ScramblePrivacy Policy
Last updated
Scramble is a word game that works without an account. Your runs and progress are saved on your device. If you use Game Center, Apple handles your leaderboard scores, achievements, battles and duels. If you buy the Full Library, Apple handles the purchase. The developer never receives any of it. This policy explains what the app does with your data and why.
In short
| What | Where it goes | Can the developer see it? |
|---|---|---|
| Your current run, progress, settings, Daily Scramble streak and the librarians you've met | Only on your device | No |
| Leaderboard scores and achievements (if you use Game Center) | Apple's Game Center | No |
| Live battles: your Game Center name, the word you play each round and how much time you had left | Sent to your opponent through Game Center during the battle | No |
| Duels: your Game Center name, score, word count, best word and your score at each second of your turn | Apple's Game Center, shared with your opponent | No |
| The Full Library purchase | Handled by Apple through the App Store; the app keeps a note on your device that you own it | No |
Who is responsible
Scramble is developed by Marco Lüthi, the controller responsible for data processing under the Swiss Federal Act on Data Protection (FADP) and, where applicable, the EU General Data Protection Regulation (GDPR).
Marco Lüthi
Gutstrasse 172
8055 Zürich
Switzerland
hi@luthi-mar.co
Data saved on your device
Scramble saves your run in progress, so you can pick up where you left off, together with your unlocked wings, settings, your Daily Scramble results and streak, the librarians you've met, your battle wins, your best scores and whether you own the Full Library. This is stored only in the app on your device. The dictionary is built into the app, so checking your words never needs a connection. Deleting the app deletes this data.
Game Center
If you are signed in to Game Center on your device, Scramble uses it for leaderboards, achievements, live battles and duels. Your scores (for example your best Time Trial, today's Daily Scramble and your best word) and the achievements you earn are sent to Apple's Game Center, where you and other players can see them according to your Game Center settings.
A live battle is a real-time Game Center match between two players. While it runs, the app sends your opponent your Game Center name, a random seed for the shared letters, the letters you lock in each round (so the word you play) and how many seconds you had left, and tells them if you leave. Game Center delivers this directly between the two devices or through Apple's servers. Nothing is kept after the battle, apart from your own win count on your device and your wins on today's battle leaderboard. Practice battles against Wren stay on your device.
A duel is a turn-based Game Center match. To let both players face the same letters and race each other, the match stores a random seed for the boards and, for each player, their Game Center name, score, number of words, best word and score at each second of their turn. Your opponent can see these.
Battles and duels have no chat: the only thing other players see from you, besides your name, is the words you play, which come from the game's built-in dictionary. Rude words are hidden from your opponent. Nothing else from your device is shared.
Game Center is a service provided by Apple to you. The developer has no access to your Game Center account. Apple processes this data under its own privacy policy: apple.com/legal/privacy. You can play every single-player mode without Game Center, and you can sign out of it in the iOS Settings app.
In-app purchase
The Main Hall is free. The Full Library, which unlocks the other four wings, is a one-time in-app purchase. Apple processes the payment through the App Store under its own terms and privacy policy. The developer receives no payment details or personal data from it, only Apple's anonymous sales reports. The app checks with the App Store whether you own the Full Library (also when you tap Restore) and remembers the answer on your device.
Legal basis
Where the GDPR applies, the processing described above is necessary to provide the game and the features you choose to use (Art. 6(1)(b) GDPR). Under the Swiss FADP, we process personal data only as described here and in line with its principles.
What Scramble does not do
- No account, sign-up or login of its own.
- No advertising, analytics or crash reporting.
- No tracking across apps or websites, and no selling or sharing of data with data brokers.
- No data is sent to the developer.
This website
This website is a static site without cookies, analytics or tracking. Fonts are served from this website itself, so your browser does not contact third-party font services. When you visit a page, the hosting provider Vercel Inc. (based in the United States, with data centres worldwide) automatically records technical access data in server logs: your IP address, date and time, the requested page, referrer and browser type. This is needed to deliver the site and keep it secure (legitimate interest, Art. 6(1)(f) GDPR). The logs are deleted after a short period. Links to the App Store take you to Apple, where Apple's privacy policy applies.
Your rights
You have the right to request access to your personal data and to have it corrected or deleted, to object to or restrict processing, and to data portability. Because the apps store your data on your device and do not identify you, the developer usually holds no personal data about you. Most of it you can delete yourself by deleting the app.
To exercise your rights, email hi@luthi-mar.co. You can also lodge a complaint with a supervisory authority: in Switzerland the Federal Data Protection and Information Commissioner (FDPIC), in the EU the data protection authority of your country.
International transfers
Apple may process data in the United States and other countries. Apple describes the safeguards it uses for these transfers, such as the Data Privacy Framework and standard contractual clauses, in its privacy policy. This website is hosted by Vercel Inc., based in the United States; its server logs are transferred under the same kind of safeguards.
Children
Scramble does not collect personal data from anyone, including children. Game Center features follow the age settings of the player's Apple Account, and purchases follow Ask to Buy and Screen Time.
Changes to this policy
If the app starts handling data differently, this page will be updated before the change ships, and the date at the top will change.