Draft — under legal review, not yet in effect.

Zoodoku Privacy Policy

Effective date: [to be set at launch]

The short version

• Zoodoku is an animal-sudoku puzzle game. You don't need to give us your name, email address or location to play.
• Your saved game, settings and statistics are stored on your device.
• We use Google Firebase to get crash reports, and to measure how the game is played only if you agree.
• The game shows ads from Google AdMob. Where the law requires it, you choose whether ads may be personalized. On iPhone and iPad, Apple asks whether we may track you, and we only do so if you allow it.
• We don't sell your personal data for money. Personalized ads may count as "selling" or "sharing" data under some US state laws, and you can opt out.
• To see or delete your data, email [email protected].

Who we are

Zoodoku, LLC ("Zoodoku", "we", "us") is a limited liability company organized in the State of Washington, USA. We make the Zoodoku app for Android and iOS (the "app") and run the website at https://zoodoku.games (the "site"). Together we call them the "Service".

For players in the European Economic Area (EEA), the United Kingdom and Switzerland, Zoodoku, LLC is the "controller" of the personal data described here. Pending review (P1)

This policy doesn't cover the Apple App Store or Google Play themselves. They have their own privacy policies.

Words we use. "Personal data" (some laws say "personal information") means information that identifies you or can reasonably be linked to you or your device, such as a device identifier. A "service provider" is a company that handles data for us under a contract. "Player ID" means the random ID the app creates for itself Planned.

1. Information we collect

We collect as little as we can. We don't ask for your name, email, phone number, contacts, photos, precise location, or health or other sensitive information, and the game has no chat or free-text fields.

Advertising identifiers. On iPhone and iPad, AdMob uses Apple's advertising identifier (IDFA) only if you allow tracking in Apple's App Tracking Transparency prompt. On Android, AdMob may use your device's Google advertising ID only if the app has access to it and your device settings and consent choices allow it. Pending review (P4) Firebase Analytics in Zoodoku doesn't use advertising identifiers on either platform.

2. How we use information, and our legal bases

We use information only for the purposes below. We don't make decisions about you that have legal or similarly significant effects based solely on automated processing.

If you're in the EEA, the UK or Switzerland, the law requires us to name a "legal basis" for each use. Here they are:

Where we rely on legitimate interests, we've weighed them against your rights, and you can object (see section 5).

3. How we share information

We share personal data only with these companies, and only for the purposes above:

We may also share information if the law requires it (for example, a valid court order), to protect the safety, rights or property of players, Zoodoku or others, or as part of a merger, sale or transfer of our business, in which case this policy will still apply to the information transferred unless you're told otherwise.

We don't sell your personal data for money. However, some US state privacy laws (for example California's) define "selling", "sharing" or "targeted advertising" broadly enough to include letting an ad network use device identifiers to personalize ads across apps. When ads in Zoodoku are personalized, that may count. You can opt out at any time (see "Your choices" in section 5). Pending review (P8)

4. How long we keep information

5. Your privacy rights and choices

Your choices

• Privacy choices in the app Planned: open Settings → Privacy choices at any time to change whether we use analytics and whether ads may be personalized. Saying no doesn't stop you playing.
• iPhone and iPad: Settings → Privacy & Security → Tracking, then turn tracking off for Zoodoku (or for all apps).
• Android: in your device settings, open Privacy → Ads (on some devices, Google → Ads) and delete or reset your advertising ID. If you delete it, apps can't use it for personalized ads.
• Uninstall: deleting the app removes the game data stored on your device. It doesn't remove data already sent to us or our service providers; ask us to delete that (below).
• Browser signals: the app can't read browser privacy signals such as Global Privacy Control, so please use the in-app Privacy choices. The site doesn't track you across other sites, so it doesn't respond to "Do Not Track" signals. Pending review (P3)

Your rights

Depending on where you live, you may have the right to:

• know and access the personal data we have about you, and get a copy in a portable format;
• correct it if it's wrong;
• delete it;
• opt out of the "sale" or "sharing" of personal data, and of targeted advertising;
• withdraw consent at any time (this doesn't affect what we did before you withdrew);
• object to uses based on our legitimate interests, or ask us to restrict them;
• appeal if we turn down your request; and
• not be treated differently for using any of these rights.

We don't use sensitive personal data, so the right to limit its use doesn't apply.

In the EEA, the UK and Switzerland you can also complain to your local data protection authority (in the UK, the Information Commissioner's Office). We'd appreciate the chance to help first.

We honor these requests from players wherever they live, even where a law doesn't require it. Pending review (P14)

How to make a request

Until the app has a built-in delete option (planned, #56), email [email protected] and say what you'd like (for example, "delete my data" or "send me a copy"). Please include:

• whether you play on Android or iOS, and roughly when you installed the app; and
• your player ID, which you'll find in Settings Planned.

How we check it's you. We don't know players' names, so we verify a request by matching the details you send to the records we hold, and we may ask you to confirm from the app on your device. We ask only for what we need to verify, and we use it only for that. If we can't link a request to any data, we'll tell you. Someone can make a request for you (an "authorized agent") if they show us your signed permission, and we may still ask you to confirm it directly.

When we'll respond. We'll confirm we received your request within 10 business days and respond within one month. If a request is complex and the law allows more time, we'll tell you why and take no longer than the law allows (up to two more months under the GDPR and UK GDPR; up to 45 more days under US state laws). Requests are free, unless they're clearly unfounded or excessive.

Appeals. If we turn down your request, reply to our answer with "Appeal" in the subject line. We'll respond within 45 days. If you're still unhappy, you can contact your state's Attorney General.

What we can't do for you. We can't reach game data that exists only on your device; delete the app or its data to remove it. Apple and Google keep your store purchase history; ask them for it.

6. Children and teens

Zoodoku is for players 13 and older. It isn't directed to children under 13, and we don't knowingly collect personal data from children under 13. If you believe a child under 13 has used Zoodoku and that we hold their data, email [email protected] and we'll delete it. Pending review (P16)

If you're under the age at which your country lets you agree to data use yourself (between 13 and 16 in the EEA, depending on the country, and 13 in the UK), please ask a parent or guardian before you agree to analytics or personalized ads. Pending review (P17)

7. Security

We protect personal data with reasonable technical and organizational measures. Data sent between the app and our service providers is encrypted in transit. We keep the data we hold to a minimum, limit who can access it, and keep keys and passwords out of the app's code. No system is perfectly secure, so we can't promise that data will never be accessed without permission. If a breach affects you, we'll tell you and the authorities as the law requires.

8. International transfers

Zoodoku, LLC is based in the United States, and our service providers process data in the United States and other countries. If you're in the EEA, the UK or Switzerland, your data is transferred outside your country. We rely on the EU-U.S. Data Privacy Framework (and its UK Extension and Swiss counterpart) where a provider is certified, and otherwise on the European Commission's Standard Contractual Clauses (with the UK Addendum where needed) in our providers' data processing terms. You can ask us for more information about these safeguards at [email protected]. Pending review (P18)

9. Changes to this policy

We'll update this policy when the game or the law changes, and change the "Effective date" at the top. If a change materially affects how we use your personal data, we'll tell you in the app or on the site before it takes effect, and ask for your consent again where the law requires it. Earlier versions are available on request.

10. Contact and requests

• Privacy questions and data requests: [email protected]
• Game support: [email protected]

Zoodoku, LLC, Washington, USA.