HoldBold Privacy Policy

Privacy Policy for HoldBold

Last Updated: May 3, 2026

1. WHO WE ARE

HoldBold is published and operated by "12MAV" LLP, a Limited Liability Partnership registered in the Republic of Kazakhstan, located at 55/16 Turan Avenue, apt. 348, Nura district, Astana, 010000, Republic of Kazakhstan (referred to as the “Company”, “we”, “us”, or “our”). We act as the Data Controller for the minimal data processed by the app. You can reach us at contact@12mav.io.

2. GLOBAL SCOPE & COMPLIANCE

This application is intended for a global audience. We strictly comply with applicable privacy regulations globally, including the GDPR (EU/UK), CCPA/CPRA (USA), LGPD (Brazil), Australia’s Privacy Act, and the applicable data protection laws of the Republic of Kazakhstan. Because we operate strictly on a local-first basis without backend user databases, we operate under applicable GDPR exemptions and do not require a physical EU representative.

3. PRIVACY-BY-DESIGN (LOCAL-FIRST PROCESSING)

HoldBold is an entirely offline, local pass-and-play party game. In strict alignment with Apple’s privacy guidelines, we process almost everything locally on your device:

No Personal Accounts: You do not need to register, create a profile, or provide a name or email to play.

No Server Uploads & No AI: All gameplay actions, category selections, and game progress are processed strictly locally. We do not operate backend servers to store your game sessions, we do not form personal data databases on our servers, and we do not use Artificial Intelligence (AI) to process your data or generate content.

No Biometric Data: The game mechanics require players to place their fingers on the screen. The app only detects basic capacitive touch coordinates (iOS UITouch data) to calculate gameplay physics. We do not scan, read, collect, or store fingerprints, Face ID, or any biometric data.

No Advertising Tracking (No IDFA): We do not collect or share data for third-party targeted advertising. We do not request access to your camera, microphone, photos, contacts, or precise geolocation. We specifically do not request, collect, or pass the Apple Identifier for Advertisers (IDFA) to any third parties.

4. INFORMATION WE COLLECT & LEGAL BASES

The only data that may leave your device is strictly related to premium purchases and voluntary customer support:

Subscriptions, Payments & Technical Data (Contractual Necessity): If you purchase a premium subscription, the transaction is handled entirely by Apple’s StoreKit natively on your device. We never see your credit card information. To verify purchases, restore access, and ensure tax compliance, we use a trusted analytics provider ("Apphud") operating in an anonymous "Observer Mode". To function, Apphud automatically generates a random, anonymous internal UUID for your device and collects strictly technical telemetry: an anonymous device identifier (IDFV), your IP address (used solely to determine your generalized region/country for correct tax calculations and pricing), Apple receipt data, OS version, locale, time zone, and device model. Under applicable privacy laws, this technical data is pseudonymous, does not allow us to directly identify your real-world identity, and is strictly necessary to fulfill our contract with you.

Diagnostics (Legitimate Interest): If opted-in via your iOS settings, Apple may share anonymous crash reports with us to help improve app stability.

Support Emails (Consent): If you contact us via the app’s “Contact Us” feature, the app will open your device's native email client and automatically pre-fill your Device Model and App Version into the email draft to help us troubleshoot technical issues. We process your email address and message purely to resolve your inquiry.

5. DATA STORAGE & CROSS-BORDER TRANSFERS

We do not sell your personal data. In compliance with applicable data localization laws in our jurisdiction of incorporation, we officially declare that we do not collect, form, or store databases containing identifiable personal data of users on our own servers. The pseudonymous technical data (IP address, IDFV, UUID) processed by Apphud is transferred to secure servers located in the United States. By using the App and initiating a purchase, you explicitly consent to the cross-border transfer of your pseudonymous technical data and support communications for the purpose of validating your purchases and providing support. We rely on Standard Contractual Clauses (SCCs) and Apple’s secure infrastructure to ensure your data is protected globally.

6. DATA RETENTION & SECURITY

Game Data: Saved locally on your device and permanently deleted when you uninstall the app.

Receipt & Technical Data: Retained by Apple and Apphud as long as legally required for tax, accounting, and subscription validation purposes.

Support Emails: Deleted routinely after your issue is successfully resolved.

7. AGE LIMITS

Our Services feature mature and adult themes. While app distribution platforms (such as the Apple App Store) may assign a specific content-based age rating (e.g., 17+) according to their classification rules, our legal terms require you to be at least 18 years old (or the age of legal majority in your country) to legally use this App and make purchases. We do not knowingly collect personal data from minors.

8. SUPPLEMENTAL PRIVACY NOTICE FOR USA RESIDENTS

This section supplements our Privacy Policy for residents of U.S. states with specific privacy laws (including California, Colorado, Connecticut, Utah, and Virginia).

No Sale or Sharing of Data: We do not sell your personal information for monetary value, nor do we "share" it for cross-context behavioral advertising.

Your Rights: You have the right to request access to, correction of, or deletion of the personal data we hold about you (primarily support communications). You also have the right to not be discriminated against. To submit a verifiable request, please email contact@12mav.io with the subject "USA Privacy Rights Request."

9. YOUR GLOBAL PRIVACY RIGHTS & HOW TO DELETE YOUR DATA

Depending on your jurisdiction, you have the right to request access to, correction of, or deletion (erasure) of your personal data, and to withdraw consent. You can exercise these rights by contacting contact@12mav.io.

Important Notice Regarding Data Deletion: Because HoldBold is designed with strict privacy principles, we do not require user accounts and do not operate backend servers. The technical telemetry processed by our analytics provider (such as an anonymous IDFV or UUID) cannot be linked to your real-world identity or email address. In accordance with applicable privacy laws (including Article 11 of the GDPR - "Processing which does not require identification"), we are not legally required to acquire additional information to re-identify your device solely to comply with a deletion request.

Therefore, the data deletion process is handled as follows:

  • Local Game Data: All your game progress and settings are stored entirely on your device. To permanently delete this data, simply uninstall the App from your device.
  • Support Communications: If you have voluntarily emailed our support team, you can request the deletion of your email address and correspondence by emailing contact@12mav.io. We will physically and permanently delete the email thread from our support inbox.

10. CHANGES TO THIS POLICY

We may update this policy to reflect legal or technical changes. The “Last Updated” date will reflect the most recent revisions. Continued use of the app implies your acceptance of the updated policy.