Layover

Privacy

What Layover stores, what it shows other players, and how to get rid of all of it.

1. Who is responsible

• Anmoll Wadhwa, sole proprietor, trading as The Wadhwa Ventures, makes Layover and decides what personal data it collects and why. Under India's Digital Personal Data Protection Act 2023 that makes him the Data Fiduciary. He is also the person who answers questions about your data and the Grievance Officer.
• Grievance Officer: Anmoll Wadhwa
• Email: hello@certifiedlost.com. Write from the address you use to sign in, so we can find your records.
• Postal address: New Delhi, India

2. The short version

• Layover is for players aged 13 and over in India, and 18 and over everywhere else. Players under 18 need a parent or guardian to agree to these terms, and we never run analytics on their accounts.
• Layover is not offered in the EU, the EEA or the UK in this version.
• We keep what we need to run the game, your rank and your purchases, and nothing is sold.
• No advertising network, no advertising identifier, no precise location.
• In the app, analytics run only if you say yes, and you can change your mind in Profile. The website works differently: see section 13.
• You can delete your account in the app in one step, or from the web page linked in section 9.

3. What we collect and why

• Email address, for the sign-in code, or from Google if you choose Google sign-in on Android. Why: to create your account and sign you in. No password is stored. Public: no.
• Handle, avatar mark and colour. Why: to show you on the weekly leaderboard. Public: yes, with your weekly points.
• Your age group (13 to 17, or 18 and over), the date you turn 18 if you are under 18, the time you answered, and, for players under 18, the time a parent or guardian agreed. Why: to apply the age rules. We keep the adult eligibility date for players under 18, which can be used to infer their birth date. The entered birth date is cleared from the device after the age check. Public: no.
• Difficulty setting and alert setting. Why: to run the game the way you chose. Public: no.
• Time zone offset in minutes. Why: to decide when your day rolls over. It is a number, not a location. Public: no.
• Play history: sessions, guesses, hints used, scores, streak, passport stamps, weekly points, lifetime points. Why: to run the game, rank you and show your passport. Public: weekly points only.
• Hint credits and purchase state. Why: to give you the hints and the Explorer Pass you bought. Public: no.
• Reports and blocks you make about other players: who did it, who it was about, both handles as they were at the time, the reason code, the time. Why: to keep the leaderboard safe. A person reads every report. The player reported is never told who reported them. Public: no.
• Launch list email, if you joined from the website. Why: to send one launch message. Public: no.
• Usage analytics (screens, taps, sign-in method, app version, operating system, and for Google Analytics a random app instance identifier), only if you allow it and you are 18 or over. Why: to find what is broken and which clues nobody solves. Public: no.
• A request counter per account. Why: to stop one account from overloading the service. Public: no.
• Daily totals of game actions (for example rounds played and hints used), one number per day with no account, device or IP address in it, and, only if you allow analytics, a few screen counts the same way. Why: to see how the game is doing as a whole. Public: no.
• We do not collect: your precise location, your contacts, your photos, your advertising identifier or your payment card details.

4. Purchases

• Payments are taken by Apple or Google, not by us. We never see your card or UPI details.
• RevenueCat, our purchase service, receives your account identifier, the products you bought or restored, the dates and the store that took payment, so that it can tell the app what you own. RevenueCat documents that it collects purchase history (https://www.revenuecat.com/docs/platform-resources/apple-platform-resources/apple-app-privacy).
• Apple or Google keep their own records of your purchases under their own privacy policies.
• To decide whether a player aged 13 to 17 can open an account, the app asks the store which country the device store account belongs to, through RevenueCat, during the age step. RevenueCat creates a random app user identifier for this check, which is not tied to your device or to any advertising identifier, and only the country comes back. No Layover account is created at this step.
• Hint packs are consumable: once spent, the hints are gone. The Explorer Pass is a monthly subscription that belongs to your store account and can be restored.
• Refunds are handled by the store that took your payment. See the refund page.

5. Notifications

• Reminders are scheduled on your phone by the app. No push token is sent to us or to any server. If that ever changes, this policy changes first.

6. Who else handles your data

• Supabase: database, sign-in and server functions. Gets everything in section 3 except analytics and purchase receipts. Where: Mumbai, India (AWS ap-south-1).
• Google (Gmail SMTP): sends your sign-in code email. Gets your email address and the code. Where: outside India.
• Google (sign-in), Android only: lets you sign in with Google if you choose it. Gets your Google email and account identifier. Where: outside India.
• Daily totals: our server adds up the game actions it already handles, such as rounds played, hints used and legs given up, into one number per day, with no account, device or IP address in the total. If you allowed analytics, the app also counts a few screens, such as the shop and your stats, the same way. They stay on our own database.
• Mixpanel: product analytics, only if you allowed it. Gets event names, your account identifier after sign-in, operating system and app version, sent with IP storage switched off. Where: outside India (the app posts to api.mixpanel.com).
• Google Analytics for Firebase (Google): app analytics, only if you allowed analytics and you are 18 or over. Gets the same event names and event details as Mixpanel, a random app instance identifier created on your phone, device model, operating system, app version, and an approximate country or city that Google works out from the connection. It never gets your email, handle, account identifier or birth date. Advertising features are switched off: no advertising identifier, no ad personalisation and no sharing for advertising. It is never switched on for players under 18. Where: outside India.
• RevenueCat: purchase and entitlement service. Gets your account identifier and purchase records. Where: outside India.
• Apple and Google billing: take payment and keep purchase records. Get what their own policies set. Where: outside India.
• Expo: builds the app. Gets nothing about you at run time. Where: outside India.
• Railway and Cloudflare: host and deliver our website, including these legal pages. They do not run inside the app. See section 13.
• Each company gets only what its job needs. We do not sell data and we do not share it for advertising.

7. Children

• Layover is for players aged 13 and over in India, and 18 and over in other countries. We ask for your day, month and year of birth before any account exists, keep only your age group and, for players under 18, the date you turn 18 so the account becomes an adult account on time. We stop if you are under 13.
• For players aged 13 to 17, a parent or guardian must agree to the Terms and this policy. We do not run analytics on these accounts, we do not track or profile them, and Layover shows no advertising to anyone.
• India's Digital Personal Data Protection Act treats everyone under 18 as a child. From May 2027 it requires verifiable consent from a parent before a child's data is processed (Act section 9; DPDP Rules 2025, rule 10). Before that date we will either add that consent step or close accounts of players under 18, and we will tell those players and their parents first.
• A parent or guardian can ask us to see or delete a teen's account at hello@certifiedlost.com. If we learn that an account belongs to someone under 13, we delete it.
• United States: Layover is not directed to children and we have no actual knowledge of collecting personal information from a child under 13, the point at which COPPA applies (16 CFR 312.2 and 312.3, https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-312). If you believe a child has an account, write to hello@certifiedlost.com.

8. How long we keep it

• Account, profile, play history, stamps, scores, reports and blocks you made: kept until you delete the account. When you delete it, everything leaves the game at once. Indian law requires us to keep your email address, handle, account identifier and any reports made by or about you, locked and unused, for 180 days after deletion, and then we erase them.
• Guest passports: you can play before you save your passport with an email. Until then we keep your age group, play history, stamps and points under a random account identifier, and only your phone holds the sign in. A guest passport with no play for 30 days is deleted automatically, with everything in it. Deleting Layover from your phone before you save also loses it, because we have no way to give it back to you. Guests are not on the weekly board and cannot buy.
• Reports, made by you or about you: kept for 180 days from the day the report is made, for safety review. If either account is deleted, the report is kept locked until 180 days after that deletion, then erased automatically. A report keeps both handles as they were.
• Weekly leaderboard row: removed with the account.
• Anonymous daily counts (plays and wins per puzzle): kept. They point at nobody.
• Purchase records at Apple, Google and RevenueCat: kept for as long as Apple, Google and RevenueCat set under their own policies. We keep our own purchase records for the period Indian tax law requires.
• Mixpanel events: deleted on request within 30 days of your request.
• Google Analytics events: kept for the retention period set in our Google Analytics property, and deleted on request within 30 days of your request. Deleting your account also clears the app instance identifier on your phone.
• Launch list email: kept until the launch message is sent or you ask us to remove it.
• Backups: our database plan keeps no automatic backups, so deleted data is not held in a backup.
• Processing logs: from May 2027, the DPDP Rules 2025 (rule 8(3)) require us to keep logs of how your data was processed for one year, then erase them. We will update this section before that date (https://www.meity.gov.in/static/uploads/2025/11/53450e6e5dc0bfa85ebd78686cadad39.pdf).
• Consumable hints do not survive deletion. If you delete your account, unspent hints are gone and cannot be restored.

9. Your rights and how to use them

• Under the DPDP Act you may ask to know what we hold and who we share it with, correct it, erase it, have it handled through a grievance process, and nominate someone to act for you if you die or cannot act (Act sections 11 to 14, same PDF as section 7).
• Layover is not offered in the European Union, the European Economic Area or the United Kingdom in this version. See section 11.
• Delete everything: Profile, Delete account, confirm. Or use https://layover.certifiedlost.com/legal/delete-account.html
• Anything else: write to hello@certifiedlost.com with your handle. We reply to privacy requests within 30 days. The DPDP Rules allow up to 90 days for grievances (rule 14(3)); we commit to the shorter time.
• Withdraw analytics consent: Profile, Privacy and Terms. Withdrawing is as easy as agreeing.
• Complaint: write to the Grievance Officer first. You may then complain to the Data Protection Board of India once it is operating.
• Layover is an online social game under India's Promotion and Regulation of Online Gaming Act, 2025. If you are not satisfied with our answer to a complaint about the game, or we do not answer, you may appeal to the Online Gaming Authority of India within 30 days.

10. Where your data goes

• Our database and server functions run in Mumbai, India (AWS ap-south-1). Some processors in section 6 are outside India. The DPDP Act permits transfers outside India except to countries the Government restricts by notification (Act section 16).

11. The EU, the EEA and the UK

• Layover is not offered in the European Union, the European Economic Area or the United Kingdom in this version. Before we offer Layover in any of those places, we will appoint the representative that GDPR Article 27 requires, set out our legal bases and the rights you would have, and update this policy.

12. Security and breaches

• Data travels over HTTPS. Sign-in uses a one-time code that expires after 10 minutes. The database has row level security on every table. If a personal data breach affects you, we will tell you without delay and tell the Data Protection Board (DPDP Rules, rule 7, including the 72 hour detailed report to the Board).

13. The website

• This section covers layover.certifiedlost.com, where you can play the daily puzzle in a browser without an account. The rest of this policy covers the app.
• Google Analytics runs for every visitor to the website. It sets a cookie named _ga that holds a random identifier, and receives the pages you open and game events such as a puzzle started, a guess, a win or a share. Google signals and advertising personalisation are switched off. Where: outside India.
• Mixpanel runs for every visitor to the website. It receives page views and the same game events, and its session replay records each visit: what the page showed and how you moved through it, such as taps, clicks and scrolls. We use the recordings to find what is confusing or broken. Where: outside India.
• The website does not ask before these two run, and it does not use them for advertising. The game does not need them: if your browser or an extension blocks them, the puzzle still works.
• Launch list: if you leave your email on the website to hear when the app launches, our server stores it, with a short code for where you found the link, in our own database (Supabase, Mumbai). We use it only for the launch message. Section 8 says how long we keep it.
• Railway hosts the website and its server, and Cloudflare sits in front of it and passes every request on. Both receive your IP address and the requests your browser makes. Our server uses your IP address, held in memory only, to limit how fast one visitor can send guesses. Where: may be outside India.

14. Changes

• We publish changes here, update the version number, and ask you again if the change needs your consent.