Effective date: Sep 1, 2020
SUDOKING APP PRIVACY POLICY
This Privacy Policy, published on SUDOKING.COM, applies to the SUDOKING mobile application on both supported platforms: the iOS version distributed through the Apple App Store and the Android version distributed through Google Play. It explains how SAS SUDOKING collects, uses, stores and protects users' personal data. In this Privacy Policy, "SUDOKING" refers to the mobile application, while "SAS SUDOKING" refers to the company that publishes the application and acts as data controller.
1. Data Controller
The data controller is:
SAS SUDOKING
1, rue Dumont
27700 Les Andelys
France
Email address: contact@sudoking.com
You may contact us at this address if you have any questions about your personal data or wish to exercise your rights.
2. General Principle
SUDOKING is a puzzle game that can be used without creating an account. Users are not required to provide their name, email address, telephone number or password in order to play. However, SUDOKING uses a technical identifier associated with the device in order to recognise the player, save progress, restore game data and operate the application.
3. Data We Collect
3.1. Technical Device Identifier
SUDOKING uses a technical identifier associated with the device. Depending on the operating system, this identifier is generated or provided by iOS or Android. It is used only to:
- recognize the player without creating an account,
- associate the player with their progress,
- save and restore game data,
- ensure service continuity,
- prevent certain errors or fraudulent uses.
The identifier used by SUDOKING is not used to personalise advertisements.
3.2. Game and Usage Data
Through SUDOKING, SAS SUDOKING stores the following information on its server:
- general progress,
- level reached,
- grids started,
- grids completed,
- scores,
- playing time,
- lives used or available,
- hints used or available,
- answers given to riddles,
- Easter Eggs discovered,
- game preferences,
- selected avatar,
- in-app purchases made,
- information required to restore purchases.
SAS SUDOKING uses this information to save progress, operate levels and purchased features and restore the player's data.
3.3. Hall of Fame
When a player discovers an Easter Egg, SUDOKING may invite the player to appear in the Hall of Fame. Participation in the Hall of Fame is entirely optional. A player may refuse without losing access to the game or any other feature.
When a player agrees to participate, the following information becomes visible to all SUDOKING players:
- the chosen nickname,
- the selected SUDOKING avatar,
- the player’s Easter Egg ranking,
- the number of Easter Eggs discovered.
The avatar must be selected from the thirty predefined avatars provided by SUDOKING. SUDOKING does not request or allow users to upload a personal photograph for the Hall of Fame.
Users should not select a full name, email address, telephone number or other directly identifying information as their nickname.
A player may ask SAS SUDOKING to delete or anonymise their nickname and the associated public information at any time by contacting: contact@sudoking.com
3.4. In-App Purchases
SUDOKING offers optional in-app purchases. Payments made in the iOS version distributed through the Apple App Store are processed by Apple. Payments made in the Android version distributed through Google Play are processed by Google.
SAS SUDOKING does not receive users’ complete payment card details.
SAS SUDOKING may receive and store information required to recognise and restore a purchase, including:
- the product purchased,
- the purchase date,
- the transaction status,
- a transaction identifier,
- information required to restore the purchase.
Purchases can be restored following reinstallation or a change of device through the Apple ID or Google account used to make the purchase.
3.5. Support Communications
When a user contacts contact@sudoking.com, SAS SUDOKING may process:
- the user’s email address,
- the contents of the message,
- technical information or documents voluntarily provided by the user,
- the correspondence history required to deal with the request.
SAS SUDOKING uses this information solely to answer the request, resolve a problem or allow the user to exercise their rights.
3.6. Technical Data and Server Logs
SAS SUDOKING and its hosting provider may process certain technical information required for the security and operation of SUDOKING, such as:
- IP address,
- date and time of connection,
- device type or model,
- operating system version,
- error logs,
- technical incident information.
SAS SUDOKING does not use this data to determine the user's precise location.
4. Device Features SUDOKING Does Not Access
SUDOKING does not request access to:
- precise location,
- contacts,
- microphone,
- camera,
- photographs,
- personal files,
- Bluetooth.
SUDOKING does not collect biometric data.
5. Historical Videos
SUDOKING downloads certain short historical videos from a server outside the application. These videos are hosted by the same provider as SUDOKING’s other server services.
Downloading these videos may require SAS SUDOKING's hosting provider to process technical connection information, including the IP address, depending on the provider's configuration.
The videos are not supplied through YouTube, Vimeo or a similar public platform.
6. Advertising
SUDOKING may display advertisements supplied by third-party advertising providers.
SAS SUDOKING uses the category and content-filtering tools made available by those providers to display advertisements intended for a general audience and consistent with SUDOKING’s age rating. It seeks to exclude sexually explicit, violent, hateful, discriminatory, illegal, shocking or otherwise inappropriate content.
Depending on applicable law, the user’s country, device settings and privacy choices, advertisements may be contextual, non-personalised or personalised. Personalised advertising is displayed only where permitted and, when required, after the user has given consent. Users may refuse or withdraw consent and continue to use SUDOKING with non-personalised advertising. If no valid consent mechanism is available, only non-personalised advertising is displayed.
Users may purchase an optional in-app product that removes advertising. The advertising provider may process technical information such as an advertising identifier, IP address, general device information, language, region, interactions with advertisements and information required for measurement, security and fraud prevention.
SAS SUDOKING does not sell or rent users’ personal data. Because advertisements are supplied by third parties, SAS SUDOKING cannot guarantee that inappropriate content will never be displayed. Users may report any advertisement they consider inappropriate or offensive by contacting: contact@sudoking.com.
7. Analytics Tools
As of the publication date of this Privacy Policy, SUDOKING does not use GameAnalytics, Google Analytics or Unity Analytics.
If SAS SUDOKING adds an analytics or audience measurement tool at a later date, it will update this Privacy Policy before activating the tool where required.
SAS SUDOKING will inform users of the data collected, the purpose of the tool, its provider and any available choices or consent mechanisms.
8. Notifications
As of the publication date of this Privacy Policy, SUDOKING does not send push notifications.
If SAS SUDOKING introduces notifications at a later date, SUDOKING will request the relevant operating system permission and this Privacy Policy will be updated to explain their purpose and the technical data used.
9. Purposes and Legal Bases
SAS SUDOKING processes personal data for the following purposes:
9.1. Provision and Operation of the Game
SAS SUDOKING processes technical identifiers, progress, scores, levels, preferences and purchase data in order to provide SUDOKING, save game data and perform purchases made by the user.
9.2. Hall of Fame
SAS SUDOKING publishes the nickname, avatar, ranking and number of Easter Eggs only when the player voluntarily chooses to participate in the Hall of Fame.
The player may withdraw that choice and request deletion of the information.
9.3. Personalised Advertising
Where SUDOKING uses personalised advertising, SAS SUDOKING relies on the user's prior consent whenever consent is required by applicable law.
Consent may be refused or withdrawn at any time. If valid consent is not obtained, only non-personalised advertising is displayed.
9.4. Security and Maintenance
Certain technical information may be used on the basis of SAS SUDOKING’s legitimate interests in order to:
- secure the servers,
- prevent fraud,
- correct errors,
- ensure the stability and maintenance of the application,
- establish, exercise or defend legal claims.
9.5. Legal Obligations
SAS SUDOKING may retain certain information where required to comply with applicable accounting, tax, judicial or regulatory obligations.
10. Recipients of Personal Data
Personal data may be accessed, within the limits of their respective roles, by:
- authorised personnel of SAS SUDOKING,
- the application developer responsible for maintenance, located in France,
- the server hosting provider,
- Apple for purchases made through the Apple App Store,
- Google for purchases made through Google Play,
- the advertising provider used by SUDOKING,
- administrative or judicial authorities where required by law.
The SUDOKING developer may access the data only where necessary for maintenance, security or incident resolution.
SAS SUDOKING does not disclose personal data to other commercial partners and does not sell or rent users’ personal data.
11. Hosting
SUDOKING’s main game data is hosted in France by a professional hosting provider.
The hosting provider processes the data on behalf of SAS SUDOKING solely for hosting, operating and securing the service.
12. International Transfers
The main game data is hosted in France.
Apple, Google and the advertising provider used by SUDOKING may nevertheless process certain data in other countries, depending on their infrastructure and the user’s country.
Where personal data is transferred outside the European Economic Area, SAS SUDOKING will ensure that the transfer is based on an appropriate legal mechanism, such as an adequacy decision, standard contractual clauses or another safeguard recognised under applicable law.
13. Data Retention
SAS SUDOKING retains personal data for the following periods:
- game and progress data: while the user is using SUDOKING and for a maximum of 24 months after the user’s last activity,
- technical player identifier: for the same period as the progress data associated with it;
- Hall of Fame data: until the player withdraws participation or requests deletion;
- technical and security logs: for no longer than 12 months, unless a longer period is necessary to investigate a security incident or comply with a legal obligation;
- support communications: while the request is being handled and for a maximum of 3 years after the last communication,
- purchase records and documents subject to a legal retention obligation: for the applicable statutory period, which may be up to 10 years.
SAS SUDOKING may delete or anonymise personal data before the end of these periods when it is no longer required.
14. Security
SAS SUDOKING implements reasonable technical and organisational measures intended to protect personal data against:
- unauthorised access,
- loss,
- alteration,
- disclosure,
- destruction
Access to the data is limited to the persons and service providers who require it to operate, secure or maintain the application. As no storage or transmission system can guarantee absolute security, SAS SUDOKING cannot completely eliminate the risk of a security incident.
15. Deletion of Personal Data
Users may ask SAS SUDOKING to delete all data associated with their device identifier by contacting:
The request may include:
- the technical identifier,
- progress,
- levels,
- grids,
- scores,
- playing time,
- lives and hints,
- riddle answers,
- Easter Eggs,
- preferences,
- nickname,
- Hall of Fame avatar and ranking.
In order to prevent the deletion of another player’s data, SAS SUDOKING may request information reasonably necessary to verify that the request relates to the relevant device or profile.
SAS SUDOKING will normally handle requests within a maximum of 30 days. This period may be extended where permitted by law and justified by the complexity of the request.
SAS SUDOKING may retain certain information despite a deletion request where required by law or where necessary to establish, exercise or defend a legal claim.
16. User Right
Depending on the applicable law, users may have the following rights:
- the right to access their personal data,
- the right to correct inaccurate data,
- the right to request deletion,
- the right to restrict certain processing,
- the right to object to certain processing,
- the right to data portability, where applicable,
- the right to withdraw consent at any time,
- the right to issue instructions concerning personal data after death, where permitted under French law.
Users may exercise these rights by contacting SAS SUDOKING at contact@sudoking.com
Users may also lodge a complaint with the competent data protection authority. In France, the competent authority is the Commission Nationale de l’Informatique et des Libertés, or CNIL.
17. California Users
This section applies to the extent that the relevant California privacy laws apply to SAS SUDOKING.
California residents may have the right to:
- know the categories of personal information collected,
- request access to certain personal information,
- request correction,
- request deletion,
- know the categories of recipients,
- opt out of the sale or sharing of personal information for cross-context behavioural advertising,
- not be discriminated against for exercising their privacy rights.
SAS SUDOKING does not sell users’ personal information.
Where California law treats personalised advertising as “sharing” of personal information, users may opt out through the advertising consent or privacy-choice mechanism. If no such mechanism is available, SUDOKING displays non-personalised advertising only.
As a mobile application, SUDOKING does not respond to browser-based “Do Not Track” signals. It respects the privacy choices made available by the operating system and the advertising consent interface.
Requests may be submitted to SAS SUDOKING at contact@sudoking.com.
18. Children
SUDOKING is a general-audience application. It is not specifically designed or marketed to children under the age of 13.
SAS SUDOKING does not seek to knowingly collect personal data from a child under the age of 13.
If a parent or legal guardian believes that a child under the age of 13 has provided personal data, they may contact SAS SUDOKING at contact@sudoking.com to request deletion.
Minor users should not use their real name, contact details or other directly identifying information as a Hall of Fame nickname.
Where local law requires parental authorisation for consent-based processing, users who are not old enough to consent on their own should not enable personalised advertising without the involvement of a parent or legal guardian.
19. Third-Party Services
SUDOKING may rely on services supplied by Apple for the iOS version, Google for the Android version, its hosting provider and the advertising provider used at the time.
These service providers may process certain information in accordance with their own privacy policies and legal obligations.
Users are encouraged to review the privacy information supplied directly by these service providers.
20. Changes to This Privacy Policy
SAS SUDOKING may amend this Privacy Policy, in particular, where:
- a new feature is introduced,
- an analytics tool is integrated,
- the advertising provider changes,
- notifications are introduced,
- the categories of data collected change,
- applicable legal or regulatory requirements change.
The date shown at the beginning of the Privacy Policy will be updated accordingly.
Where SAS SUDOKING makes a material change, information may be displayed within SUDOKING before the revised policy takes effect. SAS SUDOKING will request new consent where required by law.
21. Contact
For any question concerning this Privacy Policy or personal data processed through SUDOKING, contact SAS SUDOKING using the postal address stated in Section 1 or by email at contact@sudoking.com.
22. Updates
Last updated: 18 June 2026
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