Privacy Policy

Effective date: April 17, 2025

This Privacy Policy describes how Seagull Soup, developed and operated by Nanjing Shitu Cloud Technology Co., Ltd. (“we”, “our”, or “us”), collects, uses, and protects your personal data when you use our mobile application and services.

1. What Data We Collect

• Account Information: When you log in (via email, Google, Apple, etc.), we collect your email, user ID, and profile data if applicable.
• Device Data: If you do not log in, your progress is stored locally on your device only. This data will be lost if the app is deleted or the device is changed.
• Gameplay Data: Puzzle completions, in-game currency, hints used, score, session duration, and behavior data.
• Transaction Data: Confirmation of in-app purchases (we do not access your credit card or payment information).
• Device & Technical Info: OS version, device model, IP (anonymized), crash logs, language, and region settings.

2. Advertising & Third-party SDKs

Seagull Soup may show ads to support the free version of the game. We use third-party advertising SDKs which may collect or process your data to serve personalized or contextual ads. These include:

• AppLovin
• Google AdMob
• Meta Audience Network

These services may collect identifiers such as Advertising ID, usage behavior, IP address (non-precise), and interaction data to personalize ads, limit frequency, and prevent fraud. You may opt out of ad personalization via your device settings or through the consent prompt where required.

3. Why We Use Your Data

We process your personal data for the following purposes, depending on how you use the app:

• Gameplay: Save and load your puzzle progress, track achievements, and unlock new levels.
• Account & Sync: Sync progress across devices (only if you log in), manage your profile, and restore purchases.
• Payments: Process and verify in-app purchases through Apple or Google platforms.
• Advertising: Show relevant ads, support app monetization, apply frequency capping, and detect click fraud.
• Analytics: Understand player behavior, balance game mechanics, identify bugs and crashes, and improve experience.
• Legal & Compliance: Detect fraud, enforce our Terms of Use, and comply with applicable law.

Where required by law (e.g. GDPR), we rely on your consent for personalized ads and analytics. You can withdraw consent at any time via settings or by contacting us.

4. Data Sharing

We do not sell your personal data. We share limited data with service providers strictly for operational purposes, including:

• Advertising platforms (AppLovin, Google, Meta)
• Analytics (Firebase, AppLovin MAX)
• Crash diagnostics (e.g. Firebase Crashlytics)
• App store billing and verification services

5. Data Retention

We retain account-related data as long as your account is active. Gameplay and usage data is retained for operational and analytical use. Guest data (non-logged-in) is stored only on your device and is not recoverable once deleted.

6. Children’s Privacy

Seagull Soup is not intended for children under 13. We do not knowingly collect data from children under 13. If we become aware of such collection, we will delete it immediately. Parents may contact us to request deletion.

7. Your Rights

If you are located in the European Economic Area (EEA), the United Kingdom, California, or other regulated regions, you have rights including:

• Right to access – Request a copy of your personal data
• Right to rectification – Correct inaccurate data
• Right to erasure – Request data deletion (“right to be forgotten”)
• Right to restrict processing – In certain situations
• Right to object – Particularly for marketing purposes
• Right to data portability – Receive your data in a structured format
• Right to withdraw consent – For data uses based on your prior approval
• CCPA-specific: Right to opt out of “sale” of data, which may include sharing with ad networks

To exercise your rights, please email us at [email protected]. We may request identity verification. We will respond within 30 days or as legally required.

7.2 Legal Basis (GDPR)

Under the GDPR, our legal bases for data processing include:

• Consent: For personalized ads and optional analytics
• Contractual necessity: To provide the app and purchases
• Legal obligations: To comply with laws and requests
• Legitimate interests: For app security, optimization, and fraud prevention

8. Security

We implement reasonable technical and organizational safeguards to protect your data, including encrypted communications, secure authentication, and minimal access control. However, no digital system is completely immune to breaches.

9. Changes to This Policy

We may update this policy from time to time. Updates will be posted here with a revised date. We encourage you to review this page regularly.

10. Contact Us

If you have questions or requests regarding this policy, please contact us:

Nanjing Shitu Cloud Technology Co., Ltd.
Email: [email protected]