Grubble Dansk

Privacy policy

Version 5 · 29 October 2026

This privacy policy describes how Forwards ApS processes personal data in connection with the mobile game Grubble and the website playgrubble.com (together, the "Service"), in accordance with Regulation (EU) 2016/679 (the General Data Protection Regulation, "GDPR") and the Danish Data Protection Act.

1. Data controller

1.1The data controller is Forwards ApS, CVR no. 44696827, Klosterstræde 9, 1157 Copenhagen K, Denmark ("Forwards", "we" or "us").

1.2Enquiries concerning this privacy policy may be sent to support@playgrubble.com.

2. Personal data, purposes and legal bases

2.1Account data. When you create an account using Sign in with Apple, Forwards receives a unique identifier for your Apple ID. Forwards does not receive your name or email address. Forwards processes this identifier, an internal user ID, your username, level and points, your settings, including your choices regarding usage data and crash reports and the users you have blocked, and the version and time of your acceptance of the terms of use and the chat rules. Purpose: to create and administer your account and provide the Service. Legal basis: performance of the agreement (Article 6(1)(b) GDPR). Providing this data is necessary to enter into the agreement; without it, the Service cannot be provided.

2.2Game data. Games, moves, results, statistics, friendships and friend requests, challenges, invite links and club memberships. Purpose: to provide the Service. Legal basis: Article 6(1)(b) GDPR.

2.3Chat messages. Messages you write to friends and in club chats. Purpose: to deliver messages between users. Legal basis: Article 6(1)(b) GDPR.

2.4Moderation data. Messages are processed by automated tools before delivery in order to enforce the chat rules. When content is reported, Forwards processes a copy of the reported content and of the preceding messages in the conversation, the identity of their authors, the identity of the person reporting and the reason given. Forwards keeps a record of reports and sanctions concerning each reported user. Purpose: to enforce the terms of use, protect users and comply with the obligations of Forwards under Regulation (EU) 2022/2065 on digital services. Legal basis: legitimate interests in a safe service (Article 6(1)(f) GDPR) and legal obligation (Article 6(1)(c) GDPR).

2.5Notifications. If you allow notifications, Forwards processes your device's notification token and the language in which notifications are to be sent. Notifications contain information about the event concerned, such as a word played and its score or an excerpt of a message. Purpose: to notify you of events in the Service. Legal basis: Article 6(1)(b) GDPR.

2.6Event log. The servers of Forwards record events in the Service, such as games started and completed, moves played, and changes to friendships and club memberships, together with your user ID and the time of the event, and once the age you state at sign-up. The event log does not contain the content of messages. Purpose: statistics on the use of the Service, for its development and operation. Legal basis: the legitimate interests of Forwards in understanding and developing the Service (Article 6(1)(f) GDPR). You have the right to object, see section 9.

2.7Usage data. The app asks users who have stated that they are 15 years of age or older whether they consent to sharing usage data. Users who have stated that they are under 15 are not asked until the date on which, based on the age stated, they will be at least 15, and no usage data is collected about them before then. If you consent, the app transmits information about app openings, screens viewed and notifications opened, together with your user ID, to our analytics provider. The analytics service also automatically collects an identifier for the app installation, the device model, operating system and app version, language, session duration and an approximate location derived from the IP address. Advertising identifiers are not collected. Purpose: to analyse the use of the app. Legal basis: consent (Article 6(1)(a) GDPR). You may withdraw your consent at any time in the app under More → Settings → Share usage data. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

2.8Crash reports. If the app crashes, information about the error, the device model, the operating system version and an identifier for the app installation is transmitted to our crash-reporting provider. Crash reports are not linked to your user ID. Purpose: to identify and correct errors. Legal basis: the legitimate interests of Forwards in a functioning service (Article 6(1)(f) GDPR). Crash reports can be disabled in the app under More → Settings → Crash reports.

2.9App security. Technical verification data from the app and device is processed by our service providers to check that requests to the Service come from the genuine app. Purpose: security and the prevention of misuse. Legal basis: Article 6(1)(f) GDPR.

2.10Feedback and enquiries. Feedback sent through the app is processed together with your user ID, username, app version and language. Enquiries by email are processed together with your email address. Purpose: to handle feedback and enquiries. Legal basis: Article 6(1)(f) GDPR.

2.11Website. When playgrubble.com is visited, the IP address and technical information about the request are processed by our hosting provider. The website does not use cookies or analytics tools and does not load content from third parties. Purpose: to deliver the website. Legal basis: Article 6(1)(f) GDPR.

2.12Age. At sign-up, we ask your age. We keep the age you state and the time in your private account settings, so that your age can be calculated at any later time, and record it once in the event log (section 2.6). If you state that you are under 15, we also keep the date on which, based on the age you state, you will be at least 15. We do not collect your birth year or date of birth. Other players cannot see your age; if chat is disabled for you, your friends are, however, informed that chat with you is unavailable. Users who signed up before the age was asked stated only whether they were under 15, and chat is disabled for those who stated that they were. Purpose: to disable chat, including access to chats, for players under 13; to request consent to the sharing of usage data only from players aged 15 or older; and statistics on the use of the Service by age. Legal basis: our legitimate interests in protecting younger players and in understanding and developing the Service (Article 6(1)(f) GDPR). The age is kept while your account exists and deleted with it; in the event log it is retained as set out in sections 6 and 7.3. Contact support to correct an incorrect answer.

3. Recipients

3.1Your username, level and statistics are visible to other users, who may search for you by username. Games are visible to their participants, and games started from an open challenge in a club are also visible to the members of that club. Messages are visible to the participants in the conversation. Clubs and their members, including level, role and nickname, are visible to all users.

3.2We use Google to host and operate the Service, analyse usage where you consent, and process crash reports. Google acts as our data processor under its data processing terms, which ensure a level of protection corresponding to this privacy policy.

3.3Apple processes data in connection with sign-in, the delivery of notifications and the verification of app integrity. Apple's processing in connection with Sign in with Apple is governed by Apple's privacy policy.

3.4Personal data may be disclosed to public authorities where required by law, or where there is a suspicion of a criminal offence involving a threat to the life or safety of a person.

3.5Forwards does not sell personal data, does not show advertising and does not track users across other companies' apps or websites.

3.6In connection with a sale or merger of Forwards or of the Service, personal data may be transferred to the acquirer for the continued operation of the Service in accordance with this privacy policy. Such a transfer will be announced in the app in advance.

4. Transfers to third countries

4.1The database, servers and event log of the Service are located in the EU.

4.2Google processes account authentication data in the United States, and crash reports, notifications, usage data and the website on its global infrastructure. Personal data is therefore transferred to the United States. Transfers to Google LLC are based on the European Commission's adequacy decision for the EU-US Data Privacy Framework (Article 45 GDPR), under which Google LLC is certified, and in addition on the standard contractual clauses in Google's data processing terms (Article 46(2)(c) GDPR). A copy may be obtained on request.

5. Security

5.1Forwards uses encryption and access controls to protect personal data. Access to reports and moderation records is limited to authorised accounts.

5.2In the event of a personal data breach, Forwards will notify the Danish Data Protection Agency and, where the breach is likely to result in a high risk to you, notify you in accordance with Articles 33 and 34 GDPR.

6. Retention

6.1Personal data is retained for the periods set out below, after which it is deleted.

6.2The event log is retained for statistical purposes in accordance with Articles 5(1)(e) and 89(1) GDPR, with pseudonymisation as a safeguard.

7. Deletion of your account

7.1You may delete your account at any time in the app under More → Settings → Delete account. On deletion, your account, username, profile, friendships, messages, settings and feedback are deleted; you leave your clubs; ongoing games are ended as if you had resigned; your record of reports and sanctions is deleted; and Forwards requests Apple to revoke the authorisation of Grubble for your Apple ID.

7.2The results of completed games are retained without your username so that other users keep their game history, and you appear in them as "Deleted player".

7.3The event log and usage data are retained. Four days after deletion, your user ID in them is replaced by a random identifier, which also replaces it in the results of your games. The data is thereafter pseudonymised, not anonymous, as it contains references to games and clubs, and is used only for statistics. The data held by our analytics provider is deleted.

7.4Reports filed by you and reports concerning you, including the reported messages, are retained without your username for the periods set out in section 6, as documentation for the safety of other users and for the establishment, exercise or defence of legal claims (Articles 6(1)(f) and 17(3)(e) GDPR). Messages of yours that are quoted as context in reports concerning other users retain your username until those reports are deleted.

7.5Our service provider deletes its copies of authentication data within 180 days and crash reports after 90 days.

8. Your rights

8.1You have the right of access to your personal data (Article 15 GDPR), the right to rectification (Article 16), the right to erasure (Article 17), the right to restriction of processing (Article 18) and the right to data portability (Article 20). Requests may be sent to support@playgrubble.com stating your username. Forwards responds within one month and may ask you to confirm your identity.

8.2Where processing is based on consent, you may withdraw your consent at any time.

8.3Forwards does not take decisions based solely on automated processing which produce legal effects concerning you or similarly significantly affect you (Article 22 GDPR). Automated chat restrictions concern the chat functions only and may be reviewed by a person on request, as described in the terms of use.

8.4You have the right to lodge a complaint with the Danish Data Protection Agency (Datatilsynet), Carl Jacobsens Vej 35, 2500 Valby, Denmark, dt@datatilsynet.dk, www.datatilsynet.dk.

9. Right to object

10. Changes to this privacy policy

10.1Material changes to this privacy policy, such as new categories of data or new purposes, will be announced in the app before they take effect. Previous versions are retained and provided on request.