Privacy Policy

Last updated: January 1, 2024

kx Games and its subsidiaries and affiliated companies ("kx Games," "we," "our" or "us") respects the privacy of the visitors to our digital properties and the users of our products, and we are committed to protecting it through our compliance with this Privacy Policy ("Privacy Policy"). This Privacy Policy does not address the privacy practices of any third party that we do not own or control.

Please read this Privacy Policy and our Terms of Service, available at tos.html. By accessing, visiting, or using our Services, you acknowledge that we will collect and process your personal information in accordance with this Privacy Policy, and you agree to the practices and terms set forth in our Terms of Service. If you are not comfortable with any part of this Privacy Policy or do not agree with the Terms of Service, please immediately discontinue access or use of the Services.

To go directly to the section of the Privacy Policy of interest, please click on the section below:

1. Scope and Applicability

This Privacy Policy applies to all personal information collected by kx Games during any written, electronic, and oral communications online or offline when you:

• use websites that kx Games owns or operates that link to this Privacy Policy (collectively, the "Site(s)"),
• use software applications that we make available for use on or through computers and mobile devices that link to this Privacy Policy, including but not limited to Sudoku, Treasure of Temple, and other mobile applications (collectively, the "App(s)"),
• interact with social media pages that we control ("Social Media Pages"); or
• otherwise accessing any other pages, features or content owned and operated by kx Games that direct to this Privacy Policy ("Content," and, collectively, including the Sites, Apps, and Social Media Pages, the "Services").

You do not have to provide us with your personal information in order to use our Services; however, in some cases we may not be able to provide services to you without your personal information (for example, we would not be able to save your game progress).

2. Personal Information That We Collect

We collect certain personal information when you use our Services. Personal information is typically data that identifies an individual or relates to an identifiable individual, though the definition of "personal information" varies depending on applicable law, which may be determined by factors such as your physical location or place of residence. The personal information that we collect depends on your interactions with us, and the choices you make. We may collect personal information from you directly, from third parties, from business partners, or from publicly available sources.

Information You Voluntarily Provide Us

Personal information that we, or service providers performing services on our behalf, may collect from you include the following:

1. Account and Profile Information
   When you use some of our Services, you may create an account by signing into your third-party account credentials (such as Apple, Facebook or Google Account) to track your progress and to sync your activity across devices. You may also tailor your profile information such as your username and profile picture.
2. Preference Information
   We may collect any personal information you provide to us when you use our Services. For example, you may provide additional account information, such as your language preferences, device sound or vibration preferences, or other game settings.
3. Transaction Information
   When you subscribe to or purchase our premium features to remove Ads, obtain unlimited hints or other game features, we may collect certain limited transaction-related information. We use third parties, such as Google Play Store or Apple App Store, to process payments for purchases you made when using our Services. For example, when you subscribe to a premium plan, we receive limited personal information related to the purchase you made (namely, a user identification number, or a purchase receipt from third-party payment services). These third parties act as independent controllers, and any personal information you provide to them, such as your legal name, credit or debit card number, card expiration date, CVV code, and billing address, is not governed by this Privacy Policy.
4. Customer Service
   We collect the personal information you provide to us when you contact us for customer service, to provide feedback, or to request information. For example, when you use our feedback and choose to upload pictures, we will collect the picture information you provide for problem analysis.
5. Promotional Activity
   If you choose to participate in a surveys, sweepstakes, contests, or events ("Promotion") through our Services, we will collect and store the personal information you provide in connection with your participation in the Promotion, which may include, your name, date of birth, address email address, phone number, and/or other personal information identified in the Promotion terms. We use the information you provide to administer our promotions. We also may use the information to communicate with you about our products, services, and other promotions.
6. Feedback, Polls, or Surveys
   We may provide you with the opportunity to participate in polls, surveys, or provide feedback about your experience. If you participate, we may request certain personal information from you, typically including contact information (such as age group) and preference information. Participation in these surveys is entirely voluntary. We use this information to improve our services and product offerings.

Information We Automatically Collect

To the extent permitted under applicable law, we may automatically collect certain types of personal information about you when you use or interact with our Services.

1. Activity and Usage Data
   While accessing or using the Services, we may automatically collect information about how you interact with the Services. Such information may include your Internet Protocol ("IP") address, device identifier, advertising identifier, MAC address, operating system, browser type, language preferences, referring and exiting pages, crash data, location data, purchasing activity, and other data regarding your activities on the Services. For more information, see our Cookie Policy.
2. Device and Network Information
   If you access the Services through a mobile device (e.g. a smart phone or tablet), we may be able to identify your devices' operating system, generic physical location and geographic regions of your device from your Wi-Fi, Bluetooth and other device settings, your mobile network information (e.g. eUICC ID, IMSI), and your mobile device's advertising ID, etc. For more information see our Cookie Policy.
3. Location Information
   When you use our Services, we may infer the generic physical location and geographic regions of your device from your Wi-Fi, Bluetooth and other device settings. For example, your IP address may indicate your general geographic region. You may choose not to share your location details with us by adjusting your mobile or desktop device's location services settings. For instructions on changing the relevant settings, please contact your service provider or device manufacturer.
4. Cookies, SDKs, Pixels, and Similar Tracking Technologies
   We may use various tracking technologies to collect and store information about your use of our Services. We use these tools to ensure that you receive a personalized experience, to provide you with certain functions on our Services, to keep your account safe, and to improve and optimize our Services. For more information see our Cookie Policy.

Information From Third Parties

From time to time, we may obtain information about you from third party sources as required or permitted by law. These sources may include:

1. Single Sign-on ("SSO")
   SSO is an authentication method that enables you to securely authenticate your login within multiple applications and websites by using one set of credentials. If you choose to login to our Services through a third-party platform (such as Facebook, Google, or Apple) we may have access to certain information from that platform, such as your username, profile picture, email address, language preference, and other information listed in the authorization. The information we receive may vary based on your privacy settings on such platform or as otherwise controlled by the provider of such platform.
2. Social Media
   We may offer you the opportunity to engage with our content on or through third-party social networking websites, plug-ins and applications. When you engage with our content on or through third-party social networking websites, plug-ins and applications, you may allow us to have access to certain information associated with your social media account (e.g., username, email address, profile picture) to deliver the content or as part of the operation of the third-party website, plug-in or application. When you provide information from your social media account, we may use this information to personalize your experience on our Services and on the third-party social networking websites, plug-ins and applications, and to provide you with other products or services you may request.
3. Third Party Partners
   Unless prohibited by applicable law, we may obtain your personal information from marketing partners, analytics providers, Promotion providers, and other third-party partners to market to you, including to match custom audiences or create lookalike audiences on social media or other marketing platforms so that we can better understand which of our Services may be of interest to you, market our Services to you, and to provide us information necessary to improve our Services.

3. Why We Collect Your Personal Information

We may process your personal information as described in this Privacy Policy, except if otherwise disclosed to you at the time your personal information is collected or otherwise authorized by law or by you. We may process your personal information in connection with any of the following purposes:

1. Operate and Administer Our Services
   We use your personal information to provide you the Services you request. This may include operating games, saving your progress, gathering statistics, processing transactions, providing you with the requested features, syncing your progress and preferences across your devices, and providing you with customer service.
2. Provide Customer Support
   We collect any information that you provide for us when you contact us to respond to your inquiries and to fulfill your requests. Without your personal information, we cannot respond to you or ensure your continued use and satisfaction of the Services.
3. Send You Service-Related Communications
   We may send you administrative and account-related notification or communication to you, for example, privacy policy and terms updates, security updates, confirmations of your account actions or transactions, or other relevant service-related information. Service-related communications are not promotional in nature. You may not be able to unsubscribe from certain service-related communications, otherwise you may miss important developments relating to your account or the Services.
4. Infer Your Interest and Personalize Your Experience
   We may process your personal information to personalize the Services for you, and to present products, services, and offers tailored to you. For example, we may use such information to enable you to interact with our Services more easily across devices by using your language preferences and country location to display the correct language and time zone in the Services. We may also use such information to recommend more relevant content to you. For example, when you enable the social sharing functionalities by interacting with our content on or through third-party social networking websites, plug-ins and applications, we may use this information to personalize your experience on our Services and on the third-party social networking websites, plug-ins and applications.
5. Research and Develop our Services
   We may process your personal information and derive analytical and statistical data to better understand the way you use and interact with our Services, including by carrying out data analysis, audits, fraud monitoring and prevention, internal quality assurance, developing new products, enhancing, improving or modifying our Services, identifying usage trends, auditing use and functionality of our Services, determining the effectiveness of our promotional campaigns, and operating and expanding our business activities.
6. Promote Our Services
   We may use your personal information for our marketing activities. For example, we may conduct targeted marketing and send you information about our and our partners' products, events, and market studies that may be of interest to you. Additionally, subject to your marketing preferences (which may include consent to marketing under applicable law), sending you special discounts and offers or marketing communications we believe may interest you, for our own products and services, or on behalf of our third-party partners in accordance with applicable law.
7. Administer Promotional Events
   When you participate in Promotions, we may process your personal information to administer such activities (each of which may have additional rules and could contain additional information about how we process your personal information). You have the right to decline to provide your consent and, if consent is provided, to withdraw it at any time.
8. Ensure Security of our Services
   We may use your personal information for the purposes of identity verification, customer service, security protection, combatting spam, malware, and malicious activity, fraud monitoring, archiving and backups, ensuring the security of the Services that we provide to you.
9. Facilitate Corporate Acquisitions, Mergers and Transactions
   We may process any personal information regarding your account and your use of our Services as is necessary in the context of corporate acquisitions, mergers, or other corporate transactions.
10. Maintain Legal and Regulatory Compliance
    Our Services are subject to certain laws and regulations which may require us to process your personal information. For example, we process your personal information to pay our taxes, to fulfill our business obligations, and to manage risk as required under applicable law, or to respond to requests by judicial process or governmental agencies.
11. Enforce Compliance with Our Terms, Agreements and Policies
    When you access or use our Services, you are bound to our Terms of Service, available at tos.html. To ensure you comply with them, we process your personal information by actively monitoring, investigating, preventing and mitigating any alleged or actual prohibited, illicit or illegal activities on our Services. Subject to the applicable law, we may also process your personal information to investigate, prevent or mitigate violations of our internal terms, agreements or policies and enforce our agreements with third parties and business partners.
12. With Your Consent
    For any other purpose disclosed to you prior to you providing us your personal information or which is reasonably necessary to provide the Services or other related services requested, with your permission or upon your direction.

4. How We Disclose Your Personal Information

We may disclose your personal information as follow, as permitted under applicable law:

1. Within Our Corporate Organization
   We are a multinational organization, with cross-border legal entities and management structures. We may share your personal information within our corporate organization, including to our parent, subsidiary and affiliated companies to facilitate the Services as well as for the purpose of management and analysis; however, we will require that your personal information still be handled in the manner described herein.
2. With Our Vendors and Service Providers
   We may disclose your personal information to vendors and service providers we retain in connection with our business such as: website hosting, online store hosting, data analysis, payment processing, order fulfillment, magazine publishers, information technology and related infrastructure provision, customer service, email delivery, credit card processing, tax and financial advisers, legal advisers, accountants, auditing services, fraud prevention, identity verification, risk assessment, marketing, and network maintenance. These third-party service providers may have access to or process your personal information only for the purpose of providing services to us.
3. Business Partners, Sponsors, and Other Third Parties
   We may disclose your personal information to business partners, co-sponsors of Promotions, and other third parties in order to provide you with Services that may interest you. For example, we may co-sponsor promotions or other events with a third party and may share your personal information in connection with these events. If you provide additional information to any of these third parties, such information provided to these third parties will be subject to each third party's privacy practices and policies.
4. Analytics and Interest-based Advertising Partners
   We use third-party analytics, advertising, and marketing providers to collect information about your use of the Sites, see the overall patterns of usage on the Sites, deliver advertisements to your social media account based on email addresses, optimize ad performance, and determine whether our advertising is effective. Where permitted by applicable law, we may share your personal information with marketing and advertising partners for targeted advertising purposes, such as matching custom audience or creating lookalike audience on social media or other marketing platforms, so that we can better understand which of our Services may be of interest to you, market our Services to you, and to provide us information necessary to improve our Services. To learn more about your choices and rights, please review the "Your Privacy Rights" section below.
5. Merger, Acquisition, or Other Business Transaction
   We may disclose and transfer your personal information to a subsequent owner, co-owner, or operator of our Services, or in connection with a contemplated or agreed upon merger, acquisition, consolidation, restructuring, or the sale of substantially all our interests and/or assets (i.e., a bankruptcy proceeding). We shall require the subsequent owner, co-owner, or operator in possession of your personal information to continue to be subject to this Privacy Policy; otherwise, we shall request that they obtain the necessary consent from you. We reserve the right, as part of this type of transaction, to transfer or assign personal information and other information we have collected from users of the Services to buyers, service providers, advisors, potential transactional partners or other third parties in connection with the advisors, potential transactional partners or other third parties of a corporate transaction. By engaging with us or using our Services, you understand and agree to our assignment or transfer of rights to your personal information. If you would like for your information to not be included in such a transfer, please contact us as described below and notify us of your request to be opted-out of such transfers.
6. With Professional Advisors
   We may disclose your personal information to our professional advisors—including lawyers, auditors, accountants, insurers, and similar consultants—when such disclosure is necessary for them to provide us with their professional services, to comply with our legal or financial obligations, or to protect or enforce our rights.
7. Legal Obligations and Safety
   We may disclose your personal information if it is reasonably necessary to:
   • Comply with a valid legal process (e.g., subpoenas, warrants, court orders, etc.);
   • Comply with valid requests or investigations by public authorities;
   • Comply with applicable laws or regulations;
   • Enforce our policies, agreements, and terms, whether in litigation, other disputes, or otherwise;
   • Protect our legitimate interests, including legal interests;
   • Protect the security or integrity of the Services; or
   • Protect the rights, property, or safety of you, other users, employees, partners and affiliates, or other natural persons.
   We will, at our discretion, provide you with advance notice if we are compelled to disclose your personal information to law enforcement, public authorities, or other governmental entities, unless we are prohibited from doing so by governmental entities or the law.
8. With Your Consent
   We may disclose your personal information with other individuals or companies if you give us permission or direct us to share your personal information, such as other users (where you post information publicly or as otherwise necessary to affect a transaction initiated or authorized by you through the Services); social media services (if you intentionally interact with them through your use of the Services); or third-party business partners that you intentionally access through the Services.

5. Your Choices

1. Marketing Communications
   We may use your personal information to send you messages about new products and services, events, or other information that may be of interest to you, whether through in-app push notifications or other methods. If you do not wish to receive such information, you can change your account settings. Please note that you will not be able to opt-out of receiving non-promotional, transactional communications about your account or the Services.
2. Correct or Update Your Information
   You may make changes to the information you provided in conjunction with your account go to "settings" section and changing the applicable information. If you are not able to do so or if you wish to terminate and delete your account, you may contact us at rain.kx@gmail.com. Following receipt of a request from you, we will take reasonable steps to make changes or delete your information as required under the applicable law.

6. Your Privacy Rights

If you are located in the European Economic Area, the United Kingdom or Switzerland (collectively, the "European Countries") while using or accessing our Services, please see Section 13 instead.

If you are a resident of United States, please see Section 11 instead.

Depending on applicable law where you reside or are located, you may be able to assert certain privacy rights identified below with respect to your personal information. If any of the rights provided to you under the law that governs your personal information, we have absolute discretion in providing you with those rights.

Please note, your rights in relation to your personal information are not absolute. Depending upon the applicable law, access to your rights under the applicable law may be denied: (i) when denial of the request is required or authorized by law; (ii) when granting the request would have a negative impact on another's privacy; (iii) to protect our rights and properties; (iv) where the request if frivolous or vexatious, or for other reasons.

1. Right to Know/Access — You may have the right to obtain a copy, or a list of categories of the personal information that we hold about you, as well as other supplementary information, such as the purposes of processing, and the entities to whom we disclose your personal information.
2. Right to Correct/Rectification — You may have the right to correct any of your personal information in our records and systems. You may request us to rectify, correct or update any of your personal information held by us that is inaccurate.
3. Right to Delete/Erasure — Under certain circumstances, you may have the right to request that we delete the personal information that we hold about you. This right is not absolute, and we may refuse your right to delete if it is reasonably necessary for us to provide a service requested by you; to perform a contract between us; to maintain functionality and ensure security of our systems; to enable solely expected internal uses of your personal information; to exercise a right provided by law; to comply with a legal obligation, or if there are compelling legitimate grounds for keeping your personal information.
4. Right to Portability — Under certain circumstances, you may have the right to receive personal information we hold about you in a structured, commonly used, and machine-readable format so that you can provide that personal information to another entity.
5. Right to Restriction — You may have the right to request that we restrict our processing of your personal information in certain circumstances. For instance, this right is available if you contest the accuracy of the personal information, or you object to our processing.

Submitting a Request to Exercise Your Privacy Rights

To assert your applicable privacy rights, please contact us at rain.kx@gmail.com with the subject line "Privacy Rights Request." Once you have submitted your request, we will respond within the time frame permitted by the applicable law. To protect your privacy and security, before fulfilling your request, we are required by law to have you verify the personal information we already have on file to confirm your identity. If we cannot verify your identity based on the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.

7. Security

We use commercially reasonable administrative, technical, and physical safeguards to help protect and secure your personal information from unauthorized access, modification, disclosure, or destruction. However, no information system can be 100% secure. As a result, we cannot guarantee the absolute security of your personal information. Moreover, we are not responsible for the security of information that you transmit to the Sites over networks that we do not control, including the Internet and wireless networks. We are not responsible for circumvention of any privacy settings or security measures contained on our Services or those on third-party websites. Protecting your personal information is also your responsibility and we urge you to take precautions to protect your personal information. If you have reason to believe that your account or any interaction with us is no longer secure please let us know immediately by contacting customer support or as indicated in the "Contact Us" section at the end of this Privacy Policy.

8. Transfers of Your Personal Information

We are an international organization. When you access or use our Services, your personal information may be processed in the United States or any other country in which we, our Affiliates, or service providers maintain facilities. Such countries or jurisdictions may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. If you do not want your information transferred to, processed, or maintained outside of the country or jurisdiction where you are located, you should immediately stop accessing or using the Services.

If you are in the European Economic Area, the United Kingdom, or Switzerland, please refer to the section below titled Additional Notice to Individuals in the European Economic Area, United Kingdom, and Switzerland.

9. Retention

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. We will cease to retain your personal information or remove the means by which the personal information can be associated with you as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal information was collected and is no longer necessary for legal or business purposes. If you wish to cancel your account or request that we no longer use your information to provide you services, we may still retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

10. Children

Our Services are not intended for use by children under the age of sixteen (16). We will not knowingly collect personal information directly from children under the age of sixteen (16) without parental consent. If you are under the age of sixteen (16), please do not provide us with information of any kind whatsoever. We encourage parents and guardians to spend time with their children online and to be familiar with the websites they visit. If you have reason to believe that we may have accidentally received information from a child under the age of sixteen (16), please contact us immediately at rain.kx@gmail.com.

11. Additional Notice to Individuals in the United States

For individuals in the United States, depending on applicable law where you reside or are located, you may be able to assert certain rights identified below with respect to your personal information.

If any of the rights listed below are not provided to you under the law that governs the processing of your personal information, we have absolute discretion in providing you with those rights. Please refer to the "What Rights Apply" section below to determine the rights you have in the jurisdiction you reside. Your rights in relation to your personal information are not absolute. Depending upon the applicable law, access to your rights under the applicable law may be denied: (i) when denial of the request is required or authorized by law; (ii) when granting the request would have a negative impact on another's privacy; (iii) to protect our rights and properties; (iv) where the request is frivolous or vexatious, or for other reasons.

1. Right to Know/Access
2. Right to Correct
3. Right to Delete
4. Right to Portability
5. Right Against Discrimination
6. Right to Opt-Out of Automated Decision-making or Profiling
7. Right to Opt-Out Sale
8. Right to Opt-Out of Sharing for Targeted Advertising
9. Right to Appeal
10. Right to Obtain Third-Party List

What Rights Apply

Submitting a Request to Exercise Your Privacy Rights

If you are a resident in a state that provides the rights noted above, you can assert your privacy rights by emailing rain.kx@gmail.com and advising us which privacy rights you would like to exercise. Depending on your state of residence, applicable law may limit how many times per year you may submit a Right to Know/Access. We may charge a reasonable fee for multiple requests in the same 12-month period, as permitted by law.

Opting-out of Sharing/Targeted Advertising

You can exercise your right to opt-out of sharing for targeted advertising by clicking the "Privacy Preference" tab in the mobile app "Settings" menu and following the directions in the pop-up screen regarding how to opt-out of sales and targeted advertising. If you previously opted-out and wish to opt-in, you can use the options identified above to change your preferences.

12. Additional Notice for California Consumers: California Notice at Collection

If you are a California resident, this section applies to you in addition to the rest of this Privacy Policy. The California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, "CCPA") requires us to disclose the following additional information related to our privacy practices.

Categories of Personal Information Collected, Used, and Disclosed

In the preceding 12 months, depending on how you interact with our Services, we may have collected the following categories of personal information (as defined under Cal. Civ. Code §1798.140(v)(1)):

Shine the Light

The California Shine the Light law permits California residents that have an established business relationship with us to request certain information regarding our disclosure of certain types of Personal Information to third parties for their direct marketing purposes during the immediately preceding calendar year. To make such a request, please contact us using the information below, and indicate in your message that you are a California resident making a "Shine the Light" inquiry. This request may be made no more than once per calendar year.

Do Not Track

Your browser may allow you to adjust your browser settings so that "do not track" requests are sent to the websites that you visit. However, since uniform standards for "DNT" signals have not been adopted, we do not disable tracking technology that may be active on the Sites in response to any "do not track" requests that we receive from your browser.

13. Additional Notice to Individuals in the European Economic Area, United Kingdom, and Switzerland

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

1. Our Relationship to You
   We are a data controller with respect to any personal information collected from individuals accessing or using our Services.
2. Legal Bases for Processing Your Personal Information
   

   Purpose of Processing	Legal Bases
   Maintain Legal and Regulatory Compliance; Ensure the Security of the Services; Legal Obligations and Safety	Based on our legal obligations. Article 6(1) lit.(c) GDPR.
   Operate and Administer Our Services; Provide Customer Support; Send You Service-Related Communications; Within Our Corporate Organization; Vendors and Service Providers	Based on our contract with you or to take steps at your request prior to entering a contract. Article 6(1) lit.(b) GDPR.
   Infer Your Interest and Personalize Your Experience; Research and Develop our Services; Facilitate Corporate Transactions; Enforce Our Terms; With Professional Advisors	Based on our legitimate interest. Article 6(1) lit.(f) GDPR.
   Administer Promotional Events; Promote Our Services; With Your Consent; Analytics and Interest-based Advertising Partners	Based on your consent. Article 6(1) lit.(a) GDPR.

3. Individual Rights
   • Right to access
   • Right to rectification
   • Right to erasure
   • Right to restriction
   • Right to object to processing
   • Right to portability
   • Automated Decision-Making — We do not make any decisions based on algorithms or other automated processing that significantly affect you.
   • Right to lodge a complaint — If you reside in the European Countries, you may have the right to lodge a complaint with your national data protection authority.

   To assert your privacy rights, please email rain.kx@gmail.com.

4. Marketing
   We will only contact you if you are located in the Designated Countries by electronic means based on our legitimate interests, as permitted by applicable law or with your consent.
5. Transfer of Your Personal Information
   We transfer your personal information subject to appropriate safeguards as permitted under the relevant data protection laws.

14. Change to Privacy Policy

We may make changes to this Privacy Policy from time to time and will post the date it was last updated at the top of this Privacy Policy. Any changes to this Privacy Policy will become effective on the "Last Updated" date indicated above. We will provide additional notice to you if we make changes to this Privacy Policy that materially affect your privacy rights.

15. Contact Us

For any questions regarding our Privacy Policy or our privacy practices, please contact us at rain.kx@gmail.com.