Sudoku Online Privacy Policy

Last updated: September 23, 2026

Chigirintsev Igor Nikolaevich, an individual entrepreneur ("IE CIN") registered in the Republic of Kazakhstan (IIN: 030312501508), located at 19 Vakhtangov Street, Almaty, Kazakhstan ("we," "our," or "us"), respects the privacy of the users of our products and is committed to protecting it through compliance with this Privacy Policy ("Privacy Policy"). This Privacy Policy does not address the privacy practices of any third party that we do not own or control.

By accessing or using our Services, you acknowledge that we will collect and process your personal information in accordance with this Privacy Policy. If you do not agree with any part of this Privacy Policy, please immediately discontinue access to or use of the Services.

To go directly to a section of interest, please click on the section below:

Scope and Applicability

Personal Information That We Collect

Why We Collect Your Personal Information

How We Disclose Your Personal Information

Third-Party Services

Advertising and Consent

Your Choices

Account Deletion

Your Privacy Rights

Security

Transfers of Your Personal Information

Retention

Children

Additional Notice to Individuals in the United States

Additional Notice to Individuals in the European Economic Area, United Kingdom, and Switzerland

Changes to Privacy Policy

Contact Us

1. Scope and Applicability

This Privacy Policy applies to all personal information collected by us when you:

use our mobile application Sudoku Online (the "App"), distributed on the Apple App Store and on Google Play,

interact with any other content, page, or feature owned and operated by us that links to this Privacy Policy (collectively with the App, the "Services").

This Privacy Policy applies to the App on all platforms on which it is offered. Where a practice differs between the iOS and Android versions, this is stated explicitly.

The App is intended for users aged 13 and older. If you are under 13, you may not use the App. If you are between 13 and 16 years old, your parent or legal guardian must review and consent to this Privacy Policy on your behalf before you use the App, where required by applicable law.

You do not have to provide us with your personal information in order to use our Services; however, in some cases we may not be able to provide certain features without it (for example, we would not be able to save your game progress across devices or display your score on the global leaderboard).

We are based in the Republic of Kazakhstan, and your personal information may be transferred to, stored, and processed in Kazakhstan or other countries where our third-party service providers operate (see Section 5 and Section 11).

2. Personal Information That We Collect

We collect certain personal information when you use our Services. The personal information that we collect depends on your interactions with us and the choices you make.

Information You Voluntarily Provide Us

Account and Profile Information. When you sign in to our Services, we collect your email address, the name provided by your sign-in provider, the nickname you choose, and your country (derived from your device locale). This information is stored in our backend to maintain your account, sync your progress across devices, and display your profile on leaderboards.

Preference Information. We may collect any personal information you provide to us when adjusting your settings, such as language preferences, sound or vibration preferences, theme settings, or other game settings.

Transaction Information. When you subscribe to or purchase our premium features (such as ad removal, additional hints, or extended game modes), we may collect limited transaction-related information. Payments are processed by Apple on iOS and by Google Play on Android. We receive limited information related to the purchase you made (such as a purchase token or a purchase receipt). Apple and Google act as independent controllers, and any personal information you provide to them — such as your legal name, credit or debit card number, card expiration date, CVV code, or billing address — is not governed by this Privacy Policy.

Customer Service. We collect any personal information you provide when you contact us for customer service, to provide feedback, or to request information.

Information We Automatically Collect

Activity and Usage Data. While using the Services, we automatically collect information about how you interact with the App, such as your device's advertising identifier, operating system, language preferences, crash data, gameplay statistics (puzzles solved, completion times, streaks), and purchasing activity.

Device and Network Information. We may identify your device's operating system, model, generic physical location (country level), and your device's advertising identifier. On iOS, the advertising identifier (IDFA) is available to us and to our advertising partners only if you grant permission through Apple's App Tracking Transparency prompt (see Section 6). On Android, the advertising ID can be reset or deleted by you at any time in your device settings.

Location Information. We determine your country from your device's locale settings (for example, to display your country flag on the leaderboard). We do not collect precise GPS location.

Push Notification Token. If you grant permission for push notifications, we collect a device token used solely to deliver notification messages (such as daily challenge reminders). This token is processed by Firebase Cloud Messaging and is not used for advertising purposes.

Cookies, SDKs, and Similar Tracking Technologies. We use various tracking technologies in the App to keep your account secure, analyze usage patterns, deliver advertising (where applicable), and improve our Services.

Information From Third Parties

Single Sign-On ("SSO"). You may choose to sign in through Sign in with Apple or Game Center on iOS, or through Google Sign-In or Play Games on Android. In each case we receive a user identifier and, where the provider and your settings allow it, your email address and name. If you use Sign in with Apple, you may choose to hide your email address, in which case we receive an Apple private relay address instead of your real one. We store this information to create and maintain your account.

Gaming Platform Services. If you use Game Center on iOS or Play Games on Android, your achievements and leaderboard results may be synced with that service under your platform account, and are then also subject to Apple's or Google's own privacy policy.

Analytics and Advertising Partners. We may obtain aggregated or pseudonymized data about you from analytics providers and advertising partners to help us better understand how our Services are used and to improve them.

3. Why We Collect Your Personal Information

We may process your personal information for the following purposes:

Operate and Administer Our Services. Operating the App, saving your progress, gathering statistics, processing transactions, syncing your progress across your devices, and providing customer service.

Provide Customer Support. Responding to your inquiries and fulfilling your requests.

Send You Service-Related Communications. Sending administrative and account-related notifications, such as Privacy Policy updates, security updates, daily challenge reminders, and confirmations of your account actions or transactions.

Personalize Your Experience. Personalizing the Services based on your preferences and country, or displaying the correct language.

Research and Develop Our Services. Better understanding how our Services are used, carrying out data analysis, fraud monitoring and prevention, identifying usage trends, and improving or enhancing our Services.

Ensure Security of Our Services. Identity verification, fraud monitoring, combating spam and malicious activity, and ensuring the security and integrity of the Services.

Maintain Legal and Regulatory Compliance. Complying with applicable laws and regulations, fulfilling our business obligations, and responding to requests by judicial process or governmental agencies.

With Your Consent. For any other purpose disclosed to you prior to you providing us your personal information or with your permission.

4. How We Disclose Your Personal Information

We may disclose your personal information as follows:

With Our Vendors and Service Providers. We may disclose your personal information to vendors and service providers we engage in connection with our business, such as cloud hosting, payment processing, analytics, customer service, fraud prevention, and crash reporting. These third-party service providers may have access to your personal information only for the purpose of providing services to us. See Section 5 for a list of our key service providers.

Analytics and Advertising Partners. Where permitted by applicable law and subject to any consent you have provided (see Section 6), we may share your personal information with analytics and advertising partners to measure ad performance, deliver advertising, and improve our Services.

Merger, Acquisition, or Other Business Transaction. We may disclose and transfer your personal information in connection with a contemplated or agreed-upon merger, acquisition, consolidation, restructuring, or sale of substantially all our assets.

With Professional Advisors. We may disclose your personal information to lawyers, auditors, accountants, insurers, and similar consultants when necessary for them to provide us with their professional services.

Legal Obligations and Safety. We may disclose your personal information if reasonably necessary to comply with a valid legal process, valid requests by public authorities, applicable laws or regulations, to enforce our policies and agreements, to protect our legitimate interests, or to protect the safety of you, other users, or other persons.

With Your Consent. We may disclose your personal information with other individuals or companies if you give us permission to do so.

5. Third-Party Services

The App integrates with the following third-party services, each of which may receive certain personal information as described above. We encourage you to review their privacy policies.

Supabase — provides our backend infrastructure for storing user profiles, game statistics, leaderboard data, and powering the online multiplayer mode. Data processed by Supabase is subject to Supabase's Privacy Policy.

Sign in with Apple and Game Center (Apple, iOS only) — used for optional account authentication and for syncing achievements and leaderboard results. Subject to Apple's Privacy Policy: https://www.apple.com/legal/privacy/

Google Sign-In and Play Games (Google, Android only) — used for optional account authentication and for syncing achievements and leaderboard results. Subject to Google's Privacy Policy.

Unity LevelPlay (Unity Technologies) — ad mediation used to display advertisements in the free version of the App on both iOS and Android. Advertising demand is provided by Unity Ads and ironSource Exchange. These partners may collect device identifiers and usage data for ad serving. We configure Unity LevelPlay to serve ads appropriate for users aged 13 and older. Subject to Unity's Privacy Policy: https://unity.com/legal/privacy-policy

Apple In-App Purchase (iOS only) — used to process in-app purchases and subscriptions. Subject to Apple's Privacy Policy.

Google Play Billing (Android only) — used to process in-app purchases and subscriptions. Subject to Google Play's Terms of Service and Google's Privacy Policy.

Firebase Cloud Messaging (Google) — used to deliver push notifications (such as daily challenge reminders) to users who have granted notification permissions. Firebase processes device push tokens solely for message delivery. Subject to Google's Privacy Policy.

We are not responsible for the practices, content, or policies of any third-party services.

6. Advertising and Consent

The free version of the App displays advertisements delivered through Unity LevelPlay mediation (formerly ironSource) on both iOS and Android. Advertising demand is provided by Unity Ads and ironSource Exchange.

Ad personalization. Our mediation partners may use your device's advertising identifier to personalize advertisements.

App Tracking Transparency (iOS). On iOS, the App asks for your permission through Apple's App Tracking Transparency prompt before your advertising identifier is made available for advertising purposes. If you do not allow it, your advertising identifier is not shared and you will see non-personalized advertisements instead. You can change your decision at any time in Settings → Privacy & Security → Tracking.

Limiting ad personalization (Android). You can reset or delete your advertising ID, and opt out of personalized advertising, in Settings → Privacy → Ads (on some devices: Settings → Google → Ads).

United States. For users in US states with applicable privacy laws, you may opt out of the sale or sharing of your personal data for targeted advertising by adjusting the device settings described above or by contacting us at chigirintsevandco@mail.ru.

Ad content rating. We configure Unity LevelPlay to serve ads rated appropriate for users aged 13 and older. We do not knowingly serve ads directed at children under 13.

Premium users. If you purchase the premium version of the App, advertisements are removed entirely and no advertising data is collected for advertising purposes.

7. Your Choices

Marketing Communications. We may use your personal information to send you messages about new features, events, or other information that may be of interest to you. If you do not wish to receive such information, you can change your settings within the App.

Push Notifications. You may enable or disable push notifications at any time through your device's notification settings or within the App's settings menu.

Ad Preferences. You can limit ad personalization at any time in your device settings — on iOS: Settings → Privacy & Security → Tracking; on Android: Settings → Privacy → Ads.

Correct or Update Your Information. You may update the information associated with your account by going to the Settings section of the App and changing the applicable information.

8. Account Deletion

You may delete your account and all associated personal data at any time directly from within the App.

How to delete your account:

Open the App on your device

Go to Settings (menu icon in the top-left corner)

Tap Delete Account

Confirm the action

What gets deleted: When you delete your account, the following data is permanently removed: your profile (nickname, country), game progress, statistics, achievements, daily challenge streaks, leaderboard rankings, and all gameplay history.

Important notes:

Deletion is instant. Your account and data are removed immediately upon confirmation.

Deletion is permanent. Once your account is deleted, it cannot be recovered. You will need to create a new account if you wish to use the App again.

Subscriptions are managed separately. Deleting your account does not automatically cancel any active subscriptions. You must cancel a subscription through the store you purchased it from — on iOS: Settings → your name → Subscriptions; on Android: Google Play → Payments & subscriptions → Subscriptions.

If you experience any issues with the deletion process, please contact us at chigirintsevandco@mail.ru.

9. Your Privacy Rights

If you are located in the European Economic Area, the United Kingdom, or Switzerland, please see Section 15. If you are a resident of the United States, please see Section 14.

Depending on the applicable law where you reside, you may have the following rights with respect to your personal information:

Right to Know/Access. You may request a copy of the personal information that we hold about you.

Right to Correct/Rectification. You may request that we rectify, correct, or update any of your personal information that is inaccurate.

Right to Delete/Erasure. You may request that we delete the personal information we hold about you. As described in Section 8, you can delete your account directly within the App.

Right to Portability. You may request to receive your personal information in a structured, commonly used, and machine-readable format.

Right to Restriction. You may request that we restrict our processing of your personal information in certain circumstances.

Right to Withdraw Consent. Where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

To assert your privacy rights, please contact us at chigirintsevandco@mail.ru with the subject line "Privacy Rights Request." Once you have submitted your request, we will respond within the time frame permitted by the applicable law.

10. Security

We use commercially reasonable administrative, technical, and physical safeguards to help protect your personal information from unauthorized access, modification, disclosure, or destruction. However, no information system can be 100% secure, and we cannot guarantee the absolute security of your personal information. We are not responsible for the security of information that you transmit over networks that we do not control. If you have reason to believe that your account or any interaction with us is no longer secure, please let us know immediately by contacting us at chigirintsevandco@mail.ru.

11. Transfers of Your Personal Information

When you access or use our Services, your personal information may be processed in countries other than your country of residence, including the Republic of Kazakhstan and other countries where our third-party service providers operate. Such countries may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. If you do not want your information transferred to, processed, or maintained outside of the country or jurisdiction where you are located, you should immediately stop accessing or using the Services.

If you are in the European Economic Area, the United Kingdom, or Switzerland, please refer to Section 15.

12. Retention

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. When you delete your account through the App (see Section 8), your personal data is removed immediately. We may, however, retain certain information as necessary to comply with our legal obligations, resolve disputes, prevent fraud, or enforce our agreements.

13. Children

The App is intended for users aged 13 and older.

Content ratings and minimum age. The App's content is rated 4+ on the Apple App Store and 3+ on Google Play. These are content suitability ratings assigned by the stores; they do not change the minimum age of 13 required to use the App, which is based on how we process personal data, including for advertising.

Age restriction. We do not knowingly permit children under the age of 13 to create an account or use the App. If we become aware that a child under 13 has provided personal information without verifiable parental consent, we will take steps to delete that information as soon as possible. If you are a parent or legal guardian and believe that a child under 13 has registered for an account, please contact us immediately at chigirintsevandco@mail.ru.

Users aged 13–15 (EEA/UK/Switzerland). For users between 13 and 15 years of age located in the European Economic Area, the United Kingdom, or Switzerland, parental or legal guardian consent may be required under applicable law (GDPR Article 8) before using features that involve personal data processing. If you are in this age group, please review this Privacy Policy together with your parent or legal guardian before using the App.

COPPA compliance. The App is not directed at children under 13. We comply with the Children's Online Privacy Protection Act ("COPPA"). We do not knowingly collect personal information from children under 13. Core gameplay is available without creating an account or signing in.

Advertising. The App is not configured as child-directed for advertising purposes, as it is intended for users aged 13 and older. We configure Unity LevelPlay to serve content appropriate for a teen audience (13+), limiting ad content to material suitable for this age group.

Parental requests. If you are a parent or legal guardian and wish to review, correct, or delete information about your child, please contact us at chigirintsevandco@mail.ru. We will take prompt steps to address your request in accordance with applicable law.

14. Additional Notice to Individuals in the United States

For individuals in the United States, depending on the applicable law where you reside, you may have the following rights:

Right to Know/Access

Right to Correct

Right to Delete

Right to Portability

Right Against Discrimination for exercising any of your rights

Right to Opt-Out of Automated Decision-Making. We do not make decisions about you based solely on automated processing.

Right to Opt-Out of Sale. Like many businesses, we use SDKs and similar technologies and share certain personal information with advertising partners to provide ads. Under the broad definition of "sell" contained in some jurisdictions' privacy laws, this could be considered a sale. You may opt out in your device settings — on iOS: Settings → Privacy & Security → Tracking; on Android: Settings → Privacy → Ads — or by contacting us at chigirintsevandco@mail.ru.

Right to Opt-Out of Sharing for Targeted Advertising. You may opt out of the disclosure of your personal information to third parties for behavioral or cross-contextual advertising purposes.

Right to Appeal if we refuse to take action on your rights request.

To submit a request, please email chigirintsevandco@mail.ru with the subject line "Privacy Rights Request" and indicate which rights you would like to exercise. We may need to verify your identity before processing your request.

15. Additional Notice to Individuals in the European Economic Area, United Kingdom, and Switzerland

This section applies only to individuals located in the European Economic Area, United Kingdom, or Switzerland (collectively, the "Designated Countries").

Our Relationship to You — Data Controller. With respect to any personal information collected from individuals accessing or using our Services, the data controller is:

Chigirintsev Igor Nikolaevich (IE CIN, IIN 030312501508)

19 Vakhtangov Street, Almaty, Republic of Kazakhstan

chigirintsevandco@mail.ru

Legal Bases for Processing. We process your personal information based on:

Performance of a contract with you (for operating the App, saving your progress, processing transactions, providing support).

Our legitimate interests in operating, improving, and securing our Services (for analytics, fraud prevention, research and development, enforcing our terms).

Your consent (for personalized advertising and certain analytics activities, where required by law). You may withdraw consent at any time by contacting us at chigirintsevandco@mail.ru, by declining or revoking tracking permission on iOS, or by limiting ad personalization in your Android device settings.

Compliance with our legal obligations (for tax, accounting, or regulatory requirements).

Your Rights. You have the rights of access, rectification, erasure, restriction of processing, objection to processing, data portability, withdrawal of consent, and the right not to be subject to automated decision-making. You also have the right to lodge a complaint with your national data protection authority. You can find details of EEA Supervisory Authorities at https://edpb.europa.eu/about-edpb/board/members_en. The Supervisory Authority in the UK is the Information Commissioner's Office (ICO). The Supervisory Authority in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

To assert your rights, please contact us at chigirintsevandco@mail.ru.

Age of digital consent. In the EEA, the minimum age for providing consent to personal data processing without parental authorization varies between 13 and 16 years depending on the member state. We apply a minimum age of 13 for use of the App, and where applicable law requires a higher age for valid consent, we rely on parental consent.

Marketing. We will only contact you for marketing purposes by electronic means based on our legitimate interests, as permitted by applicable law, or with your consent. You can object to direct marketing at any time and free of charge.

Transfers of Your Personal Information. When transferring your personal information out of the Designated Countries, we rely on appropriate safeguards such as Standard Contractual Clauses, adequacy decisions of the relevant regulatory body, or derogations in specific situations.

16. Changes to Privacy Policy

We may make changes to this Privacy Policy from time to time. Any changes will become effective on the "Last Updated" date indicated at the top of this Privacy Policy. We will provide additional notice to you if we make changes that materially affect your privacy rights.

17. Contact Us

For any questions, concerns, or requests regarding our Privacy Policy or our privacy practices, please contact us using the details below.

Data Controller:

Name: Chigirintsev Igor Nikolaevich

Legal status: Individual Entrepreneur (IE CIN)

IIN: 030312501508

Country of registration: Republic of Kazakhstan

Address: 19 Vakhtangov Street, Almaty, Republic of Kazakhstan

Email: chigirintsevandco@mail.ru

By using Sudoku Online, you acknowledge that you have read, understood, and agreed to this Privacy Policy.