Privacy Policy

This page is a structured HTML version of the source privacy policy for TEMM INTL LTD.

Data controller: TEMM INTL LTD, British Virgin Islands, company number 2168780.

This Privacy Policy explains who we are, how we process personal information about you, and how you can exercise your privacy rights. We are TEMM INTL LTD, a company under the laws of the British Virgin Islands, with company number 2168780, having its registered office in the British Virgin Islands. This Privacy Policy applies to personal information that we collect through our games, mobile applications, and other products (“Games”). By using our Services, you agree to be bound by this Privacy Policy and consent to our processing of information as specified herein.

1. Information We Collect From You

Most of the information that we collect about you comes directly from you when you play our Games or interact with third-party ads in our Games or with our ads in other publisher’s Games. The information may relate to the type of device you use, information that helps us identify your device, how you play our Games, and information you voluntarily submit to us.

(a) Information that you provide voluntarily

Certain parts of our Services may ask you to provide personal information voluntarily, for example:

(b) Information that we collect automatically

When you use our Services, we may automatically collect certain information from you and/or your device, such as:

Advertising ID means Apple Identifier for Advertisers (IDFA) on Apple and Google Advertising Identity (GAID) on Android. These are unique identifiers used for personalized advertising. They are non-permanent, non-personal identifiers uniquely associated with your device.

Device identifier / information may include device type, device model, device maker, operating system, language, screen size, processor, or a combination of technical data used for compatibility checks.

(c) Information we obtain from third-party sources

(d) No special categories of information

We do not request or intend to collect special categories of information such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, or data concerning a person’s sex life or sexual orientation.

2. How We Use Your Information

2.1. In General

We use the information we collect about you and your device to deliver services and our Games to you, operate our business, improve our Games, enhance security, carry out analytics and research, promote our services and Games, display third-party advertisements, track advertising performance, prevent fraud, and comply with legal obligations.

2.2. In-App Purchases

Our Games enable in-app purchases. We do not process payments for in-app purchases and do not have access to your credit card information. Payment transactions are completed through the Apple App Store or Google Play account and are subject to their own terms and privacy policies.

3. How We Share Your Information

We share collected information with third parties where necessary for developing and delivering our services, displaying advertisements, conducting analysis and research, and measuring advertising campaign performance.

We may also disclose information in response to law, litigation, requests from authorities, for national security or law enforcement reasons, to enforce our terms and conditions, to protect our operations, users, or user experience, or as part of a reorganization, merger, or sale.

4. Advertising

4.1. In General

We use advertising to fund our Services and keep our Games free or low cost. For EEA-based users, we rely on legitimate interests to show non-personalized ads and request consent before sharing information for personalized advertising.

EEA users: Personalized advertising is shown only if consent is given. Consent may be withdrawn through the Game settings and privacy controls described in the policy.

4.2. In-game advertising

To show in-game ads, we may send your advertising ID and IP address to advertisers or ad networks so that they can select and serve relevant ads. We do not control the exact ads shown, but may blacklist certain categories.

Advertising IDs may be used to:

4.3. View of our ads on third-party services

We also advertise our Games in other apps using ad networks. Advertising IDs may be used for:

4.4. Who can show personalized ads to you?

See the list of current partners and privacy links in the table at the end of this document.

4.5. How can you turn off personalized ads?

iOS: Open Settings → Privacy → Advertising, then enable “Limit ad tracking” or reset the advertising ID.

Android: Open Settings → Google → Ads, then enable “Opt out of Ads Personalisation” or reset the advertising ID.

5. Cookies

Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. You can instruct your browser to refuse all cookies or indicate when a cookie is being sent.

6. Children’s Privacy

Our Service does not address anyone under the age of 16. We do not knowingly collect personally identifiable information from children under 16. If we learn that we have collected such information without parental consent, we will take steps to remove it.

7. Your Rights

If you are an EEA-based user, you may have rights including the right to withdraw consent, access your data, correct it, delete it, restrict processing, data portability, object to processing, and lodge complaints with a supervisory authority.

Requests may be sent to: solitaire.words.support@gmail.com

8. General

We process information lawfully under applicable EEA data protection laws, have appointed a data protection officer, retain information as needed to provide services, and may transfer information outside the EEA with appropriate safeguards.

9. Legal Bases

The legal bases we rely upon include:

10. Security

We implement appropriate technical and organizational measures to protect confidentiality, security, and integrity of collected information, and to prevent unauthorized access and misuse. No security measure is perfect or impenetrable.

11. International Transfer

Your personal information may be transferred to and processed in countries other than your country of residence. Where required, we use appropriate safeguards such as the European Commission’s Standard Contractual Clauses and transfers to certified providers.

12. Retention

We store your information as long as needed to provide services and, in any event, no later than five (5) years after your interaction with all of our Games has ceased, unless a longer retention period is required by law.

13. Information for Californian Consumers

This section supplements the rest of the Privacy Policy for consumers residing in California under the California Consumer Privacy Act (CCPA).

13.1. Categories of personal information collected, disclosed or sold

We have collected categories including identifiers, commercial information, internet information, and geolocation data.

13.2. Sources of personal information

We collect personal information directly and indirectly from you, and from third parties working with us in connection with the Services and Games.

13.3. Sharing and disclosure for business purposes

We may disclose personal information to third parties under written agreements requiring confidentiality and limiting use to business purposes.

13.4. Sale of personal information

Under the CCPA, “sale” may include making personal information available for valuable consideration, including certain ad-related uses. You have the right to opt out of such sale.

13.5. Purposes for use

We may use personal information for operational business purposes, commercial purposes, compliance with law, and defense of rights.

13.6. California privacy rights and how to exercise them

California requests may be submitted by email to: solitaire.words.support@gmail.com

14. Data Deletion Request

You may request deletion of your personal information by sending an email to solitaire.words.support@gmail.com.

15. Changes to Our Privacy Policy

We may update this Privacy Policy from time to time to protect users, provide current information, and respond to legal and technical changes.

16. Contact Us

If you have questions or concerns about this Privacy Policy, contact us:

For information collected under this Privacy Policy, the data controller is TEMM INTL LTD, a company under the laws of the British Virgin Islands, with company number 2168780, having its registered office in the British Virgin Islands.

Third Party Service Providers

Category Name of third party service provider Privacy Policy
Analytics providersChar Software, Inc. d/b/a Localyticshttps://www.localytics.com/privacy-policy/
TrackingAdjust GmbHhttps://www.adjust.com/terms/privacy-policy
https://www.adjust.com/product/gdpr
Advertising partnersAarkihttps://corp.aarki.com/privacy
Advertising partnersAd4Game (Tap Champs)https://ad4game.com/terms/
Advertising partnersAdAction Interactive LLChttps://www.adaction.com/privacy-policy
Advertising partnersAdColony, Inc.https://www.adcolony.com/privacy-policy/
Advertising partnersAdGate Media LLC.https://adgatemedia.com/pp.php
Advertising partnersAdjoe GmbHhttps://adjoe.io/privacy/
Advertising partnersAppGrowth Inc.https://www.appgrowth.com/home/privacy-policy/
Advertising partnersApple Inc. (Apple Search Ads)https://searchads.apple.com/privacy/
Advertising partnersAppLifthttps://mediaelements.com/technology-privacy-notice
Advertising partnersAppLike GmbHhttps://www.applike.info/privacy/
Advertising partnersAppLovin Corporationhttps://www.applovin.com/privacy/
Advertising partnersBlind Ferret Entertainment Inc.https://blindferret.com/privacy-policy/
Advertising partnersChartboost, Inc.https://answers.chartboost.com/en-us/articles/115001489623
Advertising partnersExmox GmbHhttps://exmox.com/privacy-policy/
Advertising partnersFacebook, Inc. (FB Analytics, FB Ads, FB Audience network)https://web.facebook.com/about/privacy/update?ref=old_policy
Advertising partnersFyber Grouphttps://www.fyber.com/legal/privacy-policy/
Advertising partnersGMO SmaAD (GMO TECH, Inc)https://gmo.tech/appendix/
Advertising partnersGoogle LLC (Google Ads)https://policies.google.com/privacy?hl=en
Advertising partnersGoogle LLC (Google AdSense)https://policies.google.com/privacy?hl=en
Advertising partnersGoogle LLC (AdMob)https://support.google.com/admob/answer/6128543?hl=e
https://support.google.com/admob/answer/7665968
Advertising partnersHuawei Technologies Co. Ltdhttps://www.huawei.com/en/privacy-policy
Advertising partnersIronSource Ltd.https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/
Advertising partnersMistplay Inc.https://www.mistplay.com/legal/privacy
Advertising partnersMobvista International Technology Limitedhttps://www.mobvista.com/en/privacy/
Advertising partnersMoloco, Inc.https://www.molocoads.com/en/privacy-policy
Advertising partnersMoPubhttps://www.mopub.com/en/legal/privacy
Advertising partnersMyTargethttps://legal.my.com/us/mytarget/privacy/
Advertising partnersOfferTorohttps://www.offertoro.com/privacy-policy
Advertising partnersPanglehttps://www.pangleglobal.com/privacy
Advertising partnersProdege LLChttps://www.prodege.com/privacy-policy/
Advertising partnersRTB House (LLC "RTB House")https://www.rtbhouse.com/rtbhouse-paperflite-privacy-policy/
Advertising partnersSky Flaghttp://admin.skyflag.jp/report/index.php?a=common/affiliate/RulesBuyer&nocache=1628605573628
Advertising partnersSmaatohttps://www.smaato.com/publisher-policies/
Advertising partnersSnap Inc.https://www.snap.com/en-US/privacy/privacy-policy/
Advertising partnersSociarohttps://sociaro.ai/privacy-policy
Advertising partnersTapjoy, Inc.https://www.tapjoy.com/legal/#privacy-policy
Advertising partnersTikTokhttps://ads.tiktok.com/i18n/official/policy/privacy?
Advertising partnersTwitter, Inc. (Twitter Audience Platform)https://twitter.com/en/privacy#update
Advertising partnersUnity Technologies Finland OY (Unity Ads)https://unity3d.com/legal/privacy-policy
Advertising partnersVungle Inc.http://vungle.com/privacy/
Advertising partnersYANDEX LLChttps://yandex.ru/legal/confidential/?lang=en
Other third-party service providersUnity Technologies (Unity platform)https://unity3d.com/legal/privacy-policy