Privacy Policy
for the app “Pocket to Portfolio” and this website · Last updated: October 15, 2026
This translation is provided for information. In case of doubt, the
German version prevails.
In short
- You don't need an account and don't have to sign up.
- Your game progress stays on your device. We don't run any servers for the app.
- We don't analyze anything ourselves: no tracking, no analytics tools, no push notifications.
- Personal data is only processed by the services listed below: Google for ads and – only if you buy “Gold” – Google Play or the App Store and RevenueCat.
1. Controller
decly UG (haftungsbeschränkt), represented by Şafak Güz
Wiesenstraße 48, 13357 Berlin, Germany
Email: privacy@decly.app
More details in our legal notice (Impressum).
2. Data on your device
The app stores your game progress only locally in the app storage on your device: the player name you choose, your character, the selected currency, your progress, whether “Gold” is unlocked and how many reward videos you've watched today. This data is not sent to us. You can delete it by starting a “New life” in the app, clearing the app data in your device settings or uninstalling the app.
3. Ads with Google AdMob
To keep the app free, it shows video ads: optional reward videos (e.g. “refill energy now”) and a short ad break every two game years. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).
- Data processed: your device's advertising ID (unless you have disabled it), IP address, device and app information (e.g. model, operating system, language) and interactions with ads.
- No personalized ads: Because the app is also played by teenagers, we only request non-personalized ads from Google. No advertising profiles about you are created or used for ads.
- Consent: On first launch – where required by law (e.g. in the EU, the UK and Switzerland) – we use Google's consent dialog to ask whether Google may store or access information on your device (Art. 6(1)(a) GDPR, Section 25(1) TDDDG). If you decline, Google only shows limited ads without storing or accessing information on your device. You can change your choice at any time in the app's privacy settings.
- Other purposes at Google: Google also processes data to deliver ads, for billing and to prevent fraud (Art. 6(1)(f) GDPR; our legitimate interest is funding the free app).
- Transfers: Google may transfer data to the USA. Google LLC is certified under the EU-U.S. Data Privacy Framework.
More: Google Privacy Policy · How Google uses information from apps that use its services
4. Buying “Gold” (in-app purchase)
“Gold” is a one-time unlock. The purchase is handled entirely by Google Play or the Apple App Store. Your payment details are processed only by these providers – we never receive payment details, only a confirmation of the purchase.
To verify purchases and restore them on a new device, we use RevenueCat (RevenueCat, Inc., USA). This involves a random app user ID, the purchase receipt (product, time, country, currency, price) and the app and operating system version. The legal basis is the performance of the purchase contract (Art. 6(1)(b) GDPR). Transfers to the USA are based on the EU Standard Contractual Clauses. More: RevenueCat Privacy Policy
5. App stores
When you download the app from Google Play or the Apple App Store, these providers process data under their own responsibility (e.g. account, download, crash reports if you have enabled them). Their privacy policies apply.
6. Children and teenagers
The app is intended for players aged 13 and up. There is no account, no chat and no content you share with others. We do not knowingly collect personal data from children.
7. This website
This website is hosted on GitHub Pages (GitHub, Inc., USA). When you visit it, GitHub processes your IP address and technical information (e.g. browser, time) to deliver the page and keep it secure (Art. 6(1)(f) GDPR). The website sets no cookies, loads no external fonts and uses no analytics tools. GitHub is certified under the EU-U.S. Data Privacy Framework. More: GitHub Privacy Statement
8. Retention
Data on your device stays there until you delete it (see section 2). Data held by Google, RevenueCat, the app stores and GitHub is subject to their retention periods.
9. Your rights
You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and to object (Art. 21). You can withdraw your consent at any time with effect for the future. Just email us at privacy@decly.app.
You also have the right to lodge a complaint with a data protection supervisory authority, for example the authority responsible for us: Berliner Beauftragte für Datenschutz und Informationsfreiheit, Alt-Moabit 59–61, 10555 Berlin, Germany.
10. Changes
If the app changes, we will update this privacy policy. The version published here applies.