Privacy Policy

Effective 1 November 2026 · Last updated 1 November 2026

1. Who we are

Risk-y Dice (the “App”) is developed and published by Federica Benacquista, an individual developer, Via del Lido 106, 04100 Latina (LT), Italy (“we”, “us”). For any personal data we decide how to use, we are the data controller under Regulation (EU) 2016/679 (the “GDPR”) and the Italian Personal Data Protection Code (Legislative Decree 196/2003, as amended by Legislative Decree 101/2018).

Contact for every privacy matter: support@copycut.it. We have not appointed a Data Protection Officer because we are not legally required to.

2. Scope

This policy covers the App for iOS and this website (risk-y-dice.web.app). It explains what information is involved when you use them, who processes it, why, and what rights you have. The App rolls the dice for battles in Risk and Risiko: you set the armies on each side and it plays the rounds for you.

3. Data stored only on your device

The App keeps the following information on your iPhone, in its private storage:

• Your battles: the armies and dice for attacker and defender, the dice rolled and the results log of each round.
• Small counters: how many battles you won and started, used to decide when to show Apple’s rating prompt and how often a full screen ad may appear.
• Purchase status: whether you removed ads and the tips you left, with the totals behind your supporter rank. To rebuild them from your purchase history, the App uses the anonymous transaction identifier that the App Store gives the App. The ad free status is kept in your iPhone’s Keychain.
• Your consent choices: the answers you give in Google’s consent form, saved on your iPhone by Google’s consent tool so the App can respect them.

We do not run a server that receives this information. Because it never reaches us, we cannot view, recover or export it for you. Deleting the App removes it. It may also be part of your own iPhone backups, which Apple, not us, controls.

4. Data processed by Google and Apple when you use the App

4.1 Advertising: Google AdMob

The free version of the App shows a banner and, between battles, an occasional full screen ad, provided by Google AdMob (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, and its affiliates, including Google LLC). Removing ads with an in-app purchase turns them off.

• What Google may process to deliver ads: your IP address and an approximate location derived from it, device and operating system information, the App’s identifier, the identifier for vendors (IDFV), the advertising identifier (IDFA) only if you allow tracking in Apple’s prompt, and information about the ads shown and tapped. Google uses this to serve ads, limit how often you see them, measure them and detect fraud.
• Europe, the UK and Switzerland. The first time you open the App, Google’s consent form appears (built on the IAB Europe Transparency & Consent Framework), followed by Apple’s tracking prompt. The Google Mobile Ads SDK is not started and no ads from Google are requested until your answer allows it.
• US states with privacy laws. You can opt out of the sale or sharing of your data and of targeted advertising in More → Manage Consent, which opens Google’s US state privacy form.
• Personalised only with your permission. Ads are personalised only if your answers allow it and you allow tracking in Apple’s prompt. Otherwise the App asks Google for non personalised ads, which are not chosen from a profile of you. If you decline, Google may still show limited ads that use only the data strictly needed to deliver and protect them, as described in Google’s policies.

For data Google processes for its own purposes, Google acts as an independent controller. See How Google uses information from apps that use its services, the ad technology providers used with AdMob and the Google Privacy Policy.

4.2 Usage statistics: Google Analytics for Firebase

The App includes Google Analytics for Firebase (Google Ireland Limited) to understand, in aggregate, how the App is used. Collection is off when the App starts and is switched on only as your choices allow:

• In the EEA, the UK and Switzerland, only if you give consent in Google’s form to storing information on your device and to measurement. Elsewhere, statistics are collected without the advertising signals described below.
• What the App records: when dice are rolled (one roll or automatic, and how many dice each side uses), when a battle ends (which side won, how many rounds, the starting armies), when a new battle starts, the steps of a purchase or restore (which product), when you tap one of our other apps, and when you open the More page. Firebase adds standard technical events such as first open, session start and engagement time.
• What Firebase may process: a random app instance identifier, device model, operating system version, language, App version and the country or region derived from your IP address. The advertising identifier (IDFA) only if you allow tracking.
• Advertising signals (ad user data and ad personalisation) are granted to Google only if your answers in Google’s form allow it and you allow tracking in Apple’s prompt; otherwise they are set to “denied”.
• We never send a user ID, your name or anything you write.

For this service Google acts as our data processor under the Firebase Data Processing and Security Terms.

4.3 Purchases: Apple App Store

Removing ads and leaving a tip are in-app purchases handled entirely by Apple under its own terms and privacy policy. We never receive your name, Apple Account, payment card or billing details. The App checks with Apple, on your device, which purchases are valid. Nothing is sent to a server of ours.

4.4 Ratings

After some battles the App may ask Apple to show its standard rating prompt. Apple decides whether it appears and handles your rating. We receive nothing from it.

4.5 When you contact us

If you write to us, for example with Contact in the App, we receive your email address, the topic, subject and message, and any screenshots you choose to attach. To help us fix problems, the App adds technical details: App name, version and build, iOS version and build, device model, language and region settings, time zone, whether low power mode is on, and the time. The form tells you these details are included, and you see the whole email before you press Send.

5. Purposes and legal bases

We do not make decisions about you based solely on automated processing that produce legal or similarly significant effects.

6. What we never do

• We never sell your personal data for money.
• We never ask for an account, your name or your phone number.
• We never ask for access to your location, contacts, camera, microphone or photo library. Screenshots for support are only the ones you pick yourself.
• We never send what you type, or your battles, to advertisers.

7. International transfers

Google may process data in the United States and other countries outside the European Economic Area. Where that happens, transfers rely on the EU-US Data Privacy Framework, under which Google LLC is certified, and on the European Commission’s Standard Contractual Clauses included in Google’s data processing terms. Apple’s processing is governed by Apple’s own safeguards.

8. How long data is kept

• Data on your device: until you delete it or delete the App.
• Analytics data: event level data is kept for the retention period set in our Google Analytics settings, and in any case no longer than 14 months, then deleted. Aggregated reports contain no personal data.
• Advertising data: according to Google’s retention policies, described in its privacy policy.
• Support emails: up to 24 months after the conversation ends, unless we must keep them longer to meet a legal obligation or defend a legal claim.

9. Your rights

Under the GDPR you have the right to:

• access the personal data we hold about you and receive a copy (Art. 15);
• rectify inaccurate data (Art. 16);
• erase your data (Art. 17);
• restrict processing (Art. 18);
• data portability (Art. 20);
• object to processing based on legitimate interest (Art. 21);
• withdraw consent at any time, without affecting processing carried out before you withdrew it (Art. 7(3)).

Because your battles stay on your device, you control them directly in the App. For anything we hold (mainly support emails), write to support@copycut.it. We will reply within one month, extendable by two further months for complex requests as allowed by Art. 12(3) GDPR. We may ask for information to confirm it is really you. For data Google processes as an independent controller, you can also contact Google directly.

You have the right to lodge a complaint with a supervisory authority, in particular in the EU country where you live or work. In Italy this is the Garante per la protezione dei dati personali, Piazza Venezia 11, 00187 Rome, www.garanteprivacy.it. We would appreciate the chance to address your concern first.

10. Your choices and controls

• Consent: review or change your ads and statistics choices in the App under More → Manage Consent. The button appears where Google’s privacy choices apply: the EEA, the UK, Switzerland and US states with privacy laws.
• Tracking: allow or deny tracking for Risk-y Dice at any time in iOS Settings → Privacy & Security → Tracking. If tracking is denied, the advertising identifier is not shared and ads are not personalised.
• No ads: removing ads with an in-app purchase turns them off on your device.

11. Young people

The App is intended for people aged 14 and over, the age at which a person can consent to online services on their own under Italian law (Art. 2-quinquies of the Italian Privacy Code). Where the law of your country sets a higher age, that age applies. If you are younger, please use the App only with a parent or guardian, who can give or refuse consent to ads and statistics on your behalf. We do not knowingly collect personal data from children. If you believe a child has contacted us, write to us and we will delete the correspondence.

12. Security

The App keeps your data in iOS’s sandboxed storage, which iOS encrypts when your iPhone is locked with a passcode. Purchase status is stored in the iOS Keychain. If a personal data breach affecting data we control occurs, we will notify the supervisory authority and you where the GDPR requires it.

13. This website

This website is hosted on Google Firebase Hosting, provided by Google Ireland Limited. To deliver each page, Google’s servers process your IP address, the page you ask for, the date and time, and your browser’s details, and keep these technical logs for a limited time for security. The legal basis is our legitimate interest in running a secure website (Art. 6(1)(f) GDPR).

The website uses no cookies, no analytics and no advertising, has no social media plugins and loads no fonts or scripts from other companies. If you email support@copycut.it, we use your message only to reply. The cookie policy explains this in more detail.

14. Information for US residents

We do not sell personal information for money. Ads in the App are personalised only if you allow tracking in Apple’s prompt; if you do, Google may use your advertising identifier for cross context behavioural advertising, which some state laws call “sharing” or “sale”. You can opt out at any time in More → Manage Consent in the App, which opens Google’s US state privacy form, or by turning off tracking for Risk-y Dice in iOS Settings → Privacy & Security → Tracking. Where state law gives you rights to know, delete or correct personal information, or to appeal a decision, you can exercise them by writing to us. We will not discriminate against you for doing so.

15. Changes to this policy

We may update this policy when the App or the law changes, and we will change the “Last updated” date above. For significant changes, for example a new way of processing data, we will also tell you in the App before the change takes effect and, where required, ask for your consent again.

16. Contact

Federica Benacquista
Via del Lido 106
04100 Latina (LT), Italy
Email: support@copycut.it

Terms of Use · Cookie policy · Italiano