1. Scope and Controller

This Policy applies to the App, its Google Play listing, and user support communications related to the App. The controller or responsible operator is:

We do not currently operate our own user account server, database, cloud save server, or independent ranking server for the App.

2. Applicable Law

We aim to operate the App in a manner consistent with applicable privacy and data protection laws, including where applicable:

• Republic of Korea: the Personal Information Protection Act (“PIPA”) and related guidance.
• United States: applicable federal and state privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA/CPRA”) for California residents, and other U.S. state privacy laws where they apply.
• European Economic Area / United Kingdom: the General Data Protection Regulation (“GDPR”), UK GDPR, and related local data protection laws where they apply.

Some laws apply only when statutory thresholds, user location, business size, revenue, or data-processing activities meet legal requirements. Nothing in this Policy limits rights that users may have under applicable law.

3. Information We Collect

We collect or process only information reasonably necessary to provide, maintain, secure, and improve the App. Certain items below apply only if the relevant feature or SDK is actually enabled.

We do not intentionally collect government identification numbers, precise financial account credentials, health information, biometric information, political opinions, religious beliefs, or other sensitive information unless expressly stated in a future update and permitted by applicable law.

4. Purposes and Legal Bases

5. Google Services, Ads, Analytics, Billing, and SDKs

The App uses or may use Google services or SDKs. We are responsible for keeping the App’s Google Play Data Safety form and this Policy consistent with the App’s actual behavior.

If we add or remove SDKs or features, we will update this Policy and the Google Play Data Safety section as required.

6. Advertising Identifiers, UMP, Cookies, and Behavioral Data

The App uses Google AdMob / Google Mobile Ads SDK to display advertisements and measure ad performance. Third-party providers, including Google, may process advertising identifiers, ad impressions, ad clicks, app interaction data, approximate location inferred from IP address or network signals where applicable, diagnostic information, and security/fraud-prevention signals.

The App may use Google UMP to request and manage consent where required. In regions such as the EEA, UK, and Switzerland, users may be shown a consent message before certain ad-related processing occurs. Users may also manage ad personalization, reset or delete the Android Advertising ID, or change privacy settings through Android, Google, or device settings. Menu names may vary by device and Android version.

The App does not use traditional web browser cookies inside its core gameplay. However, ad SDKs and platform services may use identifiers or similar technologies as described by their policies.

We do not knowingly provide targeted advertising to children under 13, and the App is not directed to children under 13.

7. Sharing, Service Providers, and Third Parties

We do not sell user personal information for money. We may share or allow processing of information with service providers and third-party SDK providers only as necessary to operate the App, display ads, manage consent, respond to support requests, comply with law, or protect rights and safety.

8. International Transfers

We are based in South Korea. Third-party service providers, including Google, may process information in the United States, South Korea, and other countries where they or their infrastructure operate.

Where required, we rely on appropriate legal mechanisms for international transfers, such as consent, performance of a contract, adequacy decisions, standard contractual clauses, or other mechanisms permitted by applicable law.

9. Retention and Deletion

We keep personal information only for as long as reasonably necessary for the purposes described in this Policy, unless a longer period is required or permitted by law.

When information is no longer needed, we delete it, de-identify it, or rely on the relevant service provider’s deletion mechanisms.

10. Security

We use reasonable administrative, technical, and organizational safeguards appropriate to the nature of the App. These may include limiting access to development systems, using platform security features, avoiding direct storage of raw payment card data, maintaining software updates, and using secure transmission provided by platform services. No method of transmission or storage is completely secure.

11. Children and Teens

The App is intended for users aged 13 and older. The App is not directed to children under 13, and we do not knowingly collect personal information from children under 13. If you believe a child under 13 has provided personal information to us, contact us at cjjoung@byulzari.co.kr and we will take appropriate steps.

For users under the age of majority in their jurisdiction, a parent or legal guardian may contact us to exercise privacy rights on their behalf where permitted by law.

12. Your Privacy Rights

Depending on your location and applicable law, you may have the right to:

• Access or know the personal information we process about you.
• Request correction of inaccurate information.
• Request deletion of personal information.
• Object to or restrict certain processing.
• Withdraw consent where processing is based on consent.
• Request portability or a copy of information in a portable format.
• Opt out of certain targeted advertising, sale, or sharing where applicable.
• Appeal a decision if applicable state or regional law provides an appeal right.

To exercise rights, contact us at cjjoung@byulzari.co.kr. We may need to verify your identity or authority before responding. You may also manage some data directly through Google account, Google Play Games, Android advertising ID, or Google Play settings if those services are enabled.

13. U.S. State Privacy Notice, including CCPA/CPRA

This section applies to residents of U.S. states with applicable consumer privacy laws, including California residents where the CCPA/CPRA applies. We provide this notice to explain categories of information, purposes, and rights.

Categories of personal information

CCPA/CPRA rights

California residents may have the right to know/access, delete, correct, opt out of sale or sharing, limit use of sensitive personal information, and not be discriminated against for exercising CCPA rights. We do not knowingly sell personal information for money. If ad SDK behavior is considered “sharing” for cross-context behavioral advertising under California law, users may opt out through device advertising settings and by contacting us.

We do not knowingly collect, sell, or share personal information of consumers under 16 years of age. We do not use or disclose sensitive personal information for purposes that would require a “Limit the Use of My Sensitive Personal Information” mechanism unless stated in a future update.

To submit a California or other U.S. state privacy request, email cjjoung@byulzari.co.kr with the subject line “Privacy Request.” Authorized agents may submit requests if they provide proof of authorization and we can verify the consumer’s identity as required by law.

14. GDPR/EEA/UK Privacy Notice

If you are in the EEA, UK, or another jurisdiction with similar rights, you may have the rights of access, rectification, erasure, restriction, portability, objection, withdrawal of consent, and the right to lodge a complaint with a supervisory authority.

You may contact us at cjjoung@byulzari.co.kr to exercise GDPR rights. You may also contact your local data protection authority.

15. Korea Privacy Notice

For users in Korea, this Policy is intended to provide notice under the Personal Information Protection Act, including purposes of processing, processed items, retention periods, destruction procedures, third-party provision, outsourcing, international transfer, safety measures, data subject rights, contact information, and dispute resolution channels.

Korean users may contact us at cjjoung@byulzari.co.kr to request access, correction, deletion, suspension of processing, or withdrawal of consent.

16. Automated Decision-Making

We do not currently make decisions solely by automated processing that produce legal or similarly significant effects for users. If we introduce such processing, we will update this Policy with the purposes, logic, categories of personal information used, and rights to request review or explanation where required by law.

17. Contact

18. Changes to this Policy

We may update this Policy when the App, SDKs, laws, or data practices change. If we make material changes, we will make the updated Policy available through the App, the Google Play listing, or another reasonably accessible method. The effective date at the top indicates when this Policy applies.

© Brian Joung, byulzari. Privacy Policy for Luma Orchard: Match 3 Garden.