Privacy policy

In short: The Bustanli app sends no data to us. There is no account, no advertising, no analytics, no tracking and no crash reports. Progress and the names your child gives the animals in the game stay on the device. You take out a subscription through the store you got the app from, that is Google Play or Apple’s App Store. We never see payment details. The website sets no cookies and has no form.

This policy has three parts: Part A covers the app, Part B the website bustanli.com, Part C both. It follows the Swiss Federal Act on Data Protection (FADP) and, for people in the EU and EEA, the General Data Protection Regulation (GDPR). This English text is a translation. If the two versions differ, the German version applies.

Who is responsible

The app and the website are provided by:

Hazdret Zuka
Hofackerstrasse 18
8953 Dietikon
Switzerland

Email: kontakt@bustanli.com

For any question about privacy and for your rights (section 12), an email to this address is enough. We reply as quickly as we can, at the latest within the legal deadline: 30 days in Switzerland, one month in the EU.

Part A: The Bustanli app

1. What the app does not do

• No account and no sign-in.
• No advertising and no advertising ID.
• No analytics or statistics tools, no tracking, no user profiles.
• No crash reporting tool, no error reports sent to us.
• No server of our own: the app sends no data to us. Its only connection to the outside is the store, for the subscription (section 3).
• It does not download images, sounds, fonts or other content from the internet. Everything is inside the app.
• No access to location, camera, microphone, contacts, photos or files.
• No chat and no contact with other users.

2. What is stored on the device

So that your child can continue where they stopped, the app keeps a game state in the app’s protected storage on the device. It contains:

• learning progress, for example letters, verses and duas learned, places and islands visited, light seeds and blossoms in the garden;
• the companion animal your child has chosen, the other animals in the garden and the names your child gives them;
• which good deeds your child has tapped on a given day, for example “helped my parents” or “said a dua”;
• the settings from the parent area, for example language, school of law, time limit, sound and voice;
• today’s playing time, so the time limit works;
• whether a subscription is active and which one, so the app knows what is open even without internet.

The app does not ask for your child’s name, age, birthday or address. A made-up name is enough for the animals. Please do not enter a full name or an address there.

Some of this information says something about your family’s faith, for example the chosen school of law. Like everything else, it stays on the device. We have no access to the game state, never see it and cannot pass it to anyone.

No backup: On Android, the game state is excluded from backup to a Google account and from transfer to a new device. On iPhone, it is excluded from iCloud backup and from backup to a computer. As a result, after changing devices or deleting the app, the game starts from the beginning. A subscription is not lost (section 3).

Deleting: You delete the game state completely by deleting the app. On Android you can also use “Clear storage” for the app in the device settings.

3. Subscription and purchases through the store

You take out the subscription in the store you got the app from: Google Play or Apple’s App Store. The store operator processes the payment, the store account and payment details as an independent controller, Google under its privacy policy, Apple under its privacy policy. We receive no payment details, no names and no email addresses.

On the device, the app only asks the store whether the signed-in store account has an active Bustanli subscription, and remembers the answer. This way, a subscription comes back after a change of device with “Restore purchases” in the parent area.

For purchases, the app contains the store’s purchase interface: the Google Play Billing library on Android, Apple’s StoreKit on iPhone. It exchanges data with the store when a subscription is started or checked. Google’s library may also send technical logs to Google. The store operator’s privacy terms apply to this. We do not receive this data.

For accounting and tax purposes, the stores provide us with sales reports. At Google they may contain the order number, product, price, date, country and, depending on the country, the region or postcode. At Apple they are sales and subscription figures by product, country and date, sometimes with a random ID per subscriber that does not tell us who it is. The reports contain no names, email addresses or payment details. We use them only for accounting, taxes and refunds, and keep them as long as the law requires, in Switzerland usually ten years.

If, as an exception, we refund money ourselves because the store cannot (see the terms of use, sections 4 and 5), we need the name and bank details you give us. We use them only for that and for accounting.

You cancel a subscription in the store. Deleting the app does not cancel it. Details are in the terms of use.

4. Internet connection

Playing works without internet. A connection is only needed for the store: to start a subscription, check its status, restore purchases and download updates. These connections go through the store, not through servers of ours.

The parent area has links to this website, to the store’s subscription management and to our email address. They open the device’s browser or mail app. The rules of that page apply there, for bustanli.com Part B.

5. Children

Bustanli is made for children aged 6 to 8 and built according to the rules of Google Play and Apple for apps for children. Because the app collects no personal data from children, no parental consent is needed under the US Children’s Online Privacy Protection Act (COPPA) or under Art. 8 GDPR.

The parent area, the subscription and all links to the outside are behind maths questions for adults. In the children’s area there are no prices, no purchase buttons and no links to the internet.

Part B: The website bustanli.com

6. Visiting the website

The website is hosted by Hostinger. Our contracting party is Hostinger International Ltd. in Larnaca, Cyprus. Hostinger processes the data on our behalf, under its data processing agreement.

When you visit, Hostinger processes technically necessary information in server logs: IP address, time, the page requested, browser and operating system, and the page you came from. This is needed to deliver the site and keep it secure. Hostinger delivers the site through its own content delivery network (CDN), so your request is often answered by a Hostinger server near you. Hostinger runs servers mainly in the EU and the United Kingdom, but also in other countries, for example in the USA, Brazil, Singapore and Indonesia.

We do not analyse the logs unless it is necessary for security, for example during an attack. Hostinger keeps them only as long as needed for operation and security.

The website sets no cookies, uses no analytics tools, has no form and loads nothing from third-party servers. The fonts are served from the website’s own server. Links to Google Play or the App Store lead to pages of those providers, whose rules apply there.

7. Emails to us

If you write to us, we process your email address, your name if you give it, and your message to reply. We forward messages to this address to our mailbox at Google (Gmail). Google also stores them in the USA and is certified under the Data Privacy Framework for this.

We delete messages once the matter is closed, at the latest two years after the last message. We only keep them longer if they belong to our accounts, for example for a refund, or if we need them for legal claims.

Please only send us what your request needs, and no information about your child.

Part C: App and website

8. Sensitive data

Using Bustanli, taking out a subscription or writing to us can reveal something about a person’s faith. Such information is particularly sensitive (Art. 5(c) FADP, Art. 9 GDPR). We process it only for the purposes in this policy, do not analyse it and pass it only to the services in section 10, as far as needed for those purposes.

9. Purposes and legal bases for people in the EU

• Subscription, refunds, withdrawal and questions about a purchase: contract and pre-contractual steps (Art. 6(1)(b) GDPR).
• Accounting and taxes, keeping sales reports: legal obligations (Art. 6(1)(c) GDPR).
• Website server logs and replies to emails: our legitimate interest in a secure website and in answering enquiries (Art. 6(1)(f) GDPR).
• Information about your faith that you send us yourself in a message: your explicit consent (Art. 9(2)(a) GDPR). You can withdraw it at any time.

You are not obliged to give us any data. Without an email address, however, we cannot reply. We make no automated individual decisions and create no profiles.

10. Recipients and other countries

Data only reaches these services:

• Google (Google Play) and Apple (App Store): subscription, payment and sales reports, as independent controllers under their own privacy terms;
• Hostinger: website, as processor (section 6);
• the provider of our mailbox: emails (section 7).

Some of these services also process data outside Switzerland and the EEA. For countries whose data protection Switzerland and the EU recognise as adequate, such as the EEA states and the United Kingdom, no further safeguards are needed. For the USA, the providers rely on the Swiss-US or EU-US Data Privacy Framework where they are certified under it, otherwise on the European Commission’s standard contractual clauses. For all other countries, the standard contractual clauses apply, adapted for Switzerland as required. You can ask us for a copy of the safeguards.

We do not sell any data and do not pass on any data for advertising.

11. Data security

• The game state stays in the app’s protected storage on the device and is not transferred.
• The website can only be reached over an encrypted connection (HTTPS).
• We protect our accounts with the stores, the host and the email provider with strong passwords and two-factor sign-in.
• Only the provider himself has access to sales reports and emails.

12. Your rights

You can request access to your data, its correction or deletion, a restriction of processing and a copy of your data in a common format. You can object to processing and withdraw consent at any time. An email to kontakt@bustanli.com is enough. If it is unclear whether a request comes from you, we will briefly check.

We do not know data that only exists on your device. You manage it yourself, for example by deleting the app.

You can also complain to a supervisory authority: in Switzerland the Federal Data Protection and Information Commissioner (FDPIC, edoeb.admin.ch), in the EU the authority where you live or work.

13. For people in the USA

Section 5 covers children. We do not sell or share personal information as defined by California law, and we do not track anyone across websites or apps. Signals such as “Do Not Track” or “Global Privacy Control” therefore change nothing: there is nothing for them to switch off.

14. Changes

If the app changes so that this policy is no longer accurate, we update it beforehand. Should a tool that transfers data ever be added, it will be listed here before it is in the app. We also mention important changes in the app’s release notes in the store. The date at the bottom of this page shows the current version. The version on this page applies.