LumosAI Tech Limited ("we," "us," or "our") is the operator of Solitaire Journey: Classic Card (package identifier: com.cooky.Solitaire.Journey) (the "App" or "Service"). This page explains what we gather, why we gather it, what we do with it, and the choices you have. We take privacy and data protection seriously. If you use our Service, you're trusting us with your info—and we don't take that lightly. Got questions? Reach us at: jack@lumos-net.com I. Data We Gather 1. How You Use the Service We collect info about your activity in the App—what you click, which screens you open, what features you use, what apps are installed on your device, what permissions you grant, and other routine stuff. We also record identifiers (like Firebase device IDs), device models, network status, SIM country, system language, and cookies related to ads. This data is only shared with our trusted analytics providers: Firebase, Facebook Analytics, and our internal system (ECS). We use it solely to make the product better and the ads more effective. Nobody else gets this data. 2. Device Details To make your experience better, we collect technical details about your device and network, like: SDK/API versions, platform, timestamps, app identifiers Device manufacturer, OS version, language, time zone, network status App release status on Google Play We keep data connected to your Android ID to track how ads work inside the app. This is treated as personal data. 3. Ad & Analytics Data from Third Parties Third-party SDKs inside the Service may access: Google Advertising ID Demographic data (like IP address) Anti-fraud metrics (like click fraud) Device specs (type, country, etc.) Ad and analytics data Advertisers may store or read cookies. How these SDKs use your data is covered by their own privacy policies. Our partners include Google AdMob, Facebook Audience Network, AppLovin, and others (see Section VI for links). 4. Android Advertising ID Your Android advertising ID is used for personalized ads and analytics. It doesn't contain sensitive identifiers (like MAC address or IMEI) and isn't connected to your personal identity. 5. Other Info Sometimes you may choose to give us info like your email, feedback, or survey answers. II. What We Do With Your Data We may request access to certain personal data stored on your device to improve your experience. Everything we collect is used only for analytics and product improvement. III. Sharing Your Data We may share personal data with outside partners (like advertisers and analytics companies) to customize ads, measure engagement, and make the Service better. How those partners handle your data is covered by their own privacy policies. IV. Why We Process Your Data (Legal Basis) We process your data based on: Contractual obligations (to deliver the Service) Legal compliance (to meet regulations) Legitimate interests (to keep the Service secure) Your consent (for things like ad cookies) Providing necessary data means you get full access to everything we offer. V. Your Rights Want to exercise your rights? Email us at jack@lumos-net.com. We may limit rights if requests: Violate legal requirements Infringe on others' privacy Harm our rights Are repetitive or excessive 1. Withdraw Consent You can withdraw your consent for data processing anytime. This won't affect processing that was already lawful before you withdrew it. 2. Access & Rectification Ask for a free copy of your data or request corrections. We might restrict access to protect other people's rights. 3. Erasure (Right to Be Forgotten) Ask us to delete your data if it's no longer needed, you've withdrawn consent, or you've objected to processing. 4. Restrict Processing Restrict processing if: The data's accuracy is disputed Processing is unlawful but you don't want it erased The data is needed for legal claims 5. Object to Processing Object to processing based on consent, contract, or legitimate interests. We might keep processing if it's needed for legal defense. 6. Data Portability Ask for your data in a machine-readable format so you can move it elsewhere, where possible. 7. Notifying Third Parties We'll inform third parties about your correction/deletion requests unless it's impractical. 8. Automated Decision-Making You can reject decisions made solely by automated processing (like profiling). 9. Lodge a Complaint Contact us with concerns or file a complaint with your local data authority. VI. Third-Party Partner Policies Links to our partners' policies: Google AdMob & Firebase: https://policies.google.com/privacy Facebook Audience Network & Analytics: https://www.facebook.com/about/privacy AppLovin: https://www.applovin.com/privacy/ Adjust: https://www.adjust.com/terms/privacy-policy/ Vungle: https://vungle.com/privacy/ Fyber: https://www.fyber.com/services-privacy-statement/ Unity: https://unity3d.com/legal/privacy-policy TikTok: https://ads.tiktok.com/i18n/official/policy/privacy ironSource: https://www.is.com/privacy-policy/ Pangle: https://www.pangleglobal.com/privacy VII. EU & UK Residents You can: Confirm/access your data Correct/delete data Restrict processing Get data in portable format Send requests to jack@lumos-net.com. We respond within one month. VIII. California Residents (CCPA) 1. Request Information Ask for details on what we collect, use, and share over the past 12 months. 2. Request Deletion Ask us to delete your data, except where we need to keep it for legal, security, or service reasons. 3. How to Submit Send verifiable requests via email. You get two per year. 4. Response Time We respond within 45 days (can extend to 90). No fees unless requests are excessive. 5. No Discrimination We won't penalize you for exercising your CCPA rights. 6. Minors The Service isn't for users under 13. Data from kids under 13 is deleted right away. IX. Children's Privacy We don't knowingly collect data from users under 13. Contact us if you think we accidentally did. X. Policy Updates Changes take effect when posted. If you keep using the Service, that means you accept the changes. XI. Contact Us Email jack@lumos-net.com