Privacy Policy

PenguDoku
Effective Date: October 9, 2026  |  Last Updated: October 9, 2026

This Privacy Policy describes how we ("we," "us," or "our") collect, use, and share information when you use our mobile game PenguDoku (the "Game" or "Service"). This policy complies with the requirements of Google Play, Apple App Store, the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and other applicable privacy laws.

Table of Contents

  1. Information We Collect
  2. How We Use Your Information
  3. How We Share Your Information
  4. Third-Party SDKs and Advertising Partners
  5. Device Permissions
  6. Data Retention
  7. Data Security
  8. Children's Privacy
  9. Your Privacy Rights
  10. International Data Transfers
  11. Changes to This Privacy Policy
  12. Contact Us

1. Information We Collect

1.1 Information You Provide

The Game uses an anonymous login system. You are not required to create an account, provide an email address, or share any personal identification details. When you first launch the Game, a unique anonymous identifier is generated and associated with your device to enable game functionality and progress saving.

1.2 Information Collected Automatically

We and our service providers automatically collect the following information when you use the Game:

Data TypeDescriptionPurpose
Device IdentifierA unique anonymous ID generated on your device (Android ID on Android; a Keychain-stored UUID on iOS).Anonymous login, game progress synchronization, fraud prevention.
Game Progress DataCurrent level, completed levels, scores, star ratings, combo records, and virtual item balances.To save and restore your game state across sessions and devices.
Client Version & PlatformApp version number, operating system, and device model.Service compatibility, troubleshooting, and analytics.
Language SettingThe language preference selected on your device.To provide localized game content.
Consent RecordsTimestamp and version of your privacy consent acceptance.To record and verify your consent as required by applicable laws.

1.3 Information Collected by Third-Party SDKs

The Game integrates third-party Software Development Kits (SDKs) for advertising, analytics, and attribution purposes. These SDKs may collect certain device and usage data as described in Section 4 below. We do not directly control the data collection practices of these third parties.

1.4 Information We Do NOT Collect

We want to be transparent about the types of data we do not collect:

2. How We Use Your Information

We use the information we collect for the following purposes:

2.1 Legal Bases for Processing (GDPR / UK GDPR)

If you are located in the European Economic Area (EEA) or the United Kingdom, we process your personal information on the following legal grounds:

You may withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

3. How We Share Your Information

We do not sell your personal information to anyone. We may share information in the following circumstances:

3.1 With Advertising and Analytics Partners

We share device identifiers and usage data with our third-party advertising and analytics SDK partners to serve ads, measure ad performance, and attribute user acquisition. A full list of these partners is provided in Section 4.

3.2 With Service Providers

We may share information with third-party service providers who perform services on our behalf, such as cloud hosting, data storage, and crash reporting. These providers are contractually obligated to protect your information and are prohibited from using it for any other purpose.

3.3 For Legal Reasons

We may disclose information if legally required to do so by law enforcement, court order, or other legal process, or if we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others.

3.4 Business Transfers

In the event of a merger, acquisition, or sale of our assets, we may transfer information as part of that transaction. We will notify you via an in-app notice or other reasonable means before your information is transferred under a different privacy policy.

4. Third-Party SDKs and Advertising Partners

The Game integrates the following third-party SDKs. Each SDK has its own privacy policy and data handling practices. We encourage you to review the privacy policies of these partners.

SDK / PartnerPurposeData Typically CollectedPrivacy Policy
Google Play Services SDKApp functionality, advertising infrastructureAdvertising ID, device info, app activityGoogle Privacy Policy
Google AdMobAd serving (banners, interstitials, rewarded)Advertising ID, device info, IP address, app activity, crash dataAdMob Privacy
Google AdsAdvertising, conversion trackingAdvertising ID, device info, conversion dataGoogle Privacy Policy
Apple Search AdsAd attributionAttribution data, device infoApple Privacy Policy
Meta Ads (Facebook)Advertising, audience networkAdvertising ID, device info, app activity, IP addressMeta Privacy Policy
Meta Audience NetworkAd mediation / servingAdvertising ID, device info, app activityMeta Privacy Policy
TikTok AdsAdvertising, user acquisitionAdvertising ID, device info, app activity, IP addressTikTok Privacy Policy
AppLovin AppDiscoveryAdvertising, user acquisitionAdvertising ID, device info, app activityAppLovin Privacy Policy
AppLovin MAXAd mediationAdvertising ID, device info, app activityAppLovin Privacy Policy
Unity AdsAd servingAdvertising ID, device info, app activityUnity Privacy Policy
MintegralAd servingAdvertising ID, device info, app activityMintegral Privacy Policy
ChartboostAd servingAdvertising ID, device info, app activityChartboost Privacy Policy
SolarEngineAttribution, analyticsAdvertising ID, device info, attribution data, app activitySolarEngine Privacy Policy

Third-Party Advertising & Tracking: Some of the SDKs listed above may use your advertising identifier and other data to serve personalized ads and measure campaign performance. On iOS, tracking is subject to your response to the App Tracking Transparency (ATT) prompt. On Android (devices with Google Play Services), you can opt out of personalized advertising by resetting your advertising ID in your device settings under Settings → Google → Ads.

4.1 Consent Management and Privacy Choices

To comply with the Google EU User Consent Policy, the EU ePrivacy Directive, the GDPR, and applicable U.S. state privacy laws, the Game uses the Google User Messaging Platform (UMP), a Google-certified consent management platform, to present you with clear consent choices before any personalized advertising or advertising-related data collection takes place.

Depending on your region, you may be asked to consent to the use of your advertising identifier and other data for personalized advertising and analytics. You can review and change your choices at any time through the “Privacy Options” or “Consent” screen available in the Game's settings. If you do not consent, the Game will only show non-personalized ads, and your ability to play the Game will not be affected.

5. Device Permissions

The Game is designed to respect your privacy. The Game does not request access to your camera, microphone, location, contacts, photos, or any other sensitive device permissions.

Game progress and settings are stored locally on your device within the app's own private storage. This requires no device permissions and does not access your device's photo library, media files, or external storage.

The only device features the Game uses are:

FeaturePermission (Android)Purpose
Audio / SoundNo special permission requiredPlaying background music and sound effects within the Game.
Vibration / Haptic FeedbackVIBRATE (normal permission)Providing haptic feedback during gameplay interactions.
Internet AccessINTERNET, ACCESS_NETWORK_STATE (normal permissions)Connecting to game servers for data synchronization, loading ads, and analytics.
Advertising IDAD_ID (normal permission)Provided to advertising SDKs for ad serving and attribution. You can reset or delete this ID in your Google Account settings.

On iOS, the Game does not request any system permissions that require user consent. Sound and vibration are used as core gameplay features without requiring special permissions. If you are on iOS 14.5 or later, the Game will display an App Tracking Transparency (ATT) prompt to request your permission before accessing your advertising identifier for ad personalization. You may choose to allow or deny this request.

6. Data Retention

We retain your information for as long as your account is active or as necessary to provide the Game's services. Game progress data is stored both locally on your device and on our servers to enable cross-session continuity.

To request deletion of your game data from our servers, please contact us at the address listed in Section 12.

6.1 Deleting Your Data

The Game uses an anonymous login system and does not require you to create an account. If you wish to delete the data associated with your device or anonymous identifier, you can:

We will process deletion requests within the timeframe required by applicable law (generally within 30 days).

7. Data Security

We take reasonable measures to protect your information from unauthorized access, alteration, disclosure, or destruction. These measures include:

However, no method of transmission or storage is completely secure. We cannot guarantee the absolute security of your information.

8. Children's Privacy

The Game is not directed at children under the age of 13 (or the applicable age of consent in your jurisdiction). We do not knowingly collect personal information from children under 13 in compliance with the Children's Online Privacy Protection Act (COPPA) and the GDPR provisions regarding children (Article 8).

If you believe a child has provided us with personal information, please contact us immediately, and we will take steps to delete such information.

Advertising served through our third-party partners is treated in accordance with applicable laws and platform policies. On Google Play, ad SDKs are configured to comply with Google's families policies where applicable. On iOS, ad personalization is subject to the user's ATT response.

9. Your Privacy Rights

Depending on your location, you may have the following rights regarding your personal information:

9.1 GDPR Rights (European Economic Area & United Kingdom)

If you are located in the EEA or UK, you have the following rights under the GDPR:

9.2 CCPA Rights (California, USA)

If you are a California resident, you have the following rights under the CCPA/CPRA:

To exercise any of these rights, please contact us at the address listed in Section 12. We will respond to your request within the timeframes required by applicable law (generally 30–45 days).

9.3 Opting Out of Personalized Advertising

You can opt out of personalized advertising at any time:

9.4 Additional U.S. State Privacy Rights

Residents of U.S. states with comprehensive privacy laws (including California under the CCPA/CPRA, as well as Virginia, Colorado, Connecticut, Utah, and other states) may have the following additional rights:

We do not sell personal information in exchange for money. However, our advertising partners may use device identifiers to serve personalized ads, which may be considered “sharing” for cross-context behavioral advertising under applicable laws. You can opt out of personalized advertising at any time as described in Section 9.3 above and through the consent choices in Section 4.1. To exercise any of your rights, please contact us at Section 12.

10. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence, including the United States and other countries where our servers or third-party partners operate. We ensure that such transfers are conducted in compliance with applicable data protection laws, including through the use of Standard Contractual Clauses (SCCs) where required.

By using the Game, you acknowledge and consent to the transfer of your information to these countries as described in this Privacy Policy.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last Updated" date at the top of this page. For material changes, we will provide a notice through the Game (such as a pop-up or in-app notification) or through other reasonable means.

We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your information.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal information, please contact us at:

We are committed to resolving your privacy concerns in a timely and transparent manner.