Privacy Policy

1. Identity of the Data Controller

For the purposes of applicable data protection laws (including the EU General Data Protection Regulation / GDPR), the Data Controller responsible for your personal data is:

• Name: Sort & Joy Studio
• Contact Email: TrainloopSup@outlook.com

2. INFORMATION WE COLLECT AND HOW

When you access our software, sign up for a user account, or play our games, we collect personal information that can be used to identify you (“Personal Data”, “Data”, or “Information”). We collect information directly from you, automatically through your interaction with our Services, or from third-party partners and platforms.

2.1 Personal Information

2.1.1 Account Information

We collect information directly from you when you provide it to us, such as via an email, an online form, through the support feature embedded in our Services, or through another form of inquiry. This information may include your name, email address, and phone number.

2.1.2 Device Information

Whenever you download, access, or use our Services, device-level information may be collected automatically by us or through third-party SDKs integrated into our games (such as Firebase and Adjust) for compatibility, stability, and analytics purposes. This information may include your Internet Protocol ("IP") address, general location data based on IP, unique Device ID (persistent/non-persistent), Advertiser ID (IDFA for iOS devices and GAID for Android devices), MAC address, browser type and settings, device model, operating system, OS version, and device technical specifications automatically provided by integrated SDKs (such as CPU architecture, RAM size, and available storage space).

2.1.3 Activity and Usage Information

While accessing or using the Services, we automatically collect details regarding how you interact with our games and websites. Such information may include your in-game session start and end times, level progress, level attempts, booster usage, rewards, purchasing activity, in-game spending, referring and exiting pages, crash data, and interaction history. If you use chat, message board, or scoreboard features within our games, we may collect and store your messages, in-game username, scores, and profile picture to display rankings, convey messages, and ensure compliance with our terms.

2.1.4 Information Obtained from Third Parties

Our games integrate Software Development Kits (SDKs) from third-party analytical service providers for app optimization and performance analysis. These third-party SDKs may also collect your information, such as your GAID, IDFA, region (defined as the location where a given language is used), location information, and IP address. This Privacy Policy does not govern third-party analytical tools; you may review their respective privacy policies on their websites. The third-party analytical SDK partners integrated into our Services include:

• Adjust: https://www.adjust.com/terms/privacy-policy/
• Firebase: https://www.google.com/intl/en/policies/privacy/
• Facebook Analytics: https://www.facebook.com/about/privacy/
• Google: https://policies.google.com/privacy

Payments for in-app purchases are executed directly by the Apple App Store or Google Play Store ("Platforms"). We do not collect or store sensitive financial details, such as your full credit card number or bank account credentials. However, Platforms may share non-financial payment and transaction details with us (such as items purchased and timestamp) to fulfill your orders and activate purchases in the game.

2.1.5 Information From Social Media Platforms

You may choose to create an account or log in to our games using your Facebook or Google account credentials. When you connect your Facebook or Google account, you authorize the platform to provide us with certain personal data, such as your name, user ID, profile picture, email address, language preference, and the list of friends who are also playing our games (where permitted by your app settings). Linking your account allows you to synchronize your game progress across multiple devices and interact with friends on leaderboards.

2.2 Cookies and Similar Data Collection Technologies

We, along with our third-party advertising networks and service providers, may use cookies, web beacons, mobile SDKs, and ad identifiers to provide, optimize, and personalize our Services and to deliver targeted advertisements.

These tracking technologies help us recognize your device, maintain your preferences, assess service performance, prevent fraud, and serve customized in-game offers. In addition, certain advertising networks may use these technologies to synchronize activity across different mobile apps, devices, and websites to tailor advertisements to your interests ("personalized advertising"), or to access your inventory of installed apps to avoid advertising apps you have already downloaded.

3. HOW AND WHY WE USE YOUR INFORMATION

We process your personal data for the following specific purposes:

3.1 Communication and Customer Support

We use your information, including contact details and support tickets, to communicate with you, respond to inquiries, solve technical issues, provide customer support, and send administrative updates, safety alerts, or game notifications.

3.2 Service Operation and Game Optimization

We use your information to operate our games, validate in-app purchases, maintain game progress, enable multiplayer/chat features, and analyze aggregated performance data to ensure our games work properly across all device types.

3.3 Serving Commercial Advertisements and Monetization

We provide collected information (such as ad identifiers, IP address, device specs, and usage data) to third-party advertising networks to serve personalized and contextual ads within our Services. Serving ads helps generate revenue to support and maintain our Services.

3.4 Abuse Prevention and Security

We use automated systems and analysis tools to detect cheating, spam, malware, unauthorized activity, and illegal content, preventing crime and securing our gaming community.

3.5 Exercising Your Opt-Out Rights

We use automated systems and analysis tools to detect cheating, spam, malware, unauthorized activity, and illegal content, preventing crime and securing our gaming community. You have the right to opt out of targeted advertising and marketing at any time. You may submit an opt-out request via email at TrainloopSup@outlook.com or manage your settings as detailed in Section 4.

4. OPT-OUT OF TARGETED ADVERTISING AND COOKIE TRACKING

If you prefer not to have your personal data processed for targeted or interest-based advertising, you can control or opt out of tracking as follows:

1. Device-Level Settings: You can reset your device's advertising identifier or disable interest-based advertising through your device privacy settings:
   • iOS Devices: Go to Settings > Privacy & Security > Tracking or Advertising.
   • Android Devices: Go to Settings > Google > Ads, and select Delete advertising ID or Opt out of Ads Personalization.
2. Social Network Settings: To adjust advertising preferences on social platforms (e.g., Facebook), log in to your account on the relevant platform and update your ad settings.
3. Browser Cookie Settings: You can configure your web browser to warn you about cookie placements or disable browser cookies entirely.

Please note: If you opt out of targeted advertising, you may still see advertisements within our games, but those ads will be non-personalized and contextual rather than based on your personal data or interests.

5. DISCLOSURE AND TRANSFER OF YOUR INFORMATION

5.1 Disclosure to Third-Party Processors

We may entrust your personal data to third-party service providers (data processors) acting on our behalf to perform necessary operations, including IT hosting, customer service, data analytics, fraud prevention, and advertising services. All such service providers are bound by strict contractual terms prohibiting them from using or disclosing your data for any purpose other than providing contracted services to us.

5.2 Legal Disclosures and Law Enforcement

We reserve the right to preserve or disclose your personal information if required or permitted by applicable law, regulation, subpoena, legal process, or administrative order. We may also disclose data if we believe in good faith that doing so is necessary to:

• Comply with law enforcement or national security demands;
• Protect the rights, property, safety, or security of Sort & Joy Studio, our users, or the public;
• Detect, prevent, or address fraud, security breaches, or technical issues; or
• Enforce our Terms of Service or legal agreements.

5.3 International Data Transfers

Information we collect may be transferred to, stored, processed, and maintained on servers or databases located outside of your state, province, country, or jurisdiction, including in Turkey, the United States, and the European Economic Area. Data protection laws in these destinations may differ from those in your jurisdiction. When transferring personal data internationally, we take appropriate legal and security safeguards (such as standard contractual clauses) to ensure your data receives adequate protection.

6. DATA SECURITY

We implement industry-standard physical, administrative, and technical security measures (such as firewalls, secure facilities, and data encryption) designed to protect against the unauthorized access, loss, misuse, or alteration of the information under our control.

However, please be aware that no server, computer, wireless network, or internet transmission system can be guaranteed to be fully secure. As a result, while we strive to protect your personal data, we cannot guarantee or warrant the absolute security of any information you transmit on or through the Services, and you do so at your own risk.

7. DATA RETENTION

Personal data shall be processed and stored for as long as required to fulfill the purposes for which it was collected. Once the retention period expires, personal data will be permanently deleted or anonymized. Consequently, rights such as access, erasure, rectification, and data portability cannot be enforced after the retention period has expired.

8. DATA DELETION AND ACCOUNT DEACTIVATION

1. You have the right to request the permanent deletion of your personal data collected by us. To exercise this right, please send a written request to our support team at TrainloopSup@outlook.com.
2. If you request account or data deletion, it may take up to 14 days from the time we initiate the process to complete the deletion of your information across our systems.
3. Important Notice regarding Deletion: If you permanently delete your account or request data erasure, all your game progress, levels cleared, scores, and unspent virtual items or assets will be permanently lost and cannot be restored in the future.
4. If you ask us to delete your personal data, we may still retain certain data as necessary for our legitimate interests, such as complying with legal obligations, resolving disputes, and enforcing our contracts.

9. AGE LIMITS AND CHILDREN’S PRIVACY

Our Services are not intended for use by children under the age of sixteen (16) [or 13 where applicable by local law]. We do not knowingly or willfully collect or solicit personal data directly from children under sixteen (16) without verifiable parental consent.

If you are under sixteen (16) years of age, please do not use our Services or submit any personal information about yourself to us. If you have reason to believe that we may have inadvertently collected personal data from a child under sixteen (16), please contact us immediately at TrainloopSup@outlook.com, and we will take prompt steps to delete such information from our files.

10. CALIFORNIA PRIVACY RIGHTS (CCPA / CPRA)

If you are a California resident, the California Consumer Privacy Act provides you with specific rights regarding your personal information:

10.1 Right to Know and Access

You have the right to request that we disclose certain details to you about our collection and use of your personal information over the past 12 months, including:

• The categories of personal information collected;
• The categories of sources from which information was collected;
• The business or commercial purpose for collecting or selling your information;
• The categories of third parties with whom we shared your information; and
• The specific pieces of personal information collected about you.

10.2 Right to Delete

You have the right to request that we delete the personal information we collected from you (and direct our service providers to do the same), subject to certain legal exceptions (such as completing transactions, fixing bugs, detecting security incidents, or complying with legal obligations).

10.3 Right to Opt-Out of Sale or Sharing

You have the right to direct us to stop sharing your personal information with third parties for personalized advertising. To submit an opt-out request, please configure your device privacy settings or contact us via email.

10.4 Non-Discrimination

We will not discriminate against you for exercising any of your CCPA privacy rights.

To exercise your California privacy rights, please submit a verifiable request to TrainloopSup@outlook.com.

11. SPECIFIC PROVISIONS FOR INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA (EEA), SWITZERLAND, AND THE UNITED KINGDOM

This section applies solely to individuals located in the European Economic Area (EEA), Switzerland, and/or the United Kingdom (collectively, the "Designated Countries") at the time of data collection.

11.1 Data Controller Status

Sort & Joy Studio acts as the Data Controller with regard to personal data collected from individuals accessing or using our Services in Designated Countries. Third-party vendors acting on our behalf are designated as Data Processors.

11.2 Your Individual GDPR Rights

You have the following rights under GDPR, which you may exercise by emailing TrainloopSup@outlook.com:

• Right to Access: Request a copy of your personal data maintained in our records.
• Right to Rectification: Request correction of inaccurate or incomplete personal data.
• Right to Erasure ("Right to be Forgotten"): Request deletion of your personal data where statutory conditions apply.
• Right to Restriction of Processing: Request temporary restriction of data processing under certain circumstances.
• Right to Object: Object at any time to processing based on legitimate interests or direct marketing.
• Right to Data Portability: Request to receive your personal data in a structured, commonly used, and machine-readable format for transfer to another controller.
• Right to Lodge a Complaint: You have the right to file a complaint with a competent Data Protection Authority in your place of residence, workplace, or place of alleged infringement.

We will verify your identity before responding to individual rights requests and reply as soon as possible, at latest within 30 days.

12. LINKS TO THIRD-PARTY WEBSITES AND ADS

Our Services may contain hyperlinks to third-party websites, applications, or external advertisements of our business partners and advertisers. Third-party advertisers may independently use cookies, web beacons, or tracking devices. We have no control over, and access to, the tracking technologies or privacy practices employed by third parties. We encourage you to review the privacy policies of any third-party sites or services you visit.

13. CHANGES TO THIS PRIVACY POLICY

We reserve the right to revise or update this Privacy Policy at our sole discretion at any time. Notification of any material changes will be posted on this page with an updated "Last Updated" revision date, or communicated via in-app notices or email prior to taking effect. We invite you to periodically consult this section for possible updates. Your continued use of the Services following the posting of changes constitutes your acceptance of the revised Privacy Policy.