Moment one
Before you install anything
You are on the Google Play listing, and the most useful thing on it is not written by us. Under
App permissions Google prints what the package actually asks for, taken from the package
itself rather than from our description of it. For Kulebane that list contains no network
permission. Everything else in this notice follows from that one line, and you can check it
before committing to anything.
Children
Kulebane suits any age and is not aimed at children in particular, nor entered into any children's
programme on the store. Norwegian law puts the age at which a young person may consent on their own to
an information society service at 13 — personopplysningsloven § 5 — but that
number decides nothing here, because nothing in this game asks anyone of any age to agree to anything.
A child can play the whole thing through on a handset that has never once had a signal, and nobody anywhere will learn that they did.
Moment two
The second you press install
Google writes the download against your Play account. That record belongs to Google, is made under
Google's own privacy notice with Google answering for it as controller, and exists before a single line
of our code has run. Never opening the app will not undo it, and we are not a party to it — Cloud
Eldring has no window onto that side of the transaction and cannot switch it off for you.
Moment three
The first time the app opens
A board appears. That is the whole of it. There is no registration screen, no sign-in, no profile to
create, no nickname to choose, no e-mail field and no consent dialogue — the last of those is absent
because consent is a basis for processing data, and there is no processing here to find a basis for.
Your name, postal address, telephone number and date of birth are never requested, at this moment or any
other.
Nor does anything get read off the handset. Not the advertising identifier. Not the Android ID, the
serial, the IMEI or the MAC address. Not an inventory of your other software. And no home-made token is
minted on the device to serve the same purpose by another name.
Moment four
While you are laying out a run
Dropping a ramp into a slot amounts to a finger on glass: the game reads it, acts on it, and lets it
go. Coordinates go unrecorded. The pause while you stare at a splitter is not measured. The order you
attempted things in is not retained in any form. Your thinking leaves nothing behind — which is also the
reason nobody here can tell you how other players solved a board.
Moment five
When you press release
The marble rolls, and every rule governing it runs on the processor in your hand. Nothing is sent
anywhere to be computed, nothing is checked against a server, and no result is reported back. A run that
works and a run that dumps the marble on the floor are equally private events.
Moment six
When you walk away mid-board
So that a half-built run survives being interrupted, one small file is written — on your device, and
nowhere else:
Progress
The packs and boards unlocked so far, and which of them are finished
Your bests
Fewest pieces and best star count on each board
Work in progress
Exactly where you left each piece on an unfinished board
Settings
Your choices for sound, vibration, how hints behave, and which wood finish is on
Android hands each app a storage area of its own, shut off from its neighbours, and that is where the
file goes. It is never read by us. Nothing synchronises it, nothing backs it up at our
end, and no duplicate of it exists anywhere on earth. Asking whether the GDPR covers it rather misses the
point: data has to be in somebody's possession before it can be their responsibility, and this is in
yours, on hardware you own.
Moment seven
When the phone has no signal
Nothing changes. Every board, every piece and every star is already on the device, so the game in
flight mode is the game. There is no queue of events waiting to be uploaded when a connection returns,
because nothing was ever queued and there is nothing to upload it with. This is the easiest claim in the
document to test, and testing it takes about four seconds.
Moment eight
Meanwhile, underneath, Android
Every app sits on top of an operating system that reports to its maker. Depending on what was chosen
when the handset was first set up, Android may forward diagnostic, usage and crash information to Google
about the software running on it, Kulebane included in the sweep. No application asks to be included and
none can decline on your behalf.
Google's own notice governs it; your handset's settings adjust it; both are reachable without us being
involved at any point, and nothing from it comes back to us. It is included because moments three to seven,
taken alone, would leave you believing that not one byte ever departs the phone. That version is neater
than the facts, and neatness is not what this page is for.
Moment nine
If you leave a review
Four things arrive at once: whatever name your Play profile carries, how many stars, what you wrote,
and when. Underneath sits a reply box that is public, and we may use it. In this entire document that is
the sole channel delivering a nameable human to us without a letter being written, and it is one you
choose to open.
The review lives in Google's system, so we cannot take it down for you; editing or deleting it inside
the Play Store is the way, and it is entirely in your hands. Treat it as the public notice board it is,
and keep anything private for the next moment.
Moment ten
If you write to us
Then, and only then, Cloud Eldring holds something about you: your e-mail address and whatever you put
in the message. It is kept while the matter is open and deleted once it is finished, is added to no list,
and goes to nobody else — there is nobody else. The basis is Article 6(1)(f), the evident interest anyone
has in being able to answer their own post.
That inventory is complete. Nothing is marketed, nobody is profiled, no machine reaches a conclusion
of the sort Article 22 is written about, and not a line of it is sold or passed along. Nor is anyone
engaged to handle it on our behalf — there is no host, no server, no helpdesk and no contractor — which is why
no Article 28 arrangement appears anywhere in this notice. Nothing of yours crosses an EEA border at our
hand, so the Chapter V machinery of clauses and derogations has nothing to attach to.
Everything you are entitled to put in that letter
The Regulation reaches Norway through the EEA Agreement and takes domestic form as
personopplysningsloven (LOV-2018-06-15-38). It gives you eight distinct entitlements, and they
are yours whatever any website says. Rather than park them in a clause of their own, here they are where
you would actually use them — as the things you may ask for, each with the answer you would get:
- Tell me what you hold.Art. 15 Nothing, unless this letter or a review is it — and you will get that in writing.
- Correct something wrong.Art. 16 There is no record of you to be wrong about.
- Delete it.Art. 17 Say the word and the letter goes. The save file is already yours to erase in two taps.
- Stop working on it.Art. 18 No work is under way on your data to pause.
- Hand it over in a usable format.Art. 20 There is no dataset here to package up.
- I object.Art. 21 The only legitimate interest claimed is answering this very letter, and no marketing is sent.
- Don't let a machine decide about me.Art. 22 Nothing in Kulebane forms any judgement about you at all.
- I take back my consent.Art. 7(3) You were never asked for any, and that is precisely why the game opens without a dialogue.
Turn those eight on Google and they have weight, because moments one, two, eight and
nine finish on Google's side of the fence and not ours. The controls sit in your Google account under
privacy, and Google publishes a route for formal requests. A request to us costs nothing, needs no particular
form and is answered inside a month. The Regulation builds in two reliefs and it is only fair to name them: a request too vague to identify
whose data is at stake may be met with a question before anything else, and one that is plainly
disproportionate or sent over and over may be declined outright.
Moment eleven
If you think this page is wrong
Nobody has to clear a complaint with us before making it, and no prior exchange is required.
kule@cloudeldring.yachts exists if you would like to try
here first; it is an offer, not a hurdle.
In Norway the body that hears these is Datatilsynet. Write to Postboks 458 Sentrum,
0105 Oslo, or begin at
datatilsynet.no. An EEA
resident outside Norway can raise precisely the same complaint with their domestic authority, and any
court action is properly brought where that person lives.
If you do go, take this with you: moment one is not an assertion of ours. Google compiles that
permission list from the binary it hands out, so the productive instruction is to have somebody open the
package, not to interrogate the people who wrote this sentence.
Moment twelve
When you clear the app's data
Android Settings → Apps → Kulebane → Storage → Clear data removes the file from
moment six in one action. Your boards reset, your bests are gone, and nothing of it survives elsewhere,
because it was never copied elsewhere. We are not notified, and would have no way to be.
Moment thirteen
When you uninstall
The same erasure happens, plus the app itself. What survives is on Google's side, not ours: the
installation record from moment two, now carrying an uninstall against it, and any review you left in
moment nine, which stays until you remove it. We see one thing change — a number in a count of
uninstalls, pooled with everyone else's and resolving to nobody.
Moment fourteen
If you come back a year later
Install it again and it will not know you. There is no account to restore, no profile waiting, no
history to sync down and no greeting that mentions last time. You start at the first board with an empty
save file, exactly as a stranger would, because as far as this software is concerned that is precisely
what you are. For most products that counts as a failure. Here it is the design.
Kristina Eldring
Controller · a private individual
Hagelundveien 8, 0963 Oslo, Norway.
Data enquiries: kule@cloudeldring.yachts
Everything else: post@cloudeldring.yachts
Norsk går like bra som engelsk — skriv på det språket du vil.
Cloud Eldring is a name used for publishing and nothing more — no AS, no ENK, no
registered legal form of any kind, and therefore no organisation number to quote. The person legally
answerable is the one named here, and whoever the Google Play listing shows as developer is the same
person. Nobody holds the title of data protection officer here. The three situations Article 37 names — a public
body, systematic monitoring at scale, special-category data at scale — describe organisations of a
different order entirely from one person publishing a puzzle that cannot reach a network.