Privacy Policy — SumiSplash

This Privacy Policy describes how Strategia-X ("we," "us," or "our") collects, uses, discloses, and protects information in connection with the SumiSplash mobile application ("SumiSplash," "the App," or "the Service"). SumiSplash is a digital drawing application for manga, anime, and illustration art, available on Android devices via the Google Play Store.

We are committed to protecting your privacy. Please read this Privacy Policy carefully to understand our practices regarding your information.

Developer: Strategia-X
Package Name: com.sumisplash.app
Contact: [email protected]

Here is a summary of our key privacy practices:

• Personal Data Collection: We do not collect personal information such as your name, email address, phone number, or physical address.
• User Accounts: SumiSplash does not require account creation, login, or authentication of any kind.
• Your Artwork: All drawings, projects, and creative content remain entirely on your device. We have no access to your artwork.
• Cloud Sync: There is no cloud storage or synchronization. All data is stored locally.
• Analytics: We do not use Firebase Analytics, Google Analytics, or any analytics platform.
• Crash Reporting: We do not use Crashlytics or any crash reporting service.
• Advertising: We use Google AdMob to display ads. AdMob may collect device-level data for ad personalization. See Section 6.
• Purchases: Subscriptions are processed entirely by Google Play. We do not handle or store payment information. See Section 7.
• Data Sharing: We do not sell, rent, or trade your personal information to third parties.

2.1 Information Stored Locally on Your Device

SumiSplash stores the following data locally on your device only. This data never leaves your device and is never transmitted to our servers or any third party:

• Project Data — Project names, canvas dimensions, creation/modification timestamps, layer count. Used for managing your art projects in the Gallery.
• Layer Data — Layer names, stacking order, visibility, opacity, blend mode settings, bitmap image files (PNG). Used for rendering and editing your multi-layer drawings.
• Thumbnails — Small preview images of your projects for Gallery display.
• App Preferences — Settings such as last brush color, brush size, left-handed mode, dark mode, onboarding completion status.
• Unlock State — Records of which premium brushes, stickers, or template packs you have unlocked via rewarded ads.
• Challenge Streak — Count of consecutive daily challenges completed.
• Ad Pacing Data — Timestamp of last interstitial ad shown, number of saves since last ad. Used to ensure ads are not shown too frequently.

We have no ability to access, read, or retrieve this locally stored data.

2.2 Information Collected by Third-Party Services

SumiSplash integrates two third-party services that may collect certain device-level information:

Google AdMob (Advertising)

Google AdMob, our advertising partner, may automatically collect:

• Device Information: Device model, manufacturer, operating system version, screen size, language setting.
• Advertising ID: Google Advertising ID (a resettable device identifier used for ad targeting).
• Ad Interaction Data: Impressions, clicks, views, and engagement with advertisements.
• Network Information: IP address (which may be used to infer approximate geographic location at the city or region level).
• App Usage Data: App identifier, app version, SDK version.

This data is collected and processed by Google under Google's Privacy Policy.

Google Play Billing (Subscriptions)

When you purchase a SumiSplash Pro subscription, Google Play processes the transaction. Google may collect:

• Purchase Information: Transaction ID, purchase token, product purchased, purchase state.
• Google Account Information: The Google account used for the purchase (managed by Google).
• Payment Information: Credit card or payment method details (handled entirely by Google — we never see or store payment information).

This data is collected and processed by Google under Google Play's Terms of Service and Google's Privacy Policy.

2.3 Information Collected Automatically

SumiSplash itself does not implement any automatic data collection, tracking, logging, or telemetry. We do not use Firebase Analytics, Google Analytics, Facebook SDK, Crashlytics, custom event tracking, fingerprinting, or device profiling. The only automatic data collection occurs through the third-party AdMob SDK as described above.

SumiSplash does not collect, access, or transmit any of the following:

• Names, email addresses, phone numbers, mailing addresses, or any personally identifiable information (PII)
• Passwords, usernames, or account credentials (no accounts exist)
• Your artwork, drawings, projects, or creative content
• Photographs, contacts, calendar data, or other personal files on your device
• Precise geolocation (GPS coordinates)
• Biometric data (fingerprints, facial recognition, voice)
• Health or fitness data
• Financial or banking information (Google Play handles all payments)
• Social media profiles or social graph data
• Browsing history or search queries
• SMS, call logs, or communication content
• Sensor data (accelerometer, gyroscope) beyond touch input for drawing
• Audio or video recordings (timelapse recordings are stored locally and never uploaded)

4.1 Locally Stored Information

Data stored on your device is used solely to:

• Save and load your art projects, layers, and settings
• Display project thumbnails in the Gallery
• Remember your preferences (brush settings, left-handed mode, etc.)
• Track your rewarded ad unlock state so unlocked items remain accessible
• Pace interstitial advertisements to avoid excessive ad frequency
• Track your daily challenge streak for motivational purposes

4.2 Third-Party Collected Information

• AdMob data is used by Google to serve relevant advertisements and measure ad performance. We receive aggregated, anonymous reporting (e.g., total ad impressions, total revenue) but cannot identify individual users.
• Google Play Billing data is used to validate your subscription status and provide Pro features.

5.1 Third-Party Services We Use

• Google AdMob (Google LLC) — Display banner, interstitial, and rewarded video advertisements. Collects device ID, ad interactions, IP address, device info. See Google Privacy Policy.
• Google Play Billing (Google LLC) — Process Pro subscription purchases. Collects purchase data, Google account info. See Google Privacy Policy.
• Google User Messaging Platform (UMP) (Google LLC) — Manage advertising consent (GDPR compliance). Collects consent preferences. See Google Privacy Policy.

5.2 We Do Not Sell Your Data

We do not sell, rent, lease, or trade your personal information to any third party. This applies under all privacy frameworks including CCPA/CPRA, GDPR, and all applicable state and international privacy laws.

5.3 We Do Not Share Data With Data Brokers

We do not provide data to data brokers, advertising networks (beyond AdMob integration), or data aggregation services.

5.4 When We May Disclose Information

We may disclose information only in the following limited circumstances:

• Legal Compliance: If required by law, regulation, legal process, or governmental request.
• Safety: To protect the rights, safety, or property of our users or the public.
• Business Transfer: In connection with a merger, acquisition, or sale of assets (users would be notified).

Since we do not collect personal information, the practical scope of any such disclosure is extremely limited.

6.1 How Ads Work in SumiSplash

SumiSplash displays advertisements to free-tier users through Google AdMob:

• Banner Ads — Displayed at the bottom of certain screens. Shown automatically; removed with Pro subscription.
• Interstitial Ads — Full-screen ads shown periodically (after every 2 project saves, minimum 60 seconds apart). Shown automatically; removed with Pro subscription.
• Rewarded Video Ads — Optional full-screen ads that grant premium unlocks. Entirely user-initiated — you choose when to watch.

6.2 Ad Personalization

Google AdMob may use device identifiers and other data to personalize the ads you see. You can control ad personalization through:

1. Google Ads Settings: Visit adssettings.google.com to manage your ad preferences.
2. Advertising ID Reset: Reset your Advertising ID in your device's Settings > Google > Ads.
3. Opt Out of Personalized Ads: Toggle "Opt out of Ads Personalization" in your device's Google settings.
4. Consent Dialog: In the European Economic Area (EEA) and UK, a consent dialog is shown via Google's User Messaging Platform, allowing you to accept or reject personalized advertising.

6.3 Ad-Free Experience

Subscribe to SumiSplash Pro to remove all banner and interstitial advertisements. Rewarded ads (which are optional and user-initiated) may still be available to unlock additional content.

7.1 Subscription Products

SumiSplash offers Pro subscriptions:

• SumiSplash Pro Monthly — Recurring monthly. All 12 brushes, 10 layers, all templates, all stickers, ad-free.
• SumiSplash Pro Annual — Recurring annually. Same as monthly (best value).

7.2 Payment Processing

All payment processing is handled by Google Play. We do not collect, view, or store credit card numbers, bank account information, or other payment details. We do not process payments directly — all transactions go through Google Play's secure payment infrastructure. We do not have access to your Google account credentials.

7.3 Refunds

Refund requests for subscriptions should be directed to Google Play Support, as all billing is managed by Google.

8.1 Local Storage Only

All user-generated content (projects, layers, thumbnails, preferences) is stored locally on your device in the app's private storage directory, protected by Android's application sandbox — other apps cannot access SumiSplash's files, and SumiSplash cannot access other apps' files.

8.2 No Cloud Storage

SumiSplash does not transmit your artwork or project data to any server, cloud service, or remote storage. Your creative work exists only on your device.

8.3 Backup & Restore

SumiSplash has opted out of Android's automatic cloud backup (android:allowBackup="false"). Your data is not backed up to Google Drive. You can manually export projects as .sumi backup files for personal safekeeping or device transfer.

8.4 Network Security

All network communication uses HTTPS only (TLS encryption). Cleartext HTTP traffic is disabled. Network communication is limited to Google AdMob (ad serving) and Google Play Billing (subscription management).

8.5 Security Measures

• Application Sandbox: All data is stored in Android's protected app-specific directory.
• No External Storage: We do not write sensitive data to shared/external storage.
• FileProvider: Shared files (for export/sharing) use Android's secure FileProvider mechanism.
• HTTPS Only: Network security configuration enforces encrypted connections.
• ProGuard/R8 Obfuscation: Release builds use code obfuscation to protect against reverse engineering.

9.1 Locally Stored Data

Your projects, preferences, and unlock states persist on your device until:

• You delete a project within the app (permanently removes that project's layers, thumbnail, and metadata).
• You clear app data in your device's settings (removes all app data including preferences and unlocks).
• You uninstall the app (removes all locally stored data).

We do not have a server-side retention policy because we do not store your data on any server.

9.2 Third-Party Data Retention

• Google AdMob: Retains data according to Google's data retention policies.
• Google Play Billing: Retains purchase records according to Google's policies and applicable tax/financial regulations.

10.1 Legal Basis for Processing

• Local data storage (projects, preferences): Legitimate Interest — necessary for the app to function.
• Serving personalized ads (via AdMob): Consent — obtained via Google's User Messaging Platform consent dialog.
• Serving non-personalized ads: Legitimate Interest — supporting the free app model.
• Processing subscription purchases: Contract — necessary to fulfill the subscription agreement.

10.2 Your GDPR Rights

If you are located in the European Economic Area (EEA), the United Kingdom (UK), or Switzerland, you have the following rights:

• Right of Access — Request a copy of personal data we hold about you. Note: we hold no personal data on our servers.
• Right to Rectification — Request correction of inaccurate personal data. Not applicable as we do not store personal data.
• Right to Erasure ("Right to be Forgotten") — Delete projects within the app, or clear app data in device settings. For AdMob data, manage through Google's controls.
• Right to Restriction of Processing — Disable ad personalization in your Google settings, or subscribe to Pro for an ad-free experience.
• Right to Data Portability — Export projects as .sumi backup files from within the app.
• Right to Object — Opt out of personalized ads via Google Ads Settings.
• Right to Withdraw Consent — Change your consent preferences in the app's consent dialog or device settings.
• Right to Lodge a Complaint — Contact your local Data Protection Authority.

10.3 Data Controller

Strategia-X acts as the data controller for locally processed data. Google LLC acts as an independent data controller for data collected through AdMob and Google Play Billing.

For GDPR inquiries, contact us at: [email protected]

11.1 Categories of Personal Information

Under the CCPA/CPRA, "personal information" includes identifiers, commercial information, internet activity, geolocation data, and inferences. SumiSplash itself does not collect personal information as defined by the CCPA. However, our third-party advertising partner (Google AdMob) may collect certain categories:

• A. Identifiers (name, address, email, etc.) — Not collected.
• B. Personal information under Cal. Civ. Code § 1798.80 — Not collected.
• C. Protected classification characteristics — Not collected.
• D. Commercial information — Limited. Google Play records subscription purchase history.
• E. Biometric information — Not collected.
• F. Internet or network activity — Limited. AdMob collects ad interaction data and IP address.
• G. Geolocation data — Limited. AdMob may infer approximate location from IP address (city/region level only; no GPS).
• H. Sensory data — Not collected.
• I. Professional or employment information — Not collected.
• J. Non-public education information — Not collected.
• K. Inferences — Limited. AdMob may make inferences for ad targeting.
• L. Sensitive personal information — Not collected.

11.2 Your CCPA/CPRA Rights

• Right to Know — Request disclosure of what personal information is collected, used, and shared.
• Right to Delete — Request deletion of personal information.
• Right to Opt-Out of Sale/Sharing — Opt out of the "sale" or "sharing" of personal information for cross-context behavioral advertising.
• Right to Correct — Request correction of inaccurate personal information.
• Right to Limit Use of Sensitive Personal Information — Limit the use and disclosure of sensitive personal information.
• Right to Non-Discrimination — Not be discriminated against for exercising your privacy rights.

11.3 Sale and Sharing of Personal Information

We do not "sell" personal information as defined under the CCPA/CPRA. Regarding "sharing" for cross-context behavioral advertising: Google AdMob may use device identifiers and ad interaction data for personalized advertising, which may constitute "sharing" under the CPRA. You may opt out by:

1. Disabling personalized ads in your device's Google Ads settings.
2. Resetting your Advertising ID.
3. Subscribing to SumiSplash Pro (which removes AdMob ads entirely).

11.4 How to Exercise Your Rights

To exercise your CCPA/CPRA rights, email [email protected] with subject line "CCPA Privacy Request." Include your request type (Know, Delete, Opt-Out, Correct) and sufficient information for us to verify your identity. We will respond within 45 days as required by the CCPA/CPRA.

If you are a resident of Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), Texas (TDPSA), Oregon (OCPA), Montana (MCDPA), or any other U.S. state with consumer privacy legislation, you may have rights including the right to access, correct, delete, and port personal data, and to opt out of targeted advertising, sale of personal data, and profiling.

To exercise your rights, contact [email protected]. If we decline a privacy rights request, you have the right to appeal by sending your appeal to the same address with "Privacy Appeal" in the subject line.

We take children's privacy seriously. SumiSplash is intended for a general audience. We do not knowingly collect personal information from children under the age of 13 (or the applicable age in your jurisdiction).

In compliance with the Children's Online Privacy Protection Act (COPPA):

• We do not knowingly collect, use, or disclose personal information from children under 13.
• We do not require any personal information to use the app.
• The app does not have user accounts, profiles, or social features.
• If we become aware that we have inadvertently collected personal information from a child under 13, we will promptly delete such information.

We recommend that parents and guardians review this Privacy Policy, monitor their children's use of mobile applications, and manage ad personalization settings on their child's device through Google's parental controls and Family Link.

If you believe we have collected information from a child under 13, please contact us immediately at [email protected].

SumiSplash does not transfer your data to our servers (we have no servers processing user data). However, Google AdMob and Google Play Billing are operated by Google LLC, headquartered in the United States. Google may process data in the United States or other countries where Google operates. Google's international data transfers are governed by Standard Contractual Clauses (SCCs) and other mechanisms as described in Google's data transfer frameworks.

SumiSplash does not track users across third-party websites or services and therefore does not respond to Do Not Track (DNT) signals. However, Google AdMob may respond to DNT and related settings — please refer to Google's privacy controls.

Managing Your Data

• Delete a project: Long-press the project in the Gallery > Delete.
• Delete all data: Go to device Settings > Apps > SumiSplash > Storage > Clear Data.
• Export your data: Export projects as .sumi backup files from the Gallery.
• Uninstall the app: Uninstalling removes all locally stored data.

Managing Advertisements

• Remove all ads: Subscribe to SumiSplash Pro.
• Opt out of personalized ads: Device Settings > Google > Ads > Opt out of Ads Personalization.
• Reset Advertising ID: Device Settings > Google > Ads > Reset Advertising ID.
• Manage ad preferences: Visit adssettings.google.com.

Managing Subscriptions

• View subscription: Google Play Store > Menu > Subscriptions.
• Cancel subscription: Google Play Store > Subscriptions > SumiSplash Pro > Cancel.
• Request refund: Google Play Store > Order History > Request Refund (subject to Google's refund policy).

Permissions

SumiSplash requests the following Android permissions:

• Internet — Serving ads, processing subscriptions.
• Network State — Checking connectivity before network operations.
• Billing — Google Play subscription management.
• Vibrate — Haptic feedback for tool selection and actions.

SumiSplash does not request permissions for camera, microphone, contacts, location, phone, SMS, or calendar.

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, the "Last Updated" date at the top of this policy will be revised. For significant changes, we will provide a prominent notice within the app (such as a dialog or banner on the Gallery screen). Your continued use of SumiSplash after changes are posted constitutes your acceptance of the updated Privacy Policy.

If you have questions, concerns, or requests related to this Privacy Policy or our data practices, please contact us:

Strategia-X
Privacy & Legal Email: [email protected]
General Support: [email protected]
Website: www.strategia-x.com

Response Times:

• General privacy inquiries — within 30 days.
• CCPA/CPRA requests — within 45 days (extendable by 45 days with notice).
• GDPR requests — within 30 days (extendable by 60 days with notice for complex requests).
• Children's privacy concerns — within 48 hours.

Summary: SumiSplash is designed with privacy at its core. Your artwork stays on your device. We don't collect personal information, don't have user accounts, don't use analytics, and don't have servers storing your data. The only data processing by third parties occurs through Google AdMob (advertising) and Google Play Billing (subscriptions), both governed by Google's privacy policies and subject to your control through device settings.