Privacy Policy

Sudoku - Math Offline game (https://sudokuoffline.netlify.app/privacy, hereinafter “Sudoku - Math Offline game”) has established and discloses this Privacy Policy in compliance with the EU General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and other applicable data protection laws to protect users’ personal information and ensure prompt handling of related concerns.

○ This Privacy Policy is effective as of May 17, 2025.

Article 1 (Purpose and Legal Basis of Personal Data Processing)

Sudoku - Math Offline game processes personal data for the following purposes and in compliance with GDPR Article 6:

• Provision of goods or services: To provide game content, personalized ads, in-app purchases, and related services (Legal basis: Contractual necessity).
• Analytics and service improvement: To monitor and improve app performance (Legal basis: Legitimate interests).
• Marketing communications: To provide users with information about updates and new features (Legal basis: User consent).
• Legal compliance: To comply with legal obligations (Legal basis: Legal obligation).

Article 2 (Retention and Use Period of Personal Data)

① Sudoku - Math Offline game retains and uses personal data within the retention period agreed upon by the user at the time of collection or as required by law.
② Specific retention periods:

• Provision of goods or services: Data is retained until no longer necessary and then securely deleted.
• Retention basis: Game service operation.
• Legal basis: GDPR compliance.

Article 3 (Users’ Rights under GDPR)

Users residing in the European Economic Area (EEA) have the following rights under GDPR:

• Right of access to their personal data.
• Right to rectification of inaccurate or incomplete data.
• Right to erasure (“Right to be Forgotten”).
• Right to restriction of processing.
• Right to data portability.
• Right to object to processing, including direct marketing.
• Right not to be subject to automated decision-making, including profiling.

To exercise these rights, users may contact Sudoku - Math Offline game via email at uibsee@hanmail.net. Requests will be addressed within one month.

Article 4 (Personal Data Items Processed)

Sudoku - Math Offline game processes the following personal data:

• Required: Device ID, IP address, advertising ID, service usage history.
• Optional: Email address (if provided for support).

Article 5 (Cross-Border Data Transfers)

Sudoku - Math Offline game may transfer data outside the EEA to service providers (e.g., Google LLC for AdMob). Such transfers are protected by Standard Contractual Clauses (SCCs) approved by the European Commission or other appropriate safeguards.

Article 6 (Third-Party Services and Advertising)

Sudoku - Math Offline game uses third-party advertising networks (e.g., Google AdMob) and analytics tools. Users’ consent is required in the EEA for personalized ads. A Consent Management Platform (CMP) is implemented to gather and manage user preferences in accordance with GDPR.

Article 7 (Cookies and Tracking Technologies)

Sudoku - Math Offline game and its partners use cookies, SDKs, and similar technologies to provide personalized ads and measure performance. Users in the EEA can manage their preferences via the in-app CMP.

Article 8 (Data Security)

• Regular internal audits.
• Access restrictions to personal data systems.
• Encryption and secure storage of sensitive data.

Article 9 (Privacy Officer)

Sudoku - Math Offline game designates the following Privacy Officer to oversee compliance:

• Name: Donghwa Lee
• Position: CEO
• Email: uibsee@hanmail.net

Article 10 (Complaints and Supervisory Authority)

Users may lodge a complaint with their local data protection authority if they believe their data has been processed unlawfully.

Article 11 (Changes to this Privacy Policy)

This Privacy Policy may be updated periodically. Significant changes will be notified in the app or via email where applicable.