Privacy Policy

Spomin · com.parcki.spomin · AK Company

In force 8 October 2026 · first edition

Spomin is a memory game that runs on the phone it is installed on and nowhere else. No account, no advertising, no analytics, no server of ours. Nothing turned over, matched, timed or set is transmitted to AK Company or to anybody else. The listing says plainly that children play this game, which changes what a page like this owes you — so the fourth card is about exactly that.

What Spomin keeps on the phone

Android gives every app a private storage area that no other app can read. Spomin writes four things into it:

All of the symbols are drawn by the app, so nothing on the cards arrived from anywhere. The four items sit in the app's own storage, they are copied into a device backup only if Android's backup is switched on — in which case Google holds that backup under Google's terms and we never see it — and uninstalling takes all of them away.

What it never does

These describe the build on the store today. The last card sets out the order in which any of them would have to be withdrawn if that changed.

Clearing it

Starting a new round replaces the saved one, and the records have their own reset where they are shown. For everything at once, Android's own app settings will clear Spomin's storage while leaving the app installed, which returns it to its first run — no round in progress, no records, board size and deck back to their defaults.

Neither route needs anything from us, and neither can be undone, because no second copy of any of it was ever made anywhere.

A child is going to play this, and that changes what this page owes you

Most privacy policies for small games treat children as a formality: one short paragraph saying no data is knowingly collected from anyone under sixteen, and on to the next heading. That paragraph is true here. It is also not the honest version, because the store listing for Spomin does not merely tolerate children — it invites them. A game to share with a child; small children and grandparents at the same kitchen table. When an app is presented that way, saying “we collect nothing from minors” is answering a question nobody asked.

The question a parent actually has is simpler: what happens to my child while they are using this? So, directly.

Nothing about them leaves the phone

Not their name, because the app never asks. Not their age, because the app never asks. Not how long they played, how quickly they finished or how many tries it took, because none of that is sent anywhere — the records sit in the app's own storage and are readable only by the app. There is no account to create, no profile to build and no identifier in the build that could follow a child to another app or another device.

Nothing is shown to them that we did not draw

Every symbol on every card is generated by the app. There is no advertising, which means no third party chooses what appears in front of a child here, and nothing in the app can be swapped out remotely after you have looked at it. The screen a parent approves today is the screen the app shows tomorrow.

Nothing in it asks for money or attention

There is no purchase, no currency, no streak, no daily reward and no notification. A child can put the phone down after one round and the app will not come looking for them. That is a design choice with a cost — those mechanisms are precisely what make children's apps profitable — and it was made deliberately.

Why this is written out rather than summarised

Because the shortcut is so easy. An app aimed at children that adds an advertising library inherits an entirely different set of obligations overnight: who may serve the ads, what may be collected, what the ads may contain, how the store listing must be filled in. A single line of code moves the app into that world, and a policy that had only ever said “no data from minors” would still be technically true while telling a parent nothing useful. If Spomin ever changes in that direction, this card gets rewritten in full before the build ships — not quietly extended.

Who is responsible

Somebody has to be named, even when there is almost nothing to be named for, and Article 13 says so. That somebody is AK Company, at Mostecno 12, 2321 Makole, Slovenia; the person who answers for it is Arbulena Kokollari.

The whole of what falls under that name is an inbox. Nothing travels from the app to us, so there is no second layer of processing standing behind the business waiting to be discovered. Downloading Spomin, or letting Google Play update it, is an arrangement between you and Google under Google's own terms — unchanged by who happens to have published the app.

If you write to us

The address is par@akcompany.space, and a person reads it. Whatever you send — the address it came from, the words in it, anything clipped to it — is kept only while the question is open and briefly afterwards in case it turns out not to be, and then it is gone. Article 6(1)(f) covers it: the legitimate interest in question is somebody replying to post about their own software. It never becomes a mailing list, never goes anywhere else, and never sells anything to anybody.

One request in return, and it is the only one on this page. If you are writing about something a child did in the app, please leave the child out of the message — no name, no age, no school, no photograph. Describe the board and what happened. We do not need to know who they are, and it is better for everybody if we never find out.

If a parent is reading this

Two laws sit behind this: the General Data Protection Regulation, and Slovenia's own Zakon o varstvu osebnih podatkov (ZVOP-2) beside it. Between them you get the usual entitlements — to know, to have a copy, to have mistakes fixed, to have things deleted or frozen, to say no, and to carry what is held away with you. What is worth setting out is not that list, which every page carries, but how far it actually gets for each of the three people likely to reach for it here.

A parent, on a child's behalf

You may ask us anything your child could ask, and you do not need to prove the relationship, because the honest answer does not depend on it: we hold nothing about your child. There is no account, no identifier and no record anywhere in our systems that the app was ever installed, let alone by whom. You will get that in writing, within days rather than the month the Regulation allows, and with this page cited.

A child, on their own behalf

The same rights apply to them directly and reach exactly as far — which is to say, to nothing. If a child writes to us, they get a real answer in plain words, not a form and not a redirection to a parent.

An adult player

Identical again. Where you have written to us before, the rights apply in full to that correspondence: we show it to you, send you a copy, correct it, erase it on request, or stop using it altogether — an objection ends the only processing there is. No charge, no particular form of words.

What none of the three can reach is the handset. The round in progress, the records and the settings are not in our possession and never have been; the third card above describes the few seconds it takes to clear them. And if what you get back from us is unsatisfactory, you are not obliged to argue about it: Slovenia's regulator, Informacijski pooblaščenec, the Information Commissioner, is at ip-rs.si and will hear from you whether or not you came to us first. Readers in other EEA countries have the same route through their own national authority.

If this page is ever rewritten

Only one date appears on this page, and whatever it says is the version you are bound by. Rewriting is cheap, which is exactly why the sequence matters: if a future build would falsify a single sentence above — because something began to be gathered, something began to be sent, a library arrived, a permission appeared — then the correction to this page comes first, the Play Console's Data safety answers are brought into line in the same sitting, and the build waits until both are done. Nobody downloads a version whose description is still in the future.

Tidying a clumsy sentence is not that kind of change, and buys nothing except a later date at the top.

Old editions are not thrown away. Write to the address below and whichever one you want comes back to you, which is the only mechanism by which anyone outside this business can check that the paragraph above was ever honoured.

AK Company

Mostecno 12, 2321 Makole, Slovenia

Responsible person: Arbulena Kokollari

Email: par@akcompany.space

Application: com.parcki.spomin

Pišite nam v slovenščini — odgovorili vam bomo v slovenščini.