English / 日本語
Effective date: October 28, 2026
This policy explains how Jinseo Kim (SEO Labs) (“we”) handles personal data in the iOS app Solo Hold’em: Offline AI Poker (the “App”).
1. Who we are
- Controller: Jinseo Kim (SEO Labs). Contact: kjsrelease@gmail.com
2. Data that stays on your device
The App has no accounts or sign-in and does not ask for your name, email or phone number. The following is stored only on your device and never sent to us or anyone else:
| Data | Why |
|---|---|
| Birth year and month | To check that you are 18 or older (first launch) |
| Age range from Apple (only if Apple shares it for users in regions with age laws) | Same age check |
| Agreement to the terms, tutorial progress, virtual chip balance, daily-reward and refill records, game stats, settings, the hand in progress | To run the game |
Deleting the App deletes this data.
3. Google and Apple services
We use two Google services and one Apple service. The Google services collect data automatically when the App runs. How Google uses this information: https://policies.google.com/technologies/partner-sites
3.1 Google Analytics for Firebase (app statistics)
- Data: app instance ID, coarse location derived from a masked IP address, device and app information (model, OS version, app version, language), app usage (screens, sessions, first open).
- Game events we define: tutorial completion, table joined (room tier, buy-in chips), hand completed (room tier, result, pot chips), out of chips / bankrupt (room tier), free refill, rewarded-ad offer / reward / failure (where, reason), interstitial shown (where), daily reward claimed (day number), tracking-permission result (status). They do not include your birth year/month or age range.
- When: Analytics starts only after the first-launch consent step. If you are in a region where consent is required (for example the UK), Analytics is off until you consent and stays off if you refuse.
3.2 Google AdMob (ads)
- Data: IP address, device and advertising identifiers, ad interactions, diagnostic information.
- Purposes: showing ads (personalised only with your consent and, on iOS, tracking permission), measuring ads, preventing fraud.
3.3 App Store version check (Apple)
Once a day, when your device is online, the App asks Apple’s App Store for the App’s latest version number so it can tell you when an update is available. The request includes only the App’s identifier, but like any internet request it reveals your IP address to Apple. We do not receive or store this information. Apple’s Privacy Policy: https://www.apple.com/legal/privacy/
4. Legal bases (UK GDPR)
| Processing | Basis |
|---|---|
| Device-only data (section 2) | Not sent to us; needed to provide the App you asked for |
| Analytics (section 3.1) | Consent (Google consent form) |
| Personalised ads (section 3.2) | Consent (Google consent form) and, on iOS, your tracking permission |
| Non-personalised ads, fraud prevention | Legitimate interests |
| App Store version check (section 3.3) | Legitimate interests (letting you know about updates) |
The UK consent form is shown by Google’s User Messaging Platform. You can change your choice any time in Settings > Privacy settings (shown when it applies).
5. Sharing and international transfers
Data in sections 3.1 and 3.2 is processed by Google LLC (USA) and its affiliates under their terms. Google LLC is certified under the UK Extension to the EU-U.S. Data Privacy Framework.
6. Retention
- Device data: until you delete the App.
- Analytics: 2 months (Google Analytics data retention setting).
- AdMob: per Google’s policies.
7. Your rights
Under UK GDPR you can ask for access, correction, deletion, restriction, objection and portability, and withdraw consent at any time (Settings > Privacy settings in the App; iOS Settings > Privacy & Security > Tracking). Because the App has no accounts, the Google data is linked only to a random app instance ID; we may be unable to identify your data without that ID. You can complain to the UK Information Commissioner’s Office (ico.org.uk).
8. Children
The App is for adults 18+. It blocks users who declare an age under 18, or whom Apple reports as under 18. We do not knowingly collect data from children.
9. Security
We do not run servers that store personal data. Data sent to Google is encrypted in transit (TLS).
10. Changes and contact
We will post changes here and on the App Store page. Contact: kjsrelease@gmail.com
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