Privacy Policy

Astuto Ltd  ·  Company No. 17263058  ·  privacy@astuto.gg  ·  Last updated 8 October 2026

1. Who we are

Astuto Ltd, a company incorporated in England and Wales, company number 17263058, with its registered office at 66 Paul Street, London, England, United Kingdom, EC2A 4NA ("Astuto", "we", "us", "our"). Operates the Astuto mobile application (the "App").

This Privacy Policy explains how we collect, use, store, and share information about you.

Contact — Email: privacy@astuto.gg · Website: astuto.gg

2. What this policy covers

This Privacy Policy applies to users in the territories where the App is currently available: the United Kingdom, the United States of America, Australia, and Mexico.

The App is not currently available in the European Union or EEA; EU/EEA coverage is planned for a future phase and is not addressed by this version.

3. Information we collect

3.1 Information you provide directly

InformationWhen collectedWhy required
Display name At registration Identify you on leaderboards
Country At registration Country-specific leaderboards and prizes
Birth year (year only) At registration Age eligibility (16+ to use the App; 18+ for prizes) and age-appropriate content and ad treatment. Self-declared; not verified.
Topic preferences At registration / when updated Personalise quiz questions
Prize email address Optionally, in Profile To send Amazon gift card prizes

Your email address is optional. You can use the App fully without providing one; an email address is only required to claim a prize.

3.2 Information generated automatically

InformationDetails
Device IDA randomly generated anonymous identifier stored on your device. Not linked to your name or email unless you choose to provide one.
Quiz answers and scoresYour responses to daily questions, time taken per answer, and calculated scores.
Leaderboard positionYour daily and monthly rank within your country.
Streak, XP and lifelinesConsecutive-play streak, experience points, and reveal/streak-shield balances.
Rewards and entitlementsStreak Shields, ad-free time earned by referring friends, and Astuto Plus subscription status.
Friend connectionsPlayer IDs of users you connect with via the Friends feature.
App usage dataScreens visited, features used, session duration.
Device and network infoDevice type, OS version, app version, country-level location via IP at onboarding only.

3.3 Information from third parties

4. How we use your information

4.1 To operate the App

Legal basis (UK GDPR): Performance of a contract (Article 6(1)(b)).

4.2 To improve the App

Legal basis (UK GDPR): Legitimate interests (Article 6(1)(f)) — improving a service we provide.

4.3 To serve advertising

Google AdMob serves advertisements in the ad-supported version, including rewarded ads you may choose to watch to earn Streak Shields. Advertising treatment depends on territory and declared age:

Legal basis (UK GDPR): Consent (Article 6(1)(a)) where required.

4.4 Aggregate statistics

We may produce anonymised, aggregated statistics that do not identify any individual. We do not sell individual user profiles or personal data. At launch, the only use of data for advertising revenue is AdMob ad serving as described in §4.3.

4.5 Legal compliance

5. Prizes and age verification

Prize competitions are open to residents of the countries listed in the Prize Rules (the UK at launch) who are 18 or older. We collect your birth year (year only) at registration to enforce this requirement; this information is self-declared and we do not independently verify it, so we rely on the accuracy of what you tell us. Providing false age information to claim a prize may result in disqualification and account suspension.

US state exclusions: prizes are not available to residents of New York, Florida, and Rhode Island. Users in those states may play but are excluded from prize eligibility until Astuto completes registration there (see Terms §6).

6. Third-party services

ServicePurposePrivacy policy
Google AdMob (Alphabet Inc.) Serve advertisements (personalised subject to consent; contextual for under-18s) policies.google.com/privacy
RevenueCat Inc. Manage the Astuto Plus subscription revenuecat.com/privacy
Amazon Web Services Infrastructure (eu-west-2, London) aws.amazon.com/privacy
Amazon (gift cards) Gift card issuance amazon.co.uk/privacy
Expo / Firebase (Google) Push notifications policies.google.com/privacy

7. Data storage and security

7.1 Where your data is stored

All personal data is stored in the United Kingdom on AWS infrastructure in eu-west-2 (London). We do not transfer personal data outside the UK without an appropriate legal mechanism (UK IDTA, EU SCCs, or an adequacy decision).

7.2 Security measures

7.3 Retention

Data typeRetention period
Quiz history (submissions, answers)90 days, then automatically deleted
Streak shield history (what added or used a shield, and when)90 days, then automatically deleted
Leaderboard records (score, rank, date)12 months
Account data (display name, topics, streak, lifelines)Until account deletion is requested
Prize email addressUntil deletion requested, or 7 years if a prize was issued (tax records)
Device ID and JWT tokensUntil account deletion
Ad-free / subscription entitlementsUntil account deletion
Push notification tokensUntil you disable notifications or delete your account

8. Your rights

8.1 Rights applicable in all territories

Contact privacy@astuto.gg. We will respond within 30 days.

8.2 United Kingdom (UK GDPR)

You have the right to access, rectification, erasure, restriction, data portability, and to object to processing. Lodge a complaint with the ICO: ico.org.uk · 0303 123 1113.

8.3 European Union / EEA — future market (not yet live)

The App is not currently available in the EU/EEA. When the App launches there (Phase 2), EU GDPR rights and the relevant national supervisory-authority contacts will be added to this section.

8.4 United States of America

California residents (CCPA/CPRA): right to know, opt out of sale/sharing (we do not sell or share individual data), delete, and non-discrimination. The same rights are available to residents of Virginia, Colorado, Connecticut, Texas, and other states with comprehensive privacy laws.

Note: prize eligibility is not available in New York, Florida, or Rhode Island (a competition rule, not a data right — see Terms §6).

8.5 Australia

The Privacy Act 1988 (Cth) and the Australian Privacy Principles apply. Complaints: Office of the Australian Information Commissioner (oaic.gov.au).

8.6 Mexico — Aviso de Privacidad

La Ley Federal de Protección de Datos Personales en Posesión de los Particulares (LFPDPPP) aplica a los usuarios mexicanos. Astuto Ltd, con domicilio en 66 Paul Street, Londres, EC2A 4NA, Reino Unido, es responsable del tratamiento de sus datos. Usted tiene Derechos ARCO: contactar privacy@astuto.gg. Quejas: INAI (inai.org.mx).

9. Children

Astuto is for users aged 16 and over. Prize competitions are open only to users aged 18 and over. We do not knowingly collect personal data from anyone under 16.

In the United Kingdom, the age of consent for information society services is 13 (Data Protection Act 2018); in parts of the EU/EEA it is 16, but the App is not yet available there.

Because age is self-declared, users who indicate they are under 18 are served only non-personalised (contextual) advertising and are not profiled for advertising. These measures are designed to align with the UK Age Appropriate Design Code (Children's Code).

Contact privacy@astuto.gg to request deletion of any data relating to someone under 16.

10. Cookies and tracking technologies

The App does not use browser cookies. On mobile devices we use:

11. Automated decision-making

We use automated systems to calculate quiz scores, apply lifelines (reveals and streak shields), rank players on leaderboards, and determine prize eligibility. These processes do not produce legal effects beyond determining prize eligibility within the competition rules. Fraud detection may flag accounts for human review.

12. Changes to this policy

We will notify you of material changes by displaying a notice in the App and updating the effective date above. Continued use constitutes acceptance of the updated policy.

13. Contact and complaints

PurposeEmail
Privacy and data rightsprivacy@astuto.gg
General supportsupport@astuto.gg

UK supervisory authority: Information Commissioner's Office (ICO) — ico.org.uk · 0303 123 1113.