Last updated: 25 October 2026
1. Who is responsible
The data controller for the Mosaico app and this website is Marius Jurca, a private individual and solo developer based in Romania, who develops and runs Mosaico ("Mosaico", "we", "us"). We can be reached by email only: for anything about your personal data, write to privacy@mosaicopuzzle.app. The trader details that Google Play requires are shown on Mosaico's page in Google Play.
We have not appointed a Data Protection Officer, because the law does not require one for Mosaico, and we do not need a representative in the EU, because we are established in the EU (Romania).
2. The short version
- Your photos stay on your phone unless you share, publish or back them up. Photos you turn into puzzles are processed and checked on your device, and we do not receive them. If you send a puzzle card to a friend, the image travels through the messaging app you choose (for example WhatsApp), not through our servers. If you back up to Google Drive, copies go to a hidden Mosaico folder in your own Google Drive, not to us; a backup runs when you start it, or, with Mosaico Plus while you are signed in, automatically at most once a day on Wi-Fi while the phone charges. Only photos you publish to Community are uploaded to our servers. If you send a puzzle card to your Mosaico friends inside the app, the card picture is stored on our servers, privately, only for the friends you chose, and deleted once the last of them has saved it to their phone, when you delete your account, and at the latest 30 days after you sent it. No message goes with it, only a greeting you may pick from our list. Cards you send through a messaging app still never pass through our servers.
- Photos you choose to publish to Community are uploaded to our servers so other players can play them. You can unpublish them at any time.
- We never read the location (GPS) of your photos. When a photo is saved or uploaded, its location and camera data are removed. A place appears on a puzzle only if you type it.
- Android's own backup is turned off for Mosaico. Android does not copy the app's photos or data to your Google account or to a new phone; only Mosaico's own Drive backup does (when you start it, or automatically with Plus).
- The camera is used only when you tap "Take a photo" or "Scan a puzzle card". Camera frames are read on your phone and never stored.
- Free players see ads. In the EEA, UK and Switzerland we ask for your consent first, and you can change your choice at any time in Settings > Privacy choices.
3. What we collect and why
| Data | When | Why (purpose) | Legal basis (GDPR) |
|---|---|---|---|
| Photos you publish, their title, theme, year | When you tap Publish | Show your puzzle in Community | Performance of contract (Art. 6(1)(b)) |
| Anonymous player ID (a random id, no name or email) and a nickname made of two preset words (for example "Calm Otter"), or a display name you type yourself (see "Your name" below) | The first time you use an online feature (a daily leaderboard time, a friend's card result, a like or a report), no sign-up needed. Not on install | Save leaderboard times, likes, reports and friends' results for players without an account | Contract |
| Account: Google account id and email, or the email address you sign in with, nickname or display name, avatar choice. When you sign in with Google, Google also gives our sign-in service (Firebase Authentication) your Google name and the address of your Google profile photo. They stay in that sign-in record, but we do not use them, show them to anyone or copy them anywhere else, and they are deleted with your account. Your email address is used only to sign you in and to recover your account, and for nothing else. We never send you marketing emails: the only emails are the one-time sign-in links you ask for. With email sign-in there is no password: we send a link to the address you type, and until you open it the app keeps the address on your phone so it can finish signing you in. The address is deleted when you delete your account. | When you choose to sign in, with Google or with your email address (never required) | Run your account, keep your progress on a new phone, recover purchases | Contract |
| Your name: a nickname from our word lists, or a display name you type. A typed name is checked against our word lists and reserved words and must be unique: the first player to take a name keeps it. Other players see it on Community, leaderboards and your creator page (weekly leagues always show your nickname from the word lists). When you change it or go back to a nickname, we keep the old name reserved for you for 7 days; when you delete your account, the name is unlinked from you and freed after the same 7 days. Other players can report a name, and a moderator can reset it to a nickname | When you type a name | Show you to other players; prevent impersonation | Contract; the reservation and the 7-day hold: legitimate interest |
| Your profile picture: one of our own curated photos that you finished, which other players see beside your name in Community and the weekly leagues. We receive only which of our photos you chose. If you use a photo from your phone as your profile photo, it stays on your phone (and in your own Drive backup if you make one) and is never sent to us; only you see it | When you choose a profile picture | Show you to other players | Contract |
| Whether you are 16 or older (yes or no), never your birth year. We ask for your birth year once, before you publish or use Mosaico friends, and keep only the answer to whether you are 16 or older, never the year itself. If you are signed in and 16 or older, that answer is saved with your account so we can check the age limit for Community and Mosaico friends; otherwise it stays on your phone | Before you publish to Community or open Mosaico friends | Check the minimum age for publishing and for Mosaico friends | Legal obligation and contract |
| Game data synced to your account: coins, gems and XP history, best times and stars per puzzle, streak, saved puzzles, likes, follows, reports, and the categories you chose for your photos (linked to a short numeric fingerprint calculated from each photo, not the photo itself). Never your photos, puzzle titles or places you typed | While you are signed in | Keep your game the same on every phone | Contract |
| Leaderboard and friends data: your daily-puzzle time, hints used and a check code of your moves (the full move list is checked for top-100 times and not kept), your nickname, your friends list (their anonymous ids and nicknames), and the times friends score on the puzzle cards you sent (numbers only) | When you finish the daily puzzle, add a friend, or a friend solves your card | Leaderboards, friends, "Ana solved your card in 3:12" | Contract; preventing cheating: legitimate interest |
| Mosaico friends (only if you are signed in and 16 or older): your friend code and a random player handle, the friends you and they accepted, friend requests, the players you blocked, whether others may find you by your exact display name, and your notification choices for friends. For each puzzle card you send to friends: the card's settings and your first name as on the card, the greeting you picked from our list (if any; never a message you type), the card picture (kept up to 30 days), and who it went to and who saved it. Your friends, and players who type your exact display name, see your name, your profile picture from our photos and nothing else; never your email, your friends list or whether you are online. We never read or upload your contacts | When you open Friends, add or answer a friend, block someone, or send a card to friends | Let you and your friends find each other and send each other puzzles; stop unwanted contact | Contract; blocks and reports: legitimate interest |
| Game data: progress, coins, stars, streak, times, likes, follows, Curator points and tier, the puzzles you suggest for Today's picks. For the daily note about creators you follow: your time zone and the time of day you usually play | While playing | Run the game, leaderboards, rewards; send the note at a good time for you | Contract |
| Which version of the Terms you accepted, and when | Before your first publish, and again when new Terms apply | Prove that you accepted the rules for publishing | Legitimate interest |
| Safety data: moderation scores, reports you make or receive, strikes, appeals, and the device signals linked to banned accounts: an app install id and Google Play Integrity results, nothing taken from your phone's hardware | When you publish, report or are reported | Keep Community safe, prevent abuse, meet legal duties | Legal obligation (Art. 6(1)(c)) and legitimate interest (Art. 6(1)(f)) |
| Abuse limits: how many requests your account and your app install made recently; Google Play Integrity checks that requests come from the real app | Every online action | Stop spam and abuse | Legitimate interest |
| Purchases: product, date, Google Play order number, subscription state (active, cancelled, ended, refunded), and a scrambled (hashed) copy of the purchase code; the code itself only until Google confirms the purchase. No name, email, card details or price; Google handles payment | When you buy, and when Google Play tells us a subscription changed | Deliver purchases, restore them on a new phone, handle refunds, prevent fraud | Contract, legal obligation (tax records) |
| Device and app data: device model, OS version, app version, language, crash logs, and technical logs of requests to our servers (including IP address) | While using the app; crash reports only while Settings > Privacy > Crash reports is on | Fix bugs, performance, security | Legitimate interest |
| Analytics events (for example "puzzle finished", "card shared") from a fixed list; never image content, titles, names or anything you type. Google Analytics adds an app-instance id and an approximate country and region from your IP address | While using the app, only while Settings > Privacy > Usage statistics is on | Improve the game | Consent where required, otherwise legitimate interest |
| Advertising id, approximate location from your IP address, and ad interaction data | When ads are shown; your consent choice each time the app starts | Show and measure ads; personalised ads only with consent | Consent (EEA/UK/CH); elsewhere as allowed by local law |
| Push notification token | If you allow notifications and use an online feature | Tell you when a friend solves your card, and send the other notices you allow (new puzzles from creators you follow, your weekly creator statistics), at the times you allow | Consent |
| Support messages, and the email and player ID you send if you ask us to delete data of a player who never signed in | If you contact us | Answer you | Legitimate interest; deletion requests: legal obligation |
| Record of an account deletion (a scrambled (hashed) form of your player id, the date, and whether it was asked in the app or on the web) | When you delete your account | Prove that we did it | Legal obligation |
| A notice, copyright claim or appeal sent with our web form (`/report`): the link, your explanation, your name and email (not needed for a child-safety notice) | When you use the form | Act on the notice, answer you, meet our duties under the EU Digital Services Act | Legal obligation; legitimate interest |
What we never collect: your private photos, your photo library, the precise location of your device or your photos, contacts, or the content of messages you send through other apps. We do learn an approximate location (country or region) from your IP address through analytics and ads, as described above.
On-device only: the month a photo was taken is read on your phone to write the label of your own puzzles ("Brasov · August 2025"). The place is shown only if you type it. Neither is uploaded to us (they are in your own Drive backup if you make one). The app never reads a photo's GPS location.
Puzzle cards. A card is a picture you send through an app you choose. It shows your photo cut into shuffled squares, its title, your first name, a QR code and a short code printed under it. The QR and the link hold only that short code. The puzzle's settings (mode, size, crop, preset title, time to beat, occasion, colours) and your first name as written on the card, never the photo, are kept on our server under the code, so your friend's app can open the card; they are kept until you delete your account. If your friend opens that link without the app, our web page receives the link and forwards them to Google Play, which passes the link to the app once it is installed so the card can open. We use Google's install referrer only for that, once, and keep nothing but a note that it was read. We do not use any advertising attribution or install-tracking service. Our web host (Firebase Hosting, part of Google) handles the request like any web request; we do not export or keep its request logs.
Scanning a card. "Scan a puzzle card" uses your camera to read the card's QR code on your phone. No picture or video is saved or sent. When a card picture is shared into Mosaico, its QR code is read from a temporary copy that is deleted at once.
Google Drive backup. When you start a backup (or, with Mosaico Plus while you are signed in, automatically at most once a day on Wi-Fi while the phone charges), Mosaico saves one file in a hidden app folder of your own Google Drive: your puzzles and photos as processed by the app, your progress and your settings, including titles, places and occasion names you typed. We cannot see it. Each backup replaces the previous one. You can delete it in Google Drive (Settings > Manage apps > Mosaico > Options > Delete hidden app data). Google's own terms and privacy policy apply to your Drive.
Permissions. Camera: only when you tap Take a photo or Scan a puzzle card. Notifications: asked once, after your third finished puzzle; if you say no, we never ask again. Mosaico does not ask for location, contacts or access to your photo library: you pick one photo at a time with Android's photo picker.
4. Who we share data with (processors and partners)
| Provider | What for | Data |
|---|---|---|
| Google Firebase and Google Cloud (Auth, Firestore, Cloud Functions, Cloud Storage, Pub/Sub, Cloud Logging, Remote Config, Analytics, Crashlytics, Cloud Messaging, App Check with Google Play Integrity, Hosting for our web pages) | App backend, web pages, security | Account, game, device, analytics data; request logs with IP address |
| Google Sign-In | Signing in, if you choose to | Google account id and email |
| Firebase Authentication email link (Google) | Signing in with your email address, if you choose to: Google sends the sign-in link for us | Your email address |
| Google Drive (your own account) | Your backup, if you start one. Google stores it for you; we cannot access it | Your backup file |
| Google ML Kit and Google Play services (on your phone) | Finding faces for the crop, suggesting a category, reading QR codes. Your images stay on your phone | No images. Google collects its own usage and performance metrics about these features, under Google's privacy policy |
| Google Play (install referrer, in-app review) | Opening a friend's card after install; asking once for a review | The card link; nothing else from us |
| Google Cloud Storage (Firebase Storage), in Belgium | Store and deliver published photos, and keep card pictures sent to Mosaico friends until they are saved | Published photos; card pictures sent to friends |
| Google Cloud Vision (SafeSearch) | Automatic safety check of published photos | Published photos, moderation scores |
| A hash-matching service for known child sexual abuse material, such as Microsoft PhotoDNA or Google CSAI Match | Detecting known child sexual abuse material | A digital fingerprint (hash) of published photos and of card pictures sent to Mosaico friends |
| Google Perspective API | Checking titles of published puzzles for abuse | The title |
| Google AdMob and its ad partners (shown in the consent form) | Ads and the consent form | Advertising id, device data, approximate location from IP, ad interactions |
| Google Play | Payments, subscriptions; our server asks Google Play to confirm each purchase | Purchase data |
| Authorities (for example NCMEC or national police) | Legal reporting of child sexual abuse material or threats to life | The content and the account data required by law |
We do not sell your personal data. We do not share your published photos with anyone except to show them in the App, to check their safety, or when the law requires it.
5. International transfers
Some providers process data outside the EEA (for example in the United States): Google Analytics, Crashlytics, Remote Config, Cloud Messaging, AdMob and Perspective API. Where they do, we rely on the EU–US Data Privacy Framework where the provider is certified, or on the European Commission's Standard Contractual Clauses. We choose EU data regions where available: our database (Firestore), our server functions and the storage of published photos and card pictures are in Belgium (Google Cloud region `europe-west1`).
6. How long we keep data
| Data | Kept |
|---|---|
| Published photos | Until you unpublish them or delete your account. When you unpublish: removed from public view at once and deleted within 24 hours. When you delete your account: within 30 days. A photo we removed, or one still waiting for a person's decision, is kept privately until the appeal period ends (6 months) or the decision is made |
| Account and game data | Until you delete your account, then deleted within 30 days |
| Anonymous player data (no sign-in) | Deleted after 14 months without use (no online action in that time) |
| Terms acceptance record (which version you accepted, and when) | While your account exists, as proof; deleted with your account |
| Daily leaderboard times | 14 months |
| Mosaico friends | Friend requests: 30 days. Cards in a friend's inbox: until they save it, at most 30 days. The card picture: deleted once the last friend you sent it to has saved it, when you delete your account, and at the latest 30 days after you sent it. Your friends list, blocks and code: until you remove them or delete your account; deleting your account also removes you from your friends' lists |
| Friends' results on your cards | 30 days after they are counted in your card statistics |
| Abuse-limit counters | 30 days after the last request |
| Push notification tokens | Until you turn notifications off, a delivery fails, you delete your account, or the token has not been used for 60 days |
| Server request logs | 30 days |
| Record of an account deletion | 1 year, with your player id kept only in a scrambled (hashed) form |
| Your Google Drive backup | In your own Drive until the next backup replaces it or you delete it |
| Purchase records | As long as Romanian tax and accounting law requires, at most 10 years. Google Play is the seller and keeps its own records |
| Safety records (removals, strikes, reports, notices from the web form) | Up to 2 years after the decision, to handle appeals and prevent repeat abuse |
| Bans, and the app install ids linked to a banned account | Until we lift the ban, so a banned person cannot simply start again |
| Content reported to authorities | As long as the law requires |
| Support and deletion emails | 2 years |
| Analytics data | Up to 14 months |
| Crash reports | Up to 90 days |
| Data on your phone | Until you delete it in the app, clear the app's data or uninstall it. Android does not back it up |
7. Your choices and rights
- Ads consent: change at any time in Settings > Privacy choices (this reopens the consent form).
- Usage statistics and crash reports: turn either off in Settings > Privacy; nothing more is sent from then on.
- Notifications: turn off all of them, or each kind (daily puzzle, streak, quests, reminders, friend results, following, creator statistics), in Settings or in Android settings.
- Camera: you can withdraw the camera permission in Android settings at any time; picking photos still works.
- Drive backup: delete it in Google Drive (Settings > Manage apps > Mosaico > Options > Delete hidden app data).
- Unpublish any photo at any time.
- Delete your account: in Settings > Delete account, or on the web at https://mosaicopuzzle.app/delete-account without needing the app (sign in with the same Google account or email address; the same deletion runs as in the app). If you never signed in, open Mosaico and choose Settings > Delete my data: this removes your anonymous records (such as leaderboard times, likes and reports) from our servers. If the app is no longer on your phone, email privacy@mosaicopuzzle.app and we will help you.
- GDPR rights (EEA/UK/CH): access, correction, deletion, restriction, objection, portability, and withdrawing consent at any time. Email privacy@mosaicopuzzle.app. We answer within one month.
- You can complain to a data protection authority: in Romania, where we are established, the National Supervisory Authority for Personal Data Processing (ANSPDCP, dataprotection.ro), or the authority of the EU country where you live or work. We would be glad if you wrote to us first, so we can try to solve the problem.
- US state privacy rights (for example California): you can opt out of the "sharing" of personal information for targeted ads in Settings > Privacy choices.
8. Children
The App is for people aged 13 and older; publishing and Mosaico friends require age 16+. To check this, we ask for your birth year once, before you publish or use Mosaico friends, and keep only the answer to whether you are 16 or older, never the year. If you are signed in and 16 or older, that answer is saved with your account; otherwise it stays on your phone. We do not knowingly collect personal data from children under 13. If you believe a child under 13 has given us data, contact privacy@mosaicopuzzle.app and we will delete it. Photos showing identifiable children are not allowed in Community.
Automatic decisions. Photos you publish, puzzle titles and display names are checked automatically for safety (section 4). An automatic check can reject a photo or a name, or hold it for a person to review. It decides nothing else about you, and you can always have a person look at the decision by appealing in the App or by email to support@mosaicopuzzle.app.
Other people in your content. If you publish or send a photo that shows other people, you are responsible for having their agreement (see our Terms of Use). We process such photos only to show them where you chose, to check them for safety and to handle reports about them. A person shown in a photo can ask us to remove it by reporting it or by writing to privacy@mosaicopuzzle.app.
9. Security
Data is encrypted in transit (HTTPS) and at rest by our providers. Requests to our servers must come from the genuine app (Google Play Integrity). Access to the moderation tool is limited to authorised reviewers, who sign in with a Google account protected by two-step verification.
10. Changes
We may update this policy when the App or the law changes. We will show important changes in the App before they apply and, where the law requires it, ask for your consent again. The date at the top shows the latest version; earlier versions stay available on our website.
11. Contact
Marius Jurca (Mosaico), by email only: privacy@mosaicopuzzle.app. Our other contacts (support, reports, copyright, child safety, the Digital Services Act contact point) are on our Contact page. The trader details that Google Play requires are shown on Mosaico's page in Google Play.