The short of it
Zaboji has no registration, keeps no profile of you, posts no times anywhere, carries no advertising, measures nothing and runs no mailing list. Beneath that run of absences sits one more that turns the rest from a promise into something checkable: the package asks Android for no internet permission. An application that has not asked for one cannot be given a connection, whatever its code attempts, and the permission list is public on the store before you install.
Whatever the game remembers of you — rooms finished, move and push counts, the half-tidied storeroom you walked away from — is written into the private area Android sets aside for this application alone, and travels no further. No copy of it reaches any machine of ours, so nothing here belonging to you can be mislaid, sold, leaked or handed over on demand.
Eleven crates follow. Between them they carry what the General Data Protection Regulation expects a notice like this to carry, and the final crate names where to take an argument about any of it.
The controller
ControllerRACUNAJ NAME d.o.o.
Formdružba z omejeno odgovornostjo, registered in Slovenia
AnswerableGrega Hočevar
SeatVodnikova cesta 31, 1000 Ljubljana, Slovenia
For this pagezaboj@racunaj.online
ApplicationZaboji — com.pushcrate.zaboji
"Controller", in Article 4(7), is whoever determines why personal data is processed and by what means. Fastened to this page the title brings one duty that is not ceremonial: that the crates below were packed honestly, and that a named person answers for any found to be mislabelled.
No data protection officer has been designated. The appointment is obligatory in three defined cases — a public authority, a core activity of large-scale systematic monitoring, large-scale handling of special categories — and a bookkeeping firm with a puzzle on the side matches none of them, so naming an officer would be a flourish rather than a safeguard.
The full contents
A puzzle with dozens of rooms must remember a little or every evening would begin at the first room. This is everything it keeps:
- Rooms completed, and in which pack, so the room list can show how far along the warehouse you are.
- Moves and pushes on each, kept against the par so a tidier run can be recognised as one.
- Stars earned per room.
- The room in progress, together with the undo history of this sitting, so shutting the app does not throw away the planning.
- Hints remaining in the allowance.
- Settings: interface language, Slovenian or English, sound, haptics, the control style, reduced motion.
Now take the list apart for what it withholds. Your name is never requested. No address of any sort is retained. The identifier Android keeps for advertisers goes unread. Nor is any assortment of handset properties collected and combined into something that would work as a fingerprint. And the app issues itself no installation number — which is the quiet omission doing most of the work here, because without one there is nothing to tell your copy of Zaboji apart from the next person's, by us or by anybody. Android adds a second wall around it: that private area is closed to every other app installed on the same telephone.
Remove the game and the whole list goes with it. To empty it and keep the game, the settings screen carries a reset, and the identical result is available from Android's own app settings under "clear data".
Why Article 6 does not appear
The usual shape of a notice is an item, then a lawful ground, then the next item. This one names no ground anywhere, and that calls for an argument instead of a gap.
Grounds answer a challenge — on what footing do you hold this? — and a challenge needs a holder and a thing held. Neither exists here. What crate 03 lists is held on a device that is yours and unreachable from here, and it identifies nobody: with no identifier among them, what remains is a tally of how one telephone fared against a few storerooms. The Regulation needs two things present before it bites: personal data, and someone processing it. Neither is present, and the second could not be without the first.
All of which holds only while the premise does. Should some later version acquire a login, a banner, a counting library or a till, the premise falls, and this text has to be redrawn and shipped with whatever version introduces that, each addition arriving with its ground named. A comment at the foot of this file explains how, in some detail.
Consent banners are absent for a related reason. What those rules catch is reading from or writing to a person's own equipment where it is not strictly required for the service they asked for; in the field that means an embedded browser, a measuring pixel, or a marker dropped by some third-party component. None of the three is in this game, nor any connection one could report over, which leaves the Slovenian implementation of those rules with nothing in this app to apply to.
One asked for, the rest refused
Asked
Vibration, for the short thud when a crate settles onto its mark, and only while you leave that switch on. The system grants it silently, and a buzzing motor tells nobody anything about its owner.
Not asked
Nothing whatever beyond that. Not the network, and therefore also not the camera, the microphone, your whereabouts, the address book, shared storage, the state of the telephone or the notification tray.
That refusal on the right is what the rest of the document rests on. Without a route out, a sentence about where data ends up stops being an intention you are invited to trust and becomes a property of the published package, confirmable by anybody prepared to open it.
A permission prompt you did not expect is worth declining and worth reporting: the version number sent to zaboj@racunaj.online settles it. There are two possibilities — this page has fallen behind the build, or the build is not one of ours — and both are worth knowing quickly.
What happens before the game opens
Every crate so far describes Zaboji in use. Obtaining it happens earlier and elsewhere, as a transaction between you and Google. Google logs the installation, each update afterwards and any rating you post against whichever account you were signed in with, under the terms it publishes for its own services. That arrangement does not include us and we cannot change what it preserves.
The Play Console gives us a summary and nothing finer: installation totals, a breakdown by country, groupings of crashes, an average score. Nothing in it descends to one person or one device. The account stays wholly on Google's side — the address it was opened with, any card against it, the handsets it has signed into — and the controls over Google's own retention live inside that account, which is where such a request has to be put.
One caution about the listing. A review is public the instant it is posted, under whichever display name the account carries, and remains readable to every later visitor the listing receives.
An empty manifest
A processor is somebody who handles data on a controller's behalf, which first requires data being handled. None of the usual contracts exists behind this game: there is no hosting account, no measurement subscription, no crash-reporting service, no advertising network, no mailing platform and no payment agent. They were not negotiated and declined — the work they would perform is simply not performed. So when Article 13(1)(e) asks which categories of recipient there are, the manifest comes back blank, and that blank is the complete answer.
Transfer abroad closes the same way. The whole toolkit for sending data abroad — a Commission adequacy finding, the model clauses, the narrow exceptions in Article 49 — exists to license a movement. No movement happens. A tally of pushes made on your handset was recorded on that handset and has been nowhere else since.
Put here so it reads as where our part stops rather than as something left unsaid: what crate 06 sets out happens on hardware Google owns, under terms Google holds with you, and the whole of it concludes before this game is launched for the first time.
Duration and audience
Duration. A term in months belongs in this clause when the keeping is done by someone the reader cannot reach. That is not the arrangement here, so what follows is a condition instead of a figure: what is stored survives for exactly as long as you choose to keep it, and the reset button or an uninstall finishes it on the spot. Nothing is copied overnight into a backup, nothing older is filed away, and no server of ours carries a version able to outlive what you decided.
Audience. Zaboji is rated for a general audience, and shoving crates about a tiled floor is a sane way for a child to spend an afternoon. A parent checking a children's game normally looks for four things: adverts pitched at the child, something buyable within reach of a clumsy finger, a channel strangers can speak through, and content other users have contributed. None of the four was ever built in. There is also Article 8, which marks the age under which a parent must authorise a child's consent to an online service. It has nothing to operate on here: no player, of whatever age, is ever asked to consent to anything. ZVOP-2 fixes that age at 15 for Slovenia. It is noted now so that the number is already written down should advertising ever be introduced and the point suddenly matter.
Eight rights and their true outcome
All eight belong to you undiminished. Only the place of exercise is unusual: for this game it is nearly always the handset itself rather than our postbox. Printing a formal request route whose single possible output is a letter reading "there is nothing here" would fatten the page and help nobody, so the manifest below records what would really happen.
Access · 15The reply would be a couple of lines saying that nothing of yours is held here. Everything the game has recorded is on the room list, in front of you, without a request to anybody.
Rectification · 16No record of ours could be inaccurate. A push count that does you too little credit is corrected by tidying that room more neatly.
Erasure · 17Yours directly and instantly: reset the record or delete the game. Nothing routes through us, so nothing can be refused, queued or drawn out to the statutory month.
Restriction · 18Puts a processing operation on hold until a dispute is resolved. There is no operation of ours to put on hold.
Portability · 20Concerns information a person gave a controller so it can be carried elsewhere. None was given, and what the game knows is already a file in your own hands.
Objection · 21There must be processing for an objection to land on. In its absolute form the right aims at direct marketing; this game conducts none.
Consent · 7(3)Nothing in the game was justified by asking your permission, because permission was never asked. There is none left standing to take back.
Automated decisions · 22Deciding whether a crate can move one square is a check of whether the square beyond it is empty. It shifts a drawing and determines nothing about you.
None of it carries a fee, none of it needs a form, and at no stage will you be asked to establish your identity. Checking identity protects one person's records from being released to another. With no records on this side the check guards nothing, and carrying it out would mean taking a document off you while assuring you that nothing is taken.
Taking it past us
The company is registered in Slovenia, which brings it under the General Data Protection Regulation together with Zakon o varstvu osebnih podatkov (ZVOP-2). Supervision is the business of the Informacijski pooblaščenec, the Information Commissioner, at Dunajska cesta 22 in Ljubljana, whose forms and guidance are at ip-rs.si.
Nothing obliges you to use Ljubljana. Article 77 gives a complainant a choice of forum: the authority of the state where you habitually live will take it, so will the one where you work, and so will the one covering the place you say the breach occurred. Choose on convenience and nothing else. No wording on this page may narrow that, and wording that tried would carry no weight.
On order of events, as a suggestion and not a condition: writing to this address tends to produce a reply within the day, whereas a supervisory authority must work through its procedure and its queue. That is a reason to write, not a duty, and there is nothing irregular about a complaint resting with the Commissioner while the correspondence with us continues.
The address, and the rule about revisions
Everything goes to one address: zaboj@racunaj.online. Send it a right you mean to use, a line here you believe is false, a permission dialogue crate 05 did not predict, or an ordinary question about how some part of it works. Slovenian and English are both read by the same person, as in the game itself.
Pišite nam mirno v slovenščini — isti naslov, odgovor pa dobite v slovenščini.
The version on the sign at the top moves whenever a word underneath it does. One rule governs when, and it does not bend: where a revision changes what actually happens — something kept that was not kept before, a third party brought inside the process, data crossing a border, another purpose adopted — the new wording ships bound to the update that brings the change about, rather than arriving a couple of weeks afterwards with the behaviour already running on people's telephones. So a glance at that version settles the one question worth asking, which is whether this text describes the copy on your telephone. Superseded versions are kept and will be sent to anyone who asks.