1. Introduction
Welcome to Sudoku Carve (the “App”), operated by Shabake OÜ, an Estonian private limited company, trading under the brand name Eduplica (“we”, “our”, “us”).
We are committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you use the App.
By using the App, you acknowledge the collection and use of information as described in this Privacy Policy.
2. Data Controller
For the purposes of applicable data protection laws, including the General Data Protection Regulation (GDPR), the data controller is:
Shabake OÜ
Ahtri 12, 15551 Tallinn, Estonia
Email: support@eduplica.com
3. Information We Collect
We collect only the minimum data necessary to operate and improve the App. We do not sell personal data.
a. Information You Provide
- Contact Information: Email address when you contact us via the “Contact Us” feature or support channels.
- Third-Party Authentication Data: When you choose to link your account using services such as Google Sign-In or Apple Sign-In / Game Center, we may receive limited information from the authentication provider such as your user identifier, display name, profile image, and, where available, your email address.
b. Automatically Collected Information
- Usage Data: Gameplay progress, scores, actions, interactions, and in-app behavior.
- Technical Data: Device type, operating system, app version, approximate region, and device identifiers.
- Analytics Data: Collected through third-party analytics tools to understand how users interact with the App. These tools may include analytics platforms, device performance monitors, and account management dashboards. All third-party tools used are bound by data processing agreements and are required to handle your data in accordance with this Privacy Policy and applicable law.
c. Purchase Information
When you make in-app purchases, Apple or Google processes the transaction directly. We may receive limited purchase records such as transaction identifiers and purchased product identifiers to validate and fulfill your purchase. We do not receive or store your payment card details.
4. How We Use Your Information
We use collected data to:
- Provide and maintain the App
- Improve gameplay experience and performance
- Respond to user inquiries and support requests
- Monitor usage trends and detect technical issues
- Ensure security and prevent abuse
- Comply with legal obligations and enforce our Terms & Conditions
We do not use personal data for targeted advertising outside the App.
5. Legal Basis for Processing (GDPR)
Where applicable, we process personal data under the following legal bases:
- Consent: When you voluntarily provide information (e.g., contacting support)
- Contractual Necessity: To operate and provide the App and its features
- Legitimate Interests: To improve functionality, analytics, security, and user experience
- Legal Obligation: To comply with applicable laws and regulations
6. Data Sharing and Disclosure
We may share data only with:
- Service Providers: Analytics, hosting, and infrastructure providers acting under data-processing agreements
- Legal Authorities: When required by law or valid legal requests
- Business Transfers: In the event of a merger, acquisition, or asset sale
We do not sell personal data to third parties.
7. International Data Transfers
Your data may be processed on servers located outside your country of residence, including within the European Union or other jurisdictions.
Where required, we implement appropriate safeguards (such as standard contractual clauses) to ensure lawful data transfers.
8. Data Retention
We retain personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy or to comply with legal obligations.
When data is no longer required, it is securely deleted or anonymized.
9. Your Data Protection Rights
If you are located in the European Economic Area (EEA), you have the right to:
- Access your personal data
- Correct inaccurate or incomplete data
- Request deletion of your data (see Section 12 for how to exercise this right)
- Restrict or object to processing
- Request data portability
- Withdraw consent at any time (where applicable)
To exercise these rights, contact us at support@eduplica.com.
10. App Permissions
The App requests only permissions necessary for functionality and performance.
We do not request access to:
- Contacts
- Camera
- Microphone
- Precise location
11. Data Security
We implement appropriate technical and organizational measures to protect your data against unauthorized access, loss, misuse, or disclosure.
No system is completely secure, but we continuously work to protect your information.
12. Account & Data Deletion
User accounts may be linked to third-party login services (e.g., Google or Apple). You may delete your account and all associated personal data directly within the App by navigating to Menu → Account → Delete Account. Upon confirmation, your account will be permanently and immediately deleted. This action cannot be undone. If you are unable to access the App, you may alternatively contact us at support@eduplica.com to request deletion, subject to identity verification and legal retention requirements.
13. Children’s Privacy
The App is not intended for children under the age of 13 (or the minimum age required by local law).
We do not knowingly collect personal data from children. If we become aware that such data has been collected, we will delete it promptly.
14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. Changes will be posted with an updated effective date.
Continued use of the App after changes become effective constitutes acceptance of the revised Privacy Policy.
15. Contact Us
If you have questions or concerns about this Privacy Policy or our data practices, please contact us at: support@eduplica.com