Privacy Policy

1. Information We Collect

1.1 Information stored locally on your device

The Services store the following categories of information locally on your device, in application storage on mobile and in browser local storage on the web: puzzle progress and completion history, best scores and statistics, daily challenge results and streaks, badges and trophies, notes entered during play, your daily hint allowance, a record of whether Bubble Sudoku Plus has been purchased, a marker recording that the browser-based game has already been counted once (Section 1.4), and application settings.

This information is not transmitted to Pop Logic Studios, is not accessible to us, and is not disclosed to any third party, except for the daily challenge score and the one-time player count described in Section 1.4. It is deleted when you delete the App, clear the App’s data, or clear your browser’s storage. If your device’s own backup service is turned on, such as iCloud Backup on iOS or backup to your Google account on Android, your device may include this information in a backup stored in your Apple or Google account, which we cannot access. We do not maintain a backup of this information and are unable to restore it.

1.2 Information collected in connection with advertising

The free version of the App displays advertising served by Google AdMob, a service provided by Google LLC and, for users located in the European Economic Area, the United Kingdom, and Switzerland, by Google Ireland Limited (“Google”). In order to deliver advertisements, limit repeated delivery of the same advertisement, measure delivery, and detect invalid activity, Google collects the following categories of information directly from your device:

Advertising is presented in four placements within the free version of the App: a banner displayed below the puzzle grid during play; a full-screen advertisement that may be displayed when you leave the completion or game-over screen; an optional video advertisement offered in exchange for an additional hint after the daily allotment of free hints has been used; and an optional video advertisement offered once per game in exchange for an additional life. The two video placements are voluntary; no feature of the Services is conditioned upon viewing them.

We instruct Google to serve non-personalized advertising in all regions. Non-personalized advertisements are selected on the basis of contextual factors rather than a profile of the user’s interests or prior behavior. The App does not present the Apple App Tracking Transparency prompt, because the App does not track users across applications or websites owned by other companies as that term is defined by Apple. Should this practice change in the future, we will update this Privacy Policy and obtain any consent required by applicable law before implementing the change.

Information described in this Section 1.2 is collected by Google directly from your device. Pop Logic Studios does not receive it, does not store it, and cannot access it in an identifiable form. We receive only aggregate reporting regarding advertising performance.

If you purchase Bubble Sudoku Plus, all four placements are turned off and the App no longer starts Google’s advertising software, so the information described in this Section 1.2 is not collected. A holder of Bubble Sudoku Plus may choose to turn the once-per-game extra-life video back on in the App’s settings; if you do, the advertising software starts again for that purpose only.

1.3 Information collected in connection with purchases

The App offers a single non-consumable in-app purchase, Bubble Sudoku Plus. Payment is processed by Apple Inc. or Google LLC in accordance with their respective terms and privacy policies. We do not receive or store payment card numbers, billing addresses, or the name associated with your payment method.

To determine and restore purchase entitlements, we use RevenueCat, Inc. RevenueCat receives a record that a transaction occurred, together with a pseudonymous application user identifier generated by the software. This identifier is not derived from your name, email address, or store account.

1.4 Information collected through the website

The website does not display advertising and does not set cookies. Typefaces are served from our own domain.

The website is hosted by Cloudflare, Inc. and uses Cloudflare Web Analytics to measure how the website is used in aggregate. When a page loads, a script provided by Cloudflare records the address of the page, the address of the page that linked to it, the type of browser, operating system, and device, the country from which the request was made, and how quickly the page loaded. Cloudflare states that this service does not use cookies or local storage and does not collect visitors’ personal data. We receive only aggregate reports, such as the number of visits to each page and the websites that referred those visits, and we use them to understand how visitors find the website and which pages are useful. The browser-based game on the website does not use advertising or analytics beyond this.

Upon completion of the daily challenge in the browser-based game, the Services transmit two data points to our server: the calendar date of the challenge and the numeric score achieved. This transmission contains no identifier, no device information, and no other content. Scores are aggregated into counts of how many players fell within each scoring range on that date, which enables the completion screen to display comparative performance.

When the first game in a given browser is finished, the browser-based game transmits one data point to the same server: the calendar date. This transmission contains no identifier, no score, no device information, and no other content. The server adds one to a running count of players and to a count for that date, and a marker stored in your browser prevents the same browser from being counted again. These counts are totals only, cannot identify anyone, and are used to understand how many people play the browser-based game. They are not published.

As is the case with any internet-connected server, our web server necessarily receives the IP address of a requesting device in order to return a response. We do not log, store, or associate IP addresses with any other information. The service that receives daily challenge scores and the player count is configured so that it does not read the originating IP address. Transient connection records maintained by our hosting provider are not searchable by us, are not exported, and are not joined to any other data.

1.5 Information you provide directly

If you contact us by email, we receive your email address and the contents of your message. We use this information solely to respond to your inquiry and to maintain a record of the correspondence.

2. How We Use Information

We use the limited categories of information described above for the following purposes:

• To provide, operate, and maintain the Services.
• To deliver advertising in the free version of the App and to compensate for the cost of developing and distributing the Services.
• To verify and restore in-app purchase entitlements.
• To generate aggregate, non-identifying statistics regarding daily challenge performance.
• To count, in aggregate and without identifying anyone, how many people play the browser-based game.
• To understand, in aggregate, how visitors find and use the website.
• To respond to inquiries, support requests, and requests to exercise privacy rights.
• To detect, prevent, and address fraud, abuse, security incidents, and technical malfunctions.
• To comply with applicable law and to establish, exercise, or defend legal claims.

We do not use information collected through the Services for automated decision-making producing legal or similarly significant effects, and we do not construct behavioral profiles of users.

3. Disclosure of Information to Third Parties

We do not sell personal information. We disclose information only to the service providers identified below, each of which processes information under its own privacy policy:

We may also disclose information where required to do so by law, regulation, legal process, or governmental request; where necessary to enforce our Terms of Use; or where necessary to protect the rights, property, or safety of Pop Logic Studios, our users, or the public. In the event of a merger, acquisition, financing, reorganization, or sale of assets, information may be transferred as part of that transaction, subject to the terms of this Privacy Policy.

4. Legal Bases for Processing (EEA and United Kingdom)

Where the General Data Protection Regulation (EU) 2016/679 or the United Kingdom General Data Protection Regulation applies, we process personal data on the following legal bases:

• Legitimate interests (Article 6(1)(f)) for the delivery of non-personalized advertising, the prevention of fraud and abuse, the security and integrity of the Services, and the aggregate measurement of daily challenge participation and of website use. Our legitimate interest is in funding and maintaining a service offered at no charge, balanced against the limited scope of the data processed.
• Performance of a contract (Article 6(1)(b)) for the verification and restoration of in-app purchase entitlements.
• Consent (Article 6(1)(a)) where consent is required by applicable law, including for the storage of or access to information on your device where an exemption does not apply. Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal.
• Compliance with a legal obligation (Article 6(1)(c)) where processing is necessary to satisfy a requirement of law.

You have the right to object at any time to processing carried out on the basis of our legitimate interests, on grounds relating to your particular situation. Section 6 describes how to do so.

5. Sale and Sharing of Personal Information

We do not sell personal information, and we have not sold personal information in the preceding twelve months. We receive no consideration in exchange for personal information.

Because we instruct our advertising provider to serve non-personalized advertising, and because no profile of any user is constructed for advertising purposes, we do not consider our advertising practices to constitute “sharing” for cross-context behavioral advertising as that term is defined under the California Consumer Privacy Act or analogous state statutes. We have not knowingly engaged in such sharing in the preceding twelve months.

Notwithstanding the foregoing, and without waiving the position stated above, we provide the following means of directing that your advertising identifier not be made available to our advertising provider:

• iOS and iPadOS. Open Settings, select Privacy & Security, select Tracking, and disable “Allow Apps to Request to Track.” Additionally, open Settings, select Privacy & Security, select Apple Advertising, and disable “Personalized Ads.”
• Android. Open Settings, select Privacy, select Ads, and select “Delete advertising ID.”
• By request. Submit a request to hello@bubblesudoku.com with the subject line “Do Not Sell or Share.” We will confirm our practices in writing within the period required by applicable law.

Purchase of Bubble Sudoku Plus turns off all advertising in the App, as described in Section 1.2.

We do not discriminate against any individual for exercising a privacy right. We do not offer financial incentives in exchange for personal information, and the Services are not made available on different terms to users who exercise their rights.

We do not collect or process sensitive personal information as that term is defined under applicable United States state privacy law.

6. Your Privacy Rights and How to Exercise Them

6.1 Rights under European and United Kingdom law

Subject to the conditions and exceptions set out in applicable law, you have the right to request access to your personal data; to request rectification of inaccurate data; to request erasure; to request restriction of processing; to object to processing; to data portability; to withdraw consent where processing is based on consent; and to lodge a complaint with your national supervisory authority.

6.2 Rights under United States state law

Residents of California, Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia, among other states, may have the right to know what personal information is collected and the purposes for which it is used; to access and obtain a copy of that information; to request correction; to request deletion; to opt out of the sale or sharing of personal information and of targeted advertising; and, in certain states, to appeal a decision declining a request.

6.3 Submitting a request

Requests may be submitted to hello@bubblesudoku.com. We will respond within thirty days, or within such other period as applicable law requires, and may extend that period where permitted upon notice to you.

Because the Services operate without accounts and because gameplay data does not leave your device, we generally hold no personal information associated with an individual user. Where we hold no responsive information, our response will state that fact. Requests concerning information collected directly by Google in connection with advertising should be directed to Google, or may be satisfied through the device-level controls described in Section 5, which prevent collection at its source. Information stored locally on your device may be deleted at any time by deleting the App or clearing browser storage.

We may request information reasonably necessary to verify a request or to identify the information to which it relates. An authorized agent may submit a request on your behalf upon presentation of evidence of authority.

7. Children’s Privacy

The Services are directed to a general audience. They are not directed to children under the age of thirteen, and we do not knowingly collect personal information from children under the age of thirteen. We do not designate the App as child-directed under the Children’s Online Privacy Protection Act, and the App is not offered in the Apple Kids Category or under the Google Play Designed for Families program.

The App contains no chat, messaging, comment, social networking, or user profile functionality; no user-generated content is transmitted or published; and the App does not request access to the camera, microphone, photo library, contacts, or geolocation.

Advertising served in the App is non-personalized for all users, without regard to age. This is the most restrictive advertising configuration offered by our advertising provider.

If you are a parent or legal guardian and you believe that a child under the age of thirteen has provided personal information to us, please contact us at the address in Section 14. We will investigate and delete any such information.

8. Data Retention

We do not retain personal information for longer than is reasonably necessary for the purpose for which it was collected. The retention period applicable to each category is set out below.

9. Security

We maintain administrative and technical safeguards designed to protect information against unauthorized access, disclosure, alteration, and destruction. All communications between the Services and our servers are transmitted over encrypted connections.

The principal safeguard in the design of the Services is the limitation of collection itself: gameplay data is not transmitted to us and therefore is not subject to loss or unauthorized disclosure by us. No method of transmission or storage, however, is entirely secure, and we cannot guarantee absolute security.

10. International Data Transfers

Pop Logic Studios is established in the United States, and our service providers may process information in the United States and in other jurisdictions. Where personal data is transferred from the European Economic Area, the United Kingdom, or Switzerland to a country that has not received an adequacy decision, such transfers are made pursuant to appropriate safeguards, including the Standard Contractual Clauses adopted by the European Commission and, where applicable, the United Kingdom International Data Transfer Addendum, as implemented by the recipient. Copies of the relevant safeguards may be requested at the address in Section 14.

11. Cookies and Similar Technologies

The website does not set cookies and does not use advertising pixels or any technology that tracks visitors across websites. The Cloudflare Web Analytics script described in Section 1.4 does not use cookies or local storage. It uses browser local storage to retain your settings and scores. Local storage is not transmitted to us, is not accessible to other websites, and may be cleared through your browser settings at any time.

The App does not use cookies. In the free version, it accesses device storage, and on Android the device advertising identifier, for the advertising purposes described in Section 1.2.

Because we do not track users across websites or applications, we do not receive information that a Do Not Track or Global Privacy Control browser signal would otherwise restrict. Our practices are consistent with the preference such signals express.

12. Third-Party Platforms and External Links

The App is distributed through the Apple App Store and Google Play. Those platforms collect information in connection with the download, installation, and updating of applications under their own privacy policies, which we do not control and to which we have no access. Where the App is available in those stores, the privacy disclosures appearing on its product pages are consistent with this Privacy Policy.

The Services may contain links to websites operated by third parties. We are not responsible for the privacy practices or content of those websites, and we encourage you to review their privacy policies.

13. Changes to This Privacy Policy

We may amend this Privacy Policy from time to time. If we make a material change, we will update the date at the top of this page and post the revised policy here before the change takes effect, and we will note the change in the release notes accompanying the corresponding version of the App. Your continued use of the Services after a revised Privacy Policy takes effect constitutes acknowledgment of the revision.

14. Controller Identity and Contact Information

Pop Logic Studios LLC, a California limited liability company, is the controller of personal data processed in connection with the Services for the purposes of the General Data Protection Regulation and the United Kingdom General Data Protection Regulation, and is the business responsible for the personal information described in this Privacy Policy for the purposes of United States state privacy law.

Inquiries and requests may be directed to:

Pop Logic Studios LLC
2108 N St, Ste N
Sacramento, CA 95816
United States
hello@bubblesudoku.com

Our Terms of Use govern your use of the Services.