Terms of Service — SumiSplash

These Terms of Service ("Terms," "Agreement") constitute a legally binding agreement between you ("you," "your," "User") and Strategia-X ("we," "us," "our," "Company") governing your access to and use of the SumiSplash mobile application ("SumiSplash," "the App," "the Service"), including all features, content, and services provided through the App.

By downloading, installing, accessing, or using SumiSplash, you agree to be bound by these Terms. If you do not agree to these Terms, do not download, install, or use the App.

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

1.1 Agreement to Terms

By downloading SumiSplash from the Google Play Store, creating a project, drawing on the canvas, purchasing a subscription, or otherwise using any feature of the App, you confirm that you have read, understood, and agree to be bound by these Terms and our Privacy Policy.

1.2 Amendments

We reserve the right to modify these Terms at any time. Changes will be effective when the updated Terms are posted within the App or on our website. If we make material changes, we will notify you through the App (e.g., via a dialog or notice on the Gallery screen). Your continued use of SumiSplash after such changes constitutes acceptance of the updated Terms.

1.3 Additional Terms

Certain features of SumiSplash may be subject to additional terms (e.g., Google Play's terms for in-app purchases). In the event of a conflict between these Terms and any additional terms, the additional terms shall control with respect to the specific feature they govern.

2.1 What SumiSplash Is

SumiSplash is a mobile digital drawing application designed for creating manga, anime, webtoon, and illustration art on Android devices. The App provides:

• A high-performance drawing canvas with multi-touch gesture support
• 12 professional brush types (6 free, 6 Pro): Ink Pen, Cel Shader, Airbrush, Screentone, Watercolor, Eraser, Sparkle, Glow, Splatter, Chalk, Charcoal, and Marker
• Multi-layer editing (up to 5 layers free, 10 with Pro) with blend modes and clipping masks
• Panel layout templates for manga and webtoon creation
• Color picker with curated anime color palettes
• Text, sticker, speech bubble, and action effect tools
• Selection, lasso, liquify, and QuickShape tools
• Symmetry mode and perspective grid guides
• Reference image import
• Timelapse recording with MP4 export
• Project export (PNG, MP4) and backup (.sumi archive files)
• Daily drawing challenges
• Optional Pro subscription for enhanced features

2.2 Local-First Architecture

SumiSplash operates primarily as a local application. All artwork, project data, preferences, and settings are stored on your device. The App does not require an internet connection for core drawing functionality. Network access is used only for advertising (free tier), subscription validation, and rewarded ad unlocks.

2.3 Service Availability

We strive to make SumiSplash available and functional at all times. However, we do not guarantee uninterrupted, error-free, or continuous access to the App. The App may be unavailable due to:

• Maintenance, updates, or upgrades
• Device incompatibility or operating system changes
• Force majeure events
• Issues with third-party services (Google Play, Google AdMob)

3.1 Age Requirements

SumiSplash is intended for a general audience. By using the App, you represent that:

• If you are under the age of 13 (or the applicable minimum age in your jurisdiction, including under 16 in the European Economic Area), you have obtained verifiable parental or guardian consent to use the App.
• If you are between the ages of 13 and 18 (or the age of majority in your jurisdiction), you have reviewed these Terms with a parent or guardian and they agree to be bound by these Terms on your behalf.

3.2 Parental Responsibility

Parents and guardians who permit minors to use SumiSplash are responsible for:

• Supervising the minor's use of the App
• Managing device-level advertising and purchase controls
• Ensuring compliance with these Terms

3.3 Compliance with Laws

You represent that your use of SumiSplash complies with all applicable local, state, national, and international laws and regulations.

4.1 Your Content

"User Content" refers to all artwork, drawings, projects, layers, text, images, and other creative materials you create using SumiSplash.

You retain full ownership of all User Content you create. Strategia-X claims no ownership, license, or rights to your artwork. Your drawings belong entirely to you.

4.2 No Content Upload

SumiSplash does not upload, transmit, or store your User Content on any server. Your artwork exists only on your device and in any backup files (.sumi archives) you manually export. We have no access to, knowledge of, or control over your User Content.

4.3 Responsibility for User Content

You are solely responsible for:

• The content of your artwork and creative materials
• Ensuring your User Content does not infringe on any third party's intellectual property rights, privacy rights, or other legal rights
• Any consequences of sharing, exporting, or distributing your User Content outside of SumiSplash

4.4 Reference Images

When you import reference images into SumiSplash, you represent that you have the right to use those images (e.g., they are your own photos, licensed for your use, or in the public domain). Strategia-X is not responsible for any intellectual property infringement arising from your use of reference images.

4.5 Sharing and Distribution

When you share or export your artwork using SumiSplash's sharing and export features, you acknowledge that:

• The shared content is sent through Android's share intent system to the app you select
• Strategia-X has no control over what happens to your content once it leaves SumiSplash
• You are responsible for ensuring your shared content complies with the receiving platform's terms of service

5.1 License to Use SumiSplash

Subject to your compliance with these Terms, Strategia-X grants you a limited, non-exclusive, non-transferable, revocable, personal license to:

• Download and install SumiSplash on Android devices you own or control
• Use SumiSplash for personal, non-commercial or commercial creative purposes
• Create, save, export, and share artwork using the App's features

5.2 License Restrictions

You may NOT:

• Copy, modify, adapt, translate, reverse engineer, decompile, or disassemble the App or any portion of its code
• Create derivative works based on the App
• Remove, alter, or obscure any copyright, trademark, or other proprietary notices
• Distribute, sublicense, lease, rent, or lend the App to third parties
• Use the App to develop competing products or services
• Circumvent, disable, or interfere with security features, licensing mechanisms, or digital rights management
• Use automated scripts, bots, or scraping tools to interact with the App
• Extract or re-use any assets, icons, stickers, templates, brushes, or other visual elements from the App for use outside of SumiSplash

5.3 Open Source Components

SumiSplash may include open source software components. Such components are licensed under their respective open source licenses, which may grant you additional rights. Nothing in these Terms restricts your rights under applicable open source licenses.

You agree to use SumiSplash in a manner that is:

• Lawful: In compliance with all applicable laws and regulations
• Respectful: Not harmful, threatening, abusive, or harassing to others
• Responsible: Not designed to harm minors or any vulnerable populations
• Honest: Not designed to deceive, defraud, or mislead

7.1 Illegal Content

You agree not to use SumiSplash to create, store, or distribute content that is illegal under applicable law, including but not limited to child sexual abuse material (CSAM), content that exploits minors, or content that incites violence or terrorism.

7.2 Intellectual Property Infringement

You agree not to:

• Create content that infringes upon the intellectual property rights (copyrights, trademarks, patents, trade secrets) of any third party without proper authorization or license
• Trace, copy, or reproduce copyrighted works without the rights holder's permission and claim them as your own

7.3 Harmful Activities

You agree not to:

• Create content intended to harass, bully, intimidate, defame, or threaten specific individuals
• Generate content that constitutes fraud, impersonation, or identity theft
• Use the App in any manner that could damage, disable, overburden, or impair the Service

7.4 Security Violations

You agree not to:

• Attempt to gain unauthorized access to the App, its underlying systems, or third-party services connected to the App
• Introduce malware, viruses, Trojans, worms, or other malicious code
• Interfere with or disrupt the integrity or performance of the App

7.5 Automated Access

You agree not to:

• Use bots, scripts, crawlers, or other automated means to access or interact with the App
• Attempt to extract, mine, or scrape data, assets, or code from the App

Note: Creating artwork that depicts fictional violence, mature themes, or controversial subjects for legitimate artistic expression is not prohibited, provided it complies with applicable law.

8.1 SumiSplash Pro Subscription

SumiSplash offers a "Pro" subscription tier with enhanced features including ad-free experience, all 12 brushes (6 premium brushes), 10 layers per project, all template packs, all sticker packs, and priority access to new features. Subscription products include:

• SumiSplash Pro Monthly — Auto-renewing subscription, billed monthly
• SumiSplash Pro Annual — Auto-renewing subscription, billed annually (best value)

8.2 Pricing

• Subscription prices are displayed in your local currency during the purchase flow in the Google Play Store.
• Prices may vary by region and are subject to change.
• We will provide notice of price changes in accordance with Google Play's policies.
• Any price changes will not affect active subscription periods — changes apply at the next renewal.

8.3 Billing & Payment

• All subscriptions are billed through Google Play.
• Payment is charged to the Google account associated with your Google Play account.
• Strategia-X does not collect, process, or store any payment information directly.
• Billing occurs at the start of each subscription period (monthly or annually).

8.4 Auto-Renewal

• Subscriptions auto-renew at the end of each billing period unless canceled at least 24 hours before the end of the current period.
• You will be charged the then-current subscription price at each renewal.
• Google Play will attempt to charge your payment method on file at the renewal date.

8.5 Cancellation

• You may cancel your subscription at any time through the Google Play Store > Subscriptions menu.
• Cancellation takes effect at the end of the current billing period — you will retain Pro access until then.
• Canceling does not entitle you to a refund for the current billing period.
• After cancellation takes effect, your access will revert to the free tier.

8.6 Refunds

• Refund requests are handled by Google Play in accordance with Google Play's refund policy.
• Strategia-X does not directly process refunds for subscriptions purchased through Google Play.
• For refund requests, contact Google Play Support through the Google Play Store app or website.

8.7 Rewarded Unlocks

• Certain premium content (individual brushes, template packs, stickers) can be unlocked by watching rewarded video advertisements.
• Rewarded unlocks are permanent and stored locally on your device.
• If you clear app data or uninstall the app without backing up, rewarded unlocks may be lost.
• Rewarded unlocks are not transferable between devices.
• We do not guarantee the availability of rewarded ads at all times — availability depends on ad inventory from Google AdMob.

8.8 Free Trial

If a free trial is offered, it will be clearly disclosed before you subscribe. Free trial terms (duration, features included, conversion to paid) will be presented during the subscription flow. You may cancel during the free trial period without being charged.

9.1 Free Tier

SumiSplash is free to download and use with the following limitations:

• Maximum of 5 layers per project
• Access to 6 basic brushes (Ink Pen, Cel Shader, Airbrush, Screentone, Watercolor, Eraser)
• Access to the Starter template pack only
• Access to basic sticker set only
• Advertisements are displayed

9.2 Advertising

The free tier of SumiSplash is supported by advertisements served through Google AdMob:

• Banner ads may appear at the bottom of certain screens.
• Interstitial ads (full-screen) may appear periodically during use (after every 2 project saves, minimum 60 seconds apart).
• Rewarded video ads may be offered as an option to unlock premium content. These are entirely user-initiated — you choose when to watch.

By using the free tier, you consent to the display of advertisements. For information about advertising data practices, see our Privacy Policy.

9.3 Ad-Free Experience

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

10.1 Google Play

SumiSplash is distributed through the Google Play Store. Your download and use of the App is also subject to Google Play's Terms of Service.

10.2 Google AdMob

Advertisement serving is provided by Google AdMob. Ad content is controlled by Google and its advertising partners. Strategia-X does not control, endorse, or guarantee the content of advertisements displayed in the App. AdMob may collect device identifiers, IP addresses, and usage data to serve personalized or non-personalized ads based on your preferences and consent choices. For more information, see Google's Privacy Policy.

10.3 Google Play Billing

In-app purchases and subscriptions are processed through Google Play Billing. Strategia-X is not responsible for billing errors, payment processing failures, or other issues arising from Google Play's billing infrastructure.

10.4 Google User Messaging Platform (UMP)

We use Google's User Messaging Platform to present consent forms to users in jurisdictions that require consent for personalized advertising (e.g., the European Economic Area under GDPR, the United Kingdom under UK GDPR). Your consent preferences are stored locally and respected by our advertising partners.

10.5 Third-Party Links and Content

Advertisements or other content within the App may contain links to third-party websites or services. Strategia-X does not control, endorse, or assume responsibility for any third-party websites, products, or services. Accessing third-party links is at your own risk.

10.6 Sharing Destinations

When you share artwork from SumiSplash, the content is sent to the app you select via Android's share intent system. Strategia-X is not responsible for how third-party apps handle your shared content.

Your privacy is important to us. Our collection, use, and disclosure of information is described in our Privacy Policy, which is incorporated into these Terms by reference.

Key highlights:

• We do not collect personal information (no accounts, no login, no email collection).
• All artwork and project data is stored locally on your device.
• We do not have access to your drawings or creative content.
• We do not use Firebase Analytics, Google Analytics, or any analytics platform.
• We do not use Crashlytics or any crash reporting service.
• Google AdMob may collect device-level data for advertising purposes.
• Google Play handles all payment processing for subscriptions.
• We do not sell, rent, or trade your personal information to third parties.

12.1 Strategia-X's Intellectual Property

SumiSplash and its original content (excluding User Content), features, and functionality are and will remain the exclusive property of Strategia-X. This includes but is not limited to:

• The SumiSplash name, logo, and branding
• App design, user interface, and visual elements
• Brush algorithms and rendering engine
• Template designs and panel layouts
• Sticker artwork and vector assets
• Color palette collections
• Source code, architecture, and technical implementation
• Documentation and marketing materials

These are protected by copyright, trademark, trade secret, and other intellectual property laws.

12.2 Trademarks

"SumiSplash," the SumiSplash logo, and related marks are trademarks of Strategia-X. You may not use these trademarks without our prior written consent, except as reasonably necessary to refer to the App (e.g., "artwork created with SumiSplash").

12.3 Your Intellectual Property

As stated in Section 4, you retain full ownership of all User Content you create with SumiSplash. Strategia-X does not claim any intellectual property rights over your artwork.

12.4 DMCA & Copyright Complaints

If you believe that any content accessible through SumiSplash infringes your copyright, please contact us at:

• Email: [email protected]
• Subject: "Copyright Infringement Notice"

Include: (a) identification of the copyrighted work, (b) identification of the allegedly infringing material, (c) your contact information, (d) a statement of good faith belief, (e) a statement of accuracy under penalty of perjury, and (f) your physical or electronic signature.

13.1 "As Is" and "As Available"

SUMISPLASH IS PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED.

13.2 Specific Disclaimers

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, STRATEGIA-X EXPRESSLY DISCLAIMS ALL WARRANTIES, INCLUDING BUT NOT LIMITED TO:

• Implied warranties of merchantability, fitness for a particular purpose, title, and non-infringement.
• Accuracy warranties — We do not warrant that the App will meet your requirements or produce specific results.
• Reliability warranties — We do not warrant that the App will be uninterrupted, timely, secure, or error-free.
• Data preservation warranties — We do not warrant that your data (projects, layers, settings) will not be lost due to device failure, OS updates, app updates, bugs, or other causes.
• Compatibility warranties — We do not warrant that the App will be compatible with all devices, operating system versions, or hardware configurations.
• Third-party service warranties — We do not warrant the availability, accuracy, or reliability of third-party services (Google Play, AdMob).

13.3 Beta and Experimental Features

If we provide beta, preview, or experimental features, these are provided "as is" without any warranty. Beta features may contain bugs, may change or be removed without notice, and may cause data loss.

13.4 No Professional Advice

SumiSplash is a creative tool. Nothing in the App constitutes professional, legal, financial, medical, or other advice. Any reliance on the App or its features is at your own risk.

14.1 Limitation

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL STRATEGIA-X, ITS OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, SUPPLIERS, OR LICENSORS BE LIABLE FOR ANY:

• Indirect, incidental, special, consequential, or punitive damages including but not limited to loss of profits, revenue, data, use, goodwill, or other intangible losses.
• Direct damages exceeding the total amount you have paid to Strategia-X for SumiSplash subscriptions in the twelve (12) months immediately preceding the event giving rise to the claim, or Ten US Dollars ($10.00), whichever is greater.

14.2 Specific Exclusions

WITHOUT LIMITING THE FOREGOING, STRATEGIA-X SHALL NOT BE LIABLE FOR DAMAGES ARISING FROM:

• Loss, corruption, or deletion of your artwork, projects, or other User Content
• Inability to access or use the App
• Unauthorized access to your device or data
• Bugs, errors, viruses, or other harmful components
• Interruption or cessation of service
• Actions or omissions of third-party service providers (Google Play, AdMob)
• Device damage, data loss, or battery drain attributed to the App
• Changes, suspension, or discontinuation of the App or any features

14.3 Basis of the Bargain

THE LIMITATIONS AND EXCLUSIONS IN THIS SECTION APPLY REGARDLESS OF THE THEORY OF LIABILITY (CONTRACT, TORT, NEGLIGENCE, STRICT LIABILITY, OR OTHERWISE) AND EVEN IF STRATEGIA-X HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. THESE LIMITATIONS ARE AN ESSENTIAL ELEMENT OF THE AGREEMENT BETWEEN YOU AND STRATEGIA-X.

14.4 Jurisdictional Limitations

SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF CERTAIN WARRANTIES OR LIABILITY. IN SUCH JURISDICTIONS, OUR LIABILITY SHALL BE LIMITED TO THE MAXIMUM EXTENT PERMITTED BY LAW. NOTHING IN THESE TERMS SHALL EXCLUDE OR LIMIT LIABILITY FOR DEATH, PERSONAL INJURY CAUSED BY NEGLIGENCE, FRAUD, OR ANY OTHER LIABILITY THAT CANNOT BE EXCLUDED OR LIMITED UNDER APPLICABLE LAW.

You agree to indemnify, defend, and hold harmless Strategia-X, its officers, directors, employees, agents, and affiliates from and against any and all claims, damages, losses, liabilities, costs, and expenses (including reasonable attorneys' fees) arising from or related to:

• Your use or misuse of SumiSplash
• Your User Content, including any claims that your content infringes any third party's intellectual property or other rights
• Your violation of these Terms
• Your violation of any applicable law or regulation
• Your sharing or distribution of content created with SumiSplash

16.1 Your Right to Terminate

You may stop using SumiSplash and delete it from your device at any time. If you have an active subscription, remember to cancel it through Google Play to avoid continued charges.

16.2 Our Right to Terminate

We reserve the right to suspend or terminate your access to SumiSplash, in whole or in part, at any time and for any reason, including but not limited to:

• Violation of these Terms
• Conduct that we determine, in our sole discretion, is harmful to other users, us, or third parties
• Legal or regulatory requirements

16.3 Effect of Termination

Upon termination:

• Your license to use SumiSplash is revoked.
• You should uninstall the App.
• Sections of these Terms that by their nature should survive termination will survive (including but not limited to Sections 4, 12, 13, 14, 15, and 18).

16.4 No Liability for Termination

We shall not be liable to you or any third party for any termination of your access to SumiSplash.

17.1 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 Google AdMob and Google Play Billing.

17.2 Legal Basis for Processing

Under the General Data Protection Regulation (GDPR) and the UK GDPR, the legal bases for processing personal data in connection with SumiSplash are:

• Consent (Article 6(1)(a)) — For serving personalized advertisements through Google AdMob. Consent is obtained via Google's User Messaging Platform consent dialog.
• Performance of a Contract (Article 6(1)(b)) — For processing subscription purchases through Google Play Billing, necessary to fulfill the subscription agreement.
• Legitimate Interests (Article 6(1)(f)) — For local data storage (projects, preferences) necessary for the App to function, and for serving non-personalized advertisements to support the free app model.

17.3 Your GDPR Rights

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

• Right of Access (Article 15) — Request a copy of personal data we hold about you. Note: we hold no personal data on our servers.
• Right to Rectification (Article 16) — Request correction of inaccurate personal data.
• Right to Erasure (Article 17, "Right to be Forgotten") — Delete projects within the App, or clear App data in device settings. For AdMob data, manage through Google's privacy controls.
• Right to Restriction of Processing (Article 18) — Disable ad personalization in your Google settings, or subscribe to Pro for an ad-free experience.
• Right to Data Portability (Article 20) — Export projects as PNG images or .sumi backup files from within the App.
• Right to Object (Article 21) — Opt out of personalized ads via Google Ads Settings.
• Right to Withdraw Consent (Article 7(3)) — Change your consent preferences in the App's consent dialog or device settings at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Right to Lodge a Complaint (Article 77) — Contact your local Data Protection Authority (DPA) if you believe your data protection rights have been violated.

17.4 International Data Transfers

Information collected by third-party services (Google AdMob, Google Play) may be transferred to and processed in the United States or other countries outside the EEA/UK. These transfers are governed by Standard Contractual Clauses (SCCs) and other data transfer mechanisms as described in Google's data transfer frameworks.

17.5 Data Protection Officer

For GDPR-related inquiries, contact us at [email protected] with "GDPR Request" in the subject line. We will respond within 30 days (extendable by 60 days for complex requests, with notice).

18.1 Categories of Personal Information

Under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (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:

• Identifiers — Device identifiers (Android Advertising ID), IP address.
• Commercial information — Google Play subscription purchase history (managed by Google).
• Internet or network activity — Ad interaction data (impressions, clicks), app version.
• Geolocation data — Approximate location inferred from IP address (city/region level only; no GPS).
• Inferences — AdMob may make inferences from the above for ad targeting.

18.2 Your CCPA/CPRA Rights

If you are a California resident, you have the following rights:

• Right to Know — Request disclosure of what personal information is collected, the sources, the business purpose, and the categories of third parties with whom it is shared.
• Right to Delete — Request deletion of personal information. You can delete all locally stored data by uninstalling the App or clearing App data in your device settings.
• Right to Correct — Request correction of inaccurate personal information.
• Right to Opt-Out of Sale/Sharing — Opt out of the "sale" or "sharing" of personal information for cross-context behavioral advertising. We do not sell personal information. However, use of advertising identifiers by AdMob may constitute "sharing" under CCPA/CPRA. You can opt out by disabling ad personalization in your device settings, resetting your Advertising ID, or upgrading to SumiSplash Pro.
• Right to Limit Use of Sensitive Personal Information — We do not collect sensitive personal information as defined under CCPA/CPRA.
• Right to Non-Discrimination — We will not discriminate against you for exercising any of your CCPA/CPRA rights.

18.3 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).

18.4 How to Exercise Your Rights

To submit a verifiable consumer request, 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. You may designate an authorized agent to make a request on your behalf.

19.1 Covered State Laws

In addition to the CCPA/CPRA, we recognize and comply with the following state consumer privacy laws to the extent they apply:

• Virginia — Virginia Consumer Data Protection Act (VCDPA)
• Colorado — Colorado Privacy Act (CPA)
• Connecticut — Connecticut Data Privacy Act (CTDPA)
• Utah — Utah Consumer Privacy Act (UCPA)
• Texas — Texas Data Privacy and Security Act (TDPSA)
• Oregon — Oregon Consumer Privacy Act (OCPA)
• Montana — Montana Consumer Data Privacy Act (MCDPA)
• Tennessee — Tennessee Information Protection Act (TIPA)
• Indiana — Indiana Consumer Data Protection Act (ICDPA)
• Iowa — Iowa Consumer Data Protection Act (ICDPA)
• Delaware — Delaware Personal Data Privacy Act (DPDPA)
• New Hampshire — New Hampshire Privacy Act (NHPA)
• New Jersey — New Jersey Data Privacy Act (NJDPA)
• Nebraska — Nebraska Data Privacy Act (NDPA)
• Maryland — Maryland Online Data Privacy Act (MODPA)
• Minnesota — Minnesota Consumer Data Privacy Act (MCDPA)
• Any other U.S. state that enacts consumer privacy legislation

19.2 Your Rights Under State Privacy Laws

Depending on your state, you may have rights including:

• The right to access, correct, delete, and obtain a portable copy of your personal data.
• The right to opt out of targeted advertising, the sale of personal data, and profiling in furtherance of decisions that produce legal or similarly significant effects.
• The right to appeal a denied privacy rights request.
• The right to non-discrimination for exercising your privacy rights.

19.3 How to Exercise Your Rights

To exercise your rights under any state privacy law, 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 will respond within the timeframe required by the applicable state law.

In accordance with CalOPPA, we agree to the following:

• Users can use our App without being required to provide personal information.
• Our Privacy Policy is accessible from within the App and linked prior to or at the point of information collection.
• Our Privacy Policy link includes the word "Privacy" and can be easily found within the App.
• Users will be notified of any Privacy Policy changes through an update to the Privacy Policy page and the "Last updated" date.
• Users can change their ad personalization preferences through their device settings.

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

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 under 16 in the European Economic Area). 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 these Terms and our 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].

22.1 Modification

We reserve the right to modify these Terms at any time. Changes will be indicated by updating the "Last Updated" date at the top of this document.

22.2 Notification

For material changes to these Terms, we will provide notice through one or more of the following:

• A prominent notice within the App (e.g., dialog, banner, or notification)
• An update to this document accessible through the App or our website

22.3 Acceptance

Your continued use of SumiSplash after changes are posted constitutes acceptance of the modified Terms. If you do not agree with the modified Terms, you should stop using the App and uninstall it.

23.1 Governing Law

These Terms shall be governed by and construed in accordance with the laws of the State of California, United States of America, without regard to its conflict of law provisions.

23.2 Informal Resolution

Before initiating any formal dispute resolution proceeding, you agree to first contact us at [email protected] and attempt to resolve the dispute informally for at least 30 days. Most disputes can be resolved without formal proceedings.

23.3 Arbitration Agreement

If informal resolution is unsuccessful, any dispute, claim, or controversy arising out of or relating to these Terms or SumiSplash shall be resolved by binding arbitration administered by the American Arbitration Association (AAA) under its Consumer Arbitration Rules.

• Arbitration shall take place in the State of California or, at your election, via telephone or video conference.
• The arbitrator's decision shall be final and binding.
• Judgment on the arbitration award may be entered in any court of competent jurisdiction.

23.4 Class Action Waiver

YOU AND STRATEGIA-X AGREE THAT EACH PARTY MAY BRING CLAIMS AGAINST THE OTHER ONLY IN AN INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS, CONSOLIDATED, OR REPRESENTATIVE ACTION.

The arbitrator may not consolidate more than one person's claims and may not preside over any form of class or representative proceeding.

23.5 Small Claims Exception

Either party may bring an individual action in small claims court for disputes within the jurisdictional limits of that court.

23.6 Exceptions

Nothing in this section shall prevent either party from seeking injunctive or equitable relief in a court of competent jurisdiction to prevent the actual or threatened infringement of intellectual property rights.

23.7 European Union Residents

If you are a resident of the European Union, you may also be entitled to submit disputes to the European Commission's Online Dispute Resolution platform at ec.europa.eu/consumers/odr.

• Entire Agreement — These Terms, together with our Privacy Policy and any additional terms for specific features, constitute the entire agreement between you and Strategia-X regarding SumiSplash and supersede all prior agreements, understandings, and communications.
• Severability — If any provision of these Terms is found to be invalid, illegal, or unenforceable by a court of competent jurisdiction, the remaining provisions shall continue in full force and effect. The invalid provision shall be modified to the minimum extent necessary to make it valid and enforceable while preserving its original intent.
• Waiver — The failure of Strategia-X to enforce any right or provision of these Terms shall not constitute a waiver of such right or provision. Any waiver must be in writing and signed by an authorized representative of Strategia-X.
• Assignment — You may not assign or transfer these Terms or your rights under these Terms without our prior written consent. Strategia-X may assign these Terms without restriction, including in connection with a merger, acquisition, corporate reorganization, or sale of assets.
• Force Majeure — Strategia-X shall not be liable for any failure or delay in performance due to circumstances beyond our reasonable control, including but not limited to: natural disasters, acts of God, war, terrorism, pandemics, government actions, power failures, internet disruptions, cyberattacks, or third-party service outages.
• Headings — Section headings in these Terms are for convenience only and do not affect the interpretation of any provision.
• No Third-Party Beneficiaries — These Terms do not create any third-party beneficiary rights, except as expressly provided. Google LLC is not a party to these Terms.
• Relationship of Parties — Nothing in these Terms creates a partnership, joint venture, agency, employment, or franchise relationship between you and Strategia-X.
• Notices — We may provide notices to you through the App (in-app messages, dialogs, or banners). You may provide notices to us via the contact information in Section 25.
• Electronic Communications — By using SumiSplash, you consent to receiving electronic communications from us, including notices, agreements, disclosures, and other communications delivered through the App. You agree that such electronic communications satisfy any legal requirement that such communications be in writing.

For questions, concerns, or communications regarding these Terms of Service:

Strategia-X
General Support: [email protected]
Legal, Terms & Privacy: [email protected]
Copyright/DMCA: [email protected] (Subject: "Copyright Infringement Notice")
Dispute Resolution: [email protected] (Subject: "Dispute Resolution")
Website: www.strategia-x.com

Response Times:

• General 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.
• Copyright/DMCA notices — within 10 business days.

By using SumiSplash, you acknowledge that you have read, understood, and agree to be bound by these Terms of Service and our Privacy Policy.

These Terms of Service apply to the SumiSplash mobile application (package: com.sumisplash.app) distributed via the Google Play Store. This document does not constitute legal advice. We recommend consulting with a qualified attorney to ensure compliance with all applicable laws in your jurisdiction.