Privacy Statement
Effective date: 01-06-2026
Version 1
Table of Contents
This Privacy Statement explains how Skillix (“we”, “us”, “our”) collects, uses and protects your personal data when you use Skillix, browse this website or sign up for the newsletter. Skillix is a sole proprietorship registered in the Netherlands (CoC number: 91335175) and is the data controller for the personal data described in this statement.
We have designed Skillix to collect as little personal data as possible. Personal data is only processed where it is genuinely necessary, as described below. This statement applies in addition to our Terms of Service.
Main privacy considerations
Here is a summary of the key privacy aspects of using Skillix:
- All of Skillix – except in-app purchases – is available without having to create an account. If you choose this, then we don’t process your e-mail address.
- The free version of Skillix has non-disruptive banner ads and these have been set up without personalization or third-party tracking, to help protect your privacy.
- Wherever possible, we have configured our infrastructure and third-party tools such that your data is processed only within the EU (see paragraph 3.1). The notable exception is that Apple and Google may process your data outside the EU for their independent purposes, see paragraph 3.2 for more information.
- We process your data for analytics purposes. We use Mixpanel to be able to capture actions that you take within the app (‘events’) to help improve Skillix, but only if you actively consent to this and without identifying you. We also use backend data to create reports on an aggregated level, for example to see how many users are at a certain level or how many users have purchased a certain item.
1. Who This Statement Applies To
This statement applies to all players of Skillix, regardless of whether they have created an account. It also applies to visitors to our website at www.skillixapp.com and to anyone who signs up for our community newsletter.
2. What Personal Data We Collect
The table below lists what personal data we process, for what purpose, under which legal basis under the General Data Protection Regulation (GDPR), and how long we keep it (retention).
| Purpose | Personal data | Legal basis | Retention |
|---|---|---|---|
| Creating and managing your account and profile | Email address and password (only if you choose to create an account), chosen username | Performance of a contract (Art. 6(1)(b) GDPR) | Until you request to have your account deleted and we complete this request, or after 2 years of inactivity (after first notifying you in case you have an account) |
| Keeping track of your gameplay progress | Account identifier, gameplay progress data (levels, buildings, resources, mission history, cosmetics owned etc.) | Performance of a contract (Art. 6(1)(b) GDPR) | Until you request to have your account deleted and we complete this request |
| Handling your purchases (Skillcoin packs, subscription and in-game items) | Purchase information (e.g. item purchased, amount spent, date of payment). We never receive your payment (card) details since this is handled by Apple/Google. | Performance of a contract (Art. 6(1)(b) GDPR) | 7 years, based on our legal obligation to retain financial records for that period of time |
| Detecting and fixing errors and crashes | Error logs, stack traces, device ID, IP address, device model, operating system version, app version. | Legitimate interest (Art. 6(1)(f) GDPR): diagnosing and fixing technical issues | 90 days in GlitchTip, then deleted |
| Processing user reports (bug reports, suggestions etc. that you choose to send us) | Details of report message. In case of a bug report we also use the data mentioned for 'detecting and fixing errors and crashes'. | Legitimate interest (Art. 6(1)(f) GDPR): responding to and handling your report | 180 days in Zammad, then deleted (only non-personal data is kept) |
| App analytics (Mixpanel): gaining insights into actions taken in Skillix | User actions in the app (events), tied to account identifier, country and device data – only collected if you consent | Consent (Art. 6(1)(a) GDPR), you can withdraw consent at any time by going to Settings - Privacy & Legal inside the app | Events are stored for two years |
| App analytics (backend): understanding user trends and progression on an aggregated level | Account identifier, device ID, account progress data (such as skill levels, streak, building levels and Skillcoins) | Legitimate interest (Art. 6(1)(f) GDPR): improving Skillix, creating a better user experience | The data used is part of a user's account and will therefore be stored until the account is deleted |
| Displaying non-personalized (limited) ads (free version only) | IP address and basic device information, processed by Google AdMob for contextual ad selection and fraud prevention | Legitimate interest (Art. 6(1)(f) GDPR): helping to fund the development of Skillix | Per Google's own retention policy |
| Sending you newsletter emails, only if you requested them via the website | Email address | Consent (Art. 6(1)(a) GDPR), you can withdraw consent at any time by clicking unsubscribe in any newsletter e-mail | Until you unsubscribe |
| Website usage and analytics | Website clicks and country linked to a anonymous ID, cookieless, masked IP address | Legitimate interest (Art. 6(1)(f) GDPR): generating anonymous aggregated reports to understand website use | Aggregated reports are kept for up to 2 years, though the underlying data is never linkable to you as a website user |
If you choose not to create an account, it means we won’t process your e-mail address. Instead, we generate a token based on your device ID in order to keep track of your gameplay data on your device.
Skillix is not intended for or directed at children under 16 years of age. We do not knowingly collect personal data from children under 16. If we become aware of a situation where such data has been collected, we will promptly delete it. If you know of a case where personal data of a child under 16 has been collected by us, kindly contact us at privacy@skillixapp.com.
3. Who We Share Data With
We do not sell your personal data. We share data only with the processors and partners listed below, and only to the extent necessary for the purposes described.
3.1 Our Processors
The following parties process personal data on our behalf and under our instruction:
| Processor | Role | Data transfers (outside the EU) |
|---|---|---|
| Leaware sp. z o.o. (Poland) | Development and technical maintenance of Skillix. Leaware has access to account, gameplay, error/crash and user report data as part of their role in developing and maintaining Skillix. Your data does not leave the EU. | Data processed in the European Union (EU), no transfer |
| Microsoft (Azure) | The Skillix database including account data is hosted on Azure servers located within the EU (Germany). | Servers hosted within the EU, no transfer |
| GlitchTip | Automatic error/crash reporting. | Self-hosted within the EU, no transfer |
| Zammad | Registration of manual reports related to bugs and improvement suggestions. | Self-hosted within the EU, no transfer |
| Mixpanel | Collecting analytical data about how you use Skillix if you have given consent. Mixpanel is configured to use a pseudonymized ID so we can't see your account details. | Data processed in the EU, no transfer |
| Brevo | Managing newsletter subscribers and automations related to emails. | Data processed in the EU, no transfer |
| Rybbit | Basic website analytics, set up without cookies and ensuring your IP address is masked. | Data processed in the EU, no transfer |
3.2 Independent Controllers
The following parties receive data in connection with Skillix but act as independent data controllers under their own privacy policies, not as our processors:
- Payment processing for purchases made on iOS. Handles all payment data independently.
- Analyzing OS-level app crash data.
- Payment processing for purchases on Android. Handles all payment data independently.
- Serving non-personalised ads in the free version of Skillix.
- Analyzing OS-level app crash data.
We encourage you to review the privacy policies of Apple and Google for information on how they handle your data. Apple: apple.com/legal/privacy. Google: policies.google.com/privacy.
4. How We Protect Your Data
We take appropriate technical and organisational measures to protect your personal data, for example:
- Passwords are stored using one-way hashing – we cannot read your password.
- Data in transit is encrypted using TLS.
- Access to personal data is limited to those who need it to operate and maintain Skillix.
- Our backend is hosted within the EU on Microsoft Azure infrastructure.
No system is completely secure. If a data breach occurs that is likely to result in a risk to your rights and freedoms, we will notify the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) within 72 hours of discovery of the breach, and, in case of a high risk breach, you directly.
5. Your Rights
As a data subject under the GDPR, you have specific rights with respect to your personal data, such as the right of access and the right to erasure (e.g. account deletion, which can also be initiated from inside Skillix by going to Settings → Account).
To read more about, and to exercise any of these rights, you can use this web form or contact us at privacy@skillixapp.com. We may ask you to confirm your identity (for example, by sending us your request from the email address linked to your account) before we act on your request, to protect your data. We will respond as soon as we can, but in any event within a month.
6. Complaints
If you believe we are not handling your personal data correctly, you have the right to lodge a complaint with the Dutch supervisory authority:
Autoriteit Persoonsgegevens
www.autoriteitpersoonsgegevens.nl
Tel: +31 (0)88 1805 250
We would, however, appreciate the opportunity to address your concern directly first. Please contact us before filing a complaint and we will do our best to resolve the issue.
7. Changes to This Statement
We may update this Privacy Statement from time to time. When we make material changes, we will notify you through the app or by other appropriate means and update the effective date at the top of this document. We encourage you to review this statement periodically.
8. Contact
For questions about this Privacy Statement and/or to exercise your rights, contact us at: privacy@skillixapp.com
Website: https://www.skillixapp.com
Postal address: Box C1238, Kwikstaartlaan 42, 3704GS Zeist, the Netherlands
