Last Updated: [Effective Date]
This Privacy Policy explains how [Company Legal Name] ("we," "us," or "our"), a company registered in the People's Republic of China, collects, uses, discloses, and protects information in connection with the mobile application [App Name] (the "App"). This App is intended for a general audience and is offered globally, primarily to users located in the United States, Europe, and other regions outside Mainland China.
By downloading, installing, or using the App, you agree to the collection and use of information in accordance with this Privacy Policy.
The App does not require account registration or login. However, when you use the App, certain information is automatically collected through advertising technology partners in order to display advertisements and support the App's free-to-play model:
To let you save and resume your puzzle progress, the App stores certain data locally on your device (using local storage mechanisms), including:
This locally stored data is not transmitted to our servers and remains on your device unless you clear the App's data or uninstall the App.
We use a third-party mobile advertising mediation platform, TopOn (operated by TOPON PTE. LTD. and/or its affiliates), to display advertisements within the App. TopOn aggregates multiple third-party advertising networks. Depending on which specific advertising network serves an ad at any given time, additional data may be collected in accordance with that network's own privacy policy.
A current list of advertising networks integrated through TopOn is available upon request by contacting us at [Contact Email].
TopOn's own data processing practices are described in their Privacy Policy: https://toponad.net/en/privacy-policy
We use the information described above to:
We do not use the collected information to create user accounts, and we do not sell your personal information for monetary consideration.
We share information only with:
We do not share your information with any other third party for their own independent marketing purposes.
If you are located in the EEA or UK, you have the right to: access, correct, delete, restrict or object to the processing of your personal data, and to data portability, and to lodge a complaint with your local data protection authority. To exercise these rights, contact us at [Contact Email].
TopOn participates in the IAB Europe Transparency & Consent Framework (Vendor ID: 1305) and will present a consent management interface where required for EEA/UK users.
If you are a California resident, you have the right to know what personal information is collected, to request deletion, and to opt out of the "sharing" of personal information for cross-context behavioral advertising (which includes the advertising identifiers shared with our ad mediation partner). To exercise these rights, contact us at [Contact Email] with the subject line "California Privacy Request."
The App is designed for a general audience and is not directed at children under the age of 13 (or the relevant age of digital consent in your jurisdiction). We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected such information, we will take steps to delete it promptly. Parents who believe their child has provided us with personal information may contact us at [Contact Email].
Locally stored game progress remains on your device until you delete the App or clear its data. Data collected via advertising SDKs is retained by TopOn and its network partners in accordance with their own retention policies, typically no longer than necessary for advertising and fraud-prevention purposes.
As our company is based in Mainland China and our users are located primarily in the United States and Europe, information described in this Policy may be transferred to, stored, and processed in countries other than your country of residence, including but not limited to China, Singapore, and the United States, which may have different data protection laws than your jurisdiction. Where required by applicable law, we and our partners rely on appropriate safeguards (such as Standard Contractual Clauses) for such transfers.
We require our advertising technology partners to implement reasonable technical and organizational measures designed to protect information from unauthorized access, disclosure, alteration, or destruction. However, no method of transmission or storage is 100% secure.
We may update this Privacy Policy from time to time. Material changes will be reflected by updating the "Last Updated" date above, and, where required by law, we will provide additional notice.
If you have questions about this Privacy Policy or wish to exercise your privacy rights, please contact us at:
[Company Legal Name]
Email: [Contact Email]