Last Updated: June 16, 2020

Please read this Privacy Policy carefully to understand our policies and practices regarding your Personal Data (as defined below) and how we will treat it.

This Privacy Policy applies to Guru Smart’s games, apps (herein refer to, "Sudoku - Sudoku puzzle, Brain game, Number game"), websites and related services (together the “Services” or “games”, “apps”, “websites” for individual categories). This Privacy Policy explains how we, and affiliated companies (collectively, "Guru Smart" or "we", "us", "our") collect, use, secure, and/or disclose end-users’ (“you” or “your”) or otherwise processes your personal information when you use our Services.

The data controller is Guru Smart Holding Limited, with a registered address at P.O. Box 905, Quastisky Building, Road Town, Tortola, British Virgin Islands.

1.INFORMATION WE COLLECT AND HOW

While using our Services, we may ask you to provide us with certain personal data or personal information that can be used to identify you (“Personal Data”, or “data” or “information”). We may also collect Personal Data automatically, or from third-party partners or services. The Personal Data we collect includes:

More information on the use of cookies on our website https://www.fungame.studio.com/ can be found in our Cookie Policy.

More information on the use of cookies in connection with our website https://www.fungame.studio.com/ can be found in our Cookie Policy.

2.PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below a description of the ways in which we use your Personal Data, the legal bases we rely upon to do so and to provide you with an option to opt-out of certain practices, where applicable. We may use your Personal Data:

3.RETENTION OF PERSONAL DATA

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Information for internal analysis purposes. Usage Information is generally retained for a shorter period of time, except when this data is used to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.

Your Personal Data collected through our Services will be deleted when they no longer serve one of the above-mentioned purposes but in any event, your Personal Data will be deleted after 14 months of inactivity in your use of our Services. Once we have deleted your Personal Data, you will not be able to exercise the right to access, the right to erasure, the right to rectification or the right to data portability.

Your Personal Data collected through our Get in Touch forms will be deleted after 2 years from the date of receipt. Once we have deleted your Personal Data, you will not be able to exercise the right to access, the right to erasure, the right to rectification or the right to data portability.

4.YOUR RIGHTS AND OPTIONS

Access Personal Data we hold about you

You have the right to request access to your Personal Data collected through our Services. Following your request, we will provide you a copy of your Personal Data in an electronic format.

Other rights

You also have other rights such as to correct your data, have your data deleted, object how we use or share your data, and restrict how we use or share your data. You also have the right to withdraw consent where you have previously given your consent to the processing of your Personal Data, for example by turning off camera access in your mobile device settings. This will not affect any data processed before such withdrawal.

Opt-out of targeted advertising

To show you personalized advertisements in our apps we use third-party advertising networks and their partners, including those that need your consent and listed in ‘APPENDIX A - Advertising networks and their partners’ below, to deliver advertisements that are tailored to you based on a determination of your characteristics or interests. To do so they use personal and non-personal information such as advertising identifiers, such as the Android advertising ID and/or Apple's ID for advertising (IDFA), and/or other tracking technologies to enable and optimize this advertising procedure.

You can opt-out from personalized advertisement experience, at any time by checking the Privacy Setting tab in any of our apps or under the privacy settings of your iOS or Android device.

For iOS Devices:

For Android Devices:

When you choose to opt-out, advertising networks will consider this choice as a withdrawal of consent to personalized advertisement experience and they will show contextual advertisements and not personalized advertisements based on your interests. Note: Irrespective of your choice and/or your device settings, you will continue to see non-customized advertising (e.g. “contextual” advertising) and you may continue to receive personalized ads from our third-party ad networks that obtain your consent on other apps and/or websites. For more information go to ‘APPENDIX A - Advertising networks and their partners’ below.

Exercise your privacy rights

Any requests to exercise your rights should be made through email at contact@fungame.studio. These requests can be exercised free of charge and will be addressed by us as early as possible and always within one month. You may also contact your local data protection authority within the European Economic Area for unresolved complaints.

5.PURPOSES FOR WHICH WE WILL SHARE YOUR PERSONAL DATA

We may share the above categories of Personal Data for certain business purposes, including:

We may also share, or otherwise “sell” the above categories of Personal Data for the following purposes, noting that a "sale" of personal information does not have the literal meaning of the word “sell” and as broadly defined under the California Consumer Privacy Act (and discussed in greater detail below) includes any sharing of information with third parties in exchange for “valuable consideration”:

In addition to the above, we may share your Personal Data in the following circumstances or for the following purposes:

6.AGE LIMITS

We appreciate the need to provide extra privacy protections to users who are children. Our Services are intended for general audiences over the age of 16 years. We do not knowingly collect personal information from children under 16 years of age. In order to request the deletion of Personal Data, for any reason, please use the in-app support feature in our Services or contact us in email at contact@fungame.studio and we will take reasonable measures to promptly delete such Personal Data from our records.

7.LINKS TO OTHER SITES

Our Privacy Policy may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the privacy terms of every site you visit. We have no control over and assume no responsibility for the content, privacy terms or practices of any third-party sites or services.

8.CALIFORNIA PRIVACY RIGHTS

The California Consumer Privacy Act (“CCPA”) provides California residents with the additional rights listed here. To exercise these rights, see the “Exercising Your California Privacy Rights” subsection below.

9.CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may change from time to time, and we encourage you to review it periodically. Your continued use of our Services signifies your acceptance of changes to this Privacy Policy.

In some cases, we may notify you of changes to this Privacy Policy with a prominent notice on our Services (for example by way of notification or pop-up), before the changes become effective and update the "effective date" at the top of this Privacy Policy.

10.CONTACT US

If you have any questions about this Privacy Policy, please contact us by email at contact@fungame.studio.

APPENDIX A - Advertising networks and their partners

For personalized advertising, the advertising networks and their partners, that are listed below, and would like your consent, if you reside in EEA, unless they have another legal basis for processing, may collect or receive device information from our apps and other apps that include personal and non-personal information, such as advertising (or ad) identifiers, IP address, or other information regarding the delivery of advertisements and your interaction with them, inventory of installed apps and/or other tracking technologies to provide measurement services, personalization, ad selection, delivery, reporting, and optimize targeted ads. Ad identifiers are non-permanent device identifiers such as the Android advertising ID and/or Apple's ID for advertising (IDFA). For more information on how to opt-out go to Opt-out of targeted advertising [hyperlink to take you above] further above. In addition, the advertising networks listed below, with the exception of Fyber, Mobfox, and PubNative who act as data processors upon our instructions, are independent data controllers in respect of your Personal Data and you can learn more about how each handles your data by accessing their respective privacy notices using the hyperlinks below.

Amazon Developer

Amazon Developer is an advertising service provided by Amazon, Inc. (US). Amazon does not require opt-in or opt-out signals from users in our Services, relevant signals are collected directly from the user upon creating an account in such service.

Privacy Policy: https://aws.amazon.com/privacy/

You can manage your personalized ad preferences in relation to Amazon directly from your Amazon account here: https://www.amazon.com/adprefs

AppLovin

AppLovin is an advertising service provided by AppLovin Corporation (US)

Privacy Policy: https://www.applovin.com/privacy

Facebook Audience Network

Facebook Audience Network is an advertising service provided by Facebook, Inc. (US) that may collect or receive information from our apps and other apps and use that information to provide measurement services and targeted ads. Facebook does not require opt-in or opt-out signals from users in our Services, relevant signals are collected directly from the user upon creating an account in such service.

Privacy Policy: https://www.facebook.com/about/privacy/

You can manage your personalized ad preferences in relation to Facebook directly from your Facebook account.

Fyber

Fyber is an advertising service provided by Fyber Group. (Israel)

Privacy Policy: https://www.fyber.com/legal/privacy-policy/

Google AdMob and their partners

AdMob by Google is provided by Google Inc. (US)

For more information on how AdMob uses the collected information, please visit the Privacy Policy of Google: https://www.google.com/policies/privacy/

For more information on AdMob Partners, please visit: https://support.google.com/admob/answer/9012903

You can opt-out from AdMob by Google service by following the instructions described by Google: https://support.google.com/ads/answer/2662922?hl=en

Google AdSense

Google, as a third-party vendor, uses cookies to serve ads on our Service. Google's use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet.

You may opt-out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: https://www.google.com/ads/preferences/

InMobi

InMobi is an advertising service provided by InMobi PTE Ltd (Singapore)

Privacy Policy: https://www.inmobi.com/privacy-policy/

Opt-out: https://www.inmobi.com/page/opt-out/

IronSource

IronSource is an advertising service provided by IronSource, Inc. (US) and does not require opt-in or opt-out signals from users in our Services, since they provide only non-personalized ads in our Services.

Privacy Policy: https://www.ironsrc.com/wp-content/uploads/2017/01/ironSource-Privacy-Policy.pdf

Liftoff

Liftoff is an advertising service provided by Liftoff, Inc. (US)

Privacy Policy: https://liftoff.io/privacy-policy/

MoPub and their partners

MoPub is provided by MoPub, Inc. (US)

For more information on what information MoPub collects and how it's used, please read MoPub Privacy Policy: https://www.mopub.com/legal/privacy/

For more information on MoPub Partners, please visit: https://www.mopub.com/legal/partners/

You can opt-out from MoPub service by following the instructions on MoPub Opt-out page: https://www.mopub.com/optout/

OpenX

OpenX is an advertising service provided by OpenX Software Ltd (US) and does not require opt-in or opt-out signals from users in our Services. Relevant signals are collected directly from Amazon for the users who have or create an account in such service.

Privacy Policy: https://www.openx.com/legal/privacy-policy/

PubMatic

PubMatic is an advertising service provided by PubMatic,Inc. (US) and does not require opt-in or opt-out signals from users in our Services. Relevant signals are collected directly from Amazon for the users who have or create an account in such service.

Privacy Policy: https://pubmatic.com/legal/privacy-policy/

Opt-out: https://pubmatic.com/legal/opt-out/

PubNative

PubNative is an advertising service provided by PubNative GmbH (Germany)

Privacy Policy: https://pubnative.net/privacy-policy/

Smaato and their vendors

Smaato is an advertising service provided by Smaato, Inc. (US)

Privacy Policy: https://www.smaato.com/privacy/

For more information on the Smaato Vendors, please visit: https://www.smaato.com/partner-list/

Unity Ads

Unity Ads is an advertising service provided by Unity Ads Inc. (US)

Privacy Policy: https://unity3d.com/legal/privacy-policy

Verizon Media and their vendors

Verizon Media, previously known as Oath, provides advertising services under their AOL, Yahoo and other brands.

Privacy Policy: https://www.verizonmedia.com/policies/ie/en/verizonmedia/privacy/index.html

For more information on VerizonAOL (OATH) Vendors, please visit: https://www.verizonmedia.com/policies/ie/en/verizonmedia/privacy/topics/thirdparties/index.html

APPENDIX B - Analytics and other service providers

We use your information to perform our own analytics and to enable analytics provided by third parties and other essential functions. We use analytical information for supporting business analysis and operations, business intelligence, product development, improving the Services, personalizing content, providing advertising, and making recommendations. In order to learn about how your information is used by our analytics service providers, you can follow the hyperlinks in the list below to each provider’s privacy notice.

Adjust

Adjust is analytics service provided by Adjust GmbH (Germany)

Privacy Policy: https://www.adjust.com/privacy-policy/

AWS

AWS is cloud computing services provided by Amazon Web Services, Inc. (US).

Privacy Policy: https://aws.amazon.com/privacy/

Fabric

Fabric is an analytics service provided by Google Inc. (US)

Privacy Policy: https://policies.google.com/privacy

Facebook Ads conversion

Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. (US) that connects data from the Facebook advertising network with actions performed on the Services.

Privacy Policy: https://www.facebook.com/about/privacy/

Facebook Analytics

Facebook Analytics is an analytics tool provided by Facebook, Inc. (US) that may collect or receive information from our apps and other apps and use that information to provide measurement services.

Privacy Policy: https://www.facebook.com/about/privacy/

Firebase

Firebase is an analytics service provided by Google Inc. (US)

You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://www.google.com/intl/en/policies/privacy/

Google reCAPTCHA

Google reCAPTCHA is a spam protection service provided by Google LLC. (US)

It is primarily used to distinguish whether an input is made by a natural person or abusive by automated processing. The service includes sending data required by Google for the reCAPTCHA service to Google. Additional information about Google reCAPTCHA and Google's privacy policy can be found at https://policies.google.com/privacy.