TEZZVO / Topper10 / Privacy

Privacy Policy

Applies to: Topper10 (Android, package com.tezzvo.topper10). Publisher: TEZZVO.
Effective date: 3 September 2026 · Last updated: 20 September 2026

The short version

1. Who we are

Topper10 is published by TEZZVO, which is the data controller for everything described on this page. Privacy contact: privacy@tezzvo.com — a monitored mailbox, read by the person who runs TEZZVO. Write to it for any request under this policy, wherever you live; we answer within one month.

We have not appointed a Data Protection Officer. The app processes no special-category data and carries out no large-scale systematic monitoring, so GDPR Art. 37 does not require one.

2. What we collect, why, and the lawful basis

Data Purpose Lawful basis (GDPR Art. 6) Leaves device?
Anonymous analytics events — screen names, “daily completed”, hits count, hints used, streak length, share-card opened, session timing, app version, coarse device model / OS version, and the country the analytics provider derives from the connecting IP address. The IP address itself is not stored with the events: the analytics project is set to discard client IP data, so the connecting IP is used to derive that country when the event arrives and is then discarded rather than kept on the event. That is a setting in the provider’s project — not something the app sends or controls. Understand retention and which features are used; find broken funnels 6(1)(f) legitimate interests — running a free game with no PII; you can object at any time (§6) Yes — to PostHog, in the United States, from a build made after we attached the analytics key on 14 September 2026; a build made before it sends none of this (§8). On unless you turn it off (§6, §8)
Crash & error reports — stack trace, screen, app/OS version, device model, non-PII breadcrumbs Detect and fix crashes 6(1)(f) legitimate interests — app stability Yes — to Sentry, once crash reporting is activated (§8: not activated today, so nothing is sent)
Anonymous installation id — a random 128-bit value generated on the device; not a hardware or ad ID; reset on data-clear or reinstall Deduplicate analytics/crash data so counts are meaningful 6(1)(f) legitimate interests Yes — attached to the analytics events above, so it reaches PostHog from a build that carries the analytics key, while analytics is on (§8)
Advertising ID — Android Advertising ID (GAID), together with ad-interaction data and coarse location Serve and cap ads, measure performance, fraud prevention — handled by Google AdMob 6(1)(a) consent where required (EEA/UK, via a Google consent prompt before the first ad); 6(1)(f) elsewhere Yes — to Google
Cloud save — your game progress: streak, coins, achievements, Journey position and the most recent 90 days of daily results, plus an anonymous Firebase sign-in identifier (a random value, not a device or ad ID). Not your display name and not your avatar — both are stripped on the device before every upload. Results carry your score, never the words you typed, and no saved mid-puzzle board is uploaded for any mode (see “Cloud save” below) Restore your progress on a new phone or after a reinstall, once you have signed in with Apple or Google — an anonymous-only save cannot be reached from a new install 6(1)(b) performance of the contract — the backup is part of how the game keeps your streak, and it runs without a separate request from you (§8) Yes — to Google Firebase; deletable in-app (§6)
Friends-leaderboard nickname, avatar & score (opt-in) — a nickname you choose, deliberately a separate field from your profile display name; your chosen avatar; your daily score, hint and wrong-guess counts; the time you finished; and the anonymous account id the row belongs to Show an invite-code-only group of people you know a daily leaderboard 6(1)(a) consent — an explicit in-app gate before the first nickname or score leaves the device Yes, but only to the members of the group you joined
Account name & email (opt-in, only if you sign in with Apple or Google) — the name and email address the provider shares; Apple lets you hide your real address behind a private relay Create and manage the backup account so your progress follows you to a new device 6(1)(b) performance of the service you asked for (an account you created) Yes — to Google Firebase Authentication; never shown to other players, never used for marketing
On-device only — display name, settings, the answers and guesses of every puzzle you play, and the saved mid-puzzle board of a daily, a Journey level or a category puzzle you leave unfinished. Your avatar too, with the single exception in the row above: publishing a leaderboard score carries the avatar with it Play the game and keep progress between sessions 6(1)(b) performance of the service you asked for (local only) No

We do not collect your phone number, contacts, photo library, precise location, calendar, microphone or camera input, health data or files. We collect no name and no email address at all unless you choose to sign in. Three pieces of text you type can leave the device at all: the nickname you choose for a friends leaderboard and the name of a group you create — both deliberate, both visible only to that group’s members; and the note you write in “Found an error?” after a puzzle, which your own mail app sends to corrections@tezzvo.com when you tap send — that one reaches us with the address you send it from, and is used only to fix the question. Puzzle text never reaches a leaderboard and never reaches analytics.

What analytics can never carry. This is two mechanisms, not a promise. The event list is closed — every event is declared in advance with the exact fields it may carry, and none of those fields is free text. The event recorded for each guess carries the puzzle, the guess’s position, whether it was right and which rank it filled; there is no field for the words themselves. Behind that, a filter strips any property whose name contains name, avatar, answer, guess, label, email, phone, token or secret before anything is handed to a provider. So your display name, your avatar, the answers, and the words you type are not sent to PostHog — and would still not be if someone added the wrong field tomorrow. That promise is load-bearing in every build that carries the analytics key (§8). The installation id that travels with these events is a random 128-bit value the app generates on your device: not a hardware identifier, not an advertising ID, not an install referrer. Clearing the app’s data resets it.

Notifications. If you turn on the daily reminder, the app schedules a local notification on your device. No push tokens are sent to us and no server is involved.

Cloud save

Cloud save mirrors the progress part of your local save to Google Firebase under an anonymous, app-scoped identifier that the app creates for itself the first time it backs up. It is on in a released build and nothing switches it off before the first upload — it is how a reinstall or a new phone keeps your streak, and it is the reason the filter described next exists. It carries no display name and no avatar — both are stripped on the device before every upload, so they stay per-device by construction. It keeps the most recent 90 days of daily results — anything older is never uploaded — and your Journey record up to a 200-entry ceiling, which is set above a complete run of the campaign, so no level you have cleared is left behind. Delete it at any time from Settings → Data; your local progress is untouched.

No typed text is carried. If you leave a category puzzle part-way through, the app saves that board so you can pick it up where you stopped, and the saved board includes the guesses you had already entered — on your device only. That board is stripped out of the backup before every upload, and so are the equivalent boards for the daily puzzle and for a Journey level. What the backup carries from a category puzzle is your best score on it and whether you finished it: numbers, not words. If you reinstall, your scores come back and the half-finished boards do not.

Friends leaderboard (opt-in)

The leaderboard is closed and invite-only: you see, and are seen by, only the group of up to 50 people you explicitly joined or created with a code someone gave you. There is no public or global board, no chat, no messaging, and no way to browse or search for other players.

Signing in (opt-in)

By default the app is anonymous. If you turn on Settings → Back up your progress you can sign in with Sign in with Apple (iOS) or Google (Android) — each platform offers exactly one provider. Signing in links your existing anonymous save to a provider account so it is recoverable on a new phone, which an anonymous-only save cannot be. The name and email the provider shares are used for account management only: never for analytics, never for advertising, never shared onward, never visible to other players. Signing out returns you to a fresh anonymous session; deleting your account removes the account record itself (see §6).

3. Children

The app is not directed to children under 13 (or the applicable age of digital consent in your country, up to 16 in parts of the EEA). We do not knowingly collect data from children. Content rating: we completed the Google Play / IARC content-rating questionnaire — no violence, sex, language or gambling content of any kind, and alcohol appears only as the subject of production and consumption statistics in four questions — and the band the questionnaire returns is the one shown on the store listing, which differs by territory. We will list it with a target age group of 13+, carrying a Google Play “users interact” notice because of the opt-in friends leaderboard. The app is not enrolled in Google Play’s Designed for Families programme. If you believe a child has provided us data, contact us and we will delete it.

4. Who we share data with

We do not sell personal data. We share it only with the recipients below, each acting as our processor under a data-processing agreement (Google AdMob acts as an independent controller for ad serving).

RecipientRoleDataRegionPolicy
PostHog (PostHog, Inc.) — active in builds made after 14 September 2026, see §8 Product analytics processor — it acts on our instruction under its data-processing addendum. This is not a sale of your data and not a transfer of control A fixed list of 81 named events plus the anonymous installation id, the app version and the update id. A build made after 14 September 2026 is sending these unless you have turned analytics off (§6); a build made before it sends none of them (§8) US Cloud (us.i.posthog.com) — the project is in PostHog’s United States region posthog.com/privacy
Sentry Crash / error reporting processor Crash reports + installation id — nothing today, because crash reporting is not activated (§8) EU region (ingest.de.sentry.io) sentry.io/privacy
Google Firebase (Google LLC) — Cloud Firestore and Firebase Authentication Progress-backup processor; also hosts the opt-in friends-leaderboard groups and, if you sign in, your account record Your progress save document and anonymous sign-in identifier; your nickname, avatar and daily score for any group you joined; your account name and email if you signed in United States (Firebase multi-region nam5) firebase.google.com/support/privacy
Google AdMob / Google Ireland Ltd Ad serving (independent controller) Advertising ID, coarse location, ad-interaction data Global (Google infrastructure) policies.google.com/technologies/ads
Google Play App distribution Install/uninstall metrics; optional OS-level crash data Global policies.google.com/privacy

International transfers. Two of our processors are in the United States, and a third serves globally.

The transfer basis for PostHog, named — we signed their data-processing agreement on 15 September 2026. Until that date this page said we had verified no transfer mechanism for PostHog at all, because no controller–processor agreement existed. One does now, and it carries two mechanisms that stand at the same time.

So the Clauses are not conditional on the Framework surviving. That matters, because the Framework’s two predecessors — Safe Harbour and Privacy Shield — were both struck down; if that happened again, or if PostHog left the Framework, the Clauses already apply on their own terms and the agreement has the parties settle an alternative as well.

Two things this does not settle, and we are not going to blur them. First, Google’s basis is still open: the Firebase and AdMob transfers would ordinarily rest on Google’s own EU Standard Contractual Clauses and UK Addendum under its Data Processing and Security Terms, and that has not been reviewed by a lawyer for this app. Second, no lawyer has read any of this, the paragraphs above included — signing a counterparty’s agreement establishes a mechanism, it is not a legal review of our processing as a whole. Both are open items in our legal review. A build made after 14 September 2026 does send the §2 events to the United States, however it reached your device — a Google Play release, closed testing included, an over-the-air update, or one of our internal test builds (§8) — and if you would rather not take part while the second point is open, Settings → Privacy → “Analytics & crash reporting” turns it off (§6). We may also disclose data if required by law.

5. Retention

6. Your rights & how to delete your data

Under the GDPR/UK GDPR (and comparable laws such as CCPA/CPRA and LGPD) you can request access, rectification, erasure, restriction, objection, and portability, and withdraw consent at any time.

Because analytics data is not linked to your identity, we may be unable to single out those records without the installation id (GDPR Art. 11). Cloud save, leaderboard and account data are keyed to your account and are deletable in the app whether or not you can quote an id.

7. Security

Data in transit to Google and to PostHog — and to Sentry once crash reporting is activated, which it is not today (§8) — is encrypted with HTTPS/TLS. On-device data uses the platform’s app-private storage. Access is enforced server-side by security rules: your cloud save is readable and writable only by your own account, and a leaderboard group’s rows only by the members of that group. Inside a group those members do see each other’s nickname, avatar and score — that is the feature, and §2 sets out exactly what it publishes; outside it, one player cannot reach another’s data. No system is perfectly secure, but we keep third parties to a minimum.

8. What is switched on today

A released build does not necessarily run every component described above, so here is the honest state as of the “last updated” date:

9. Changes

We’ll update this page and the “last updated” date for material changes, and surface an in-app notice for significant ones.

10. Contact

privacy@tezzvo.com