Privacy policy

1. Controller and contact

APPLODI STUDIO LIMITED (埃鐠樂狄有限公司) is responsible for the data described in this policy for Tibumo Puzzle and its website. Registered office: Room 5017, Floor 5, Yau Lee Centre, 45 Hoi Yuen Road, Kwun Tong, Hong Kong. Company registration: 80379487; business registration: 80379487-000-05-26-8.

For questions or requests: contact[AT]applodistudio.com. Replace [AT] with @ in your email application.

2. Children and parents

Tibumo Puzzle is used under adult supervision. No child account, name, date of birth or public profile is required. The available paths represent difficulty, not the child’s actual age. Settings, purchases and external links are protected by a parental check.

The application contains no advertising. Data is not sold or used for advertising or cross-site tracking.

3. Data on your device

Games in progress, progress, preferences and parental-control information are stored on your device. They let you resume a game and apply your settings, without an account or progress synchronisation on our servers.

This data stays on the device without automatic expiry. You can remove it through system storage controls or by uninstalling the application. System backups follow their own settings. The publisher cannot erase this storage remotely and does not guarantee recovery of games after reinstallation.

4. Connection, application statistics and purchases

Games and their media are included in the application and remain usable offline. When connected, the application sends internal statistics to Matomo, self-hosted by the publisher at metrics.applodistudio.com, to understand usage and improve it. Transfers use HTTPS encryption and pause in the background; a failure of this service does not block play.

Statistics cover screens viewed and some actions: opening, starting or completing a game, help and abandonment. They may include the game, difficulty path, level number and technical information about the application and screens. Available events vary between games. This service does not transmit names, emails, parental codes or answers, payment data or saved-game content.

A random visit identifier stays only in memory and is renewed after 30 minutes of inactivity. It is not a permanent device identifier; renewal does not erase statistics already received. This transport uses no analytics cookies or advertising identifier.

The server receives the IP address. The instance’s documented configuration masks part of the recorded IP while using the full IP to infer an approximate location. No GPS access is requested for these statistics. The absence of accounts and cookies does not guarantee anonymity.

The application does not request analytics consent and provides no control to disable this service. The website’s Statistics choice applies only to the browser. The parental check is not consent to statistics.

Purchases are processed by the store under its terms. The application checks transactions locally to unlock access; the publisher does not receive your banking details through this process. The unlock offered is a one-time purchase, without a subscription.

5. Website visits

The website receives the IP and technical information needed to deliver pages and keep them secure. Server logs are separate from statistics and may contain the full IP. The browser stores your language and theme preferences. Presentation pages require no account or payment.

6. Website statistics

The website automatically measures pages viewed and some actions using Matomo, without analytics cookies. You can stop new transmissions through Statistics at the bottom of the page. This choice is saved in this browser, or only in the tab if storage is unavailable. Previous refusals that are still valid are respected.

This choice does not disable application statistics or erase history already received. The website does not transmit a child’s name, parental code or saved-game content.

7. Messages to the publisher

If you write to us, we receive your email, message and attachments to answer your request. An adult should contact us without including unnecessary information about the child, passwords, parental codes or banking details. These messages are not used for advertising.

8. Purposes and grounds

Where the GDPR applies, service functions and related requests rely on the service relationship; legal obligations rely on the applicable law. Security, the defence of rights and website improvement rely on the publisher’s legitimate interests. You can object to website statistics through its footer. Hong Kong data-protection principles also apply to the publisher.

Limited application statistics help us understand which games are used and improve how they work, on the basis of the publisher’s legitimate interests. They are not used for advertising or to profile a child and are not linked to an account or the child’s identity.

9. Recipients, hosting and transfers

Data is accessible to authorised publisher staff and providers needed for the service. The website and Matomo are hosted by Hostinger in Kuala Lumpur, Malaysia, with HOSTINGER PTE LTD in Singapore as provider. Email is hosted by Infomaniak in Switzerland. Stores process their operations separately.

The publisher is established in Hong Kong. Neither Hong Kong nor Malaysia has a general European Union adequacy decision. Hostinger’s terms include a data-processing agreement and standard contractual clauses for transfers within their scope: https://www.hostinger.com/legal/dpa. You can request a copy of the safeguards applicable to the processing concerned.

10. Retention and deletion

Application and website statistics are managed manually in Matomo, with no fixed retention period or automatic deletion configured. The in-memory identifier’s 30 minutes are not a server retention period. Contact us with requests about your data; identification limits are explained below.

Closed enquiries are retained for up to 24 months after the last exchange, with manual deletion. Some items may be kept separately for a legal obligation or dispute for the justified period.

Logs support operation, security and incident diagnosis; their retention depends on server settings and rotation, with no verified uniform period. Technical copies follow Hostinger’s and Infomaniak’s cycles. According to Hostinger’s documentation for default settings, the two most recent weekly VPS backups are retained. They do not back up games stored only on your device.

11. Your rights

Write to contact[AT]applodistudio.com or the publisher’s registered office to request access to or correction of your data and, depending on applicable law, erasure, restriction, a portable copy or to object to processing. Specify the service and period concerned. We may request proportionate verification to protect your data.

Without an account or identity in statistics, locating a particular visit may be impossible. An email does not automatically disable transmissions from the application. We will explain any limitations and respond within applicable deadlines: generally one month under the GDPR and 40 days for access under Hong Kong law. You can complain to the competent authority in your country or Hong Kong’s Privacy Commissioner for Personal Data.

12. Security and updates

The system protects local storage and the transmissions described use HTTPS. No system is risk-free: keep your device and access secure. This policy is updated when processing changes; the final document’s date appears at the top of the page.

13. Free browser games

The 12 free levels of every game and path are directly available, without an account or payment. Progress and the current game are stored in this browser, separately from the mobile app. Clearing site storage removes them. If storage is unavailable, resumption is limited to the open tab.

The web games use the site statistics described above: opening, starting, completing, leaving and requesting help, with the game, selected difficulty and level number. The path does not reveal a person’s actual age. No names, saved game content or details of each gesture are transmitted. The “Statistics” option is available in the web game settings.

Games and their media are loaded from tibumo.com; a connection may be needed. Enabled sounds start after an interaction. No microphone access is requested.