In short
Dotliner is a dots-and-boxes game that runs on your phone and nowhere else. There is no account, no advertising, no analytics and no server of ours anywhere in it. Nothing you draw, score, name or set is transmitted to EMPWR Limited or to anyone else, and there is no mechanism in the app by which it could be.
That makes this a short document. The only two parts worth real attention are what the app saves locally between games, and the fact that a pass-the-phone game involves a second person whose data is not yours.
What Dotliner saves on your phone
Android gives each app a private storage area that no other app can read. Dotliner writes five things into it:
- The game in progress — which lines are drawn, which boxes belong to whom, and whose turn it is, so that closing the app mid-duel does not lose it.
- The initials and colours chosen for the two players, so the next game starts with the same two marks on the board.
- The result of the last game — the final box count that the end screen tallies up.
- Your settings — grid size, difficulty of the computer opponent, and whether hints are switched on.
- Nothing else. There is no running archive of past games, no record of how often undo was pressed, no log of the moves you reconsidered.
All five sit in the app's own storage. They are copied into a device backup only if you have Android's backup turned on, in which case Google holds that backup under Google's terms and we never see it. Uninstalling removes all of it from the handset.
What it never does
- No sign-in and no profile. The app never asks for a name, an email address or a telephone number, and has nowhere to keep one if you offered.
- No advertising and no advertising identifier. There is no ad library in the build, so nothing reads the Advertising ID and nothing is inferred from how or when you play.
- No analytics and no crash reporting. No session counted, no screen logged, no stack trace sent.
- No permissions worth the name. No location, contacts, camera, microphone, photos or files — and the whole game works with the phone in flight mode.
- No online play and no leaderboard. Your opponent is either the device or the person holding it next. Neither route leaves the handset.
These describe the build published today. The last card on this page sets out the order in which any of them would have to be withdrawn if that ever changed.
In a hot-seat game, the other person is the privacy question
Almost every privacy policy is written about a company on the far end of a network. There is no far end here, so the honest version of the question changes shape: the only way anything in Dotliner is seen by someone other than you is if they are holding your unlocked phone. Usually that is the person you just handed it to, because that is how the game is played.
Two small things follow from that, and both are worth saying rather than leaving implied.
The second player's initial is not your data. When someone sits down opposite you and the board records a letter for them, that letter — tiny as it is — identifies a real person to anyone who recognises it, and it belongs to them, not to you. It stays in the app's storage until the next game overwrites it. We never receive it and could not produce it if we were ordered to, because it has never existed anywhere but on your handset.
The app does not pretend to be a safe. Dotliner has no passcode of its own, and adding one would be security theatre: anyone able to open the app has already unlocked the phone. Rather than claim a protection it cannot provide, the app keeps as little as possible — the current game, two initials, one score — so that there is very little for the person across the table to find in the first place.
Clearing it
Starting a new game replaces the board that was saved. Changing the initials replaces the initials. For everything at once, Android's own app settings will clear Dotliner's storage while leaving it installed, which returns it to the state it was in on first run — no saved game, no initials, default settings and difficulty.
Neither route needs anything from us, and neither can be undone, because no second copy of any of it was ever made anywhere.
Who is responsible
The data controller is EMPWR Limited, a company registered in England and Wales with its registered office at 76 Old School Place, Croydon CR0 4GA, United Kingdom, trading as EMPWR Games. The person answerable is Rolan Daniel Garcia. The UK GDPR requires a controller to identify itself even where the processing is as slight as it is here, which is why the company is named in full.
In practice that responsibility covers correspondence and nothing else, because the app sends us nothing to be responsible for. Obtaining or updating Dotliner through Google Play is a separate relationship between you and Google, which is its own controller for that, on its own terms.
If you write to us
Mail reaches us at [email protected]. Your address, your message and anything attached arrive here and are kept while the matter is open and for a short while after it closes, in case it reopens, then deleted. The lawful basis is legitimate interests — replying to people who write to us about our own software. It is used to answer you and for nothing else: no list, no onward sharing, no marketing. Ask for a thread to be deleted sooner and it goes.
Because nothing in the app is identified, nothing in your email can be matched against anything you played. If a game scored oddly, describe the board — the grid size and roughly what the position looked like — since we have no way to retrieve it.
Your rights, and the regulator
The UK GDPR and the Data Protection Act 2018 give you rights over personal data held about you. In a case like this the useful way to read them is by asking where the data actually sits, because the answer differs sharply between three places.
Data in our inbox
If you have written to us, the full set applies to that correspondence: access, a copy, rectification, erasure, restriction, objection and portability. There is no charge, no particular form of words is needed, and the answer is due within one month of us receiving the request. Send it to the address above.
Data on your handset
The saved game, the initials, the last result and the settings are not in our possession and never have been. We cannot disclose, correct or erase them, and any claim to the contrary would be false. They are reached by you, in the app, as the card above describes — which is a worse answer than a one-click form would be, and a true one.
Data that does not exist
There is no account, no identifier, no play history on any server and no profile of you anywhere. A subject access request aimed at that will be answered to say so, which is the complete and final response rather than a holding one.
One question deserves its own answer: if somebody you played against asks us to erase the initial recorded for them, we cannot, because we do not have it. The only person who can is whoever holds the phone, by starting a new game or clearing the app's storage. We will say exactly that, to them, in writing, if asked.
The supervisory authority for the United Kingdom is the Information Commissioner's Office, at ico.org.uk. It takes complaints directly and you are not required to raise anything with us first.
Children
Dotliner has no chat, no content shared with anybody, no links out of the app and no purchases. It collects no data from any user, which includes any user under thirteen, so there is no age gate to operate and no parental consent to obtain, and neither is pretended. It is a grid of dots and a pencil line, which is what it was when it was played on the back of an exercise book.
If this page is ever rewritten
The date under the title names the edition in force. Where a release would make any statement above untrue — anything collected, anything transmitted, a component added, a permission requested, a transfer out of the United Kingdom — the sequence does not vary: this page is corrected first, the Data safety declaration in the Play Console is corrected in the same sitting, and only then does that release reach anybody. A sentence rewritten for clarity is not that sort of change and brings nothing with it but a fresher date.
Superseded editions are kept. Ask at the address below for the earlier text and it will be sent, which is the only way anyone outside the company can hold the paragraph above to account.
EMPWR Limited
Trading as EMPWR Games
76 Old School Place, Croydon CR0 4GA, United Kingdom
Responsible person: Rolan Daniel Garcia
Email: [email protected]
Application: com.boxduel.dotliner
If any of this is unclear, write and ask for it in plain words — we will answer without the legal vocabulary, and in as much detail as you want.