Privacy Policy
Last updated: September 13, 2026
This Privacy Policy explains how personal data is processed when using the AnyWhen application, available for iOS and Android, and its related services. It describes the categories of data processed, the purposes and legal bases for processing, and the rights available to data subjects under Regulation (EU) 2016/679 (the "GDPR").
Data controller
The data controller is:
BitWare S.a.s.
Via Alessandro Volta, 46 — 25030 Roncadelle (BS), Italia
VAT no. 04399580986
Contact: apps@bitwaresas.it
Data we process
Using AnyWhen as a guest
When AnyWhen is used as a guest, users are not asked to provide an email address, a user-selected nickname, or other identifying registration information. The application automatically generates a fictional display name and a technical profile identifier used to associate games, scores, and tokens with the guest profile on the device.
Guest profiles do not have access to groups, public profiles, or notifications.
Creating an account
- Email address: used for sign-in, address verification, and password recovery through one-time OTP codes. It is not used to send promotional communications.
- Nickname: public and may appear on leaderboards and within groups. It can be changed in the settings and is checked against a list of prohibited or reserved terms.
- Password: stored only as a bcrypt hash. Passwords are not stored in plain text and cannot be read by BitWare S.a.s..
Game data
We process data required to operate the game, including games played, answers, scores, timing information, and game dates. These data are used for game history, resuming games, leaderboards, and achievements. The profile is also associated with the avatar collection, unlocked achievements, token balance, and token transaction history.
Information visible to other users
- Leaderboards: nickname, avatar, and score are visible.
- Public profile: users in the same group may view the nickname, selected avatar, avatar collection, number of achievements, game statistics, the date the user started playing, and whether the Premium subscription is active. The email address, individual game history, and subscription expiry date are not displayed.
- Groups: the group owner can see the nickname of users requesting to join, and participants can see one another's nicknames in the group list.
Groups
When a group is created or used, we process the group name, invitation code or link, participant list, membership requests, and the related approval or rejection decisions. The group name is visible to anyone who receives the invitation link, including before they join. BitWare S.a.s. may also access the group name for moderation and to handle reports.
Reports and blocks
When a user reports a player or a group, we process the reporting account, the reported player or group, the nickname or group name as it appeared at the time of the report, the selected reason, any optional note, and the outcome of the review. Reports are visible only to BitWare S.a.s., which reviews them for moderation purposes, and are not disclosed to the reported user. Each new report is notified by email to the support address.
When a user blocks another player, we store the link between the two accounts and the date of the block. The blocked player is not notified. A block can be removed at any time from the app settings.
Preferences and settings
We store the language selected in the application, the time zone reported by the device, the user's daily-challenge reminder preference, and the currently selected avatar. These data allow the service to be presented in the chosen language and, where notifications are enabled, allow reminders to be delivered at an appropriate local time.
Premium subscription
Payments for Premium subscriptions are processed entirely through the Apple App Store or Google Play. BitWare S.a.s. does not receive or store payment card or bank account details.
We use RevenueCat to manage subscription status. RevenueCat receives an opaque user identifier and purchase status information from the relevant stores. The identifier does not contain the user's email address or nickname. AnyWhen servers retain the Premium subscription expiry date.
Push notifications
Push notifications are optional and require permission from the device operating system. Refusing permission does not restrict the functionality of the application, and relevant notices remain available within the service.
Notifications are managed through OneSignal, which processes the device token required for delivery, technical device and delivery data, the same opaque user identifier used for subscription management, and the message content. Delivery is then handled through Apple Push Notification service (APNs) or Firebase Cloud Messaging (FCM). Permission can be withdrawn at any time through the device settings, while the daily-challenge reminder can also be disabled within AnyWhen.
Technical and security data
- Server logs: IP address and the date and time of requests, processed for security, abuse prevention, access-attempt rate limiting, and technical diagnostics.
- Sessions: to keep users signed in on their devices, session tokens are stored only as a cryptographic digest and never in plain text. Signing out revokes those tokens.
- Installation identifier: a random code generated by the application and not directly linked to the user's identity. It is used in connection with advertising videos to prevent circumvention of daily limits by repeatedly creating guest profiles on the same device.
Advertising
AnyWhen does not display advertising to users with an active Premium subscription. For other users, the application does not use banner ads or pop-up ads: advertising videos are shown only when the user chooses to start one, for example to obtain tokens under the rules displayed in the application.
Advertisements are provided through Google AdMob. To serve advertisements, measure their performance, and prevent advertising fraud and invalid traffic, Google may process the device advertising identifier, IP address, device information, and data relating to interactions with advertisements, under its own privacy policies and as an independent controller for those processing activities.
Consent for personalised advertising is managed through Google User Messaging Platform and may be changed or withdrawn at any time under Settings → Ad settings. If consent is not given, advertisements remain non-personalised. On iOS, permission may also be requested under Apple's App Tracking Transparency framework; refusing that permission does not prevent use of the application.
Advertising content is restricted to a rating suitable for a general audience. AnyWhen servers record only that a video was watched and the number of tokens, if any, credited as a result. The advertisement content itself and an advertising profile are not stored on AnyWhen servers.
Processing we do not carry out
- We do not sell or disclose users' personal data to third parties for those third parties' own marketing purposes.
- We do not use analytics or behavioural tracking tools within the application except as necessary for the advertising processing described in this Privacy Policy.
- We do not send promotional communications to the email address used for an AnyWhen account.
Legal bases for processing
- Performance of a contract — Article 6(1)(b) GDPR: account management, games, leaderboards, groups, blocks between users, tokens, and Premium subscriptions.
- Legitimate interests — Article 6(1)(f) GDPR: service security, technical logs, abuse prevention, and moderation of nicknames and group names, including the review of reports.
- Consent — Article 6(1)(a) GDPR and, where applicable, Article 122 of the Italian Privacy Code: personalised advertising, storage of or access to information on the device for advertising purposes, and push notifications. Consent is optional and may be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal.
Where data is processed and third parties involved
Data managed directly by BitWare S.a.s. is hosted on servers located in the European Union, in Italy. We also use the following service providers or third parties for specific functions:
| Service / party | Role | Data involved |
|---|---|---|
| Intersail S.r.l. (Italy) | Hosting of application servers and database, network connectivity and TLS termination | Account and game data; technical logs |
| Aruba S.p.A. | Outgoing email for OTP codes and report notifications, domain management | Email address and message content, including the details of a report |
| Google Ireland Ltd / Google LLC (USA) — Google Drive | Storage of backups | Encrypted database copy (GPG, AES-256); Google does not hold the encryption key. Any transfers outside the EEA are covered by the applicable safeguards, including Standard Contractual Clauses under Article 46 GDPR and, where applicable, the EU-US Data Privacy Framework. |
| RevenueCat (USA) | Subscription-status management | Opaque user identifier and purchase status; transfers outside the EEA supported by applicable safeguards, including Standard Contractual Clauses. |
| OneSignal (USA) | Push-notification delivery | Opaque user identifier, device token, and technical device and delivery data; transfers outside the EEA supported by applicable safeguards, including Standard Contractual Clauses. |
| Apple / Google | Independent controllers for in-app payments and notification delivery (APNs, FCM) | Payment and billing data and notification tokens, according to their respective privacy policies. |
| Google Ireland Ltd / Google LLC (USA) — AdMob and User Messaging Platform | Independent controller for advertising, related measurement, and the prevention of advertising fraud | Advertising identifier, IP address, device data, and interactions with advertisements; any transfers outside the EEA are covered by the applicable safeguards, including Standard Contractual Clauses under Article 46 GDPR and, where applicable, the EU-US Data Privacy Framework. |
Data retention
- Registered accounts: data is retained for as long as the account remains active. Users can delete the account directly in the application under Settings → Delete account. Deletion removes the associated data, including games, scores, tokens, avatar collection, group memberships, and groups owned by the user, subject to the backup retention period described below.
- Guest profiles: automatically deleted after an extended period of inactivity, currently set at 180 days.
- Technical logs: retained for a limited period and in any event for no longer than 90 days.
- Reports: retained while they are being reviewed and, once closed, for no longer than 12 months, so that repeated behaviour can be recognised. If the reporting user deletes their account, the report no longer contains any reference to that account.
- Blocks: retained until the user removes them or until either account is deleted.
- Backups: one encrypted backup is retained per day on a seven-day rotation. Backups are overwritten after seven days. As a result, data relating to a deleted account may remain for up to one week solely within backup copies, which are used only to restore the service.
Your rights
Under Articles 15–22 GDPR, users may exercise, where applicable, the rights of access, rectification, erasure, restriction of processing, data portability, and objection by contacting apps@bitwaresas.it.
Certain actions are available directly within the application, including changing the nickname, changing the password, and deleting the account. Users also have the right to lodge a complaint with the Italian Data Protection Authority, the Garante per la protezione dei dati personali (garanteprivacy.it), or with the supervisory authority of their country of residence.
Children and age requirements
Users must be at least 14 years old to create an account independently, which is the age established in Italy for valid consent to online services, unless local law requires a higher age. Users below the applicable age may use the application as guests without providing identifying registration data, or may use an account created by a parent or legal guardian.
AnyWhen is not specifically directed at children. Users who have not reached the applicable age for valid consent are shown only non-personalised advertisements.
Changes to this Privacy Policy
Any material changes to this Privacy Policy will be published on this page and the "Last updated" date will be revised accordingly. The version published from time to time describes the processing applicable to the current use of the service.
Please also see the AnyWhen Terms of Service.