Privacy Policy
Version 1.2 · in effect from 1 November 2026
This is a translation of the Italian version. If the two versions differ, the Italian version prevails, except for the consumer protection rules of the country where you live.
This policy explains what personal data Voltvale (the Android app and the website voltvale.app) processes, why, who it shares it with, how long it keeps it and what rights you have. It is provided under Articles 13 and 14 of Regulation (EU) 2016/679 (“GDPR”) and the Italian Personal Data Protection Code (Legislative Decree 196/2003).
1. In brief
- You can play as a guest: that is an account with no email or name, with a random identifier.
- With an account, even as a guest, we save your pseudonym, your first-launch answers and your progress in our database, so that you don’t lose them and can sync them between phones.
- We don’t ask for your real name, location or contacts, and we don’t read the phone’s advertising ID. We don’t sell your data.
- We use our own statistics to understand how the app is used: which screens you look at, for how long, which lessons you do, on which phone. They are linked to your account, we don’t send them to Google or anyone else, and you can turn them off in the settings.
- You can delete your account at any time from the app or from the Delete account page.
2. Who the controller is and how to contact them
The data controller is Emanuele Antonio Mannara, a natural person, the app's developer, with address at Via Giuseppe della Corte 24B, 84013 Cava de' Tirreni (SA), Italy.
For any question or request about privacy, write to privacy@voltvale.app. We have not appointed a data protection officer (DPO): it is not mandatory for a project of this size, and requests are handled directly by the controller.
3. What this policy applies to
It applies to the Voltvale app for Android, to this website (including the sign-in and account deletion pages) and to the emails we exchange. It does not apply to third-party services the app takes you to (for example Google Play, or Google or Facebook when you use them to sign in): those are covered by their own policies, which are linked further down.
4. What data we process and why
4.1 Until you have an account
Until you have chosen how to continue, if there is no connection, or if accounts can’t be created at that moment, your game data (profile, progress, hearts, gems, missions) stays only in the phone’s memory: we don’t receive it, and if you uninstall the app or change phones it is lost. Your settings (sounds, vibration, language, reminder time), the questions to review always stay only on the phone. Even in these cases the app sends the anonymous statistics described in 4.8, unless you have turned them off; those in 4.9 stay on the phone until there is an account.
4.2 Accounts: guest, email code, Google, Facebook
- Guest: we create an account with no email or name, with a random identifier: this is pseudonymous data, not anonymous data. It is used to save your progress on the server; if you lose your phone there is no way to recover it, because we don’t know who you are. A guest account that is inactive for 18 months is deleted automatically (see section 9).
- Email code: we process your email address to send you a one-time code and to recognize you when you sign in again. We don’t use passwords. An account whose email is never confirmed with the code is deleted after 7 days (see section 9).
- Google or Facebook: we receive from the service you choose your email address and an identifier of your account with that service. The service may also send us your name and profile picture: we don’t use or display them, but they stay in the account’s technical record managed by our authentication provider for as long as the account exists. With Facebook we verify the access token on our server before letting you in.
- With every account the authentication provider also records technical data such as the creation date, the date of the last sign-in and, in its logs, the IP address.
Why: to provide the service you ask for (saving and finding your progress). Legal basis: performance of the contract, that is, the Terms (Art. 6(1)(b) GDPR).
4.3 Synced profile and progress
- Profile: pseudonym (don’t use your real name), character and color, your first-launch answers (why you want to learn, what level you’re at, how many minutes a day, the topics you already know and, if you answer, how you heard about us).
- Progress: experience points, stars per lesson, unlocked components, streak days, hearts, gems, streak freezes, daily missions and dates of last activity.
Why: to save the game, sync it between phones and adapt suggestions (for example the daily goal). We also use the first-launch answers in aggregate form to understand who uses the app. Legal basis: performance of the contract (Art. 6(1)(b)); for aggregate use, our legitimate interest in improving the service (Art. 6(1)(f)).
4.4 Proof of acceptance of the Terms
When you tick the acceptance box in the app we save, linked to your account: the version of the Terms and Privacy Policy you saw, the date and time you ticked the box (according to the phone’s clock) and the date and time our server received it. This data can’t be deleted or backdated from the app; if we publish a new version we ask you to accept it again and we save the new acceptance. Why: to be able to show that you accepted the conditions in force. Legal basis: performance of the contract (Art. 6(1)(b)) and our legitimate interest in defending our rights (Art. 6(1)(f)).
4.5 Weekly leaderboard (leagues), reports and points checks
If you have an account with email, Google or Facebook (not as a guest) and have finished at least 3 lessons, you join a weekly leaderboard with a group of at most 30 players. To make it work we record every lesson you finish (which lesson, when you finished it, stars, mistakes, duration if available) and calculate the points on the server, applying anti-cheating checks (see the section Automated decisions). The other players in the group see only your pseudonym, character, color and points for the week: never your email, identifiers or other data.
You can stay off the leaderboard by turning off “Show me in leagues” in the app’s settings: from that moment others can’t see you and your points don’t count for the league.
Every player can report a pseudonym or a behavior and hide another player. To moderate, we process who reports, who is reported, the pseudonym, the reason and the date; reports are deleted 24 months after they are closed (see section 9). If you hide a player we save who you hid and when, so as not to show them on your leaderboard any more. An offensive pseudonym can be rejected by the system or changed by us. You can change your own pseudonym in your Profile, unless we have changed and blocked it.
Legal basis: performance of the contract for the leaderboard (Art. 6(1)(b)); legitimate interest in a fair competition for the checks (Art. 6(1)(f)); legitimate interest in the safety of the other players for reports and moderation (Art. 6(1)(f)).
4.6 Voltvale Plus subscription
Payment takes place entirely on Google Play: we neither see nor keep the details of your card or payment method. We record, linked to your account: subscription status (for example active, in trial, expired), product and plan (monthly or annual), expiry date, auto-renewal yes/no, whether it is a trial or a test purchase, and the purchase code issued by Google Play (“purchase token”). We give Google Play a cryptographic fingerprint (hash) of your account identifier, not your email, to link the purchase to the account. We verify every purchase directly with Google.
Why: to activate the Plus benefits on all your devices, confirm the purchase to Google and manage renewals and expiry. Legal basis: performance of the contract (Art. 6(1)(b)); retention for legal obligations, if and when applicable (Art. 6(1)(c)). If you turn on notifications, on the fifth day of the free trial the phone shows you a reminder: it is a local notification and sends no data.
4.7 Rewarded videos (Google AdMob)
The only advertising in Voltvale is a video that you choose to watch when you have run out of hearts, at most 3 a day. There are no banners or videos that start by themselves, and Plus subscribers see no advertising.
- The video is provided by Google through the Google Mobile Ads SDK (AdMob). We always request non-personalized ads, with content suitable at most for all audiences. Before the first video, if you are in the European Economic Area, the United Kingdom or Switzerland, we ask for your consent with Google’s tool (User Messaging Platform): it concerns the device access required by the SDK.
- We have removed from the app the permission to read the phone’s advertising ID and those for Android’s advertising APIs: Google doesn’t receive it from us.
- To show and measure the video and to prevent fraud, Google’s SDK processes device data (model, operating system, language, IP address), ad interaction data and diagnostic data. For these activities Google acts as an independent controller: see Google’s privacy policy and the page on how Google uses information from apps that use its services.
- You can change your choice from the app in Settings → Ads and consent (the item appears after the first consent request).
Legal basis: to show a video you ask for, performance of the contract (Art. 6(1)(b)); for the device access required by the SDK, your consent (Art. 6(1)(a) GDPR and Art. 122 of the Italian Privacy Code).
4.8 Our own anonymous statistics
The app records events such as “first-launch screen seen”, “lesson finished in 95 seconds”, “question 3 wrong”, “lesson rated too easy”, “sign-in chosen: Google” or “rewarded video watched”, to understand where people stop and to improve the game. Each event contains only a name, a step, a duration and a little technical information, and is sent without your account’s sign-in data: no identifier of your account or phone, no pseudonym, no email, and our database doesn’t save the IP address with the event. We only look at them as totals. The IP address still passes, for technical reasons, through the database provider, which keeps it in its logs for a short time (see 4.12).
Legal basis: our legitimate interest in improving the app (Art. 6(1)(f)), with minimal impact because the data doesn’t identify you. You can turn them off in Settings → Game statistics.
4.9 Usage statistics linked to your account
To understand how the game is used and decide what to improve, we record what happens in the app and link it to your account (guest accounts too): when you open and close the app and for how long, which screens you look at and for how long, lessons and answers, the choices you make in the game, purchases, technical errors (only their type). With these we save the phone’s model and system, app version, language and country. We work out the country from the network request without saving your IP address.
We don’t record email, pseudonym, text you type, precise location or advertising ID. This data is pseudonymous, not anonymous: we can link it to your account, for example to understand what happened to someone who reports a problem. Only we process it, on our own database: we don’t send it to external analytics services and we don’t use it for advertising.
Legal basis: our legitimate interest in understanding how the service is used and improving it (Art. 6(1)(f)). You can object at any time by turning off Settings → Game statistics: from then on we record nothing more from that phone, and the game works the same. To delete what has already been recorded, write to us or delete your account.
4.10 Reminders and notifications
The daily reminder (at the time you choose) and the Plus end-of-trial reminder are local notifications, scheduled on the phone: they don’t go through our servers and send no data. They only start if you authorize them in the Android popup; you can turn them off in the settings of the app or the phone.
4.11 Security, abuse and account suspension
To protect the service we may suspend an account that breaks the Terms (for example with an offensive pseudonym or by cheating). In that case we save the account identifier, the date and a short reason. Every action taken from the administration panel (suspensions, changes, deletions, exports) is recorded in an internal log with the date, the type of action and the identifier of the account concerned. The panel can only be accessed by the controller, with an email code and a second factor. Legal basis: legitimate interest in the security of the service and of the other players, and in being able to show what was done (Art. 6(1)(f)).
4.12 Technical data and logs
When the app or the website connect to our providers, these record technical data such as IP address, date and time, type of request and any errors. We use them only for security, abuse prevention and bug fixing. Legal basis: legitimate interest (Art. 6(1)(f)).
4.13 When you write to us
If you write to us by email we process your address and the content of the message in order to reply. Legal basis: performance of the contract or steps requested by you (Art. 6(1)(b)) and, for requests about your rights, legal obligation (Art. 6(1)(c)).
4.14 What we don’t do
We don’t ask for your location, contacts or real name and we don’t read the phone’s advertising ID. Only if you watch a rewarded video, Google may estimate an approximate location from your IP address (for example the country or city). We don’t sell data, we don’t use it for advertising profiling of our own and we don’t use it to train artificial intelligence systems.
Email, Google and Facebook are optional: you can play as a guest. Some data, however, is necessary for a feature: without an email (or Google/Facebook) you can’t recover your progress on another phone or join the leaderboard, and without accepting the Terms you can’t use the app beyond the first lesson.
5. Summary of purposes and legal bases
| Purpose | Legal basis |
|---|---|
| Account, sign-in, saving and syncing progress, email code | Contract (Art. 6(1)(b)) |
| Proof of acceptance of the Terms | Contract (Art. 6(1)(b)) and legitimate interest in defending ourselves (Art. 6(1)(f)) |
| Weekly leaderboard | Contract (Art. 6(1)(b)); you can leave it from the settings |
| Anti-cheating points checks | Legitimate interest in a fair competition (Art. 6(1)(f)) |
| Reports and leaderboard moderation | Legitimate interest in the safety of the other players (Art. 6(1)(f)) |
| Plus subscription | Contract (Art. 6(1)(b)); legal obligations (Art. 6(1)(c)) |
| Rewarded video chosen by you | Contract (Art. 6(1)(b)); for the device access required by the SDK, consent (Art. 6(1)(a); Art. 122 Italian Privacy Code) |
| Our own anonymous statistics; aggregate use of first-launch answers | Legitimate interest (Art. 6(1)(f)); the statistics can be turned off from the settings |
| Usage statistics linked to your account (see 4.9); counting website visits without cookies | Legitimate interest (Art. 6(1)(f)); you can object by turning them off in the settings |
| Security, technical logs, account suspension, log of administration actions | Legitimate interest (Art. 6(1)(f)) |
| Database backups | Legitimate interest in not losing data through faults or errors (Art. 6(1)(f)) |
| Replies to your requests and rights | Contract (Art. 6(1)(b)) and legal obligation (Art. 6(1)(c)) |
When we rely on legitimate interest we have assessed that it doesn’t override your rights; you can ask us for the details of the assessment and object at any time.
6. Automated decisions
The server applies automatic rules to leaderboard points: for example it doesn’t count a lesson declared finished in less than 20 seconds, the same lesson repeated within 2 minutes, a date in the future or older than 7 days, or points above an hourly and daily limit. At the end of the week, again automatically, the top players in the group move up a league and the bottom players move down. The system can also reject an offensive pseudonym: in that case the previous one stays, or a generic one, and you can choose another. These rules only decide points, league and pseudonym in the game: they have no legal effects and don’t significantly affect you, so they don’t fall under Art. 22 GDPR. If you think a result is wrong, write to us and we’ll check it by hand. We don’t do profiling for other purposes.
7. Providers and other recipients
The data is processed by the controller. To make the service work we use these providers. Those listed as processors process data on our behalf, under a data processing agreement (Art. 28 GDPR); those listed as independent controllers process it for their own purposes, under their own policies.
| Provider | What it does | Role | Where |
|---|---|---|---|
| Supabase, Inc. | Database, authentication, server functions, logs | Processor | Data hosted in London (United Kingdom); support and sub-processors also in the USA |
| Cloudflare, Inc. | Hosting of this website, return page after sign-in | Processor | USA and global network |
| Brevo (Sendinblue SAS) | Sending emails with the sign-in code | Processor | European Union |
| GitHub, Inc. | Encrypted storage of database backups (private archive). If encryption isn’t configured, the backup isn’t made. | Processor | USA |
| Google (Google Commerce Limited, Google Ireland Limited, Google LLC) | Google Play: app distribution, payment and management of the Plus subscription | Independent controller | EU and USA |
| Sign-in with Google; rewarded videos (AdMob) | Independent controller | EU and USA | |
| Meta Platforms Ireland Limited / Meta Platforms, Inc. | Sign-in with Facebook (only if you choose it) | Independent controller | EU and USA |
| Microsoft (Outlook.com) | The controller’s mailbox that receives your emails | Mailbox provider | EU and USA |
Privacy policies of the main providers: Supabase, Cloudflare, Brevo, Google, Meta, GitHub.
The other players in your league group see your pseudonym, character, color and points (see 4.5). We may disclose data to authorities only when required by law. We don’t sell or hand over data to third parties for their own purposes.
8. Transfers outside the European Union
- United Kingdom (Supabase database in London): the transfer is based on the European Commission’s adequacy decision for the United Kingdom.
- United States: for providers that, according to their own statements, participate in the EU-U.S. Data Privacy Framework (including Google LLC, Meta Platforms, Inc. and Cloudflare, Inc.) the transfer is based on the EU-U.S. adequacy decision of 10 July 2023; for other cases, and in addition, on the standard contractual clauses approved by the European Commission (Decision 2021/914), included in the providers’ contracts (for example Supabase’s).
You can ask us for information about the safeguards applied by writing to privacy@voltvale.app. You can check whether a provider participates in the Data Privacy Framework on the program’s official website.
9. How long we keep data
| Data | Duration |
|---|---|
| Accounts with email, Google or Facebook: profile, progress, hearts, gems, freezes, missions | As long as the account exists. When you delete it they are erased immediately from the database. |
| Guest accounts (no email) and all their data | As long as you use them. If one stays inactive for 18 months (the app isn’t opened and no progress is saved) we delete it automatically with all its data. We don’t automatically delete a guest account with a Plus subscription still active or renewing, nor one suspended for abuse while the suspension is in effect. |
| Accounts with an email never confirmed | 7 days from creation, then deleted automatically. |
| Leaderboard reports | 24 months after being closed, then deleted automatically. If you delete your account, reports received are deleted immediately and reports you made remain without your identifier. |
| Players you have hidden on the leaderboard | Until you remove the block or one of the two accounts is deleted. |
| Lessons recorded for the leaderboard and league results | As long as the account exists, and at most 24 months: after that we delete the closed league weeks and the lesson submissions, keeping only the first submission of each lesson (it tells us you’ve already done it) and your current league. |
| Acceptance of the Terms | As long as the account exists; it is deleted with the account. |
| Plus subscription data | As long as the account exists; it is deleted with the account. Payment receipts and tax data are kept by Google Play under its rules. |
| Account suspension | While the suspension is in effect or the account exists. |
| Database backups | One encrypted copy a day, with no sessions or access tokens, deleted automatically after 90 days. So the data of a deleted account may remain in a backup for up to 90 days. Backups aren’t used for anything else: if we had to restore one, we would again delete the accounts deleted in the meantime. |
| Log of deleted accounts | Only the account’s random identifier and the date of deletion (no name, email or progress), for 120 days: it is used solely to delete those accounts again if we had to restore a backup. It is then deleted automatically. |
| Our own anonymous statistics | 180 days, then deleted automatically; they aren’t linked to you. |
| Usage statistics linked to your account | 14 months, then deleted automatically; they go immediately if you delete your account. |
| Providers’ technical logs (IP, requests) | For the short period set by the provider’s plan (generally from a few hours to a few days). |
| Log of administration actions | 24 months, to show the actions taken and defend our rights; then deleted automatically. |
| Emails you send us | The time needed to reply and to handle any follow-up. |
| Data only on the phone | Until you uninstall the app or delete the account; it stays under your control. |
Deleting your Voltvale account does not cancel your subscription on Google Play: you have to cancel it from the Play Store (see the Terms).
10. Your rights and how to exercise them
Within the limits set by the GDPR (Articles 15-22) you have the right to:
- access your data and get a copy;
- have inaccurate data rectified;
- have your data erased (you can also do this yourself: see below);
- restrict processing;
- receive the data you gave us in a machine-readable format (portability);
- object to processing based on legitimate interest;
- withdraw a consent at any time, without affecting what was done before the withdrawal.
Write to privacy@voltvale.app from the address linked to your account, so that we can recognize you. We reply within one month (which can be extended by two more in complex cases, and we’ll tell you if so). If the account is a guest account we can’t know which one is yours: in that case use the app’s features.
Deleting your account: from the app, in Settings → Delete account, or from this web page, even without the app.
Complaints: if you believe the processing breaks the rules you can lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) (or the authority of the EU country where you live or work) or go to court.
11. Minimum age: why 16
Voltvale is intended for people who are at least 16 years old, and by accepting the Terms you declare that you are. In Italy a minor can give consent to data processing for online services on their own from the age of 14 (Art. 2-quinquies of the Italian Privacy Code), but we chose a higher limit because the app includes a leaderboard visible to the other players in your group, a paid subscription and advertising videos, and because it is not a service designed for children. We don’t knowingly collect data from younger people: if we realize that an account belongs to someone under 16, or a parent tells us, we delete it.
12. Cookies and browser storage on the website
The website doesn’t use statistics cookies or third-party tools. We count visits with an anonymous row (page viewed and referring site), with no identifiers and nothing saved in your browser.
| Name | Type and purpose | Duration |
|---|---|---|
voltvale-return | Browser session storage (not a cookie), only on the return page after signing in with Google or Facebook: holds the sign-in data, or the error, to pass to the app. Technical, necessary for the function you ask for. | At most 5 minutes: it is deleted as soon as the app opens |
voltvale-admin | Browser local storage (not a cookie), only in the administration panel, reserved for the controller: keeps the sign-in. Technical. | Until sign-out or session expiry |
We don’t record statistics on the sign-in and account deletion pages or in the administration panel. The Delete account page doesn’t save sessions in the browser: signing in with the code only lasts while the page stays open.
13. Security
Connections are encrypted (HTTPS). The database rules ensure that each user can read and change only their own data; secret keys stay only on the servers. Administrative access is reserved for the controller and protected by an email code and a second factor. No system is 100% secure: in the event of a data breach concerning you that poses a high risk, we’ll notify you as required by the GDPR.
14. Changes to this policy
If we change this policy we update the version and date at the top. For important changes we notify you in the app and, when the change also concerns the Terms, we ask you to accept the new version. Previous versions are available on request.
This policy is available in Italian and English. If the two versions differ, the Italian version prevails, except for the consumer protection rules of the country where you live.
See also: Terms of Use · Delete account