Updated: 6 October 2026
1. Controller
Christian Hermann & Martina Hermann GbR, An Rainen 3, 72525 Münsingen, Germany; email: apps@bitbeans.de.
2. Data processed
Language, appearance, introduction status, daily plan and exercise progress are stored only on the device.
For purchases, restoration and refund status, Pensaro processes a random anonymous purchase session, product ID, store platform and technical receipt data. Receipts are verified server-side and stored encrypted; there is no Pensaro account or visible sign-in. With a purchase we also store which page it came from (locked game, Settings or introduction), so that purchases per page cannot be miscounted; it is deleted together with the purchase data.
Limited purchase diagnostics are stored only as daily totals containing a funnel stage, platform, app version, fixed failure reason and, where applicable, the origin (test or store installation), then deleted after 14 days. Account, device, order and transaction identifiers are not transmitted with these diagnostics. If a purchase diagnostic or usage event comes from the networks Google publishes for its automated pre-launch tests (Firebase Test Lab), our backend counts it as test traffic; the IP address is only compared for this and not stored.
Anonymous usage and review statistics (from version 1.6.0): the app reports a few fixed events – introduction started, finished or skipped; first to third game started or finished successfully; first to third completed daily round and training round; Complete page opened from a locked game; Complete page opened and its buy button tapped, each with the page it came from (locked game, Settings or introduction); whether a rating request was possible, the fixed reason it was postponed or failed, whether it went to Apple or Google and whether the store page was opened from Settings. Each report contains only the event name, a fixed stage or reason, platform, app version, app language and, where applicable, the origin (test or store installation) – no identifier, no game, score or moves, and no stars or content of a rating. How often an event is sent is capped: introduction and Complete page at most once per installation; game started, game finished successfully, daily round and training round only the first to third time; whether a rating request was possible, made or postponed at most once per app version (postponed: per reason); a failed request at most once per day and reason, and opening the store page at most once per day; Complete page opened and buy button tapped at most once per day and page. Single reports are not stored but counted per day right away and deleted after 14 days; daily counters without identifiers copied into our internal operations overview are kept for at most 120 days. The legal basis is Article 6(1)(f) GDPR (finding errors, improving the app). As the reports contain no identifier, we cannot link them to a person (Article 11 GDPR). You can object under Article 21 GDPR at any time via apps@bitbeans.de.
Game history stays local, limited to 90 calendar days and 2,000 completed games. Voluntary feedback sends your message, optional contact details, category, app version, platform and language to our backend. Game reports also include the game ID, seed, level, mode and, where applicable, trial; you can inspect this context before sending. A random request ID prevents duplicate reports. The IP address is hashed for abuse prevention. Feedback is deleted after 180 days. There is no advertising or advertising tracking.
3. Purposes and legal bases
We process data to provide the app, verify purchases, deliver online features you actively use, maintain security, resolve errors and answer voluntary requests. Depending on the operation, the legal bases are Article 6(1)(b), (f) or, where expressly requested, (a) GDPR.
4. Recipients and service providers
We use Cloudflare for anonymous purchase sessions, secure purchase verification, restoration, refund status, aggregate purchase diagnostics, the anonymous usage and review statistics and storage and internal email delivery of voluntary feedback. Apple and Google process store purchases and payments as independent providers.
5. International transfers
Some providers may process data outside the EU or EEA. Where no adequacy decision applies, transfers rely on appropriate safeguards, in particular EU Standard Contractual Clauses, or on applicable statutory exceptions.
6. Advertising and tracking
The app contains no third-party advertising. We do not create advertising profiles, sell personal data or use advertising tracking.
7. Retention and security
Local data remains on the device until it is removed in the app or through system settings. Server data is retained only for as long as required for the respective function, security and statutory evidence. Transfers are encrypted.
8. Delete data and account
Local data can be removed in the app or through the device’s system settings. Where an account or cloud data exists, deletion can be requested in the app or by emailing apps@bitbeans.de. Store purchases are managed separately by Apple or Google.
9. Your rights
Subject to the statutory requirements, you have rights of access, rectification, erasure, restriction, portability and objection. Consent can be withdrawn for the future. You may also lodge a complaint with a data-protection authority; the LfDI Baden-Württemberg is the authority responsible for our registered office.
