Privacy Policy

App: Naval Battle P2P  ·  Last updated: 27 April 2026  ·  Effective: 27 April 2026

This Privacy Policy explains how Federico G. Ramos (“we”, “us”, “our”) processes personal data in connection with the iOS application Naval Battle P2P (the “App”). We are committed to protecting your privacy and to complying with the Argentine Personal Data Protection Law (Ley 25.326) and, where applicable to users located in the European Economic Area, the EU General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”).

1. Data Controller

The data controller responsible for the processing of your personal data is:

2. Scope and Principles

Naval Battle P2P is designed with privacy by default. The App is a two-player iOS game that pairs two nearby devices over your local network (Wi-Fi or Bluetooth) using Apple's MultipeerConnectivity framework, with no accounts, no servers operated by us, and no internet connection required to play. Whenever possible, your data never leaves your device or, during a match, your local network. We process only the minimum personal data necessary to operate the App, and we do not sell, rent, or trade personal data to any third party.

3. What Data We Process

3.1 Data stored on your device

The App stores the following information locally on your iPhone or iPad using Apple's SwiftData and UserDefaults frameworks:

• Your chosen player display name.
• Per-match results and lifetime statistics (wins, losses, accuracy, ships sunk).
• App preferences such as audio, haptics, and Solo Captain difficulty.

This information is stored solely on your device. Federico G. Ramos has no access to it.

3.2 Data exchanged with peers on your local network

When you pair with a nearby player to play a match, the App exchanges the following data directly with that peer device over your local Wi-Fi or Bluetooth connection, using Apple's MultipeerConnectivity framework:

• The player display name you have set.
• A randomly generated peer identifier (UUID) used only to coordinate the current match.
• Game state: your ship placements (sent only to your opponent and only as required by gameplay), shot coordinates, hit / miss / sunk markers, turn ordering, and ready states.

This data is exchanged only with the peer device you have explicitly paired with, only for the duration of the match, and never leaves your local network. We do not host, route, intercept, log, or otherwise have access to any of this peer-to-peer traffic. Apple's MultipeerConnectivity framework provides platform-level encrypted transport for these sessions.

3.3 Data we do not collect

• We do not operate user accounts, and no registration is required.
• We do not operate any backend service. The App makes no network requests to any server controlled by us.
• We do not use analytics, telemetry, crash reporting, or advertising SDKs.
• We do not use cookies, tracking pixels, or similar technologies.
• We do not collect the IDFA or any cross-app or cross-site tracking identifier.
• We do not access your contacts, calendar, location, microphone, camera, photos, or files outside the App's sandbox.
• We do not synchronise your data through iCloud or any other cloud service operated by us. (If you have enabled iCloud Backup on your device, iOS itself may include the App's local data in your personal device backup; that backup is governed by Apple's privacy practices, not ours.)

4. Legal Basis for Processing

Under Article 5 of the Argentine Personal Data Protection Law (Ley 25.326) and, where applicable to users in the EU/EEA, Article 6(1) GDPR, we rely on the following legal bases:

• Performance of a contract (Art. 6(1)(b) GDPR / consent to use the App under Ley 25.326): processing necessary to provide the core matchmaking and gameplay functionality of the App that you have chosen to install and use.
• Legitimate interests (Art. 6(1)(f) GDPR): maintaining the local statistics that the App keeps on your behalf at your request.
• Legal obligations (Art. 6(1)(c) GDPR / Art. 5 Ley 25.326): where applicable, to comply with our obligations under Argentine and, where relevant, EU law.

5. How We Use Information

Any data processed in connection with the App is used exclusively to:

• Provide and maintain the App's features (peer pairing, turn-based gameplay, scoring, statistics, Solo Captain mode).
• Preserve your preferences and statistics between sessions.
• Diagnose and resolve technical issues strictly based on information you choose to share with us by email.

6. Data Sharing and Third Parties

We do not sell or share personal data for advertising or profiling. The App relies only on the following third-party services, acting as independent controllers as indicated:

• Apple Inc. / Apple Distribution International Ltd. — operator of the App Store and the iOS platform on which the App runs. Apple acts as an independent controller for the services it provides to you (App Store distribution, in-app purchase processing, optional iCloud Backup). Apple's handling of this data is governed by the Apple Privacy Policy.

We do not engage any other processor, analytics provider, advertising network, or backend service.

7. International Transfers

Because the App does not transmit personal data to any server operated by us, we do not perform any international transfer of your personal data. Any data exchanged with a peer during a match remains on your local network. Argentina has been recognised by the European Commission as providing an adequate level of data protection (Decision 2003/490/EC). Apple's own handling of App Store and any optional iCloud data is governed by Apple's own safeguards and privacy policy.

8. Data Retention

• Data stored locally on your device (statistics, preferences) is retained for as long as you keep the App installed or choose to keep that data. You can delete your statistics from within the App at any time, or remove all of it by uninstalling the App.
• Data exchanged with a peer during a match is held only for the duration of that match; only the resulting score is persisted locally.
• Correspondence you send to us (for example, support emails) is retained only for as long as necessary to handle your request, and typically no longer than 24 months.

9. Security

We apply appropriate technical and organisational measures to protect personal data, including iOS app sandboxing, Apple's MultipeerConnectivity framework with platform-level encrypted transport for peer sessions, and the use of Apple's platform security for local storage. No method of electronic storage or transmission is entirely secure; however, we continuously work to apply industry-standard safeguards.

10. Your Rights

Subject to the conditions set out in the Argentine Personal Data Protection Law (Ley 25.326) and, where applicable, the GDPR, you have the right to:

• Access the personal data we hold about you (Art. 14 Ley 25.326 / Art. 15 GDPR).
• Request rectification of inaccurate or incomplete data (Art. 16 Ley 25.326 / Art. 16 GDPR).
• Request erasure of your personal data (Art. 16 Ley 25.326 / Art. 17 GDPR).
• Object to or request restriction of processing (Art. 27 Ley 25.326 / Arts. 18, 21 GDPR).
• Data portability, where applicable (Art. 20 GDPR).
• Withdraw consent at any time, where processing is based on consent, without affecting the lawfulness of prior processing.

Because nearly all data processed by Naval Battle P2P is stored exclusively on your device, exercising these rights in practice often means using the App's own controls (e.g. clearing your statistics from Settings) or simply uninstalling the App. For any request concerning data we may hold directly (for example, your support correspondence), please contact us using the details in Section 13.

11. Supervisory Authority

If you believe that our processing of your personal data infringes applicable data protection law, you have the right to lodge a complaint with a supervisory authority. The competent authority in Argentina is:

Users in the EU/EEA may also lodge a complaint with the national supervisory authority of their place of residence, place of work, or place of the alleged infringement.

12. Children's Privacy

Naval Battle P2P is rated 4+ in the App Store and is suitable for all ages. The App does not require accounts, does not collect personal data on any server we operate, and does not transmit data outside your local network during gameplay. We do not knowingly collect personal data from children through any out-of-band channel. If you believe a child has provided personal data to us (for example, by email), please contact us so we can take appropriate action.

13. Contact Us

For any questions, requests, or complaints regarding this Privacy Policy or the processing of your personal data, please contact:

14. Changes to this Policy

We may update this Privacy Policy from time to time to reflect changes in the App, our practices, or applicable law. When we make material changes, we will update the “Last updated” date above and, where appropriate, provide additional notice within the App. We encourage you to review this page periodically.