Last Updated: February 25, 2026 | Effective Date: February 25, 2026
Gürkan Gül ("Company," "we," "us," or "our") respects your privacy and is committed to protecting the personal information you provide when using the Sudoku Arena mobile application, website, and all related services, features, and functionality (collectively, the "Services"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the Services.
By accessing or using the Services, you acknowledge that you have read, understood, and agree to the collection and use of your information in accordance with this Privacy Policy. If you do not agree with this Privacy Policy, please do not access or use the Services.
This Privacy Policy is incorporated into and forms part of our Terms of Service.
Except where expressly stated by applicable law, this Privacy Policy is for transparency and compliance purposes and does not create independent contractual rights beyond those set out in our Terms of Service.
We collect personal information in the following ways:
| Category | Examples |
|---|---|
| Account Information | Username, email address, password (hashed), profile picture (if provided through social login) |
| Social Login Data | When you sign in via Apple, Google, Facebook, or other third-party authentication providers, we receive your name, email address, profile picture, and unique account identifier as permitted by you and the provider |
| Customer Support Data | Information you provide when contacting us for support, including your name, email address, device information, and description of your issue |
| Communication Data | Information included in any correspondence you send to us, including feedback, suggestions, and survey responses |
| Category | Examples |
|---|---|
| Device Information | Device type, model, manufacturer, operating system and version, screen resolution, device language, timezone, unique device identifiers (IDFV, Android ID) |
| Advertising Identifiers | Apple Identifier for Advertisers (IDFA), Google Advertising ID (GAID) — collected only with your consent where required |
| Network Information | IP address (used to derive approximate country/region; raw IP is not stored long-term), network type (Wi-Fi, cellular), carrier information |
| Usage Data | Gameplay data (game progress, scores, achievements, play time, difficulty levels), app access times, session duration, feature usage, in-app navigation patterns, screen flow |
| Transaction Data | In-app purchase history, subscription status, transaction identifiers (we do NOT receive or store your payment card details — all payments are processed by Apple, Google, or other platform providers) |
| Performance Data | Crash reports, error logs, app version, performance diagnostics |
| Location Data | Approximate (coarse) location inferred from your IP address. We do NOT collect precise GPS location. |
| Source | Data |
|---|---|
| Social Login Providers (Apple, Google, Facebook) | Name, email, profile picture, account identifier (as authorized by you) |
| App Store Platforms (Apple, Google) | Transaction and subscription data, refund status |
| Analytics Providers | Aggregated usage and performance data |
| Advertising Partners | Ad interaction data, attribution data, audience segment information |
| Purpose | Description | Legal Basis (GDPR) |
|---|---|---|
| Service Delivery | Provide, operate, maintain, and improve the Services; create and manage your account; save game progress; enable multiplayer features; sync data across devices | Contract performance |
| Authentication | Verify your identity, manage login sessions, process account recovery | Contract performance |
| In-App Purchases | Process and fulfill purchases, manage subscriptions, verify transaction status, provide premium features | Contract performance |
| Customer Support | Respond to your inquiries, troubleshoot issues, provide technical assistance | Legitimate interests |
| Analytics and Improvement | Analyze usage patterns, monitor performance, identify and fix bugs, improve game features and user experience | Legitimate interests |
| Personalization | Customize your experience, recommend content, remember preferences and settings | Legitimate interests |
| Advertising | Display advertisements, including personalized ads based on your interests (with your consent where required by law) | Consent / Legitimate interests |
| Marketing Communications | Send push notifications about game updates, events, and promotions (with your consent) | Consent |
| Security and Fraud Prevention | Detect, investigate, and prevent fraudulent transactions, cheating, abuse, and security threats; enforce our Terms of Service | Legitimate interests / Legal obligation |
| Legal Compliance | Comply with applicable laws, regulations, legal processes, or governmental requests; exercise or defend legal claims | Legal obligation / Legitimate interests |
| Aggregation and Anonymization | Create anonymized, aggregated, or de-identified data sets for research, analytics, and business purposes. Once anonymized, this data is no longer personal information. | Legitimate interests |
We do not sell your personal information for monetary consideration. We may share your information in the following circumstances:
| Recipient | Purpose | Data Shared |
|---|---|---|
| Service Providers | Companies that provide services on our behalf (hosting, analytics, customer support, email delivery, push notifications, cloud storage) | As necessary for the service |
| Advertising Partners | To deliver advertisements, measure ad effectiveness, and provide interest-based advertising | Device identifiers, advertising IDs, IP-derived location, ad interaction data, usage data |
| Analytics Providers | To analyze usage, performance, and trends | Device information, usage data, crash reports |
| Payment Processors / App Stores | To process in-app purchases and subscriptions (Apple, Google) | Transaction data (we do NOT share or receive payment card details) |
| Social Login Providers | To authenticate your account (Apple, Google, Facebook) | Authentication tokens only; one-way verification |
| Law Enforcement / Government | When required by law, legal process, court order, or government request; to protect our rights, property, or safety; to detect and prevent fraud or illegal activity | As legally required |
| Professional Advisors | Lawyers, accountants, auditors, and insurers providing professional services | As necessary for the engagement |
| Corporate Transactions | In connection with a merger, acquisition, reorganization, bankruptcy, asset sale, or similar transaction | All information may be transferred as a business asset |
| With Your Consent | In any other case with your explicit consent | As specified at the time of consent |
We require all third-party service providers to respect the security of your personal information and to process it in accordance with applicable law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
When legally permitted, we will attempt to notify you in advance if we are compelled to disclose your information to law enforcement or governmental authorities.
We use third-party advertising networks and partners to serve advertisements within the Services. These partners may use technologies such as software development kits (SDKs), cookies, pixels, and similar tracking technologies to collect information about your device and your interactions with the Services and other websites and applications.
Our advertising partners may collect or receive the following types of information:
Our advertising partners may use the information collected to provide interest-based (personalized) advertising. For EEA, UK, and Swiss users, personalized advertising is displayed only with your prior consent, which you may manage through the consent prompt displayed when you first use the Services or through in-app settings.
You can manage your advertising preferences through the following methods:
Please note that opting out of personalized advertising does not mean you will no longer receive ads; rather, the ads you see may be less relevant to your interests.
Where technically supported, we recognize Global Privacy Control (GPC) signals. If your browser or device sends a supported GPC signal, we treat it as a request to opt out of sale or sharing for targeted advertising in jurisdictions where this is required.
Our Services do not currently respond to "Do Not Track" (DNT) browser signals, as there is no industry-standard technology for recognizing and implementing DNT signals. We will update this policy if a standard is adopted.
For a full list of our advertising partners, see Appendix A.
We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements.
To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the information, whether we can achieve those purposes through other means, and applicable legal requirements.
Specific retention periods:
When your personal information is no longer needed, we will securely delete or anonymize it. Once information has been anonymized, it is no longer personal information and may be used by us for any purpose.
We implement reasonable and appropriate administrative, technical, and organizational security measures designed to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include, but are not limited to:
However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee its absolute security. You are responsible for maintaining the security of your account credentials and for any activities under your account.
In the event of a data breach that is likely to result in a high risk to your rights and freedoms, we will notify you and the relevant supervisory authority as required by applicable law. Notification may be provided by email, in-app notification, prominent posting on our website, or other means as required by law.
Your personal information may be transferred to and processed in countries other than the country in which you reside, including the United States and other countries where our servers, service providers, and partners operate. These countries may have data protection laws that differ from the laws of your country.
When we transfer your personal information internationally, we implement appropriate safeguards to ensure that your information receives an adequate level of protection, including:
The Services are not directed to children under the age of sixteen (16). We do not knowingly collect, use, or disclose personal information from children under 16. If you are under 16, please do not use the Services or provide any information to us.
If we learn that we have collected personal information from a child under 16 without verification of parental consent, we will take steps to promptly delete that information.
If you are a parent or guardian and believe that your child under 16 has provided us with personal information, please contact us at the email address listed in the Contact Us section, and we will take steps to delete the information from our systems.
We do not serve targeted or personalized advertisements to users we know to be children.
Depending on your jurisdiction, you may have some or all of the following rights regarding your personal information:
To exercise your rights, please contact us using the information in the Contact Us section. We will respond to your request within the timeframes required by applicable law (typically 30-45 days). We may need to verify your identity before processing your request.
You may also designate an authorized agent to submit requests on your behalf. Authorized agents must provide proof of authorization (such as a power of attorney or signed authorization form) and we may require verification of your identity directly.
If you reside in the European Economic Area (EEA), United Kingdom, or Switzerland, the following additional provisions apply:
Gürkan Gül is the data controller responsible for your personal information. Contact details are provided in the Contact Us section.
We process your personal information only when we have a valid legal basis under the GDPR (or UK GDPR). Our legal bases are specified in the table in Section 2 and include:
In addition to the rights listed in Section 9, you have the following rights under the GDPR:
We use a Consent Management Platform (CMP) compliant with the IAB Transparency and Consent Framework to manage your consent preferences for advertising and analytics. You may review and modify your consent choices at any time through the privacy settings within the Services.
We do not intentionally collect special categories of personal data (e.g., health data, racial or ethnic origin, political opinions, religious or philosophical beliefs, sexual orientation, genetic or biometric data). If we inadvertently collect such data, we will promptly delete it.
If you are a resident of a U.S. state with applicable privacy legislation, including California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia, the following additional provisions apply:
| CCPA Category | Examples | Collected |
|---|---|---|
| A. Identifiers | Username, email address, unique device identifiers, IP address, advertising identifiers | Yes |
| B. Personal Information (Cal. Civ. Code 1798.80(e)) | Name, email address | Yes |
| C. Protected Classifications | Age range (for age-gating purposes only) | Limited |
| D. Commercial Information | In-app purchase history, subscription records | Yes |
| F. Internet or Similar Network Activity | App usage data, gameplay data, ad interaction data, browsing history within the Services | Yes |
| G. Geolocation Data | Approximate location derived from IP address | Yes |
| K. Inferences | User preferences, gameplay patterns, interest profiles for advertising | Yes |
We do not "sell" your personal information in the traditional sense (i.e., for monetary consideration). However, our use of third-party advertising SDKs that collect information for interest-based advertising may be considered "selling" or "sharing" under the CCPA/CPRA's broad definitions. You have the right to opt out of this activity.
We do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age.
We will respond to verifiable consumer requests within forty-five (45) days. If we need additional time, we will inform you of the extension and the reason.
Under California Civil Code Section 1798.83, California residents who have provided personal information to a business may request information about whether the business has disclosed personal information to any third parties for the third parties' direct marketing purposes. To make such a request, please contact us using the information in the Contact Us section.
The Services may contain links to third-party websites, applications, or services that are not owned or controlled by us. This Privacy Policy does not apply to third-party services. We are not responsible for the privacy practices of such third parties. We encourage you to read the privacy policies of every website or application you visit or use.
You have the right to opt out of the "sale" or "sharing" (as defined by applicable law) of your personal information. To exercise this right:
Upon receiving and verifying your request, we will cease sharing your personal information with advertising partners for interest-based advertising purposes. Please note that this may result in less relevant advertisements but will not affect the functionality of the Services.
We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will update the "Last Updated" date at the top of this page and, where required by applicable law, provide additional notice (such as in-app notification, email, or prominent posting). Your continued use of the Services after any changes constitutes your acceptance of the updated Privacy Policy. We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices.
For material changes that affect your rights, we will provide at least thirty (30) days' notice before the changes take effect for users in jurisdictions that require such notice.
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:
Gürkan Gül
Privacy Inquiries: tooloraio@gmail.com
General Support: tooloraio@gmail.com
Address: Turkiye / İstanbul
We will respond to all privacy-related inquiries within the timeframes required by applicable law.
The following third-party advertising partners may collect information through the Services. Each partner processes data in accordance with their own privacy policy. We encourage you to review each partner's policy:
| Partner | Privacy Policy |
|---|---|
| Google AdMob | https://policies.google.com/privacy |
This list is updated periodically. Last review: February 2026.
The following third-party service providers may process information in connection with the Services:
| Provider | Service | Privacy Policy |
|---|---|---|
| Google Firebase | Analytics, Crash Reporting, Cloud Messaging (Push Notifications) | https://firebase.google.com/support/privacy |
| RevenueCat | In-App Purchase and Subscription Management | https://www.revenuecat.com/privacy |
This list is updated periodically. Last review: February 2026.
© 2026 Gürkan Gül. All rights reserved.