Round Jigsaw Puzzles — Privacy Policy

1. Introduction & Acceptance

This Privacy Policy explains how CODELUMA LLC ("Company," "we," "us," or "our") collects, uses, discloses, and safeguards information in connection with your download, installation, access, and use of the Round Jigsaw Puzzles mobile application (the "App").

BY DOWNLOADING, INSTALLING, ACCESSING, OR OTHERWISE USING THE APP, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND VOLUNTARILY AGREE TO BE BOUND BY THIS PRIVACY POLICY IN ITS ENTIRETY, INCLUDING THE DISCLAIMER OF LIABILITY IN SECTION 20. If you do not agree with any part of this Privacy Policy, you must not download, install, or use the App, and must uninstall it from your device. Your continued use of the App constitutes your ongoing acceptance of this Policy.

2. Eligibility & Children's Privacy

The App is intended for general audiences. However, because the App displays third-party advertisements, offers optional in-app purchases, and integrates analytics services, it is not directed at children under the age of 13 (as defined under COPPA) or under 16 where the GDPR applies. We do not knowingly collect personal information from such children without verifiable parental consent.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us using the details in Section 21. We will take reasonable steps to delete such information promptly.

It is the sole responsibility of any parent or guardian to supervise and manage a minor's use of the App, including through device-level parental controls, App Store / Play Store family settings, and in-app purchase restrictions.

3. Information We Collect

3.1 Account & Authentication Information

You may sign in to the App using Google Sign-In or Sign in with Apple. When you do, we receive and store the following information solely for authentication and account management:

• Email address associated with your Google or Apple account (if provided by the provider).
• Display name (if you choose to share it or if the provider sends it on first sign-in).
• Provider identifier (Google "sub" / Apple "sub"), a unique opaque ID.
• An internal account UUID generated by our servers.

We do not receive or store your Google or Apple password. Authentication is handled entirely by Google or Apple.

3.2 Gameplay & Progress Data

To synchronize your progress across devices and enable game features, we store:

• Your in-game Coin balance and unlocked level.
• List of completed levels, replay counts, and best completion times.
• Preferred language.
• Privacy Policy acceptance timestamp.

3.3 Purchase & In-App Purchase (IAP) Data

The App offers optional in-app purchases of virtual Coins. All payments are processed exclusively by Apple App Store (iOS) or Google Play Billing (Android). We never see or store your payment card details, billing address, or bank information.

When you make an in-app purchase, we receive and store:

• The transaction identifier and product identifier issued by Apple or Google.
• The receipt / purchase token (used to verify the purchase with Apple/Google's servers).
• The purchase status (pending, verified, rejected, refunded).
• The coins granted and the corresponding virtual item package.

We use this data solely to verify the purchase, credit the corresponding virtual Coins, prevent fraud, and comply with tax and accounting obligations.

3.4 Push Notification Data

If you grant permission, we register a Firebase Cloud Messaging (FCM) device token and basic device information (platform: iOS or Android) to deliver push notifications such as new level releases or event announcements. You may disable push notifications at any time in your device settings; the token will no longer be used.

3.5 Information Collected Automatically (Advertising & Analytics)

The App displays third-party advertisements (including rewarded video ads that grant optional in-game bonuses) and uses analytics services. The following information is collected automatically by the App and by integrated SDKs:

• Advertising Identifiers: Apple's IDFA on iOS and Google's AAID on Android. On iOS this requires your explicit consent via Apple's App Tracking Transparency (ATT) prompt.
• Device Information: device model, operating system and version, language and locale, time zone, and screen resolution.
• Usage & Analytics Information: levels played, session duration and frequency, ad impressions and completions, crash and performance diagnostics.
• Technical & Log Information: IP address, app version, and similar technical data generated automatically during use.

4. How Information Is Collected

Information described in Sections 3.1, 3.2, and 3.4 is transmitted to and stored on our secure servers when you sign in or use account-linked features. Information described in Section 3.5 is collected automatically by the App and by third-party SDKs integrated for advertising and analytics purposes.

5. How We Use Information

We and our service providers use the information described above to:

• authenticate you and manage your account and game progress;
• verify in-app purchases and credit the correct amount of virtual Coins;
• operate, maintain, and improve the App and its puzzle mechanics;
• deliver, personalize, and measure third-party advertisements, including rewarded ads;
• send push notifications about game updates or events (with your permission);
• analyze usage patterns to improve the overall experience;
• detect, investigate, and prevent fraud, cheating, abuse, and unauthorized activity;
• comply with applicable legal obligations and lawful requests from public authorities; and
• provide customer support and respond to inquiries.

6. Advertising & Analytics

The App displays third-party advertisements and integrates analytics services. Providers may include Google AdMob, Google Analytics / Firebase, Meta Audience Network, and similar industry-standard mobile advertising and measurement platforms. These providers may collect and process your advertising identifier, IP address, device information, and app usage data to deliver personalized ads, measure performance, prevent ad fraud, and generate aggregated statistics.

These third-party providers act as independent data controllers for the data collected through their SDKs. We do not control their data processing practices beyond our integration choices. We encourage you to review their policies:

• Google: policies.google.com/privacy
• Meta: facebook.com/privacy/policy

6.1 App Tracking Transparency (iOS)

On iOS 14.5 and later, the App will present Apple's App Tracking Transparency prompt before accessing your IDFA. If you decline, the App will continue to display advertisements, but they will not be personalized based on your activity across other apps and websites.

6.2 Rewarded Advertisements

The App may offer optional rewarded video advertisements that grant in-game bonuses (such as doubling the Coins earned from a completed level or extending time during a level). Rewarded ads are always opt-in; you may skip them at any time without affecting access to core gameplay.

6.3 Your Advertising Choices

• iOS: Settings → Privacy & Security → Tracking — manage tracking permissions and reset your IDFA.
• Android: Settings → Privacy → Ads — reset or delete your Advertising ID, or opt out of interest-based ads.
• Industry opt-out tools: Digital Advertising Alliance (optout.aboutads.info) or the Network Advertising Initiative (optout.networkadvertising.org).

Opting out of personalized advertising will not stop ads from being displayed; it means the ads you see will be less relevant to your interests. It will not affect any of the App's core puzzle features.

7. In-App Purchases (IAP)

All in-app purchases of virtual Coins are processed by Apple's App Store or Google Play Billing under their respective terms and privacy policies. We do not process payments directly, do not store payment card information, and do not sell any virtual goods for real-world currency outside of the official store channels.

Virtual Coins have no real-world monetary value, are non-transferable, non-redeemable for cash, and may only be used within the App. Purchase verification is performed using Apple's or Google's official APIs; failed or fraudulent transactions may result in reversal of the credited Coins.

Refunds are handled exclusively by Apple or Google in accordance with their refund policies. Please contact them directly for refund requests; we do not have the ability to issue refunds ourselves.

8. Push Notifications

With your permission, we send push notifications regarding new level releases, events, announcements, and service updates. You can disable push notifications at any time in your device settings. When disabled, your FCM token is no longer used for messaging, though it may remain registered until you sign out or uninstall the App.

9. Account Deletion & Data Retention

You may request deletion of your account at any time from within the App. When you do:

• Your account is permanently deactivated and cannot be reactivated.
• All active authentication sessions and push tokens are revoked.
• For legal, tax, and fraud-prevention reasons, certain records (such as purchase history and account identifiers) are retained for a period of up to five (5) years, after which they are permanently purged or anonymized.

Advertising and analytics data collected by third-party SDKs is retained in accordance with those providers' own policies. Any information we directly hold is retained only as long as necessary for the purposes described in this Policy or as required by law.

10. Sharing & Disclosure of Information

We do not sell your personal information for monetary consideration. However, sharing your advertising identifier and related data with advertising partners as described in Section 6 may constitute a "sale" or "sharing" of personal information under certain laws, such as the CCPA/CPRA. You may opt out of such sharing as described in Section 6.3.

We may otherwise disclose information:

• to service providers and vendors performing services on our behalf (hosting, analytics, advertising, support, authentication, cloud storage);
• to comply with applicable laws, regulations, legal process, or governmental requests;
• to protect the rights, property, or safety of the Company, our users, or others;
• in connection with a merger, acquisition, reorganization, bankruptcy, or sale of assets; and
• with your consent or at your direction.

11. Legal Bases for Processing (GDPR / UK GDPR)

If you are located in the European Economic Area, the United Kingdom, or a jurisdiction with similar requirements, we process personal information on the basis of:

• Consent (Art. 6(1)(a)): for advertising and analytics-related processing, which you may withdraw at any time;
• Performance of a contract (Art. 6(1)(b)): for account management, gameplay synchronization, and IAP verification;
• Legitimate interests (Art. 6(1)(f)): in operating, securing, and improving the App, and preventing fraud and abuse;
• Compliance with a legal obligation (Art. 6(1)(c)): to retain purchase records and comply with tax, accounting, and other applicable laws.

12. Your Privacy Rights

Depending on your place of residence, you may have the right to:

• request access to, and a copy of, the personal information we hold about you;
• request correction of inaccurate or incomplete information;
• request deletion of your personal information;
• request restriction of, or object to, certain processing;
• request data portability in a structured, commonly used format;
• withdraw consent at any time, without affecting prior lawful processing;
• (California residents) opt out of the "sale" or "sharing" of personal information, including cross-context behavioral advertising; and
• lodge a complaint with a competent data protection supervisory authority.

To exercise these rights, contact us at [email protected]. We aim to respond within 30 days under GDPR and 45 days under CCPA, subject to permitted extensions.

13. International Users & Applicable Law

The App may be downloaded and used worldwide, including in jurisdictions governed by the GDPR, UK GDPR, Turkey's KVKK, CCPA/CPRA, Canada's PIPEDA, Brazil's LGPD, Australia's Privacy Act 1988, and other applicable laws. It is your sole responsibility to determine whether your use of the App is lawful in your jurisdiction.

14. Data Security

We implement reasonable technical and organizational measures to protect information from unauthorized access, loss, or alteration, including encrypted transmission (HTTPS/TLS), hashed authentication tokens, and access controls on our servers. However, no method of electronic transmission or storage is 100% secure. You are solely responsible for maintaining the security of your device, including keeping your operating system updated and using device-level authentication.

15. International Data Transfers

Information we collect may be transferred to and processed in countries other than your country of residence, including the United States and the European Union, which may have data protection laws that differ from those of your country. Where required, we and our service providers rely on appropriate safeguards such as standard contractual clauses (SCCs) or equivalent mechanisms. By using the App, you acknowledge and accept such transfers.

16. Third-Party Services

The App integrates third-party services including Google Sign-In, Apple Sign-In, Google AdMob, Firebase Analytics, Firebase Cloud Messaging, Apple App Store, Google Play Billing, and Cloudflare (CDN). We are not responsible for the privacy practices of any third party and encourage you to review their policies before interacting with them.

17. Changes to This Privacy Policy

We may update this Policy from time to time. The "Last Updated" date at the top of this page reflects the most recent revision. Your continued use of the App after any update constitutes acceptance of the revised Policy. It is your responsibility to review this Policy periodically.

18. Governing Law

This Privacy Policy is governed by the laws of the State of Delaware, United States of America, without regard to conflict-of-laws principles, except to the extent that mandatory consumer protection or data protection laws of your country of residence apply and cannot be waived. Any dispute arising out of or relating to this Policy or the App shall be subject to the exclusive jurisdiction of the courts located in Delaware, unless otherwise required by mandatory law.

19. Data Protection Officer

Our designated Data Protection Officer (DPO) contact for privacy-related matters is: Burhan Sağlanmak — [email protected].

20. Disclaimer of Liability

21. Contact Us

For questions, concerns, or data requests regarding this Privacy Policy:

CODELUMA LLC

1111B S Governors Ave STE 39133, Dover, DE 19904, United States

Email: [email protected]