Privacy Policy for Sudoku Up! - Logic Puzzle

This privacy policy applies to Sudoku Up! - Logic Puzzle (iOS / visionOS) by Malik Erdem.

Language versions of this app privacy policy: Deutsch · English · Türkçe

1. Controller and contact

Malik Erdem
Propsteistr. 55
90455 Nuremberg
Germany
Email: malik@erde-m.de

You can contact this address for privacy requests, rights requests, or country-specific legal questions.

2. Scope and app-store availability

This notice explains data processing in the app itself. Website data processing is described in the separate website privacy pages.

The app is currently available as of 2 August 2026 in Germany, Austria, Switzerland, Ireland, the United Kingdom, Türkiye, the United States, Canada, and Australia.

3. Data categories that may be processed

Depending on app usage, device settings, and consent choices, the following categories may be processed. The list is aligned with the services actively used in the app (in particular Google Analytics for Firebase, Google AdMob, and Apple platform services).

3.1 Technical and usage data

  • App launches, session duration, and feature interactions
  • Device model, OS version, app version, language settings
  • Technical event data for diagnostics and reliability

3.2 Analytics and performance data

  • Event-level usage data for product improvement and balancing features
  • Aggregated or pseudonymised performance indicators
  • Provider-side metrics such as number of users, number of sessions, session duration, app opens/launches, app updates, operating systems, and in-app purchase status

3.3 Advertising and measurement data

  • Advertising identifiers (for example IDFA) where personalised ads are enabled
  • Ad impression, interaction, and campaign measurement signals
  • Country/region data for delivery and compliance controls

3.4 Apple platform data

  • In-app purchase status information (no full payment card data is processed by the developer)
  • Optional Game Center-related identifiers/progress when leaderboards or achievements are used

3.5 Data sources

  • Directly from in-app use (events, diagnostics, crash signals)
  • Via integrated SDKs/processors (Firebase Analytics, AdMob, Apple)
  • From system settings (tracking permission, ad identifiers, region)

4. Purposes of processing

  • Providing and operating app functionality
  • Maintaining security, reliability, and error-free operation
  • Product analytics and quality improvement
  • Serving and measuring ads via AdMob
  • Meeting legal obligations and preventing abuse

5. Legal bases and region-specific frameworks

The legal basis depends on where the app is used.

  • EU/EEA (including Germany, Austria, Ireland): GDPR, including Art. 6(1)(a), (b), and (f), plus applicable ePrivacy requirements for tracking technologies.
  • United Kingdom: UK GDPR and Data Protection Act 2018, together with PECR where relevant.
  • Switzerland: revised Federal Act on Data Protection (FADP), in force since 1 September 2023, plus related ordinances.
  • Türkiye: Personal Data Protection Law No. 6698 (KVKK).
  • Canada: PIPEDA and applicable provincial law (including Quebec Law 25 where applicable).
  • United States: applicable state privacy law (for example CCPA/CPRA in California) where thresholds and scope are met.
  • Australia: Privacy Act 1988 and Australian Privacy Principles (APPs).

Where required, consent is collected before specific processing activities (for example personalised advertising or tracking).

5.1 Mapping to current App Store countries

  • Germany, Austria, Ireland: GDPR / EEA framework, including data subject rights under Articles 12-22 GDPR
  • United Kingdom: UK GDPR + Data Protection Act 2018 (+ PECR where applicable)
  • Switzerland: revised FADP framework
  • Türkiye: KVKK No. 6698 framework
  • Canada: PIPEDA framework (plus provincial law)
  • United States: applicable state privacy law framework (for example CCPA/CPRA)
  • Australia: Privacy Act + APP framework

5.2 Direct legal and regulator references

6. Consent, tracking, and ad preferences

Where legally required, ad and tracking features are only enabled after valid consent. You can change your choices in iOS settings or app-level controls.

For AdMob in the EEA, UK, and Switzerland, a consent-based flow is used according to Google requirements (CMP/TCF-compatible UMP setup). For US states with applicable privacy laws, privacy options and opt-out handling must be applied according to Google AdMob privacy controls.

IDFA access on iOS depends on Apple App Tracking Transparency (ATT) permission status.

  • Settings → Privacy & Security → Tracking
  • Settings → Privacy & Security → Apple Advertising

Google EU user consent policy · Google AdMob US states privacy settings · Apple ATT documentation

7. Processors and third-party recipients

7.1 Google Analytics for Firebase

Used for app analytics and performance insight. Provider: Google Ireland Limited / Google LLC.

Data categories can include: trackers, usage data, unique ad identifiers (Google Advertiser ID / IDFA), device information, geography/region, number of users, number of sessions, session duration, in-app purchases, app opens/launches, app updates, and operating systems.

The app can control analytics collection state and consent timing via Firebase configuration and runtime controls.

Google Privacy & Terms · Firebase Analytics data collection controls

7.2 Google AdMob

Used for ad delivery and ad measurement. Provider: Google Ireland Limited / Google LLC.

Data categories can include: trackers, usage data, ad identifiers (Google Advertiser ID / IDFA), ad impression and interaction data.

AdMob Privacy Information

7.3 Apple services

Distribution via App Store and optional platform services such as in-app purchases, Game Center, and iCloud. Provider: Apple Inc.

Apple Privacy

8. International transfers

Google and Apple services may process data in multiple countries, including outside the EU/UK. Where required, appropriate safeguards are used (for example Standard Contractual Clauses or equivalent transfer protections).

9. Retention and deletion

Data is stored only for as long as needed for the purposes described above, or as required by law.

  • Usage and diagnostics: only as long as necessary for reliability and analysis
  • Ad and measurement data: according to provider-side retention configurations and legal requirements
  • Local game data: mainly stored on your device and controllable via app/device settings

10. Security

Reasonable technical and organisational measures are used to protect data against unauthorised access, loss, or manipulation, including encrypted transmission, access controls, and periodic technical reviews.

11. Your rights by region

Depending on your location, you may have rights of access, rectification, deletion, restriction, portability, objection, and complaint with a competent authority.

  • EU/EEA: rights under GDPR Articles 12 to 22
  • UK: rights under UK GDPR / Data Protection Act 2018
  • Switzerland: rights under FADP
  • Türkiye: rights under Article 11 KVKK
  • Canada: rights under PIPEDA and provincial law where applicable
  • USA: rights under applicable state privacy law
  • Australia: rights under Privacy Act 1988 and APP framework

For requests from Germany, Austria, Switzerland, Ireland, UK, USA, Canada, Australia, or Türkiye, the central contact channel is: malik@erde-m.de.

12. Children

The app is not designed to target children for personalised advertising. Parents or legal guardians can contact the controller at any time regarding data processing questions.

13. Changes to this policy

This policy is updated when app features, service providers, or legal requirements change.

14. Contact

For privacy requests: malik@erde-m.de

Last updated: 2 August 2026