Effective date: 22.06.2026

 

This Privacy Policy explains how **Divisors - Math Game** ("the App") collects, uses, and shares information. The App is developed and operated by Giovanni Santini ("we," "us," or "our").

 

Contact: info@giovannisantini.com

 

Developer address: Jiangnan Jingxiu 22-1401, Kunshan City, China

 

By using the App, you acknowledge that information may be collected and used as described in this Privacy Policy.

 

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## 1. Information We Collect

 

We do not collect information such as your name, email address, phone number, contacts, photos, messages, or precise GPS location unless you explicitly provide such information to us, for example by contacting us for support.

 

However, upon user agreement, the App may collect or allow third-party service providers to collect the following types of information:

 

### Gameplay and App Usage Data

 

We may collect anonymized in-game events and app usage data, such as:

 

- tutorial progress;

- level start and completion events;

- gameplay actions;

- rewards earned or claimed;

- ad views, ad completions, and ad interactions;

- purchase-related events;

- session activity;

- app settings and feature usage.

 

We use this information to understand how the App is used, improve gameplay, fix issues, balance the game, measure performance, and prevent abuse.

 

The user can choose whether the App gathers those data or not. If the user disagrees, the App will not track those data.

 

### Device and Technical Data

 

The App and third-party services may collect technical information, such as:

 

- device model;

- operating system version;

- app version;

- language;

- country or approximate region;

- device identifiers, such as IDFV;

- advertising identifier, such as IDFA, where permitted by the user and iOS settings;

- diagnostic and performance data.

 

### Advertising Data

 

The App displays advertisements through LevelPlay / ironSource and advertising partners. These services may collect advertising-related data, such as:

 

- ad impressions;

- ad clicks;

- rewarded ad completions;

- ad placement information;

- advertising identifiers, where permitted;

- device and technical information;

- performance data related to ad delivery.

 

On iOS, tracking for personalized advertising is subject to Apple's App Tracking Transparency permission and the user's device settings.

 

### Approximate Location

 

We do not collect precise GPS location and the App does not request iOS Location Services permission. Some third-party services may infer approximate location, such as country or region, from technical information such as IP address. This may be used for analytics, fraud prevention, legal compliance, or advertising availability.

 

### Purchases

 

If the App offers in-app purchases, purchases are processed by Apple through the App Store. We do not receive or store your full payment card information. We may receive or store limited purchase-related information, such as transaction status, product purchased, purchase validation status, and whether a purchase should unlock in-game content or remove ads.

 

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## 2. How We Use Information

 

We use the information described above to:

 

- provide and operate the App;

- save or restore game progress and purchases, where applicable;

- show advertisements;

- reward users for completed rewarded ads;

- measure ad performance;

- understand how users interact with the App;

- improve gameplay, difficulty, balancing, and user experience;

- detect, prevent, and fix crashes or technical issues;

- prevent fraud, abuse, or unauthorized manipulation of purchases or rewards;

- comply with legal obligations.

 

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## 3. Third-Party Services

 

The App may use third-party services that collect and process information according to their own privacy policies and technical settings. These services may include:

 

- **LevelPlay / ironSource**, for ad mediation and advertising — [Privacy Policy] https://www.is.com/privacy-policy/;

- **Firebase**, for app infrastructure, analytics, diagnostics, cloud features, or related services — [Privacy Policy] https://firebase.google.com/support/privacy;

- **Google Analytics for Firebase**, for app usage analytics and user engagement measurement — [Privacy Policy] https://policies.google.com/privacy;

- **Apple App Store**, for in-app purchases and payment processing — [Privacy Policy] https://www.apple.com/legal/privacy/;

- **Apple Game Center**, if Game Center features are enabled — [Privacy Policy] https://www.apple.com/legal/privacy/.

 

These third-party services may process information independently from us. Their data collection may depend on the SDKs included in the App, user consent, device settings, and the features enabled in the App.

 

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## 4. Advertising and App Tracking Transparency

 

The App may show ads. Some ads may be personalized if the user gives permission through Apple's App Tracking Transparency framework.

 

If you allow tracking, advertising partners may use identifiers such as the IDFA and other advertising-related data to provide, measure, and improve ads. If you do not allow tracking, the App may still show ads, but they may be less personalized.

 

We and our advertising partners may still use information that does not require tracking permission, such as contextual information, aggregated ad performance data, or privacy-preserving attribution methods where available.

 

You can change tracking permissions at any time in your iOS settings.

 

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## 5. Legal Bases for Processing for Users in the EEA, UK, or Switzerland

 

If you are located in the European Economic Area, the United Kingdom, or Switzerland, we process personal data under the following legal bases, where applicable:

 

- **Performance of a contract:** to provide the App, gameplay features, purchases, rewards, and app functionality.

- **Legitimate interests:** to improve the App, analyze usage, fix technical issues, prevent fraud, maintain security, and understand app performance. Where we rely on legitimate interests, you have the right to object to such processing at any time by contacting us at info@giovannisantini.com. We will assess your request and cease processing unless we have compelling legitimate grounds that override your interests, rights, and freedoms.

- **Consent:** for personalized advertising, tracking, and access to advertising identifiers where required.

- **Legal obligation:** where processing is necessary to comply with applicable laws, tax rules, accounting requirements, or valid legal requests.

 

You may withdraw consent where processing is based on consent. Withdrawal of consent does not affect processing that occurred before the withdrawal.

 

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## 6. GDPR / European Privacy Rights

 

If you are located in the European Economic Area, the United Kingdom, or Switzerland, you may have rights regarding your personal data, including the right to:

 

- access your personal data;

- correct inaccurate personal data;

- request deletion of your personal data;

- restrict or object to certain processing;

- request data portability, where applicable;

- withdraw consent where processing is based on consent;

- lodge a complaint with your national data protection authority.

 

To exercise these rights, contact us at: info@giovannisantini.com

 

We will respond to your request within 30 days of receipt. In complex or multiple cases, this period may be extended by a further two months, in which case we will notify you.

 

We may need to verify your request before responding. Some requests may be limited where data is anonymous, aggregated, technically inaccessible to us, needed for security, needed to complete transactions, or required to be retained by law.

 

As we are based outside the EEA, there is no single EU lead supervisory authority for our processing activities. You may lodge a complaint with the data protection authority of your country of residence or habitual establishment within the EEA or UK.

 

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## 7. California Privacy Rights / CCPA and CPRA

 

If you are a California resident, you may have certain rights under California privacy laws, including the right to:

 

- know what categories of personal information are collected, used, disclosed, sold, or shared;

- request access to personal information;

- request deletion of personal information;

- request correction of inaccurate personal information;

- opt out of the sale or sharing of personal information, where applicable;

- limit the use of sensitive personal information, where applicable;

- not be discriminated against for exercising your privacy rights.

 

We do not sell personal information for money. However, some advertising practices may be considered "sharing" under California law if advertising partners use information for cross-context behavioral advertising.

 

You can limit tracking through iOS privacy settings, including Apple's App Tracking Transparency controls.

 

To make a California privacy request, contact us at: info@giovannisantini.com

 

In accordance with the California Online Privacy Protection Act (CalOPPA), this Privacy Policy is made available from the App Store listing and/or within the App. The App does not respond to browser "Do Not Track" signals. You can control app tracking and advertising permissions through your iOS privacy settings.

 

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## 8. Children's Privacy

 

The App is not directed to children under 13, or the applicable age of digital consent in your country, whichever is higher. We do not knowingly collect personal information from children.

 

If you believe that a child has provided personal information through the App, contact us at info@giovannisantini.com, and we will take appropriate steps to delete the information where required.

 

If the App is later made available to children or configured as child-directed, we will update this Privacy Policy and the App's data practices accordingly.

 

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## 9. Data Retention

 

We retain information only as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the App, maintain records, analyze performance, prevent fraud, resolve disputes, comply with legal obligations, and enforce our agreements.

 

As a general guideline, we retain:

 

- gameplay and app usage data for up to 24 months from collection;

- purchase-related records for up to 7 years, where required for tax or accounting purposes;

- support correspondence for up to 3 years after the last interaction.

 

Analytics, advertising, and diagnostic data may be retained by third-party services according to their own retention policies, which may differ from our retention periods above.

 

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## 10. International Transfers

 

The App may be available internationally. Information may be processed in countries other than the country where you live, including China, the United States, and other countries where our third-party service providers operate. These countries may have data protection laws different from those in your jurisdiction. Where required, we rely on appropriate legal mechanisms for international transfers.

 

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## 11. Security

 

We use reasonable technical and organizational measures to protect information. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

 

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## 12. Changes to This Privacy Policy

 

We may update this Privacy Policy from time to time. When we update it, we will change the effective date above. Your continued use of the App after an update means that you acknowledge the updated Privacy Policy.

 

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## 13. Contact Us

 

For questions, privacy requests, or concerns, contact us at: info@giovannisantini.com

 

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## Version History

 

| Version | Date | Description |

|---------|------|-------------|

| 1.0 | 22.06.2026 | Initial release |