Çengel Bulmaca Privacy Policy

Data controller

Çengel Bulmaca is published by Bellis Labs, an independent individual developer based in Istanbul, Türkiye. Bellis Labs is the data controller under the Turkish Personal Data Protection Law No. 6698 (KVKK) and, for users in the European Economic Area (EEA), the General Data Protection Regulation (GDPR). You can reach us at hello@bellislabs.com.

What data

What we do not collect

The app has no account or sign-in. We do not ask for or collect your name, e-mail address, phone number, contacts, photos or GPS location. No special categories of (sensitive) personal data, such as health or beliefs, are processed.

What stays on your device

Your puzzle progress, coins and settings are stored on your phone and are not sent to us (see Data stored on your device).

What is processed by service providers

While the app runs, the following data is processed by the service providers named here:

• Google AdMob (Google LLC)

  Data: Android advertising ID, ad interaction data (ads shown and tapped, rewarded videos watched), IP address, device and app information.

  Purpose: to show ads and measure their performance.

• Firebase Analytics (Google LLC)

  Data: a randomly generated app-instance ID, usage events (for example starting or solving a puzzle), device model, Android version, app version, country.

  Purpose: to understand how the app is used and improve it.

• Firebase Crashlytics (Google LLC)

  Data: crash reports, that is a record of the error and the device state at the time of the crash (for example device model, OS version, free memory).

  Purpose: to find and fix bugs.

• Firebase Remote Config (Google LLC)

  Data: no personal data is used; the app only downloads remote settings.

  Purpose: to switch some features on or off without releasing a new version.

• Cloudflare (Cloudflare, Inc.)

  Data: IP address and standard connection information, transiently.

  Purpose: to download new and corrected puzzles.

Google's and Cloudflare's servers may be located outside Türkiye (for example in the United States and the European Union), so this data may be transferred abroad. These companies process it under their own privacy policies and data processing terms. We do not sell your data and, unless required by law, we do not share it with anyone other than the providers above.

Ads and consent

Çengel Bulmaca is free; ads pay for it. Ads are served by Google AdMob:

• Banner: a small ad area at the bottom of the game screen.
• Rewarded video: a video you can choose to watch to earn coins. It plays only when you tap the button.

AdMob uses your Android advertising ID, ad interaction data and IP address to select and show ads, limit how often the same ad is shown, prevent fraud and measure ad performance.

European Economic Area and United Kingdom

If you are in the EEA or the UK, the app shows Google's consent form (User Messaging Platform) on first launch. If you consent, ads may be personalized to your interests. If you do not, non-personalized ads are shown: they are chosen from information such as the app's content and your approximate location (for example your country) rather than your interests, and still use limited data for frequency capping, fraud prevention and measurement. You can change or withdraw your choice at any time from the privacy options in the app's Profil (Profile) tab.

In these regions personalized ads are shown only with your consent; non-personalized ads rely on our legitimate interest in offering the app for free.

Other countries

In other countries, including Türkiye, no consent form is shown and Google may personalize ads. You can limit this in your device settings as described below.

In every country, including Türkiye, the app shows a short notice on first launch that summarises ads, usage statistics and crash reports, and the data kept on your device, with a link to this policy. By continuing to use the app you acknowledge this policy; you can always limit ad personalization in the device settings described below.

Your advertising ID

On your Android device you can reset or delete your advertising ID under Settings > Privacy > Ads (on some devices Settings > Google > Ads). Resetting it breaks the link to past ad data; deleting it stops apps from using your advertising ID.

You can read how Google uses this data in How Google uses information from sites or apps that use our services and in the Google Privacy Policy.

Analytics and crash reports

We use Google's Firebase services to make the app better:

• Firebase Analytics records events about how the app is used, for example starting or solving a puzzle. Together with these events it sends a randomly generated app-instance ID, the device model, Android version, app version and country. This ID does not identify you by name (pseudonymous data); we see reports in aggregate, for example "how many puzzles were solved today".
• Firebase Crashlytics sends a crash report if the app crashes: the lines of code where the error occurred, the app version, device model, OS version and the device state at the time of the crash (for example free memory and disk space, screen orientation). We use these reports only to find and fix bugs.
• Firebase Remote Config lets us change some settings remotely (for example whether ads or the daily puzzle are switched on); no personal data is used for this.

Google processes this data on our behalf and keeps it according to its own retention periods (for example, Crashlytics keeps crash reports for 90 days). Analytics and crash reports rely on our legitimate interest in running and improving the app. Details: Privacy and Security in Firebase.

Content server

All puzzles ship inside the app. New and corrected puzzles are downloaded from content.bellislabs.com, which is operated by Cloudflare, Inc. Each time the app opens it checks a small index file and, if needed, downloads new puzzle packs.

The downloaded files are the same for everyone and contain no information about you; the app sends no identifier with these requests. During the connection your IP address and standard request information (time, requested file, client information) are processed transiently by Cloudflare to establish the connection, keep it secure and prevent abuse (for example excessive requests), and may be kept briefly in Cloudflare's standard logs. We do not use these logs to identify people. Details: Cloudflare Privacy Policy.

Data stored on your device

The following is stored only on your phone and is not sent to us:

• the puzzles you have solved or left unfinished and the letters you entered,
• your coin balance,
• your settings (for example theme and vibration),
• puzzle packs downloaded from the server.

If Android backup is turned on, this data is included in the backup Android makes to your Google account, so your progress is not lost when you change phones. Google stores this backup; we have no access to it. Uninstalling the app or clearing its data in Settings deletes this data from your device.

Children

Çengel Bulmaca is not directed at children under 13, and we do not knowingly collect personal data from children under 13. If you believe a child's data has been processed, write to hello@bellislabs.com and we will do what is needed to have it deleted.

Your rights

Under Article 11 of the KVKK and, if you are in the EEA, the GDPR, you have the right to:

• learn whether your data is processed and access it,
• ask for incorrect or incomplete data to be corrected,
• ask for your data to be deleted,
• object to the processing of your data (under the GDPR also ask for restriction of processing and data portability),
• withdraw your consent at any time.

Send requests to hello@bellislabs.com; we reply within 30 days at the latest. Because we keep no account that identifies you, we may ask for additional information to match your request to the relevant records.

Some steps you can take yourself right away:

• change your ad consent from the privacy options in the app's Profil (Profile) tab,
• reset or delete your Android advertising ID in your device settings,
• uninstall the app: all app data on the device is deleted and no new data is collected.

If you are not satisfied with our reply, you can apply to the Turkish Personal Data Protection Authority in Türkiye or, in the EEA, to the data protection authority of your country.

Changes

We may update this policy as the app or the services we use change. The current version is always on this page; the effective date at the top shows the latest change.

Contact

For any privacy question or request: hello@bellislabs.com
Bellis Labs, Istanbul, Türkiye