Privacy Policy

1. Introduction & Scope

Welcome to Klondike Solitaire (the "Application" or "Game"), developed and operated by Brylle Seraspe / BDST PH ("Developer", "Company", "We", "Us", or "Our").

This Privacy Policy explains how we collect, use, process, disclose, and safeguard your information when you download, install, access, or play Klondike Solitaire on Android and iOS devices. It also details your privacy rights under applicable data protection laws, including:

• The Google Play Developer Program Policies (including the User Data Policy, Families Policy, and Data Safety requirements);
• United States Federal and State Privacy Laws, including the Children's Online Privacy Protection Act (COPPA), the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), and applicable state privacy statutes; and
• Republic of the Philippines Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations (IRR), overseen by the National Privacy Commission (NPC).

By downloading, accessing, or playing the Application, you acknowledge that you have read and understood the data collection and processing practices described in this Privacy Policy. If you do not agree with this policy, please do not use the Application.

2. Interpretation & Definitions

Interpretation

Words with capitalized initials have meanings defined under the following conditions. The definitions carry the same meaning whether appearing in singular or plural form.

Definitions

• "Application" (or "App", "Game") refers to Klondike Solitaire, the software application developed by Brylle Seraspe / BDST PH.
• "Company" (or "We", "Us", "Our", "Developer") refers to Brylle Seraspe / BDST PH, based in the Philippines.
• "Personal Data" (or "Personal Information") means any information that relates to an identified or identifiable natural person, as defined under the Philippine Data Privacy Act of 2012, California Consumer Privacy Act, and other applicable laws.
• "Usage Data" refers to data collected automatically from the use of the Application (e.g., duration of gameplay, move counts, feature usage, diagnostic logs).
• "Device" means any internet-connected device used to access the Game, including smartphones and tablets running Android or iOS.
• "Service Provider" refers to third-party companies or service vendors employed to facilitate our Application, deliver advertisements, provide analytics, or diagnose software defects on our behalf.
• "You" (or "User", "Player") means the individual accessing or using the Application.

3. Information We Collect

We collect information in two general ways: (1) information collected automatically through device sensors and software development kits (SDKs), and (2) information you provide to us directly.

A. Information Collected Automatically

When you install and open Klondike Solitaire, certain technical and gameplay information is automatically recorded to ensure the game functions properly:

• Device & Hardware Identifiers: Operating system version (Android / iOS), device manufacturer, device model, screen resolution, locale/language settings, network connectivity status (Wi-Fi/Cellular via connectivity_plus), battery state, and wake-lock states.
• Pseudonymous Service Identifiers:
  • Firebase Installation ID (FID): Generated by Firebase to manage remote configurations, error telemetry, and push notifications.
  • Mobile Advertising ID: Google Advertising ID (GAID) on Android and Identifier for Advertisers (IDFA) on iOS (only accessed on iOS if you grant permission via Apple's App Tracking Transparency framework).
• Gameplay & Progress Metrics: Current game deals, win/loss history, scores, move count, hints and undo actions used, difficulty setting, draw mode (Draw 1 or Draw 3), completion time, and custom card or background selections. This data is primarily stored locally on your device via SQLite / local storage.
• Diagnostic & Crash Information: Stack traces, memory state, crash logs, and timestamps collected via Firebase Crashlytics to detect and fix stability issues.
• Aggregate Analytics: Session starts, duration, screens viewed, and engagement events tracked via Google Analytics for Firebase.

B. Information You Provide Directly to Us

• Customer Support Correspondence: If you contact us directly via email (e.g., at brylleseraspe@gmail.com), we receive your email address, name, and any screenshots or details you include in your message. We use this information solely to respond to and resolve your inquiry.
• In-App Purchases / Subscriptions: If you purchase in-app products (such as "Remove Ads" or virtual subscriptions), transactions are processed directly by the Google Play Store (Google LLC) or the Apple App Store (Apple Inc.). We do not collect, process, or store credit card numbers, bank details, or billing addresses. We only receive a transaction receipt/token confirming purchase status to unlock your feature.

4. Information We Do Not Collect

To ensure high privacy protection, our Application explicitly does NOT collect, request, or store:

• Precise GPS location data;
• Biometric data (fingerprints, facial recognition);
• Contacts, phone books, or call logs;
• Microphone audio, camera feeds, photos, or media files;
• Government-issued identification numbers (e.g., SSN, PhilSys Card, Driver's License);
• User registration credentials or mandatory account passwords (no login is required to play).

5. Third-Party Services & SDK Integrations

Klondike Solitaire integrates industry-standard third-party SDKs provided by Google. These third parties collect and process information subject to their independent privacy policies:

To learn how Google manages data across partner apps, please review Google's official guide: How Google uses information from sites or apps that use our services.

6. How We Use Collected Information

We use the data collected for legitimate business and gameplay purposes:

• Provide and Maintain the Game: Loading deals, verifying solvable boards, saving your personal best scores, statistics, and customized theme settings.
• Advertising & Monetization: Serving banner, native, and rewarded video ads that allow the game to be offered free of charge. Rewarded ads provide optional in-game hints or undos when chosen by the player.
• App Optimization & Diagnostics: Investigating crashes, diagnosing performance bottlenecks, and optimizing memory usage across diverse Android and iOS hardware.
• Customer Support: Answering player inquiries, addressing bug reports, and handling feedback submitted by email.
• Security & Fraud Prevention: Preventing automated tampering, abuse of ad units, and ensuring game integrity.
• Legal Compliance: Complying with regulatory obligations, Google Play developer requirements, and law enforcement requests where mandated by law.

7. Legal Bases for Processing

Under the Philippine Data Privacy Act of 2012 (RA 10173) and international privacy frameworks, we process personal information under the following legal bases:

• Consent: Where required by law (e.g., personalized advertising via the User Messaging Platform or Apple App Tracking Transparency), we process your data based on your freely given, specific, and informed consent. You can revoke consent at any time.
• Performance of a Contract: Processing necessary to provide you with the Game and its features in accordance with our End-User License Agreement.
• Legitimate Interests: Processing necessary to analyze crash logs, ensure application security, maintain server stability, and improve overall player satisfaction, provided these interests do not override your fundamental privacy rights.
• Compliance with Legal Obligations: Processing necessary to fulfill legal and statutory duties under applicable domestic and international regulations.

8. Advertising & Tracking Consent Management

Our game displays advertisements via Google AdMob. Depending on your jurisdiction and device settings, you can control how your information is used for advertising:

• Google User Messaging Platform (UMP): In regions requiring consent (such as the EEA/UK and applicable US state frameworks), an in-app consent dialog is presented allowing you to accept or manage personalized advertising choices.
• Apple App Tracking Transparency (iOS): On iOS devices, the app requests explicit permission before accessing the IDFA for tracking across apps. You may decline at any time.
• Resetting or Opting Out on Android: You can opt out of personalized ads or delete your Google Advertising ID at any time by navigating on your Android device to:
  Settings > Google > Ads > Delete advertising ID (or Reset advertising ID).
• Resetting or Opting Out on iOS: You can manage tracking permissions at any time on your Apple device via:
  Settings > Privacy & Security > Tracking > Klondike Solitaire (toggle off).

9. Sharing & Disclosure of Information

We do not sell, rent, or trade your personal information to third parties. We share information only under the following limited circumstances:

• Authorized Service Providers: We share data with Google LLC (AdMob, Firebase) strictly to deliver advertising, process crash analytics, and provide cloud synchronization as described in Section 5.
• Legal Requirements: We may disclose information if required to do so by applicable law, lawful warrant, subpoena, court order, or official request from government authorities (including the Philippine National Privacy Commission or law enforcement agencies).
• Protection of Rights: We may disclose information when necessary to enforce our End-User License Agreement, protect against fraud or technical vulnerabilities, or defend the legal rights and safety of our users, developers, or the public.
• Business Transfers: In the event of a merger, acquisition, restructuring, or sale of assets, user data may be transferred as part of that transaction, subject to the recipient honoring the commitments in this Privacy Policy.

10. Data Retention & Deletion Rights (Google Play Policy)

In compliance with Google Play's User Data & Data Safety policies, we maintain clear standards for data retention and user deletion requests:

Retention Periods:

• Local Gameplay Data: Scores, preferences, and game history stored on your device remain until you clear the application data or uninstall the Game.
• Crash & Diagnostic Logs: Firebase Crashlytics retains crash logs for up to 90 days, after which they are permanently purged.
• Analytics Data: Google Analytics for Firebase data is retained according to standard Google retention periods (2 to 14 months) before automatic aggregation or deletion.
• Customer Support Inquiries: Emails sent to customer support are retained for up to 12 months for record-keeping and issue resolution, after which they are deleted.

How to Request Data Deletion:

11. Your Rights Under Philippine Law (Data Privacy Act of 2012 / RA 10173)

If you are a resident of the Philippines, your personal data is protected under the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and issuances of the National Privacy Commission (NPC). Under the DPA, you have the following rights as a Data Subject:

• Right to be Informed: You have the right to know whether your personal data is being processed, the sources, categories, purposes, and recipients of such data. This Privacy Policy serves as our notice to you.
• Right to Access: You have the right to obtain reasonable confirmation and access to your personal data in our possession.
• Right to Object: You have the right to object to the processing of your personal data, including processing for direct marketing, automated profiling, or based on legitimate interest.
• Right to Erasure or Blocking: You have the right to suspend, withdraw, or order the blocking, removal, or destruction of your personal data from our systems if it is incomplete, outdated, unlawfully obtained, or no longer necessary for the declared purpose.
• Right to Rectification: You have the right to dispute and correct any inaccuracies in your personal data.
• Right to Data Portability: Where data is processed by electronic means, you have the right to obtain an electronic copy in a structured, commonly used format.
• Right to Damages: You have the right to be indemnified for damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of personal data.
• Right to File a Complaint: If you believe your rights under the Data Privacy Act have been violated or your requests have not been addressed satisfactorily, you have the right to lodge a formal complaint with the National Privacy Commission:
  National Privacy Commission (NPC)
  Website: https://privacy.gov.ph
  Email: info@privacy.gov.ph / complaints@privacy.gov.ph
  Address: 5th Floor Delegation Building, PICC Complex, Vicente Sotto Avenue, Pasay City, Metro Manila 1307, Philippines.

12. Your Rights Under United States Laws (CCPA/CPRA & State Laws)

If you reside in the United States, including California, Virginia, Colorado, Connecticut, Utah, or other states with comprehensive consumer privacy laws, this section outlines your specific rights:

A. Notice at Collection & Categories of Information Collected

In the past 12 months, we have collected the following statutory categories of personal information:

• Identifiers: Pseudonymous device IDs, Google Advertising ID (GAID), Apple IDFA (where permitted), Firebase Installation IDs, IP address.
• Internet or Network Activity: Gameplay events, time spent, moves count, buttons clicked, and crash diagnostics.
• Commercial Information: Records of in-app purchase tokens (e.g. "Remove Ads") processed via Google Play / Apple App Store.

B. Notice Regarding "Sale" or "Sharing" of Personal Information

You have the absolute right to opt out of the "sale" or "sharing" of your personal information for targeted advertising. You can exercise this right at any time by:

• Declining tracking through the in-app consent banner (UMP) or iOS App Tracking Transparency prompt;
• Disabling personalized ads or deleting your Advertising ID in your Android or iOS device settings (as outlined in Section 8);
• Contacting us directly by email at brylleseraspe@gmail.com.

C. Your California & US State Consumer Rights

• Right to Know / Access: Request disclosure of the categories and specific pieces of personal information collected about you, the categories of sources, and third parties with whom it was shared.
• Right to Delete: Request deletion of your personal information, subject to statutory exceptions.
• Right to Correct: Request correction of inaccurate personal information.
• Right to Non-Discrimination: We will not discriminate against you (e.g., denying game access or altering gameplay quality) for exercising any of your privacy rights.

To exercise any of these rights, please email us at brylleseraspe@gmail.com with the subject "US Privacy Request". We will respond within 45 days.

13. Children's Privacy (COPPA & Google Play Families Policy)

Protecting children's privacy is critically important to us:

• General Audience Rating: Klondike Solitaire is intended for a general audience. It is not directed to children under 13 years of age in the United States, nor to individuals under 18 years of age in the Philippines without verifiable parental consent.
• No Intentional Collection: We do not knowingly collect, solicit, or maintain personally identifiable information from children under 13 (or under 16/18 where local jurisdiction mandates).
• Parental Removal: If you are a parent or legal guardian and discover that your child has provided us with personal information without your consent, please contact us immediately at brylleseraspe@gmail.com. Upon notification, we will promptly verify and delete the corresponding information from our records.
• Google Play Families Policy Compliance: In accordance with Google Play developer requirements, our ad configurations adhere to age-appropriate standards and do not display ads targeted at children.

14. Data Security Measures

We employ appropriate technical, administrative, and physical safeguards designed to protect your information against unauthorized access, destruction, loss, alteration, or disclosure:

• All network communications between the Game and Google/Firebase servers are encrypted using modern Transport Layer Security (HTTPS / TLS 1.2+);
• Data stored in Google Cloud and Firebase is protected by Google's multi-layered security infrastructure;
• Local data is stored within sandboxed application storage on your device.

While we strive to use commercially reasonable standards to protect your data, please note that no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

15. International Data Transfers

The Application operates globally, and your information may be transferred to, stored, and processed in countries outside of your home country, including the United States, where Google LLC maintains server facilities. These countries may have data protection laws different from your home jurisdiction. By using the Application, you consent to the transfer of data to facilities governed by standard contractual clauses and robust data protection practices.

16. Changes to this Privacy Policy

We reserve the right to update or modify this Privacy Policy at our discretion to reflect changes in our operational practices, new game features, or updated legal and regulatory standards.

When modifications occur, we will update the "Last Updated" date at the top of this page. For material updates, we may provide prominent in-app notification or display an updated consent dialog before the revised policy takes effect. We encourage you to review this page periodically to stay informed about our data handling practices.

17. Contact Us & Data Protection Officer

If you have questions, concerns, comments, or wish to exercise your privacy rights under the Philippine Data Privacy Act, US Privacy Laws, or Google Play policies, please contact our designated privacy contact: