Privacy Policy

Effective ⟦SET BEFORE PUBLISHING⟧ · Version 1.1

You can play Keenergy without telling us anything about yourself. There are no advertising, analytics or tracking tools in the app, we ask for no device permissions, and we do not sell your data. We do collect crash reports when something breaks, and they go to our own systems with personal details stripped out — and you can switch them off in your profile. The one thing to know is that your names, score and rank are public to other players — that is what a leaderboard is.

1. Who we are

This policy explains how 01 Capital LLC, a Delaware limited liability company doing business as Keenergy, collects and uses personal data when you use the Keenergy app, its games and this website (the “Service”). For data-protection purposes Keenergy is the data controller.

01 Capital LLC d/b/a Keenergy, 4600 South Syracuse Street #1450, Denver, CO 80237, USA — support@keenergy.com.

2. Guest and saved accounts

Keenergy signs you in as a guest automatically so you can play immediately. A guest account is identified only by a random account identifier and a display name. We hold no email address, no phone number and no real-world identifier for it, and the credential lives in your device’s secure storage.

The consequence runs both ways, and you should know both halves:

• We know almost nothing about you.
• We therefore cannot identify you, restore your account, or connect you to it if you lose the device, uninstall the app or clear its data. There is no server-side guest recovery. It also means that for a guest account we may be unable to act on a data request — we have no way to verify that an account is yours.

Saving an account by adding an email address and password attaches a credential to the same account. From then on we hold your email address, and the account can be identified as yours.

3. What we collect

Information you give us

• Account credentials, only if you save an account: your email address and a password. The password is stored only in hashed form; we never see or store it in readable form.
• Your display name (up to 24 characters) and your username, a unique @handle. We generate a username for you automatically when your account is created and you can change it. Neither name is ever derived from your email address. Both are screened automatically for offensive and impersonating content.
• Your base language — English, French, Spanish or Italian — which determines which daily board you are served and ranked on.
• League names and invite codes you create, if you run a private league. League names are screened the same way.
• Reports you submit about another player or a league: what you reported, the reason and any note you add.
• Players you block — we store the list so we can hide them from you.
• Support messages you send us.

We do not collect a profile photo. The app has no avatar upload.

Information generated by playing

• Game sessions — which game you played, in which mode, when, and the record of your moves, stored as opaque game data. For daily puzzles we also store the local calendar date of the daily you played.
• Scores, ranks, leaderboard entries and streaks for each game.
• Plan-usage counters — how many non-daily plays you have started in a game on a given local date, used to enforce free-plan allowances.
• League memberships — which leagues you belong to, your role, and when you joined.

Billing information

• Subscription and purchase records received from Apple, Google and RevenueCat: which plan you hold, its status and dates, and transaction identifiers.
• Activation-code redemptions, where you redeem one.
• We never receive or store your card details. Payment is handled entirely by the app store.

Technical information

• Your device’s time-zone offset, sent with certain requests so we can work out your local calendar day — which daily is today’s, when your play allowance resets, and how far back your archive reaches. We use it to compute a date. We do not store it as part of your profile and we do not use it to locate you.
• App version, platform and protocol version, sent when the app checks whether it is up to date. These are recorded only as an aggregate daily count — how many checks came from a given version and platform — and are not linked to your account.
• Server logs needed to operate, debug and secure the Service.
• Crash and error diagnostics. When the app or our server hits an unexpected error, we may record a diagnostic report so we can find and fix the fault. A report contains the error and where in the code it happened, your app version and platform, and — for errors that happen on our server — your account identifier, the operation being run and an internal request id. Reports from the app itself carry no account identifier. They go to an error-tracking system we run on our own infrastructure, not to an outside analytics or crash-reporting company. The reporter is set to exclude personal data by default: no screenshots, no behavioural or performance tracing, and an automatic pass that strips email addresses, sign-in tokens and web-address query strings from a report before it leaves your device. We use these reports only to diagnose faults — never to profile you, to track you, or to make decisions about you. You can turn this off. Your profile carries a Crash reporting switch: it is per-device, on by default, and switching it off stops reporting on that device straight away. That is how you exercise your right to object — we rely on legitimate interests for diagnostics rather than consent, so they run unless you turn them off.

Stored on your device, not sent to us

A flag recording that you have seen the intro; your acknowledgements of in-app announcements, which are deliberately device-local and never sent to our servers; and a cached copy of your current plan so the app can show the right screens. Your sign-in token is held in your device’s secure storage.

What we do not collect

• No advertising or tracking. The app contains no third-party advertising, analytics, attribution or tracking tools. We do no cross-context behavioural advertising and no profiling. The one diagnostic component in the app is the crash reporter described above, which reports to our own infrastructure and is not an analytics or tracking tool.
• No device permissions. The app requests no location, contacts, camera, photo-library, microphone or health permissions.
• No push notifications. We send none, and no push token is collected from you — no version of the app registers one.
• No biometric or precise-location data, and no data from other apps or your address book.

4. What other players can see

Keenergy is competitive, so some of your data is public within the Service by design:

• Your display name, your @username, your score and your rank appear on the leaderboards of games you play, visible to every other player who views that board.
• Your display name, @username, role and join date are visible to the other members of any league you belong to.

Choose names that do not identify you. Do not use your real name or any other personal detail — they will be shown to strangers. You can change either at any time in the app and the change takes effect immediately.

Your email address is never public. It is never used as a name and never shown to other players.

Names are screened automatically for offensive and impersonating content when you set them, and rejected if they fail. We may also change or reset a name that breaches the Terms.

You can report and block. Reporting sends a player or league to us for review. Blocking hides that player’s names from the leaderboards and rosters you see; it is one-way and the person you block is not told.

Nothing else is exposed to other players — not your email address, your plan, your purchases, your play history away from the leaderboards, your streaks in other games, or which other leagues you belong to.

5. Children and teenagers

• You must be at least 13 to use Keenergy. The Service is not directed to children under 13 and we do not knowingly collect personal data from them. If we learn that an account belongs to a child under 13 we will close it and delete the data. If you believe a child under 13 is using the Service, contact us.
• Where the age of digital consent is higher than 13 — 16 in several European countries — a player below that age may use the Service only with the consent of a parent or guardian, whom we treat as the person exercising the child’s rights with us.
• Purchases require an adult.
• How we protect younger players, by construction. We show no advertising, run no tracking or analytics, do not profile players, collect no location data, and make no automated decisions about anyone. Our only diagnostic collection is the crash reporting described in section 3, which goes to our own systems and is used solely to fix faults. A guest account carries no personal identifier at all.
• The one exposure a younger player needs to understand is their public names — which is why the app warns, in plain language, at the moment a name is chosen: during first-run setup, when editing a display name, and when editing a @handle.
• We do not knowingly sell or share the personal information of anyone under 16 — we do neither for anyone.

6. Who we share data with

We do not sell your personal information and do not share it for cross-context behavioural advertising. We share data only with service providers who process it on our behalf under contract, strictly to run the Service:

Reports and blocks are handled entirely by us and our staff. They are never shared with a third party, and the person you report or block is not told who did it.

We may also disclose data to comply with law, to enforce our Terms, or to protect rights and safety; and in a merger or acquisition, subject to this policy.

7. Artificial intelligence

No Keenergy feature sends your data to an AI service. Your moves, scores, messages, names and account data are never processed by a large language model or any other AI provider, and are never used to train any model — ours or anyone else’s.

Some of our puzzle content is prepared with computer assistance before publication, working from dictionaries and word lists. That happens offline, before a puzzle is ever published, and involves no player data at all.

8. We do not sell or share your personal information

We do not sell your personal information and do not share it for cross-context behavioural advertising, as those terms are defined under the California Consumer Privacy Act. We have not sold or shared personal information in the preceding 12 months. Because we do neither, no “Do Not Sell or Share My Personal Information” link is required — but you still have the rights described below.

9. How we use data, and our legal bases

We do not use your data for advertising, for profiling, or to train AI models. We make no automated decisions producing legal or similarly significant effects about you. Anti-cheat measures can void a score or suspend an account; those decisions are reviewable by a human — contact us.

10. Your rights

Everyone: you can view and edit your display name, username and language in the app at any time, and you can ask us to delete your account and all its data.

EU, EEA and UK (GDPR / UK GDPR): you have the rights of access, rectification, erasure, restriction, data portability and objection, and to withdraw consent at any time. You may lodge a complaint with your local supervisory authority — in the UK, the Information Commissioner’s Office. We will respond within one month.

California (CCPA/CPRA) and similar US state laws: you have the rights to know and access, delete, correct, and opt out of sale or sharing (we do neither), to limit use of sensitive personal information, and to non-discrimination for exercising your rights. You may use an authorised agent. We will confirm receipt within 10 days and respond within 45 days.

A copy of your data. On request we provide a machine-readable export containing your profile, your plan, subscription and purchase records, your play-usage counters, your leaderboard entries, your streaks, your league memberships, your session participation and your activation-code redemptions.

How to exercise: in the app, or by writing to support@keenergy.com. We will verify your request against your account before acting — which, as explained above, we may be unable to do for a guest account, since we hold nothing that could establish it is yours.

11. Deleting your account

You can delete your account and its data in the app (Profile → Delete account) or, if you can no longer sign in, by writing to support@keenergy.com. Full details are at keenergy.com/delete-account.

What happens:

1. Your account is scheduled for deletion. It keeps working, and you can cancel at any time during the grace period below — nothing is erased yet.
2. For 14 days the deletion is reversible — contact us if you change your mind.
3. After that your data is permanently erased: leaderboard entries, streaks, league memberships, play-usage counters, subscription, plan and purchase records, code redemptions, and your participation in game sessions. A session left with no remaining participants is deleted outright. Your profile is anonymised — your names are replaced and remaining identifiers cleared.

Two things survive, and you should know why: a blocked authentication record is kept so the account cannot be reactivated, and billing and tax records are kept for as long as the law requires.

Deleting your account does not cancel a subscription billed by Apple or Google — cancel that in the relevant store.

12. How long we keep data

• While your account is active, we keep the data described above for as long as you use the Service.
• After you ask us to delete it: 14 days’ reversible grace, then permanent erasure.
• Closed leagues are kept for 30 days so their owner can reopen them, then deleted along with their roster and invite codes.
• Billing and tax records are kept for as long as tax and accounting law requires, which is generally seven years, even after your account is deleted.
• Residual copies may persist in routine encrypted backups until those backups are overwritten on our normal rotation.
• Aggregate app-version counts contain no personal data.

13. International data transfers

Keenergy operates from the United States, and our providers may process data in the US and elsewhere. Where we transfer personal data out of the EEA or the UK we rely on an appropriate safeguard — the EU–US Data Privacy Framework where available, otherwise Standard Contractual Clauses or the UK International Data Transfer Agreement in our provider agreements.

14. Security

We protect data with encryption in transit, encryption at rest, access controls and hashed passwords. The server is authoritative for every score and plan, and game answer keys are never sent to a client.

We do not offer end-to-end encryption, and we can read the data described in section 3 other than your password. Your gameplay data is stored in a form we can process in order to run the Service.

No method of transmission or storage is completely secure and we cannot guarantee absolute security. You are responsible for safeguarding your credentials.

15. Cookies and similar technologies

The Keenergy app uses only the local storage necessary to operate — keeping you signed in, remembering that you have seen an announcement, and caching your plan. It sets no advertising or analytics cookies. This website sets no cookies at all and loads no third-party resources.

16. Changes to this policy

We may update this policy. For material changes we will give reasonable notice in the app or by email and update the date at the top of this page. Continuing to use the Service after the effective date means you accept the update.

17. Contact

Questions or requests: 01 Capital LLC d/b/a Keenergy, 4600 South Syracuse Street #1450, Denver, CO 80237, USA — support@keenergy.com. EU and UK residents may also contact their local supervisory authority.