The short version
- Sugaku gives your phone an anonymous account on our server: a random number and a made-up player name. You never give us an email address, a phone number or a password.
- The server keeps what the game needs: your games and scores, Stars, Stickers and power-ups, your weekly Class, spins, achievements and Season pass, and your answer to "are you 18 or older?" (never your date of birth).
- Sticker packs are bought through the App Store or Google Play. We see the store's receipt, never your payment details.
- Ads appear only when you choose to watch one for a reward (for example to double a prize or to keep playing), through Google AdMob. You choose whether ads may be suited to you; players under 18 only get ads that are not.
- Usage statistics, which do not identify you, can be switched off in Settings. We do not sell your data.
- You can delete your account and everything it holds from inside the app: Account → Delete my account and data.
1. Who is responsible
Sugaku is developed and published by Martin Pisacic, an individual developer established in the European Union, acting as the data controller for the personal data described here.
Questions, requests, and complaints: contact@sugaku.win.
This policy covers the Sugaku mobile app and its server. This web page itself is a static document: it sets no cookies, runs no analytics, and loads nothing from third-party servers.
2. Your account and what the server keeps
The first time you open Sugaku, it creates an account for your phone on our server. The account is anonymous: the server gives it a random number, a secret key the app keeps in your phone's secure storage (we store only a fingerprint of it), and a made-up player name such as "Curious Owl", which you can change.
| What the server keeps | Why |
|---|---|
| The account's random number, its name, and when it was made | To know your games and rewards are yours, and to show your name in your Class and the Daily Drop ranking. |
| If you make a transfer code: a scrambled form of it (never the code itself), and when you made it | So you can move your account to a new phone. |
| Your answer to "are you 18 or older?", whether you or your phone's app store gave it, and when it changed | Buying Sticker packs is only for players 18 or older, and players under 18 only get ads that are not suited to them. The date of birth you enter never leaves your phone. |
| Each game: when it was played, whether it was the Daily Drop, its score, the power-ups you brought, and summary numbers such as drops, level and tens made | To pay Stars, rank you in your Class and the Daily Drop, and count achievements. |
| Stars, Stickers, power-ups, paper themes, and a history of what came and went | So what you earn and buy is kept safely and counted once. |
| Your weekly Class, spins, attendance, achievements and Season pass | To run those parts of the game. |
The server runs on Cloudflare. As with any internet request, Cloudflare processes connection data such as your IP address to deliver it and to protect the service from abuse. We do not keep IP addresses in our database.
3. What other players see
Your player name and scores are visible to other players in your weekly Class and in the Daily Drop ranking. The made-up name you start with says nothing about you; if you choose your own, please pick a nickname rather than your real name or anything else you would not want shown.
4. Data kept on your device
Some things are kept only in the app's private storage on your phone, which is removed when you uninstall the app: your lifetime statistics and best score, your Daily Drop record and streak, your Sound and Haptics settings, your ad choice, the paper you picked, a copy of your wallet and Class for when you are offline, and games waiting to be sent when you played without a connection.
If you use Use my App Store age or Use my Google Play age, your phone asks Apple or Google for your age range. Only whether you are 18 or older is sent to our server, and the answer is used only to decide whether you may buy Sticker packs; it is never used for ads or statistics.
5. Purchases
Sticker packs are bought through the App Store or Google Play, which handle the payment under their own terms. Our server receives the store's signed receipt and keeps: the store, its transaction number, the pack, the date, and any refund the store reports (a refunded pack's Stickers are taken back). We never see your card or payment details.
6. Ads
Sugaku shows an ad only when you choose to watch one for a reward: to double a spin prize or a game's Stars, to keep playing after Game over, to keep your attendance streak, or for a free power-up, Stickers or spin. Ads come from Google AdMob. Before the first ad you choose between ads suited to you and general ads; both work the same. In the EEA and the UK, Google's consent form follows, and on iPhone Apple's tracking question appears only if you chose suited ads. Players who said they are under 18 only get ads that are not suited to them.
When an ad is shown, Google processes data such as your device's advertising identifier (if allowed), IP address and device information, as described in Google's ad policies. When you finish watching, Google tells our server which account the reward is for, what it is for (the spin, game or reward), and a transaction number; we keep those to pay each reward once. You can change your ad choice in Settings › Ad choices.
7. Usage statistics
If statistics are on (the default), the app sends Aptabase short events such as "a game ended after 9 minutes at level 6", "the app was used today", "a spin was spun on the Gold spinner" or "a pack of 500 Stickers was bought". Each event carries the app version, the operating system and its version, the device model and the device language. Numbers are rounded into ranges, the start date is given only as a week, and no event carries your account, your player name or a device identifier. Statistics are never combined with what our server keeps.
To receive the events, Aptabase sees your phone's IP address. It uses the address only in memory: to work out a country and region, and to make a pseudonymous ID that changes every day, so that one day's events can be counted as one player without linking them to the next day or to other apps. The IP address itself is never stored.
Turn them off in Settings › Share usage stats: the app sends one last event saying so, deletes its record, and sends nothing more. No crash reports are collected.
8. What we never collect
- No email address, phone number, password, or real name (unless you type one as your player name).
- No date of birth: only whether you are 18 or older leaves your phone.
- No precise or coarse device location.
- No contacts, photos, camera, microphone, calendar, or files.
- No payment card or bank details.
- No crash reports, and no usage statistics that identify you or your device.
- No sale of personal data, and no sharing of it for cross-context behavioural advertising.
9. Device permissions
Sugaku needs network access and vibration (for haptic feedback). On iPhone, Apple's tracking question appears only if you chose ads suited to you. The store's age and purchases each show the system's own sheet when you start them.
10. Legal bases
Under the GDPR, we rely on the following legal bases:
- Contract (Art. 6(1)(b)) for your account, your games, wallet, Class, rewards and purchases: they are the game you asked to play.
- Legal obligation (Art. 6(1)(c)) for the age answer that keeps buying for adults only.
- Consent (Art. 6(1)(a)) for ads suited to you, for Apple's tracking, for signing in with Apple or Google, and for asking your app store for your age. You can withdraw it at any time.
- Legitimate interests (Art. 6(1)(f)) for checking that reported scores are possible, limiting how many requests one account or address can send, and protecting the service from abuse (including keeping a deleted account's store transaction numbers so a purchase cannot be credited twice), and for usage statistics, which you can switch off in Settings.
11. Age
Sugaku is not directed at children. On first launch the app asks whether you are in the EU and your age, and will not continue unless you are at least 16 in the EU, or at least 13 elsewhere. Before the first purchase it asks for your date of birth and keeps only whether you are 18 or older; buying is off for anyone under 18.
If you are a parent or guardian and believe a child has used the app, contact us at contact@sugaku.win and we will delete the account.
12. Service providers and international transfers
- Cloudflare, Inc. hosts our server and its database, and serves this page.
- Apple and Google handle purchases and the store's age range.
- Google (AdMob) serves the ads you choose to watch and its consent form.
- Aptabase (Technov Solutions SRL, Romania) receives the usage statistics and processes and stores them only in the European Union.
Cloudflare, Apple and Google may process data outside the European Economic Area, including in the United States. Those transfers rely on the European Commission's Standard Contractual Clauses and, where applicable, the EU–US Data Privacy Framework. We do not disclose your data to anyone else except where the law requires it.
13. How long data is kept
- Your account and its data: until you delete the account (see Deleting your data).
- Records of Sticker packs bought: until you delete the account. After that, only each purchase's store transaction number is kept, linked to nothing, so the same purchase cannot be credited twice.
- On your device: until you delete your account, clear the app's storage, or uninstall the app.
- Usage statistics: kept by Aptabase for up to 5 years. Because they cannot be linked to you, they cannot be found and deleted on request; switching statistics off stops new ones.
14. Deleting your data
- Delete your account and data: open Account (or Settings → Ads & privacy) in the app and choose Delete my account and data. After you confirm, our server deletes at once and for good: your games, your Stars, Stickers, power-ups and papers with their history, your places in weekly Classes, spins, attendance, achievements, Season pass progress, and your answer to the age question and its changes. Your name is removed, and the account's key on your phone stops working. The app then also deletes what it kept on your phone (statistics, the Daily Drop record, your best score) and starts again as a new player. This cannot be undone.
- What is kept: your purchases and refunds are deleted too. Only each purchase's store and transaction number stay, linked to no account, so the same purchase cannot be paid out twice. Apple and Google keep their own records of what you bought. Finished weekly Class tables keep your place, shown as "Deleted player", so other players' results stay correct. Settings on your phone (sound, haptics, ad choices, usage statistics) stay until you uninstall the app.
- Remove everything held locally: uninstall the app, which deletes its private storage.
If you no longer have the app and want your account deleted, email us your player name from contact@sugaku.win and we will delete it.
15. Your rights under the GDPR
If you are in the EEA, the UK, or Switzerland, you have the right to request access to your personal data, to have it corrected or erased, to restrict or object to its processing, to receive it in a portable form, and to withdraw consent at any time.
Most of these are in your hands in the app: you can see your games, wallet and purchase history, change your name and your age answer, turn ads suited to you and statistics off, and delete your account.
For anything else, write to contact@sugaku.win with your player name. We will respond within one month. You also have the right to lodge a complaint with your national data protection supervisory authority.
16. California residents
The categories of personal information Sugaku handles are: identifiers (the account's random number and a player name), commercial information (Sticker packs bought), and internet or other electronic network activity information (games played in the app, and, through Google AdMob, ads you chose to watch). They are used to run the game, and ad data as described in section 6.
We do not sell personal information. We do not share it for cross-context behavioural advertising for anyone under 18, and for others only if they chose ads suited to them. You have the right to know, delete, and correct your information, and not to be discriminated against for exercising those rights: use the in-app controls above or write to contact@sugaku.win.
17. Security
All traffic between the app and our server uses HTTPS. The app's secret key lives in your phone's secure storage, and the server keeps only a fingerprint of it, so a copy of our database cannot be used to sign in. There are no passwords. No system is perfectly secure, but the personal data involved is deliberately kept as small as the game allows.
18. Changes to this policy
If this policy changes, the revised version is published on this page with a new effective date. Material changes to what is collected will be reflected in the app before they take effect, and where the law requires it we will ask for your consent again.
19. Contact
Martin Pisacic
Sugaku
contact@sugaku.win
Last updated 14 November 2026 · Applies to Sugaku 3.0.0 and later.