Jelly Nudge Privacy Policy

Fidelio Co., Ltd. ("we") respects the privacy of everyone who plays Jelly Nudge (the "app"). This policy applies from app version 1.0.0.

2. Ads (Google AdMob) and the information Google processes

The app shows ads with Google AdMob (the Google Mobile Ads SDK) from Google LLC: full-screen ads between levels, and rewarded ads that you choose to watch for a hint.

When the app requests and shows ads, the Google Mobile Ads SDK automatically collects the following and sends it to Google.

• Purposes: serving ads, measuring and analysing ad performance, and preventing fraud such as invalid clicks. Where you have consented, or where consent is not required, it may also be used for personalized (interest-based) ads.
• All of this data is encrypted in transit using TLS.
• This list follows Google's "Data disclosure for Google Play's Data safety section" for the Google Mobile Ads SDK (https://developers.google.com/admob/android/privacy/play-data-disclosure).
• Google processes this data under the Google Privacy Policy (https://policies.google.com/privacy) and "How Google uses information from sites or apps that use our services" (https://policies.google.com/technologies/partner-sites).

3. Ad consent (EEA, UK and Switzerland)

• The app uses Google's User Messaging Platform. When the app starts, it checks with Google whether consent is needed where you are. Users in the European Economic Area (EEA, for example Malta), the United Kingdom and Switzerland are asked for consent to the use of their information for advertising (such as storing and accessing information on the device and personalized ads).
• You can play the whole game without consenting. Non-personalized or limited ads may then be shown.
• You can change or withdraw your choice at any time in the app under Settings > Privacy options. Withdrawing consent does not affect processing that happened before. This option is shown where a choice is required.
• Your choice is stored on your device.
• Legal bases under the EU and UK General Data Protection Regulation (GDPR and UK GDPR): your consent for personalized ads and for storing or accessing information on your device; our legitimate interest in funding a free game for non-personalized ads and fraud prevention; and performance of our contract with you for delivering items you buy (section 6).

4. Personalized ads and how to opt out

Google AdMob may use your app activity and advertising ID to infer your interests and show personalized ads.

• Delete or reset your advertising ID in Android Settings > Privacy (or Google) > Ads. After you delete it, the app receives a string of zeros instead of an advertising ID.
• In the EEA, the UK and Switzerland, change your consent in the app under Settings > Privacy options.
• In U.S. states with consumer privacy laws, opt out of the "sale" or "sharing" of your personal information under Settings > Privacy options (section 13).
• Review and adjust the information Google uses for ads in My Ad Center (https://myadcenter.google.com).
• After opting out you will still see ads, but they may be less relevant. If you do not want any data sent for ads, please uninstall the app.

5. Information stored only on your device

The following is stored only on your device. We cannot access it.

• Game progress: levels cleared, stars, Daily Puzzle results and streaks, hints, the game in progress
• Settings: music, sound effects, vibration, reduce motion, language, tips
• Tutorial progress
• Versus records: your latest record, challenges you received and their results
• Ad pacing records (how often a full-screen ad was shown, so that ads do not appear too often) and your ad consent choice
• Purchase records: which items you bought (for example "remove ads") and one-way fingerprints of purchase tokens, so the app can give you your items exactly once

It is removed when you uninstall the app or clear the app's data in your device settings. If Android backup is turned on, your device may include this data in your own Google account backup, depending on your device settings. Google keeps that backup in your account; we cannot see it.

6. In-app purchases (Google Play billing)

• Paid items in the app (such as removing ads or hint packs) are sold only through Google Play's billing system, operated by Google. Google Play shows the payment screen and collects and processes your payment details, such as your card number, under the Google Play Terms of Service and the Google Privacy Policy. We never receive or store your card number, bank details or billing address.
• After a purchase, Google Play passes a purchase confirmation to the app on your device (the item ID, order number, purchase time, purchase state and a purchase token). The app checks it on your device, gives you the item and keeps a purchase record on your device (section 5): which items you own, and a one-way fingerprint (hash) of the purchase token so that the same purchase is never given twice. The app does not send this information to us or to anyone else; we have no server for it.
• Your purchase also stays in your Google Play order history in your Google account. If you reinstall the app or change devices, use "Restore purchases" with the same Google account to get permanent items such as "remove ads" back. Again, the app only receives the information from Google Play on your device.
• As the seller, we receive sales and payout reports from Google Play (such as order numbers, items, prices and the country of purchase). We use them only for accounting, tax, refunds and answering your questions, and keep them for as long as the law requires. They do not include your name, email address or payment details.
• Refunds are handled by Google Play under its refund policies. If you contact us about a purchase, please include the order number shown in your Google Play order history.

7. Sharing results and challenges

• When you tap "Share", the puzzle result text or challenge is passed to the app you choose (for example, a messenger). We do not receive it. Once shared, the privacy policy of that app applies.
• A challenge code contains only the puzzle number, your tap order and timing, the jelly look you had equipped, and how many hints you used. It contains no name, contact details, account or device information.
• Challenges you receive are checked and replayed on your device only. The sender is shown in the app only as "Friend".

8. How the app was installed

If you installed the app from Google Play, the first time it starts it reads, once, the install source value that the Google Play Store app provides on your device. If you installed through a challenge link, this lets the app open that challenge for you. This value never leaves your device.

9. Features that are turned off: leaderboards and usage statistics

• The app contains Google Play Games Services components for a future leaderboard feature. That feature is not turned on in this version, so these components do not run and send no information. We will update this policy before releasing an update that turns leaderboards on.
• This version has no usage statistics. Nothing is sent, even if the "Send usage stats" setting is on.

10. Who the app is for

The app is intended for adults aged 18 and over. It is not directed to children, and we do not knowingly collect information from children.

11. Sharing, processors and international transfers

• We do not collect personal information ourselves, so we do not share it with, or outsource its processing to, anyone.
• Google AdMob, which is part of the app, collects the data in section 2 directly for Google LLC. Google uses it to serve and measure ads, prevent fraud and, where allowed, personalize ads. Payments are processed by Google Play (section 6).
• Google may process this data in the United States and other countries where it operates. It is encrypted in transit. For data from the EEA, the UK and Switzerland, Google states that it complies with the EU-U.S. and Swiss-U.S. Data Privacy Frameworks and the UK Extension, and relies on standard contractual clauses where required (https://policies.google.com/privacy/frameworks). Retention follows Google's retention policy (https://policies.google.com/technologies/retention).

12. Your rights

• Depending on where you live, data protection laws (for example the EU GDPR and the UK GDPR) may give you the right to access the personal information about you, to have it corrected or deleted, to receive a copy of it, to restrict or object to its processing, to withdraw consent at any time, and to complain to the data protection authority where you live (for example the UK Information Commissioner's Office or the authority of your EU country). You can exercise these rights wherever you live by contacting us (section 15); we will answer within the time your law requires.
• We hold no information about you. You can delete the information stored on your device at any time by uninstalling the app or by clearing its data in Settings > Apps > Jelly Nudge > Storage.
• You can manage ad data processed by Google in the ways described in section 4. To ask Google for access to or deletion of your data, follow the instructions in the Google Privacy Policy.
• Because we do not know your name or account, we cannot identify you to delete Google's data, but we will tell you how to make the request.

13. U.S. state privacy rights

This section applies if you live in a U.S. state with a consumer privacy law, such as California (the California Consumer Privacy Act as amended by the California Privacy Rights Act, "CCPA"), Colorado, Connecticut, Texas, Virginia and others.

• Information collected in the last 12 months, through the Google Mobile Ads SDK and not received by us: identifiers (advertising ID, app set ID, IP address); internet or other electronic network activity (app launches, taps, ad views); approximate location inferred from the IP address (no precise geolocation); app and SDK diagnostics. Source: your device. Purposes: section 2. Recipient: Google LLC, an advertising network. Retention: Google's retention policy (section 11).
• "Sale" and "sharing": we do not sell personal information for money. When Google AdMob uses this information for personalized ads, that may count as "sharing" for cross-context behavioral advertising under the CCPA, or as a "sale" or "targeted advertising" under other state laws.
• We do not collect sensitive personal information, and we do not knowingly sell or share the personal information of consumers under 16 (the app is for adults aged 18 and over).
• Your rights: to know what personal information is collected and how it is used, to access it, to delete it, to correct it, to opt out of its sale or sharing and of targeted advertising, and not to be discriminated against for using these rights (we will not deny you the game, charge you a different price or give you a different quality of game; ads may simply become less personalized).
• How to opt out: in the app, open Settings > Privacy options. Where U.S. state privacy laws apply, this opens Google's opt-out message, where you can opt out of the sale or sharing of your personal information and of targeted advertising. You can also delete your advertising ID in Android settings (section 4) or contact us.
• How to make a request: email us (section 15). You may use an authorized agent. We may ask for information to confirm the request; because we hold no information that identifies you, we will explain how to make requests about data Google holds. If we refuse a request, you can appeal by replying with "Appeal" in the subject line, and we will answer within the time the law requires.
• More information: California Attorney General, https://oag.ca.gov/privacy/ccpa

14. Changes

If we change this policy, for example to add usage statistics or leaderboards, we will update it before releasing the app update that includes the change, and post the change on this page at least 7 days before it takes effect.

15. Contact

• Company: Fidelio Co., Ltd.
• Privacy contact: Fidelio Co., Ltd. Privacy Team — support@fidelio.kr