Privacy Policy for Puzzle Breeze™

Last updated: May 03, 2025

1. Introduction

CLEVERBIT LTD (“we”, “our”, or “us”) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use the Puzzle Breeze™ mobile application (the “App”). This policy applies to users worldwide.

2. Who We Are

CLEVERBIT LTD
Kyriakou Matsi 9, Emba,
8250, Paphos, Cyprus
Contact: support@cleverbit.net

3. Definitions

• Personal Data: any information relating to an identified or identifiable individual.
• Processing: any operation performed on personal data, including collection, use, storage, disclosure, or deletion.
• Data Controller: the entity that determines the purposes and means of processing personal data.

4. Data We Collect

We may collect the following data via Firebase, AdMob, and other tools:

• Device and usage data: IP address, device identifiers (IDFA/GAID), app interactions, session duration
• Location: Approximate location inferred from IP
• Transaction data: Information related to in-app purchases or subscriptions
• Crash and performance data: Diagnostic information

We do not collect names, email addresses, photos, or any directly identifying information unless explicitly provided by you.

5. Legal Bases for Processing (GDPR)

We process your personal data based on:

• Your consent (for personalized advertising, where required)
• Performance of a contract (to provide access to the app and features)
• Legitimate interests (app analytics, fraud prevention)

6. How We Use Your Data

• Provide and maintain the App
• Analyze and improve the user experience
• Serve ads and monetize the App through AdMob
• Enable in-app purchases and subscriptions

7. Data Sharing and Third-Party Services

We share data with:

• Google LLC (Firebase, AdMob)
• App store providers (Google, Apple)

These providers process your data under their own privacy policies.

8. International Data Transfers

Your data may be transferred and stored in countries outside your own, including the United States and European Union, where our third-party providers operate. We ensure appropriate safeguards such as Standard Contractual Clauses (SCCs) or rely on service providers certified under relevant frameworks.

9. User Rights

Depending on your jurisdiction, you may have the following rights:

• Access to your data
• Correction of inaccurate data
• Erasure (“right to be forgotten”)
• Restriction or objection to processing
• Data portability
• Withdraw consent at any time (for personalized ads)

To exercise your rights, please contact us at support@cleverbit.net.
As the App uses third-party services (such as Firebase and AdMob), we may forward your request to those providers where applicable. We will make reasonable efforts to assist you in exercising your data rights in accordance with applicable law.

10. Children’s Privacy

The App is not intended for children under 13. We do not knowingly collect personal data from children. If you believe a child has provided us with data, please contact us.

11. Data Retention

We retain personal data only as long as necessary for the purposes described in this policy or as required by law. Analytics and advertising data may be retained for statistical purposes in aggregate form.

12. Your Choices

You can manage ad consent preferences within the App using the Google UMP SDK consent screen (in applicable regions). Personalized ads can be disabled through your device settings or ad settings screen.

13. Data Security

We take appropriate technical and organizational measures to secure your data. However, no method of transmission or storage is completely secure.

14. Changes to This Privacy Policy

We may update this policy from time to time. We will notify you of significant changes via the App or our website.

15. Contact

If you have any questions or concerns about this Privacy Policy or your data, contact us at:
support@cleverbit.net
CLEVERBIT LTD
Kyriakou Matsi 9, Emba,
8250, Paphos, Cyprus