a user account and without a server of our own. As the provider, we receive no personal data from the app unless you write to us yourself (see section 5).

6.1 Data stored on your device

So you can continue where you left off, the app stores the following on your device only:

This data does not leave your device and is not sent to us. The legal basis is Art. 6(1)(b) GDPR (providing the game); storing it on your device is strictly necessary for the service you requested (Section 25(2) no. 2 TDDDG). You can delete it at any time in the app under Settings → “Reset progress”; uninstalling the app removes it completely. Depending on your device settings, app data may be included in your personal device backup with Apple (iCloud) or Google; we have no access to it.

6.2 “Copy statistics”

Settings → “Copy statistics” places your game statistics (version, levels completed, failed attempts per level) on your device’s clipboard. Nothing is sent automatically. We only receive the statistics if you paste them into a message to us yourself (see section 5).

6.3 In-app purchases

In Driftlet you can make a one-time purchase “Go ad-free – support the developer”. Purchase and payment are handled exclusively by Apple (Apple Distribution International Ltd., Hollyhill Industrial Estate, Hollyhill, Cork, Ireland) or Google (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) via your store account. We receive neither your name nor your payment details. The app only receives a confirmation from the store about the item purchased (product ID, purchase time, transaction ID) in order to unlock it. “Restore purchases” asks the store for your previous purchases.

The legal basis is Art. 6(1)(b) GDPR (performance of a contract). Apple and Google also provide us with aggregated sales and payout reports, which we keep to meet our tax and commercial retention obligations (Art. 6(1)(c) GDPR).

6.4 Ads (Google AdMob)

Driftlet shows ads in two cases: (1) after every fifth level in which you failed, a short ad break at the end of the level – not if you have bought “ad-free”; (2) a video ad if you choose to skip a level. They are served by Google AdMob, a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).

Consent: On first launch, the app uses Google’s consent solution (User Messaging Platform) to ask whether Google may store or access information on your device and show you personalised ads. On iPhone and iPad, iOS additionally asks whether the app may track your activity across other companies’ apps (App Tracking Transparency). You can change or withdraw your choice at any time in the app under Settings → “Privacy settings” or in the iOS settings.

Data processed: the device’s advertising ID (on iOS only with your permission), IP address (used to derive an approximate country or city-level location), device type, operating system and version, language setting, app ID and version, and information about the ads shown and your interaction with them.

Purposes and legal bases:

Google processes this data under its own responsibility to deliver and measure ads and to improve its services. See “How Google uses information from sites or apps that use our services” and Google’s privacy policy. Data may be transferred to Google LLC in the USA. Google LLC is certified under the EU-US Data Privacy Framework, so an adequacy decision of the European Commission applies (Art. 45 GDPR). Google has additionally concluded EU standard contractual clauses.

You can also object to the use of your advertising ID or reset it in your system settings: on Android under Settings → Privacy → Ads, on iOS under Settings → Privacy & Security → Tracking.

6.5 Crash reports and usage statistics from the stores

If you have agreed in your device settings to share analytics with app developers, Apple or Google provide us with aggregated crash reports and usage statistics (e.g. number of installs, device and OS versions). We cannot link this data to any individual. We use it to fix bugs (Art. 6(1)(f) GDPR). The app itself contains no analytics or crash reporting tool of its own.

6.6 Vibration and permissions

The app only uses the permissions it needs for its features: vibration (feedback when you hit a rock), internet access (ads and in-app purchases), access to the advertising ID (for ads only, see 6.4) and the store’s billing service. The app does not access your camera, microphone, contacts, location (GPS) or files.

6.7 Children

Driftlet is suitable for all ages but is not specifically directed at children. For children under 16, consent to personalised ads can only be given by a parent or guardian (Art. 8 GDPR). We do not knowingly collect personal data from children.

Part C – Your rights

7. Recipients and retention at a glance

Personal data is only shared with the service providers named above (hosting, email) and with Apple and Google in the cases described. We do not pass data to any other third parties, sell data or make automated decisions within the meaning of Art. 22 GDPR. We keep data only as long as necessary for the respective purpose or as required by statutory retention obligations.

8. Your rights

You have the right at any time to

As we receive no data about you from our apps, we cannot provide information on data that exists only on your device or with Apple or Google. You can delete that data in the app itself; for data held by Apple or Google, please contact them.

9. Right to object

Where we process data on the basis of Art. 6(1)(f) GDPR, you have the right to object at any time on grounds relating to your particular situation (Art. 21 GDPR). We will then stop processing the data unless we can demonstrate compelling legitimate grounds that override your interests, or the processing serves the establishment, exercise or defence of legal claims.

10. Right to lodge a complaint

You have the right to lodge a complaint with a data protection supervisory authority, in particular in the member state of your habitual residence, place of work or place of the alleged infringement (Art. 77 GDPR).

11. Obligation to provide data

You are under no legal or contractual obligation to provide us with personal data. Without the technically necessary connection data, however, the website and the online features of the apps (ads, purchases) cannot be used.

12. Changes

We update this privacy policy when our offerings or the law change, and add new apps here. The version published here applies.

This is a translation for convenience. In case of discrepancies, the German version prevails.