Privacy Policy

App Name: Elfins's Water Sort Puzzles
Last Updated: June 15, 2026

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application "Elfins's Water Sort Puzzles" (the "Application"). Please read this Privacy Policy carefully. By using the Application, you consent to the practices described in this Privacy Policy.

We are an individual developer based in mainland China. We take your privacy seriously and are committed to protecting your personal data in accordance with applicable laws, including the Personal Information Protection Law of the People's Republic of China (PIPL), the General Data Protection Regulation (GDPR) for users in the European Economic Area, the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA) for residents of California, USA, and the California Online Privacy Protection Act (CalOPPA).

If you do not agree with this Privacy Policy, please do not use the Application.

1. Information We Collect

1.1 Information You Provide Directly

We do not collect any personal information that you provide directly. The Application does not require you to create an account, register, or provide your name, email address, phone number, home address, or any other personally identifiable information.

1.2 Information Collected Automatically (Analytics)

We use the Google Analytics for Firebase SDK to help us understand how users interact with the Application and to improve the user experience. This SDK automatically collects the following non-personally identifiable information:

Device Information: Device model, operating system version, screen resolution, language settings, app version, and device identifiers (such as Apple IDFA/IDFV or Android Advertising ID);
Usage Data: How you interact with the Application, including screens viewed, features used, session duration, and in-app actions;
Crash Data: Technical information about app crashes and errors to help us fix bugs;
Approximate Location: Coarse geographic location derived from your IP address at a country or city level (not precise GPS location).

The Google Analytics for Firebase SDK does not collect your name, email address, phone number, or any other directly identifying personal information. All collected data is aggregated and used in a way that does not personally identify you. For more information, please see Google's Privacy Policy at https://policies.google.com/privacy.

1.3 Information Collected by Advertising Partners

The Application displays advertisements. Our advertising partners may automatically collect certain information to deliver relevant ads, including:

Device identifiers (IDFA / Android Advertising ID);
IP address;
Ad interaction data (e.g., ad impressions, clicks);
Device type and operating system.

We currently use the following advertising services:

Google AdMob – Privacy Policy: https://support.google.com/admob/answer/6128543
AppLovin – Privacy Policy: https://legal.applovin.com/privacy/

Please note that we do not control what information is collected by our advertising partners. You should review their privacy policies for more information.

1.4 In-App Purchase Information

The Application offers in-app purchases (e.g., removing ads). All payment transactions are processed solely by the Apple App Store or Google Play Store (the "App Stores"). We do not collect, process, or store any payment or financial information, such as credit card numbers or billing details. Please refer to the relevant App Store's privacy policy for information on how your payment data is handled.

2. How We Use Your Information

We use the information we collect for the following purposes:

To operate, maintain, and improve the Application;
To analyze usage trends and user behavior to enhance the user experience;
To detect and fix technical issues, crashes, and errors;
To serve advertisements through third-party ad networks;
To process in-app purchases (through the App Stores);
To comply with legal obligations and enforce our Terms of Service.

3. Analytics

We use the Google Analytics for Firebase SDK provided by Google LLC ("Google") as our analytics service. This SDK helps us understand how users interact with the Application by collecting and reporting usage data. Google may use the collected data to track and examine the use of the Application and to prepare reports on its activities.

You can learn more about how Google uses data when you use our Application by visiting https://policies.google.com/technologies/partner-sites.

Your choices regarding analytics:

Opt out of Analytics: You may opt out of analytics data collection through your device settings (see Section 4 below for details);
App Tracking Transparency (iOS 14.5+): On iOS devices, you will be prompted to grant permission before the Application tracks your activity across other apps and websites. You can manage this setting at any time in your device's Privacy settings.

4. Advertising

The Application displays advertisements provided by third-party ad networks, including Google AdMob and AppLovin. These ad networks may use device identifiers and other information to deliver interest-based advertising. We do not share your personal information directly with ad networks for their own marketing purposes.

Your choices regarding advertising:

Disable Personalized Ads: You can disable personalized advertising at any time within the Application by going to Settings > About and turning off "Personalized Ads". This will stop the sharing of data for interest-based advertising while still showing non-personalized ads.
Device-Level Opt Out: You may also opt out of interest-based advertising through your device settings:
- iOS: Go to Settings > Privacy & Security > Apple Advertising and enable "Limit Ad Tracking";
- Android: Go to Settings > Google > Ads and enable "Opt out of Ads Personalization";
Ad Removal: You may purchase an in-app item to remove all advertisements from the Application.

5. In-App Purchases

In-app purchases (such as ad removal) are processed exclusively through the Apple App Store or Google Play Store. We do not collect, store, or process any payment information. Refunds and billing inquiries are handled by the respective App Store in accordance with its policies.

6. Third-Party Services

The Application integrates with the following third-party services. Each service operates under its own privacy policy:

| Service | Purpose | Privacy Policy | |---------|---------|---------------| | Google Analytics for Firebase SDK | Usage analytics | https://firebase.google.com/support/privacy | | Google AdMob | Advertising | https://support.google.com/admob/answer/6128543 | | AppLovin | Advertising | https://www.applovin.com/privacy | | Apple Game Center | Leaderboards & achievements (iOS) | https://www.apple.com/legal/privacy | | Google Play Games Services | Leaderboards & achievements (Android) | https://policies.google.com/privacy | | Apple App Store | App distribution & payments (iOS) | https://www.apple.com/legal/privacy | | Google Play Store | App distribution & payments (Android) | https://policies.google.com/privacy |

7. Data Sharing and Disclosure

We do not sell, trade, rent, or otherwise transfer your personal information to third parties, except in the following circumstances:

With Service Providers: We may share anonymized, aggregated data with trusted service providers (e.g., analytics and advertising partners) who assist us in operating the Application, subject to contractual restrictions;
Legal Compliance: We may disclose information if required to do so by law, regulation, legal process, or governmental request;
Protection of Rights: We may disclose information to protect our rights, property, or safety, or the rights, property, or safety of others;
Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction, with notice provided to you.

8. Data Retention and Security

We retain the analytics data collected through the Google Analytics for Firebase SDK for a period of 14 months in accordance with Google's default data retention settings. After this period, the data is automatically deleted.

We implement reasonable technical and organizational measures to protect your information against unauthorized access, alteration, disclosure, or destruction. However, no method of electronic storage or transmission is 100% secure, and we cannot guarantee absolute security.

9. Children's Privacy

The Application is designed for general audiences. We do not knowingly collect personal information from children under the age of 13 (or the applicable age threshold in your jurisdiction). Since the Application does not collect personal information such as names, email addresses, or phone numbers from any user — including children — there is no personal data at risk of being collected from children.

The analytics data collected through the Google Analytics for Firebase SDK (device identifiers, usage statistics, and coarse location) is anonymized and does not constitute personal information under applicable children's privacy laws such as the US Children's Online Privacy Protection Act (COPPA).

If we become aware that a child under 13 has provided us with personal information contrary to this policy, we will take steps to delete such information promptly. If you believe that a child under 13 has provided us with personal information, please contact us immediately at support@elfin.cc.

10. Your Rights

10.1 Rights for All Users

You have the right to:

Access and Know: Request information about what data we hold about you;
Rectify: Request correction of inaccurate data;
Delete: Request deletion of your data;
Withdraw Consent: Withdraw your consent at any time, where processing is based on consent.

To exercise any of these rights, please contact us at support@elfin.cc. We will respond to your request within the timeframe required by applicable law. Please note that because we do not collect personal information directly, most of these rights will relate to the analytics data collected by the Google Analytics for Firebase SDK.

10.2 GDPR Rights (for Users in the European Economic Area)

If you are located in the European Economic Area (EEA), you have the following additional rights under the General Data Protection Regulation (GDPR):

Right to Restrict Processing: Request restriction of processing of your data;
Right to Data Portability: Request a copy of your data in a structured, commonly used, machine-readable format;
Right to Object: Object to the processing of your data for direct marketing purposes or based on our legitimate interests;
Right to Lodge a Complaint: Lodge a complaint with your local data protection supervisory authority.

Legal Basis for Processing: We process your data based on:

Consent (Article 6(1)(a) GDPR) — for analytics and advertising; you may withdraw consent at any time through your device settings or the in-app "Personalized Ads" toggle;
Legitimate Interests (Article 6(1)(f) GDPR) — for app improvement and crash detection.

Data Controller: The data controller for the purposes of GDPR is the developer of the Application. You can contact us at support@elfin.cc.

Data Transfers: The Google Analytics for Firebase SDK is operated by Google LLC, which is based in the United States. Data collected through the SDK is transferred to and processed on Google's servers. Google has certified compliance with the EU-US Data Privacy Framework to ensure adequate data protection.

10.3 CCPA/CPRA Rights (for California, USA Residents)

If you are a resident of California, USA, the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA) grants you the following rights:

Right to Know: You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the sources from which it was collected, the business purpose for collecting it, and the categories of third parties with whom it was shared;
Right to Delete: You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions;
Right to Correct: You have the right to request correction of inaccurate personal information;
Right to Opt Out of Sale/Sharing: You have the right to opt out of the "sale" or "sharing" of your personal information for cross-context behavioral advertising. We do not sell your personal information. However, the sharing of device identifiers with advertising partners for interest-based advertising may be considered a "sale" or "sharing" under the CCPA/CPRA. You can opt out by:
- Turning off "Personalized Ads" in the Application (Settings > About);
- Adjusting your device's "Limit Ad Tracking" (iOS) or "Opt out of Ads Personalization" (Android) settings;
- Contacting us at support@elfin.cc;
Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights.

Categories of Personal Information Collected and Disclosed (Last 12 Months):

| Category | Collected? | Source | Business Purpose | Shared/Sold? | |----------|-----------|--------|-----------------|-------------| | Identifiers (device ID, IP, advertising ID) | Yes (via analytics & ads) | Automated collection | Analytics, advertising | Shared with ad networks | | Commercial information (purchase history) | No | — | — | — | | Internet/electronic activity (usage data) | Yes (via analytics) | Automated collection | App improvement | Not sold | | Geolocation data (coarse, IP-based) | Yes (via analytics) | Automated collection | Analytics | Not sold |

To exercise your CCPA/CPRA rights, please contact us at support@elfin.cc. We will verify your request and respond within 45 days (extendable by an additional 45 days with notice). You may designate an authorized agent to make a request on your behalf.

10.4 CalOPPA / Do Not Track

Under the California Online Privacy Protection Act (CalOPPA), we are required to disclose how we respond to Do Not Track (DNT) signals. The Application does not respond to Do Not Track signals at this time, as no uniform industry standard for DNT has been established. We will reassess this practice as industry standards evolve.

CalOPPA also requires us to disclose how users can review and request changes to their personal information. As we do not maintain user accounts or profiles, there is no separate mechanism for reviewing or changing personal information within the Application. You may contact us at support@elfin.cc with any inquiries.

11. International Data Transfers

Your information, including data collected through the Google Analytics for Firebase SDK, may be transferred to and processed on servers located outside your country of residence, including in the United States and other jurisdictions where Google and its sub-processors operate. We ensure that appropriate safeguards are in place for such transfers in compliance with applicable data protection laws (including Standard Contractual Clauses for GDPR purposes or the EU-US Data Privacy Framework where certified).

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational reasons. We will notify you of any material changes by:

Displaying a notice within the Application;
Updating the "Last Updated" date at the top of this Privacy Policy.

We encourage you to review this Privacy Policy periodically. Your continued use of the Application after the effective date of any changes constitutes your acceptance of the updated Privacy Policy.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Email: support@elfin.cc

We will respond to your inquiry as soon as possible and within the timeframe required by applicable law.

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