Privacy Notice

This Privacy Notice for Okuta Labs, LLC ("we," "us," or "our") describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you download and use our mobile applications (Velum Games, Ultimate Sudoku, and Word Bonds) or any other application of ours that links to this Privacy Notice, or engage with us in other related ways, including any sales, marketing, or events.

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [email protected].

Summary of key points

This summary provides key points from our Privacy Notice; for more details, see the full notice below.

• What personal information do we process? It depends on how you interact with us and the Services, the choices you make, and the products and features you use.
• Do we process any sensitive personal information? We do not process sensitive personal information.
• Do we collect information from third parties? We may collect information from public databases, marketing partners, social media platforms, and other outside sources.
• How do we process your information? To provide, improve, and administer our Services; communicate with you; for security and fraud prevention; and to comply with law.
• In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.
• How do we keep your information safe? We have organizational and technical processes and procedures to protect your personal information, but no system is 100% secure.
• What are your rights? Depending on where you live, you may have certain rights regarding your personal information and how it is processed.
• Do we use your information for advertising? Yes. Our apps show ads, and we share identifiers, usage data, and advertising data with advertising partners. Velum Games may also use usage data to track you across apps and websites owned by other companies. See sections 4 and 6.
• How do you exercise your rights? Submit a data subject access request or contact us.

1. What information do we collect?

Personal information you disclose to us. We collect personal information you provide when you register, request information, participate in activities, or contact us. We do not process sensitive information.

Social Media Login Data. If you register using a social media account, we may receive certain profile information, as described in “HOW DO WE HANDLE YOUR SOCIAL LOGINS?”

Application Data. If you use our application(s), we may collect geolocation information (with your permission), mobile device data, and push notification preferences to maintain security and operation, troubleshoot, and for internal analytics.

Information automatically collected. We collect device and usage data (e.g., IP address, browser/device characteristics, language preferences, referring URLs, country, location, usage timestamps, pages viewed) and use cookies and similar technologies. This includes log and usage data, and location data (you may opt out via device settings).

Account sign-in. You can create an account and sign in to our apps with your email address, Sign in with Apple, or Google Sign-In. When you do, we receive your name, your email address, and a user ID. If you use Sign in with Apple and choose to hide your email address, we receive a private relay address from Apple instead.

Google API. Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Information collected through our apps. Depending on the app and the features you use, our apps may collect: contact information (your name and email address); identifiers (a user ID and device identifiers, including your device's advertising identifier); usage data (how you interact with the app, and advertising data such as the ads you see and interact with); and diagnostics (crash data and performance data).

Information collected from other sources. We may collect information from public databases, joint marketing partners, affiliates, data providers, and social platforms.

2. How do we process your information?

We process your information to provide, improve, and administer our Services; communicate with you; for security and fraud prevention; and to comply with law. We may also process your information with your consent.

Specifically, depending on the app, we use the information described in section 1 to: run the apps and their features; personalize your experience; understand how the apps are used and fix problems (analytics and diagnostics); show and measure ads in the apps, including ads from third-party advertising partners; and send you news and offers about our games by email. You can unsubscribe from marketing emails at any time.

3. What legal bases do we rely on to process your personal information?

Depending on your location, we rely on consent, legitimate interests, legal obligations, or vital interests, consistent with GDPR/UK GDPR and other applicable laws.

4. When and with whom do we share your personal information?

We may share information in specific situations, including business transfers and with third parties such as offer wall providers, subject to the uses described.

Advertising and analytics partners. Our apps work with third-party advertising and analytics service providers. We share identifiers (such as your device's advertising identifier), usage data, and advertising data with them so they can show ads in our apps, measure how those ads perform, and help us understand how the apps are used. These partners process the information under their own privacy policies. They currently include:

• Unity (Unity LevelPlay, ironSource Ads, and Unity Ads), to choose and show ads in our apps: Unity Game Player and App User Privacy Policy
• Google AdMob, to show ads in our apps: How Google uses information from sites or apps that use its services
• AppsFlyer, to measure where app installs come from and how our ads perform: AppsFlyer Services Privacy Policy

5. What is our stance on third-party websites?

Links to third-party sites are provided for convenience. Their policies govern their handling of your data.

6. Do we use cookies and other tracking technologies?

We may use cookies and similar technologies for functionality, security, analytics, and advertising. See your browser settings to control cookies. Google Analytics opt-out: tools.google.com/dlpage/gaoptout. Google Privacy: policies.google.com/privacy. Our Google API use complies with Google API Services User Data Policy and Limited Use.

Tracking across apps and websites. Velum Games may use usage data to track you across apps and websites owned by other companies, for third-party advertising. Ultimate Sudoku and Word Bonds do not use your data for this kind of tracking. On iPhone and iPad, you can control whether apps may ask to track you in Settings > Privacy & Security > Tracking, and you can reset or limit your device's advertising identifier in your device settings.

7. How do we handle your social logins?

If you choose to log in using a social account, we receive profile information per that provider’s policies and your settings. We use that information per this notice.

Our apps offer Sign in with Apple and Google Sign-In. See section 1 for the information we receive when you use them.

8. How long do we keep your information?

We retain personal information only as long as necessary for the purposes described, or as required by law.

9. How do we keep your information safe?

We implement appropriate technical and organizational measures to protect your information; however, no method is 100% secure.

10. Do we collect information from minors?

Our apps are made for a general audience and are not directed to children under 13 (or the minimum age required in your country). We do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13, we will delete it. If you believe a child has given us personal information, please contact us at [email protected].

11. What are your privacy rights?

Depending on your location, you may have rights to access, correct, delete, or restrict processing of your personal information, opt out of certain processing, and portability. You may unsubscribe from marketing at any time.

12. Controls for Do-Not-Track features

We do not currently respond to DNT signals, as no uniform standard exists.

13. Do United States residents have specific privacy rights?

If you are a resident of certain US states (including CA, CO, CT, DE, FL, IN, IA, KY, MD, MN, MT, NE, NH, NJ, OR, RI, TN, TX, UT, VA), you may have rights as described in the notice.

14. Do we make updates to this notice?

We will update this notice as necessary to stay compliant with relevant laws.

15. How can you contact us about this notice?

16. How can you review, update, or delete the data we collect from you?

To submit a data subject access request, contact us at [email protected] or use our DSAR portal: Termly DSAR.