Privacy Policy

Effective Date: May 1, 2025

Arkay Group LLC ("we," "our," or "us") respects your privacy and is committed to protecting your personal information while using our mobile application Moji ("App") and/or Maku ("App") and/or Ascendry ("App") and/or My75 ("App"). This Privacy Policy explains what information we collect, how we use it, how we share it, and your rights regarding your data, including specific rights under the General Data Protection Regulation (GDPR) for users in the European Economic Area (EEA).

1. Information We Collect

We collect the following types of information when you use the App:

a. Personal Information

• Device Identifiers: We may collect your iOS Identifier for Advertisers (IDFA) or similar device identifiers for serving personalized advertisements through Google Mobile Ads. This is considered personal data under GDPR and is only collected with your explicit consent.
• Payment Information: For in-app purchases, payment transactions are processed securely by Apple (via App Store). We do not store payment details but may store a record of your purchase status (e.g., AdsDisabled flag) locally on your device.

b. Non-Personal Information

• Usage Information: We collect anonymized data about how you interact with the App, such as gameplay statistics (e.g., number of rounds played, hints used, stars earned) stored locally in PlayerPrefs. This data is not linked to your identity unless combined with personal data like IDFA.
• Device Information: We may collect non-identifying device details, such as operating system version, device type, and IP address, for technical purposes (e.g., ad delivery, app performance).

c. No Account Information

• The Apps do not require you to create an account or provide personal details like name or email address.

2. How We Use Your Information

We use the information we collect for the following purposes:

• To Provide Services:
  • Manage in-app purchases and store preferences like AdsDisabled, HintsRemaining, or TotalStars locally on your device.
  • Deliver advertisements (personalized or non-personalized, based on your consent).
• To Improve the App: Analyze anonymized usage patterns (e.g., rounds played) to optimize gameplay and performance.
• To Communicate: Send technical notifications through the App Store.
• To Comply with Legal Obligations: Maintain records of purchases or ad consent as required by law, including GDPR.

3. Legal Basis for Processing (GDPR)

For EEA users, we process personal data under the following legal bases:

• Consent: We process IDFA for personalized ads only with your explicit consent, obtained via a consent popup (using Google’s User Messaging Platform).
• Contract: We process purchase data to fulfill the contract for providing in-app purchase features.
• Legitimate Interests: We process anonymized usage data and device information to improve the App, provided it does not override your rights.

You may withdraw consent or object to processing at any time (see Section 7).

4. Data Sharing

We do not sell your personal data. We may share data in the following cases:

• Third-Party Service Providers:
  • Google Mobile Ads: Processes IDFA and device information to serve ads. Google’s privacy policy applies (https://policies.google.com/privacy).
  • Apple (App Store): Processes payment data for MojiNoAds purchases. Apple’s privacy policy applies (https://www.apple.com/legal/privacy/).
  • These providers are GDPR-compliant and act as data processors under our instructions.
• Legal Compliance: We may disclose data if required by law, to enforce our rights, or to protect the safety of users or the public.
• Anonymized Data: We may share aggregated, non-identifiable data (e.g., gameplay stats) with partners for analytics.

5. Data Retention

• Personal Data:
  • IDFA is retained by Google Mobile Ads as per their policy, unless you withdraw consent.
  • Purchase status (e.g., AdsDisabled) is stored in PlayerPrefs until you delete it via the App’s “Delete My Data” feature or uninstall the App.
• Non-Personal Data: Gameplay data (e.g., HintsRemaining, TotalStars) is stored locally in PlayerPrefs until deleted.
• We retain data only as long as necessary for the purposes outlined or as required by law (e.g., tax records for purchases).

6. Data Security

We use industry-standard security measures to protect your data:

• Local Storage: PlayerPrefs data (e.g., AdsDisabled, HintsRemaining) is stored securely on your device.
• Third-Party Security: Google Mobile Ads and Apple use secure protocols for ad and payment data.
• However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

7. Your Rights (Including GDPR Rights)

Depending on your location, particularly in the EEA under GDPR, you have the following rights:

• Access: Request a copy of your personal data (e.g., IDFA, purchase status).
• Rectification: Correct inaccurate data.
• Erasure: Delete your data using the “Delete My Data” button in the App, which clears all PlayerPrefs (e.g., AdsDisabled, HintsRemaining, TotalStars).
• Restriction: Restrict processing of your data (e.g., opt out of personalized ads via consent popup).
• Data Portability: Request your data in a machine-readable format (limited to PlayerPrefs data).
• Object: Object to processing based on legitimate interests (e.g., anonymized analytics).
• Withdraw Consent: Revoke consent for personalized ads at any time via the App’s ad consent settings.
• Lodge a Complaint: Contact a data protection authority in your country (e.g., ICO in the UK, CNIL in France).

To exercise these rights, use the “Delete My Data” feature in the App or contact us (see Section 10). We will respond within one month, as required by GDPR.

8. Children’s Privacy

The App is not intended for children under 13. We do not knowingly collect personal data from children. If you believe we have collected data from a child under 13, please contact us, and we will delete it immediately.

9. International Data Transfers (GDPR)

For EEA users, personal data (e.g., IDFA) may be transferred to third parties (e.g., Google, Apple) outside the EEA. We ensure these transfers comply with GDPR through:

• Standard Contractual Clauses (SCCs): Used by Google and Apple to protect data.
• Adequacy Decisions: Where applicable, based on EU agreements.
• You can request details of these safeguards by contacting us.

10. Updates to This Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. Updates will be posted in the App, and the “Effective Date” will be revised. For significant changes affecting EEA users, we will notify you via the App or obtain renewed consent, as required by GDPR.

11. Contact Us

If you have questions about this Privacy Policy, your data, or your GDPR rights, please contact us:

• Email: Ssupport@arkaygroup.io
• In-App: Use the “Help & Feedback” feature linked in the App.

For GDPR purposes, Arkay Group LLC is the data controller responsible for your personal data.