Privacy Policy for Poodle Clicker

Last updated: 26 May 2025

Your privacy is important to us. This Privacy Policy explains how Soyhan Yazgan, a sole‑proprietorship based in Finland (“we”, “our”, “us”), collects, uses, discloses and safeguards your information when you play the App, and the rights you have over that information.

1  Who is the data controller?

Controller:
Soyhan Yazgan
Heikkiläntie 4 B 4
16300 Orimattila, Finland
Email: soyhan15@gmail.com

Because the App is available worldwide, we comply with the EU General Data Protection Regulation (GDPR), the UK GDPR, the U.S. Children’s Online Privacy Protection Act (COPPA), the California Consumer Privacy Act (CCPA) and any other laws that apply in the regions where the App is distributed.

2  Children’s privacy & COPPA statement

The App is rated “Everyone / 3 +” on Google Play and is therefore directed to children under 13 in the United States and to children under 16 in the European Economic Area (EEA).

  • We have enabled Google’s “Tag for Child‑Directed Treatment” in AdMob, so only contextual, non‑personalised ads are shown.

  • We do not knowingly collect personal information from children beyond what is strictly necessary to operate the App (see Section 3).

  • Parents or guardians may review, delete or stop any further collection of their child’s information by writing to soyhan15@gmail.com.

3  Information we collect and the lawful bases

Category Examples Purpose Legal basis (GDPR Art. 6)
Device information Device model, OS version, language, country, IP address Enable core functionality, compatibility & security Contract (\§6 1 b)
Advertising ID (AAID/IDFA) Resettable ID provided by Android/iOS Display contextual ads via AdMob Legitimate interests (\§6 1 f) & No personalised ads
Usage data Session length, levels played, taps, achievements, leaderboard scores Game analytics (Firebase Analytics) to improve gameplay Legitimate interests (\§6 1 f)
Purchase data Order ID, product ID, purchase timestamp Deliver in‑app purchases, restore purchases Contract (\§6 1 b)

We do not request or store your name, email address, photos, contacts, microphone/audio, precise location, or any user‑generated text or chat.

Opt‑in Google Play Games sign‑in (achievements & leaderboards)

If you choose to sign in with Google Play Games Services, Google provides us with your Gamer ID, display name and avatar solely for achievements and leaderboards. You may sign out at any time in the Play Games overlay.

4  How we use your information

  • Operate and maintain the App and its features (clicking gameplay, achievements, leaderboards, in‑app purchases).

  • Serve contextual advertisements through Google AdMob (child‑directed mode, no personalised ads or ad targeting).

  • Analyse aggregate gameplay metrics using Firebase Analytics (child privacy mode) to improve game balance and stability.

  • Fulfil legal obligations, handle refund requests, detect fraud and security incidents.

We do not use your data to build marketing profiles or to enable cross‑site behavioural advertising.

5  Data retention

We keep:

  • Gameplay & analytics logs for up to 24 months or until you request deletion, whichever is sooner.

  • Purchase records for the statutory accounting period (currently 6 years in Finland).

  • Google Play Games profile data only while you are signed in.

If you request deletion (Section 10) we will anonymise or erase your stored data within 30 days unless we must keep it to comply with legal obligations.

6  Sharing of information

We share data only with the following processors under data‑processing agreements:

Recipient Function Safeguards
Google AdMob Serve non‑personalised ads EU–US Data Privacy Framework & Standard Contractual Clauses
Google Firebase Analytics Aggregate app‑usage analytics Same as above
Google Play Games Services (optional) Achievements & leaderboards Same as above

We do not “sell” personal information for money or engage in cross‑context behavioural advertising. If this practice is ever interpreted as a “sale” under the CCPA, you may opt out via the email address above.

We may disclose information if required by law or to defend legal claims, or in a merger or acquisition (users will be notified).

7  International transfers

Our processors are located in the United States and other jurisdictions. Transfers of personal data outside the EEA rely on:

  • Google’s certification under the EU–US Data Privacy Framework; and/or

  • the Standard Contractual Clauses approved by the European Commission.

8  Security

We use industry‑standard technical and organisational measures, including encryption in transit (HTTPS) and access controls, to protect your data against loss, misuse or unauthorised access.

9  Your rights

Depending on where you live, you have the right to:

  • Access the personal data we hold about you;

  • Correct inaccurate data;

  • Delete data (right to erasure);

  • Restrict or object to processing;

  • Data portability (receive a structured file of the data you provided);

  • Withdraw consent at any time, where processing is based on consent;

  • Complain to a supervisory authority (in Finland: Tietosuojavaltuutetun toimisto, www.tietosuoja.fi).

Residents of California also have rights to know, delete and opt out of any “sale” of personal data, and to equal service and price.

10  How to exercise your rights or ask questions

Email soyhan15@gmail.com with the subject line “Privacy Request”.
If you are a parent making a COPPA request on behalf of your child, please specify your child’s Gamer ID (if any) and the device identifier.

We will respond within 30 days (45 days for CCPA) and may ask for limited information to verify your identity.

11  Changes to this Privacy Policy

We may update this Privacy Policy from time to time. The “Last updated” date at the top indicates when the latest changes were made. Material changes will be announced inside the App or on its Google Play listing.

Thank you for playing Poodle Clicker!