PhantomBrain · Legal

Privacy Policy

Version 2 · Effective 20 October 2026

Read this together with the PhantomBrain Terms of Service.

This policy explains what personal data PhantomBrain collects, why, who can see it, how long we keep it and the rights you have. PhantomBrain means the PhantomBrain apps for iPhone and Android, their games Phantom Grid, Phantom Stack and Phantom Math, the online service behind them, and this website, phantombrain.app. The policy applies to everyone who uses PhantomBrain, wherever they live.

1. Who is responsible

Gentle Bits SRL (“GentleBits”, “we”, “us”) is the controller of your personal data in PhantomBrain:

• Registered office: Str. Vulturilor nr. 4, 300144 Timișoara, Timiș County, Romania
• Trade Register number: J35/173/2017 (EUID ROONRC.J35/173/2017); sole registration code (CUI): 36950672
• Email: contact@gentlebits.net

We haven’t appointed a data protection officer, because the law doesn’t require one for us. Write to the address above about anything in this policy.

2. What we collect and why

We collect data from these sources: from you and the app on your phone; from Apple or Google when you sign in; from Apple or Google when you buy Premium or connect Game Center or Play Games; and, for partners, from what we agree with you. The table lists each kind of data, why we need it, and the legal basis under the EU General Data Protection Regulation (GDPR):

• Contract: we need the data to provide PhantomBrain to you under our Terms (GDPR Article 6(1)(b)).
• Legitimate interests: we use the data for interests of ours that your rights don’t outweigh, namely keeping PhantomBrain secure and working, preventing abuse, keeping play fair, understanding usage in aggregate, paying partners correctly, and keeping other players’ match histories accurate (Article 6(1)(f)).
• Legal obligation: the law requires us to keep or use the data (Article 6(1)(c)).

The sign-in, profile and game data are needed to use PhantomBrain: without them we can’t provide it. Notifications, Game Center, Play Games and crediting a partner are optional. iOS asks for your permission before the app shows you notifications or reads your Game Center friends, and Android 13 and later asks before the app shows you notifications.

3. What other players and partners can see

• Anyone signed in can find you by your username (never by your name) and see:
  • your username and the initials made from it;
  • whether you have Premium;
  • your Phantom Grid rating and level, your Phantom Stack ratings, and your Phantom Math rating and level.
• Your opponents, during a match and afterwards in their recent games and head-to-head records, see your username, initials, rating (marked “?” while provisional), level, whether you have Premium, and your head-to-head record against them. In a live match they also see your progress as you play.
• Friends also see your name, whether you are online or in a game, when you became friends, and whether you were added through Game Center or Play Games.
• A player you have a challenge with sees your username, initials, whether you have Premium, whether you are online or in a game, and your rating for the challenge’s game and level.
• Async opponents. Your finished games can be replayed to other players as their async opponent, shown with your username, initials, rating and whether you have Premium. We only use games played through to their end, as each game’s rules define. Your ranked solo games are also played by the next players, to settle your result.
• Solo results. When your game settles another player’s solo result, that player is told your username and how the game went. In the same way, you are told who settled yours.
• Players you block aren’t told. They no longer find you in search or see your online status.
• Partners. If you credit a partner, that partner sees, on their partner page: your username; when you created your account and when you credited them; your plan and whether you have Premium now; when you first paid for Premium, and how long after crediting them; whether your subscription renews, ends, has expired or was refunded, with the date; and until when you count for them. They don’t see your name, email, games or anything else about you.
• If you are a partner, anyone, signed in or not, can find you by your username in the app’s partner search and see your name next to it.
• After you delete your account, other players’ histories show you as “Former player”, and your games are never served as async opponents again.

We don’t publish player profiles on the web.

4. What we don’t do

• We don’t show ads or use advertising identifiers.
• We don’t track you across other companies’ apps or websites.
• The apps contain no analytics, crash-reporting or advertising code. The only code in them from other companies is:
  • on iPhone, Google’s sign-in library and the open-source components it relies on. It runs only when you sign in with Google, and when you delete an account you signed in to with Google; Google then receives what it needs, including your iOS version, under Google’s privacy policy;
  • on Android, Google’s sign-in (Credential Manager and Sign in with Google), Google Play Billing, and Firebase Cloud Messaging, which delivers notifications. Firebase creates an installation identifier on your phone that it sends to Google, not to us. Where the app offers Play Games, Google’s Play Games library as well.
• We don’t sell or rent personal data, or share it for advertising.
• We don’t send newsletters or marketing email.
• We don’t make decisions about you, based solely on automated processing, that have legal or similarly significant effects. Matchmaking, ratings, levels, the daily limit and which of your games become async opponents are worked out automatically, from your games, each game’s rules and your plan. The app explains the rules.

5. Who we share data with

• Hetzner Online GmbH (Industriestr. 25, 91710 Gunzenhausen, Germany) hosts our servers and database, and this website, in its data centres in the European Union (Germany or Finland). It acts as our processor under a data processing agreement and may use your data only on our instructions.
• Apple provides Sign in with Apple, the Apple Push Notification service (which delivers our notifications on iPhone, and their text), the App Store (which sells Premium and tells us about your subscription) and Game Center (which confirms your Game Center identity). Apple handles that data under its own privacy policy.
• Google provides Sign in with Google, and withdraws PhantomBrain’s access when you delete your account. On Android it also provides Firebase Cloud Messaging (which delivers our notifications, and their text), Google Play (which sells Premium, confirms purchases to us and tells us about your subscription through Google Cloud Pub/Sub) and Play Games (which confirms your Play Games identity). Google handles that data under its own privacy policy.
• Resend, Inc. sends our emails to partners (the invitation and sign-in links). It receives the partner’s email address, first name and username, and the email’s content. It acts as our processor.
• Apple also hosts our email (iCloud Mail), so messages you send us pass through Apple.
• Cloudflare, Inc. runs the contact form on gentlebits.net. If you write to us through it, Cloudflare processes your message and IP address to deliver the message and to check that you aren’t a bot.
• Partners see what section 3 describes, if you credit one.
• Other players see what section 3 describes.
• Authorities, when the law requires it, or when it is needed to establish, exercise or defend legal claims or to protect someone’s safety.
• A buyer, if GentleBits or PhantomBrain is sold or merged. The buyer must keep to this policy, and we will tell you before it applies.

We don’t share your personal data with anyone else.

6. Where your data is processed

Our servers and database are in the European Union, at Hetzner. Some data reaches Apple, Google, Resend and Cloudflare, which may process it in the United States and other countries outside the European Economic Area:

• signing in with Apple or Google;
• notification text sent through Apple’s push service or Firebase Cloud Messaging;
• the account identifier the app attaches to App Store and Google Play purchases;
• the tokens we send to withdraw PhantomBrain’s access when you delete your account;
• our emails to partners, sent through Resend;
• emails you send us, and messages sent through the contact form on gentlebits.net.

These transfers rely on safeguards recognised by EU law: the EU–U.S. Data Privacy Framework, which the European Commission has found to give adequate protection, or the Commission’s standard contractual clauses. Apple’s, Google’s, Resend’s and Cloudflare’s privacy policies give the details.

7. How long we keep data

8. Deleting your account

You can delete your account at any time in the app, on iPhone or Android (Account › Delete account); without the app, on our web page api.phantombrain.app/account-deletion, where you sign in with Apple or Google to confirm it is you; or by writing to us. If you write to us, we may ask you to confirm the request from the app or that page. If you delete the Apple Account you use with PhantomBrain, Apple tells us and we delete your PhantomBrain account too.

At once

• Your username, name, email and sign-in identity are removed, and your username becomes free for others.
• You are signed out on every device, and your notification tokens are removed.
• Your pending challenges are cancelled, a live match in progress is forfeited, and an async or solo game is cancelled or abandoned.
• Your friendships, friend requests, blocks and your Game Center or Play Games link are removed.
• Your games stop being served as async opponents.
• If you are a partner, your partnership ends, and your email address, sign-in links and sessions are removed.

Within 24 hours

• We erase your ratings and their history, your head-to-head records, per-level results, daily losses, settings, preferences, legal acceptances, devices, sessions, exports, event log, the reports you sent and the reports about you, and other personal records.
• If you signed in with Apple, we ask Apple to withdraw PhantomBrain’s access to your Apple Account, and delete the token we kept for that.
• If you signed in with Google and delete your account in the iPhone app, the app withdraws PhantomBrain’s access to your Google account and we ask Google to confirm it. Otherwise, you can remove PhantomBrain’s access yourself in your Google Account, at myaccount.google.com/connections.

What we keep, and why

• Game records without your name. We keep the games and matches you played, linked only to an internal identifier, so that other players’ match histories and ratings and our puzzle-difficulty statistics stay accurate. Other players see you as “Former player”.
• A minimal account record. The game records point to it: the internal identifier, which sign-in provider you used, the relevant dates, and your Phantom Grid and Phantom Math levels.
• Matchmaking and challenge records that led to matches: the game, mode, level, platform and app version.
• Subscription and payment records, so that a subscription you haven’t cancelled can be restored to a new account, to handle refunds and disputes, and as financial records.
• Your partner credit, if you credited a partner: which partner, when, and the one-way codes of your devices described in section 2, so that the partner’s earnings stay right and your phone isn’t counted again.
• If you were a partner: your partnership’s terms, earnings and payments, without your email address, as financial records.
• A record that the deletion happened (when and how, and the outcome of withdrawing access), and our internal log of administrative actions, which identifies accounts only by internal identifier.
• Short-lived copies in other players’ data, which expire on their own: your username or name can remain in another player’s event log for up to 72 hours, and in a data export a friend made before your deletion for up to 7 days.

Deleting your account doesn’t cancel a store subscription. Cancel it in the App Store or Google Play, wherever you bought it.

9. Security

We protect your data with appropriate technical and organisational measures:

• Connections between the apps and our servers are encrypted.
• Tokens from Apple and Google are encrypted in our database (AES-256-GCM), and sign-in session tokens are stored hashed or encrypted, never in plain text. Partner sign-in links and sessions are stored only as one-way codes.
• Access to production data is limited to the people who run PhantomBrain, and every action through our administration tool is logged.
• On iPhone, your session is kept in the iOS Keychain. On Android, it is encrypted with a key that Android Keystore keeps on the phone.

No system is perfectly secure. If a breach puts your data at risk, we will inform the authorities and you as the law requires.

10. On your phone

On iPhone

• Your sign-in session, in the iOS Keychain, on that iPhone only. Signing out removes it.
• A random installation identifier, until you delete the app.
• A “Continue as” record of the last account used on this phone (name, username, sign-in provider and email), so you can sign back in with one tap. Using a different account, or deleting your account in the app, removes it.
• If you use Google, the sign-in record Google’s sign-in library keeps for itself. Deleting your account in the app removes it.
• A partner you picked before creating your account, until you create it.
• Your appearance and sound settings, whether you have seen the intro, which quote the Welcome screen showed last, and your notification token.
• The match in progress: your opponent’s username and rating, the game’s progress, and results waiting to reach our servers. It stays until the match ends; anything older than 24 hours is dropped.

Apart from your session, these can be included in your iPhone’s backups.

On Android

• Your sign-in session, encrypted with a key that Android Keystore keeps on that phone; the short-lived part of it is kept only in memory. Signing out removes it.
• A random installation identifier, until you delete the app or clear its data.
• A “Continue as” record of the last account used on this phone (name, username and sign-in provider). Deleting your account in the app removes it.
• The last notification token the app registered, and whether it has asked for permission to show notifications.
• A partner you picked before signing in, until you create your account.
• A copy of your settings and preferences, with any changes not yet sent.
• The match in progress: your opponent’s username and rating and your record against them, the game’s progress, and results waiting to reach our servers.
• Your appearance and sound settings, whether you have seen the intro, and which quote the Welcome screen showed last.

Of these, only the “Continue as” record and the appearance, sound, intro and quote settings are included in Android’s backups (to your Google account, or when you move to a new phone). Everything else is excluded.

The apps use your phone’s motion sensors for a lighting effect on the game boards. That data stays on the phone and is never sent to us. The apps use no cookies and no tracking technologies.

11. Notifications

Your phone asks whether PhantomBrain may send you notifications: iOS on iPhone, and Android 13 or later on Android. If you allow them, we send notifications when a player challenges you, when a challenge you sent is accepted or declined, and when another player settles the rating of one of your solo games.

• You can turn them on or off with the app’s Notifications switch, or in your phone’s settings. On Android you can also turn Challenges, Accepts and Rating updates on or off separately in the phone’s settings.
• They are delivered through Apple’s push service on iPhone and through Firebase Cloud Messaging on Android, and can include other players’ usernames.
• We send them only when the app isn’t open; while it is, in-app banners take their place.
• On iPhone, the app icon’s badge counts the challenges waiting for you, and we send silent updates to keep it right, for example when a challenge is cancelled.

12. Your rights

You have these rights over your personal data:

• Access: you can ask what we hold about you and get a copy. On the app’s Account tab you can ask for a file with your account, settings, devices, friends, the players you blocked and the reports you sent, challenges, matches and games, ratings, daily losses, purchases and payments, the partner you credited and, if you are a partner, your partnership and our payments to you. The download link works for 7 days, and you can ask for one export every 24 hours.
• Rectification: you can change your name in the app; for anything else that is wrong, write to us.
• Erasure: you can delete your account in the app or ask us to (section 8).
• Restriction: you can ask us to limit how we use your data while a concern is resolved.
• Portability: the export is a machine-readable JSON file you can take elsewhere.
• Notifications, Game Center and Play Games: you can turn notifications off at any time, in your phone’s settings or with the app’s Notifications switch, and disconnect Game Center or Play Games in the app.
• Complaint: you can complain to a data protection authority. In Romania that is the National Supervisory Authority for Personal Data Processing (ANSPDCP): B-dul G-ral Gheorghe Magheru 28-30, Sector 1, 010336 București; anspdcp@dataprotection.ro; www.dataprotection.ro. You can also complain to the authority in the country where you live or work.

Your right to object. You can object at any time, on grounds relating to your situation, to any use of your data based on our legitimate interests. We will then stop, unless we have compelling legitimate grounds that override your interests, rights and freedoms, or need the data to establish, exercise or defend legal claims.

To use a right, write to contact@gentlebits.net. It is free. We answer within one month; for complex requests that can extend by up to two more months, and we will tell you if it does. We may ask you to confirm your request from the app, so we know it comes from you.

13. Children

You must be at least 13 to use PhantomBrain. If you are under 18, a parent or guardian must accept the Terms for you (Terms, section 2). We don’t knowingly collect personal data from children under 13; if we learn that we have, we delete the account. If you are a parent or guardian and have a concern, write to us.

14. This website

phantombrain.app is served from our own servers at Hetzner.

• The presentation page and these legal pages set no cookies and load nothing from other companies; their fonts are our own copies. The web server logs each request, and our servers use your IP address to limit requests, as section 2 describes.
• The partner page, phantombrain.app/partners, is for partners. When you ask for a sign-in link, we use the address you type only to look up whether it belongs to a partner and, if it does, to email the link; the page’s answer is the same either way. When you open a link, we set one cookie, pb_partner, which keeps that browser signed in for 30 days and which the partner page can’t work without. Signing out removes it.
• The account deletion page, api.phantombrain.app/account-deletion, loads Sign in with Apple and Sign in with Google from Apple’s and Google’s servers, so that you can confirm who you are. Apple and Google then receive your IP address and browser information under their own privacy policies, and may set their own cookies. We receive only the proof of sign-in that identifies your account.

We use no cookies for analytics or advertising.

15. Changes to this policy

We may update this policy, for example when PhantomBrain changes. Each version has a number and an effective date, and if you ask, we’ll send you a copy of an earlier version you accepted. If a change matters to you, we will tell you before it takes effect, in the app and, where we can, by email, and the app will ask you to accept the new version before you carry on playing.

16. Contact us