Privacy policy
This website (sudoku.frog-job.com)
This website provides information about the app Sudoku Sanctuary. It uses no cookies, no analytics or tracking tools and loads no content from third parties; fonts and graphics are served from our own web space.
Hosting: the website is hosted by Hostinger International Ltd., 61 Lordou Vironos str., 6023 Larnaca, Cyprus. Hostinger processes the data on our behalf under a data processing agreement pursuant to Art. 28 GDPR. Hostinger uses sub-processors, including providers based in the USA (for example Cloudflare, Inc.); transfers to third countries are covered by the EU Standard Contractual Clauses or, where the recipient is certified, the EU-US Data Privacy Framework.
Server log files: when a page is requested, the server processes technically necessary data: IP address, date and time of the request, page requested, amount of data transferred, status code, referrer URL, and browser and operating system. The purpose is to deliver the website and to keep it secure and stable (for example, to defend against attacks). The legal basis is Art. 6(1)(f) GDPR; our legitimate interest is the secure operation of the website. The log files are stored according to the hosting provider's settings and deleted as soon as they are no longer needed for these purposes. You may object to this processing under Art. 21 GDPR.
The data is not passed on to any other third parties. For your further rights and the competent supervisory authority, see the app's privacy policy below, which also applies to this website.
Summary
This privacy policy explains, in accordance with Art. 13 of the General Data Protection Regulation (GDPR), which personal data is processed when you use the app Sudoku Sanctuary, for which purposes and on which legal basis.
- Sudoku Sanctuary is an offline game. You need no account and no registration; we do not learn who you are.
- Your game progress and settings stay on your device. We do not run a server of our own and do not receive this data.
- We use no analytics or tracking tools, no crash-reporting SDKs, no fonts loaded from the internet and no content delivery networks.
- Ads appear only if you have consented (in particular to TCF Purpose 1): banners at the top of some screens (also above the puzzle in progress), full-screen ads between two puzzles and when you return after a longer break, medium-sized ads on the pause and result screens, and voluntary videos with a reward. Without consent, under 16 and with the Guardian Pass the app shows no ads; every game feature remains available.
- Purchases are handled exclusively by Google Play.
Controller
The controller within the meaning of the GDPR is:
Nam Le
Geest Anger 6
24855 Jübek
Germany
E-mail: info@frog-job.com
We have not appointed a data protection officer because there is no legal obligation to do so (Art. 37 GDPR, Section 38 BDSG).
No account, no identifiers of our own, no analytics tracking
You can use Sudoku Sanctuary without an account, without signing in and without giving your name or e-mail address (Section 19(2) TDDDG). Even when you buy something, the app does not tell us your name; Google handles the payment.
The app creates no installation, user or device identifiers of its own and contains no analytics, statistics or crash-reporting SDKs (such as Firebase). The only exception: if you consent to ads, Google also processes device identifiers such as the Android advertising ID via the ad SDK (see “Ads (Google AdMob)”). Fonts, icons, graphics and sounds are included in the app and are not loaded from the internet. A technical safeguard (Content Security Policy) prevents the game interface from loading content from third-party servers.
Connections to Google only occur in the cases described below: for the consent tool, at the earliest after your first completed puzzle or when you tap an ad button yourself before that (see “Google’s consent tool”); for the purchase check, only when you tap an ad button (see “Purchases via Google Play”); for ads, only after you have consented (see “Ads (Google AdMob)”); and when you open the Premium section of the shop or the Guardian Pass screen, buy something or select “Restore purchases” (Google Play Billing).
Data on your device
To make the game work, the app stores the following in its app storage on your device: your game progress (for example puzzles, farm, companions, items, quests and streaks), your settings (for example language, sound, vibration, motion effects and reminders), your ad choice, your age answer (only “under 16” or “16 and over”), local ad counters (times and numbers of ads shown, without identifiers), the last known status of your purchases and Google Play purchase tokens, so that each purchase is credited only once.
This data is sent neither to us nor to a cloud backup (such as Google Drive). Only if you carry out a direct transfer from your old to your new device on Android 12 or later can it be moved to the new device. We have no access to this data and cannot link it to any person. Storing it is strictly necessary to provide the game you have expressly asked to use (Section 25(2) No. 2 TDDDG); no consent is required. Where the GDPR applies, the legal basis is Art. 6(1)(b) GDPR (providing the game under the Terms of Use).
Retention: until you delete the data. Settings → “Delete all data” removes your game progress, settings, stored purchase data and scheduled reminders. The values stored by the consent tool are kept; you change your choice via “Privacy & ad choices”. All app data, including these values, is deleted when you uninstall the app or clear the app’s storage in the Android settings.
Please note: without cloud saving, your game progress and virtual items already credited are lost when you delete the data, uninstall the app or change devices without a direct transfer. Permanent purchases and an active subscription are restored via Google Play.
Motion sensors, vibration and sound
For the tilt effect (parallax) and the shake gesture, the app reads your device’s orientation and acceleration sensors. It also uses vibration and sound. These values are processed in real time on your device only; they are neither stored nor transmitted.
This access serves only the game effects you use (Section 25(2) No. 2 TDDDG). You can switch off the tilt effect, vibration and sound in the settings at any time; the “Reduce motion” option also turns off motion effects.
Local reminders
If you wish, the app reminds you, for example, of crops ready to harvest or daily quests. Reminders are scheduled on your device only and displayed by the Android system. There is no push server; no data is sent to us or to third parties.
Reminders stay off until you switch them on and grant Android’s notification permission. You can turn them off at any time in the app or in the Android settings. Legal basis: Section 25(2) No. 2 TDDDG and Art. 6(1)(b) GDPR (a feature you requested).
Google’s consent tool (User Messaging Platform)
When the consent tool starts: never at the first start, in the introduction puzzle or in the first puzzle. After your first completed puzzle, at a calm moment on the Play screen, the app first asks for your year of birth and then starts Google’s consent tool; it does not check your purchases for this. If you tap an ad button yourself before that, the same order runs at once, with a brief purchase check before the consent tool (see “Purchases via Google Play”). After that, the app asks Google for the current status at each start only if you have consented or not yet decided. If you refused, the app does not ask again at every start, but at the earliest once after 6 months, or when you open “Privacy & ad choices” yourself. Under 16, the tool never starts. As long as the app knows that you own the Guardian Pass, it does not start by itself; it is loaded only when you open “Privacy & ad choices” yourself, so that you can change or withdraw a choice stored earlier. After a reinstall, the app only knows this once you select “Restore purchases”, open the Premium section or the Guardian Pass screen, or tap an ad button; until then the consent tool may appear once.
At that point, before you have made any choice, your device sends your IP address and technical information about the app and device to Google, so that Google can determine whether and in what form a consent request must be shown. If a request is needed, the first screen shows equivalent buttons to consent and to decline, plus an option to set your choices in detail.
The tool stores your choice on your device as TCF consent values (TC string) so that it can be respected and demonstrated. The tool also opens when you select “Privacy & ad choices” in the settings.
The legal basis is Art. 6(1)(c) GDPR in conjunction with Art. 7(1) GDPR and Section 25(1) TDDDG (obligation to obtain valid consent and to be able to demonstrate it) and Art. 6(1)(f) GDPR (our legitimate interest in offering ads only in a lawful way). Storing your choice on the device is strictly necessary for the consent management you use (Section 25(2) No. 2 TDDDG). Google receives this data as the provider of the consent tool (Google Ireland Limited or Google LLC, addresses under “Ads (Google AdMob)”) and, according to Google, processes it to provide the consent request; Google’s Privacy Policy applies (https://policies.google.com/privacy).
As long as the app knows that your Guardian Pass is active (or the game is ad-free for you because of an earlier purchase from a test version), it does not start the consent tool by itself and runs no ad code. Only when you open “Privacy & ad choices” yourself is the consent tool loaded (with the transmission to Google described above), so that you can change or withdraw a choice stored earlier.
Ads (Google AdMob)
The app shows ads via Google AdMob (Google Mobile Ads SDK) in these formats: (1) a banner at the top of the Play, Companion, Farm, Kitchen and Quests screens, in the Shop (not in the Premium area) and above the puzzle in progress, always labelled “Ad” and kept apart from controls; (2) full-screen ads after a won puzzle (at the earliest after the third completed puzzle, at most every 3 minutes, 6 per session and 15 per day) and after a return to the app after at least 30 minutes (at most 2 per day, at least 4 hours apart); (3) a medium-sized ad (300 × 250) on the pause screen when you pause yourself, and below the buttons of the result screen; (4) voluntary videos with a reward that you tap yourself, and occasionally a “Bonus” card with a 5-second countdown and an equally large “No thanks” button. There are no full-screen ads while a puzzle is in progress. The ads SDK is initialised and ads are requested only if you have consented in the consent tool, in particular to storing and accessing information on your device (TCF Purpose 1). Without this consent the app shows no ads, not even so-called limited ads. If no TCF consent exists outside the European Economic Area, the app shows no ads there either. So that ads appear without a wait, the app loads the next ad in advance after you have consented, for example right after a rewarded ad or between two puzzles; no full-screen ad is preloaded while a puzzle is in progress.
Data processed (according to Google): IP address (from which an approximate location can be derived), interactions with the app and the ad (for example app launches, taps, video views), diagnostic data (for example loading time, hangs, energy use), device identifiers (Android advertising ID, app set ID) and your TCF consent values. The transfer is encrypted with TLS.
Purposes: selecting and serving the ad, measuring ads (for example reach and billing with advertisers), preventing fraud and abuse, and fixing errors. Whether ads are personalised, that is, based on a profile created by Google, is your choice in the consent tool; without consent to personalisation, Google shows non-personalised ads or no ads.
The legal basis is your consent (Art. 6(1)(a) GDPR; for access to your device, Section 25(1) TDDDG). For technical delivery, security and fraud prevention (“special purposes” in the TCF) and, where applicable, for certain other purposes marked as “legitimate interest” in the consent tool (for example measuring ad performance), Google states that it relies on legitimate interests (Art. 6(1)(f) GDPR). You can object to these purposes in the consent tool where it offers a choice for them. In our app, this processing also takes place only after you have consented.
Responsibility: we integrate the SDK into the app and are (jointly) responsible for the collection and transmission of your data through the SDK. Google is independently responsible for any further processing: for users in the European Economic Area and Switzerland, Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, and also Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Our cooperation is based on the Google Ads Controller-Controller Data Protection Terms (https://business.safety.google/adscontrollerterms/). You can exercise your rights against us and against Google.
Retention: consent values and ad identifiers remain on your device until you change your choice, reset or delete the advertising ID, or delete the app data. Google decides how long it keeps data. Information from Google: https://policies.google.com/privacy and https://policies.google.com/technologies/partner-sites
To keep the gaps and daily limits, the app stores on your device only the times and numbers of ads shown (without identifiers). These ad counters are written only after your consent, never transmitted and never exported (Section 25(2) no. 2 TDDDG; Art. 6(1)(f) GDPR, our interest in not showing ads more often than announced).
If you tap an ad, the advertiser’s website or store listing may open. The advertiser’s privacy policy applies there.
Withdrawing or changing your consent
You can withdraw or change your consent at any time with effect for the future (Art. 7(3) GDPR): in the app under Settings → “Privacy & ad choices”. Withdrawal does not affect the lawfulness of processing carried out before it.
You can also reset or delete your advertising ID in the Android settings under “Ads” (the name depends on the device).
If you do not consent or withdraw your consent, every game feature remains available. Rewards offered for watching an ad can also be obtained in other ways, for example with coins, by waiting or by playing. We do not pressure you to consent.
As long as your Guardian Pass is active (or the game is ad-free for you because of an earlier purchase from a test version), the app does not use a previously stored choice. You can remove it at any time by clearing the app’s storage in the Android settings.
Purchases via Google Play
In-app purchases (the Starter Bundle, the Guardian Pass and coin packs) are handled exclusively through Google Play’s billing system. The seller and your contracting party is currently Google Commerce Limited, 70 Sir John Rogerson’s Quay, Dublin 2, D02 R296, Ireland. Google processes payment data, your Google account and billing details under its own responsibility; Google’s Privacy Policy (https://policies.google.com/privacy) and the Google Play Terms of Service (https://play.google.com/about/play-terms/) apply.
The app connects to Google Play’s billing system when you open the Premium section of the shop or the Guardian Pass screen (to load the prices), buy something or select “Restore purchases”, and for the purchase check when you tap an ad button (see the next paragraph). Only if you have bought something or restored a purchase does it also check your purchases when you start or return to the app; merely opening the Premium section does not count. In doing so, it receives, among other things, the product ID, purchase status, purchase time and a purchase token, and it acknowledges new purchases to Google Play. This information is stored only on your device so that purchases can be unlocked and restored and consumables are credited only once. With each of these connections, the Google Play Billing Library built into the app also sends technical diagnostic data about the billing process (for example the library version, result and error codes, and device and app information) directly to Google; Google uses it to operate and improve the billing service (https://policies.google.com/privacy).
Purchase check before an ad you request: when you tap an ad button, the app first checks once with Google Play whether you own the Guardian Pass, so that subscribers get the reward at once instead of an ad. The check takes at most 3 seconds and is answered offline from Google Play’s local purchase cache. It connects to Google Play’s billing system, which sends diagnostic data to Google even if you have bought nothing. If it finds no Pass, the app remembers the result for 30 days. The app never checks your purchases by itself: not at start, and not before the consent tool, banners or other ads. After a reinstall it therefore only recognises a Guardian Pass once you select “Restore purchases”, open the Premium section or the Guardian Pass screen, or tap an ad button; until then the consent tool may appear once and, if you consent, ads may appear too. The legal basis is Art. 6(1)(f) GDPR (our interest in keeping the promise “no ads with the Guardian Pass”). For the related access to Google Play’s purchase store on your device we rely on Section 25(2) No. 2 TDDDG: it is strictly necessary so that we can provide the game as it is offered (no ads with the Guardian Pass). If the check does not finish in time, nothing ad-related starts in that session.
Through the Google Play Console, Google provides us with order and sales information (for example order number, product, price, taxes, date, status, country and, where applicable, region or postal code). If you contact us about a purchase, we can find the order there using the order number or the e-mail address of your Google account. We use this information for billing, accounting, customer service and refunds.
Legal bases: Art. 6(1)(b) GDPR (providing the content you bought), Art. 6(1)(f) GDPR (our legitimate interest in restoring purchases after a reinstall or on another device) and Art. 6(1)(c) GDPR (retention obligations under tax and commercial law). Checking your purchases on your device is strictly necessary to provide the content you bought (Section 25(2) No. 2 TDDDG).
Retention: purchase data on your device until the app data is deleted; order information held by us until the statutory retention periods expire (in particular under Section 147 of the German Fiscal Code).
Contacting us by e-mail
If you e-mail us (for example with support questions, questions about purchases, reports of accessibility barriers or security vulnerabilities), we process your e-mail address, your name if given, the content of your message and technical details you share with us (for example app version, device, Android version).
The purpose is to handle your request. The legal basis is Art. 6(1)(b) GDPR where your request concerns a contract or purchase, and otherwise Art. 6(1)(f) GDPR (our legitimate interest in answering enquiries). Our e-mail provider processes the messages on our behalf (Art. 28 GDPR).
If you use the app’s withdrawal function (Settings → “Withdraw from a contract”), the app composes your declaration on your device (contract, purchase date, Google Play order number, and your name and e-mail address if you enter them) and opens your e-mail app; we receive the declaration only when you send it. We use it to handle your withdrawal and to confirm receipt (Art. 6(1)(c) GDPR). The purchase list for this function is stored only on your device.
We delete your messages once your request has been dealt with, unless statutory retention obligations (for example for business letters) require us to keep them longer.
Crash and performance data (Android vitals)
The app contains no crash-reporting tool of its own. If you have agreed in your Android device settings to share usage and diagnostics data, the Android system itself records stability and performance data (for example crashes or apps not responding). Google provides this data to us in aggregated form in the Google Play Console (“Android vitals”). You manage this setting in the Android or Google settings of your device. We use these reports only to fix errors (Art. 6(1)(f) GDPR).
Links to other providers
Before the app opens an external page (for example our website, Google Play’s subscription management or Google’s privacy information), it tells you that you are leaving the app (Section 19(3) TDDDG). The page opens in your browser or in Google Play, where the privacy policy of the respective provider applies.
Recipients at a glance
- Google Ireland Limited and Google LLC: consent tool (at the earliest after the first completed puzzle or when you request an ad), purchase check (only when you request an ad), ads (additionally only after your consent), Google Play (purchases, updates), Android vitals.
- Google Commerce Limited: seller for purchases via Google Play.
- Our e-mail provider (processor): when you write to us.
- Authorities, courts and advisers bound by professional secrecy (for example tax advisers): only where we are legally obliged to or where it is necessary to protect our rights.
We do not sell personal data.
Transfers to third countries
Google also processes data in the USA and in other countries outside the European Economic Area. For the USA, there is an adequacy decision of the European Commission (EU-US Data Privacy Framework, Implementing Decision (EU) 2023/1795); Google LLC is certified under it (https://policies.google.com/privacy/frameworks). In addition, Google uses the European Commission’s Standard Contractual Clauses (Art. 46(2)(c) GDPR), which are also part of the Google Ads Controller-Controller Data Protection Terms. These apply in particular to other third countries and in case the adequacy decision ceases to apply.
Retention at a glance
- Game progress, settings and purchase data on your device: until you delete them or uninstall the app.
- Consent values on your device: until you change your choice or delete the app data.
- Data held by Google (ads, purchases): according to Google’s retention periods.
- E-mails to us: until your request has been dealt with, and beyond that only for statutory retention periods.
- Order information from the Google Play Console: until the retention periods under tax and commercial law expire.
Your rights
Under the GDPR you have the right of access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18) and data portability (Art. 20), and the right to withdraw consent at any time with effect for the future (Art. 7(3)).
Please contact info@frog-job.com. Data stored only on your device is not available to us; you can delete it yourself via “Delete all data” or in the Android settings. We cannot link ad data held by Google to you because we have no identifier (Art. 11 GDPR). You can also exercise your rights directly against Google (https://policies.google.com/privacy).
Right to object under Art. 21 GDPR
Where we process data on the basis of legitimate interests (Art. 6(1)(f) GDPR), you have the right to object at any time on grounds relating to your particular situation. We will then stop processing the data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims.
Where data is processed for direct marketing, you may object to this at any time without giving reasons. The easiest way to object to ads is via Settings → “Privacy & ad choices”; you can also write to us at info@frog-job.com.
Right to lodge a complaint with a supervisory authority
You have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR), in particular in the Member State of your habitual residence, place of work or place of the alleged infringement. The authority responsible for us is:
Unabhängiges Landeszentrum für Datenschutz Schleswig-Holstein (ULD)
Holstenstraße 98
24103 Kiel
No obligation to provide data
You are under no legal or contractual obligation to provide us with personal data. The game works without consent to ads. To make purchases you need a Google account; without the data required for this, Google cannot process the purchase.
Automated decisions and profiling
We do not make automated decisions within the meaning of Art. 22 GDPR and do not create profiles. If you have consented to personalised ads, Google may analyse your data automatically to select ads (profiling). Google explains the details at https://policies.google.com/technologies/partner-sites
Children and young people
Sudoku Sanctuary is intended for people aged 16 and over and is not directed at children. Anyone under 16 cannot validly consent to ads themselves (Art. 8 GDPR).
Before the app asks for consent to ads for the first time, it asks once for your year of birth. Only whether you are under 16 or 16 and over is stored, on your device only; the year of birth itself is not stored. The answer is never transmitted to us or to third parties and never exported. Because a year of birth alone does not reveal the birthday, a year that could still mean 15 counts as under 16.
Under 16, the app starts neither the consent form (Google UMP) nor the ads SDK; rewards then come from coins, waiting or play. Every game feature remains available. You can change the answer once in Settings under “Privacy & ad choices”.
Legal basis: Art. 6(1)(c) GDPR in conjunction with Art. 8(2) GDPR (age check before consent); storing it on the device is permitted under Section 25(2) no. 2 TDDDG. Storage period: until you delete the app’s data or uninstall the app.
Data security
We protect the app in line with the state of the art (Section 19(4) TDDDG): the game interface may only load files included in the app, unencrypted connections are blocked, and the integrated Google services transmit data in encrypted form (TLS). You will find more under “Security and product information”.
Changes and date
We update this privacy policy when the app or the law changes. The current version is available in the app and at https://sudoku.frog-job.com/datenschutz.
Last updated: 31 October 2026