Privacy Policy

Effective Date: 11 February 2026 Last Updated: 11 February 2026

1. Who We Are

Apps Foundry Labs Ltd operates the Sudoku Masters: World Champion application. Our company details are:

  • Company Number: 16288141
  • Incorporated: 3 March 2025
  • Type: Private limited company
  • Business Classification: 58290 – Other software publishing
  • Address: Unit 7, 97 Western Road, Southall, England, UB2 5HN
  • Email: privacy@appsfoundrylabs.com

We act as Data Controller under UK GDPR, Data Protection Act 2018, EU GDPR, CCPA, and Australian Privacy Act 1988.

2. Information We Collect

User-Provided Information

  • Display name / username
  • Email address (optional, for email sign-in)
  • Country code (2-letter, for leaderboards)
  • Profile photo (optional)
  • Apple ID or Google account credentials (if using social sign-in)

Automatically Collected Information

  • Device type and OS version
  • App version
  • Gameplay statistics (puzzles completed, best times, streaks, level, XP)
  • Crash reports and diagnostics (Firebase Crashlytics)
  • Anonymised usage events (Firebase Analytics)
  • Firebase Cloud Messaging token (if notifications enabled)
  • Platform identifier (iOS or Android)

Purchase Information

  • Subscription status and expiry date (via RevenueCat)
  • Coin balance and transaction history
  • Payment card details are NOT collected; processing is handled by the app stores

3. How We Use Your Data

We use your data for the following purposes:

  • Account creation and management
  • Saving gameplay progress and statistics
  • Displaying leaderboard rankings
  • Managing in-app purchases and ad delivery
  • Sending push notifications (with consent)
  • Analytics and performance improvement (anonymised only)
  • Identifying and fixing technical issues
  • Legal compliance

4. Legal Basis for Processing

Contract: Core services including account creation, gameplay, and leaderboards.

Legitimate interests: Security, fraud prevention, crash reporting, and product improvement.

Consent: Optional features like push notifications, profile photos, and camera access.

Legal obligation: When required by law or regulators.

5. Advertising

The App displays ads through Google AdMob with the following practices:

  • Non-personalised ads only – no behavioural tracking or user profiling
  • Does NOT collect IDFA or request App Tracking Transparency consent
  • Uses Apple SKAdNetwork for anonymous ad attribution on iOS
  • Premium subscribers (“Sudoku Masters+”) see no advertisements
  • Users may voluntarily watch rewarded ads for in-app coins or hints

6. Sharing Your Data

We do not sell or rent your data. Data sharing occurs only with:

  • Google Firebase – authentication, database, storage, analytics, crash reporting, notifications
  • RevenueCat – in-app purchases and subscriptions
  • Google AdMob – non-personalised ads
  • Apple / Google – app store processing and crash diagnostics
  • Legal authorities – when required by law

7. International Data Transfers

Data may be processed outside the UK using:

  • Adequacy decisions for approved countries
  • Standard Contractual Clauses approved by UK/EU
  • EU-US Data Privacy Framework certified providers

8. Your Rights

You may have the right to:

  • Access: Request a copy of your personal data
  • Correction: Update inaccurate information
  • Deletion: Request account and related data removal
  • Withdraw consent: Opt out of optional features
  • Object / Restrict: Limit certain processing
  • Portability: Receive data in a machine-readable format
  • Non-discrimination (CCPA): Not be treated differently for exercising rights

Contact privacy@appsfoundrylabs.com to exercise your rights. We may request identity verification.

9. Data Retention

  • Active accounts: Retained while active
  • Deleted accounts: Permanently removed within 30 days
  • Inactive accounts: Removed after 3 years of inactivity
  • Leaderboard entries: Removed upon account deletion
  • Profile photos: Deleted upon account deletion
  • Anonymised analytics: Retained up to 12 months

10. Data Security

Our security measures include:

  • Encryption in transit (TLS/HTTPS)
  • Firebase Security Rules and role-based access controls
  • Local-first data architecture (gameplay data stored primarily on device)
  • Limited staff access under confidentiality agreements
  • Regular security monitoring

No digital system is completely secure. We take reasonable steps to protect your data but cannot guarantee absolute security.

11. Children

  • The App is rated 18+ on both App Store and Google Play
  • We do NOT knowingly collect data from children under 13 without parental consent
  • We collect minimal personal data (display name, optional country code)
  • No social features like messaging or chat
  • Contact privacy@appsfoundrylabs.com if a child provided data without consent

12. Offline Functionality

The App functions fully offline. Gameplay data and progress are stored locally using encrypted storage. Cloud synchronisation with Firebase is optional and automatic when internet is available.

13. Global Compliance

We comply with the following frameworks:

  • UK GDPR and Data Protection Act 2018
  • EU General Data Protection Regulation
  • California Consumer Privacy Act / CPRA
  • Australian Privacy Principles
  • Other applicable regional data protection regulations

Users outside the UK/EU may exercise equivalent rights under these laws.

14. Changes to This Policy

We may update this policy from time to time. Changes will be reflected in the “Last Updated” date, and we will notify you of material changes.

15. Contact Information

Apps Foundry Labs Ltd
Unit 7, 97 Western Road
Southall, England, UB2 5HN
Email: privacy@appsfoundrylabs.com

ICO (UK): https://ico.org.uk/make-a-complaint/

© 2026 Apps Foundry Labs Ltd. All rights reserved.