Privacy Policy

Last updated:

This Privacy Policy explains how the mobile application Not Sudoku: pair or 10 (the “App”), distributed via the Apple App Store and other platforms, processes personal data in accordance with the EU General Data Protection Regulation (GDPR), the UK GDPR, and other applicable data protection laws.

1. Data Controller & Contact

Controller: Independent developer (indie developer).

Privacy contact: sergiusblr@gmail.com

2. What the App Does

The App is a casual number-puzzle game. It is free to download. Users may optionally remove ads permanently via a one-time in-app purchase.

On Android: The App is monetized through advertising provided by Google AdMob. For users in the EEA, the UK, and Switzerland, we display the Google User Messaging Platform (UMP) consent form before any ads are loaded, where required by law.

On iOS: The App is also monetized through Google AdMob. Before loading ads or using data for tracking, we request your permission via Apple’s App Tracking Transparency (ATT) framework (system dialog on first launch). The in-app purchase “Remove Ads” is available on iOS to permanently disable ads.

3. Categories of Data & Purposes

On Android and iOS (where the App shows ads), the following may apply:

Device identifiers (such as the Android advertising ID, or on iOS the Identifier for Advertisers (IDFA) when you allow tracking): ad personalization, ad delivery, frequency capping, fraud prevention, and aggregated measurement.
Usage data (such as ad impressions, interactions, and aggregated gameplay events): analytics, ad performance measurement, and service improvement.

On iOS, we request your permission via ATT before using data for tracking; you can allow or deny in the system dialog. If you deny, ads may still be shown in a non-personalized form.

We do not collect names, email addresses, or other direct contact details inside the App.

In-app purchases (such as the optional one-time purchase to remove ads) are processed directly by the Apple App Store. We do not receive, store, or process payment or billing information.

4. Legal Bases for Processing

Consent — for personalized advertising and tracking, where required (e.g. via ATT and UMP).
Legitimate interests — for non-personalized ads, security, fraud prevention, and aggregated measurement.
Performance of a contract — to provide the App’s core functionality.
Legal obligations — to comply with applicable laws.

5. Recipients & Third Parties

Data may be processed by the following categories of recipients:

Google AdMob / Google Ireland Limited (on Android and iOS) — ad serving, personalization, measurement, and consent management (UMP on Android, ATT on iOS).
Platform providers (such as Apple) — app distribution, in-app purchases, and system-level services.
Authorities — where required by law.

6. International Data Transfers

Data may be processed outside your country of residence, including outside the EEA and the UK. Where applicable, appropriate safeguards such as Standard Contractual Clauses are used by our partners.

7. Data Retention

We do not store personal data on our own servers. Advertising and usage data is processed and retained by our partners in accordance with their own privacy policies and retention periods.

8. Your Choices & Controls

On Android, you can consent to or decline personalized advertising where required (e.g. via the UMP consent form).
On iOS, we request tracking permission via the ATT dialog on first launch. You can allow or deny; you can change this later in Settings → Privacy & Security → Tracking.
You can limit ad personalization or reset the advertising identifier in your device settings (relevant where ads are shown).
You can permanently remove ads via the optional in-app purchase on both Android and iOS.

9. Your Rights

Depending on your location, you may have rights to access, rectify, erase, restrict, or object to the processing of your personal data, as well as the right to withdraw consent at any time. To exercise your rights, contact: sergiusblr@gmail.com.

10. Children

The App is intended for a general audience and is not specifically directed at children under the age of 13. We do not knowingly collect personal data from children.

11. Security

We apply reasonable technical and organizational measures to protect data. However, no method of transmission or storage is completely secure.

12. Changes to This Policy

We may update this Privacy Policy from time to time. The updated version becomes effective when published on this page.

13. Contact

For privacy-related questions, please contact: sergiusblr@gmail.com.