Privacy Policy

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 monetizes through Google AdMob ads. For users in the EEA/UK/CH, we display the Google User Messaging Platform (UMP) consent form before any ads are loaded. Your selection is stored by UMP and can be revisited in the App (section “Privacy / Ads preferences”, if available).

3. Categories of Data & Purposes

• Device identifiers (e.g., Advertising ID): ad delivery, frequency capping, fraud prevention, aggregated measurement.
• Technical & diagnostic data (device type, OS, app version, crash events): stability, debugging, quality improvements.
• In‑app interaction data (aggregated usage events): product analytics and UX improvements.

We do not collect names, emails, or other contact details inside the App. If you email us, we will process your message solely to respond.

4. Legal Bases for Processing

• Consent — for personalized ads and certain processing in the EEA/UK/CH via UMP.
• Legitimate interests — security, abuse prevention, non‑personalized ads, aggregated measurement.
• Performance of a contract — providing the App’s core functionality.
• Legal obligations — compliance with applicable law (e.g., accounting and tax obligations at ad partners).

5. Recipients & Processors

Data may be processed by or accessible to the following categories of recipients:

• Google AdMob / Google Ireland Limited and affiliates — ad serving and measurement, UMP consent.
• System service providers (operating systems, app stores) — updates delivery, crash reports.
• Competent authorities — where required by law and to the extent strictly necessary.

Depending on the scenario, each third party may act as an independent controller or as a processor under its own terms.

6. International Transfers

Processing may occur outside your country (including outside the EEA/UK). We rely on safeguards used by our partners, such as Standard Contractual Clauses and technical/organizational security measures.

7. Retention

We do not store personal data on our own servers. Ad/diagnostic data is processed and retained by service providers in accordance with their policies and only as long as necessary (e.g., for fraud prevention and aggregated measurement).

8. Your Choices & Controls

• In the EEA/UK/CH, the UMP form is shown before ads load. You can consent to personalized ads or opt out.
• You can review/change your decision within the App (“Privacy / Ads preferences”), if available.
• On your device, you can limit ad personalization or reset the Advertising ID in system settings.

9. Your Rights (GDPR/UK GDPR)

Subject to applicable law, you may have the rights to access, rectification, erasure, restriction, portability, objection, and to withdraw consent (without affecting the lawfulness of processing before withdrawal). To exercise your rights, contact: sergiusblr@gmail.com. You may also lodge a complaint with your local data protection authority.

10. Children

The App targets a general audience and is not intended for children below the age of digital consent as defined by your jurisdiction. If we become aware that data from a child was collected without proper safeguards, we will take steps to delete it.

11. Security

We apply organizational and technical measures appropriate to the data and risks involved. No method of transmission or storage is entirely secure, but we strive to protect data against unauthorized access and leaks.

12. Changes to this Policy

We may update this Policy from time to time. The new version becomes effective when posted on this page. The update date appears above.

13. Contact

For privacy questions or rights requests: sergiusblr@gmail.com.

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