Lucky Cat HSK — Privacy Policy

DRAFT — not legal advice. Developer-authored working draft. All identity and policy placeholders are now filled; before publishing it still MUST be reviewed by a qualified privacy professional (Thailand PDPA + EU GDPR). It reflects the intended data practices per the Monetization & Production PRD (§6.4, §9); confirm each claim against the shipped build (the §2e analytics and §6 sign-out claims were checked against the current code).

Effective date: 2026-07-17

App: Lucky Cat HSK

Provider / data controller: Sarach Sriklab, Bangkok 10400, Thailand

Contact: sarach.northbear@gmail.com

1. Who this applies to and our approach

Lucky Cat HSK helps people learn HSK Chinese vocabulary. You can install and play entirely as a guest, offline, without an account. In that mode your progress lives only on your device and is not sent to us. Cloud features, ads, purchases, and the optional analytics setting add data collection, described below. We collect the minimum needed to run those features and never sell your personal data.

This policy covers our obligations under Thailand's Personal Data Protection Act (PDPA) and the EU/UK General Data Protection Regulation (GDPR).

2. Data we collect

a) Guest play (default) — stored only on your device.
Learning progress, mastery, streak, quests, wallet/coins, owned cosmetics, and preferences are saved in your device's local storage (nbhsk.*). This data is not transmitted to us while you play as an offline guest.

b) Account & cloud save (optional — only if you sign in).

c) Purchases (only if you buy something).
In-app purchases (the one-time Supporter unlock and coin packs) are processed by Apple App Store / Google Play via RevenueCat. We receive a purchase/entitlement confirmation and a purchase token — we do not receive or store your payment card details.

d) Ads (only if ads are shown).
We show ads via Google AdMob. Depending on your consent choice, AdMob may process an advertising identifier, coarse device/usage signals, and your consent state to serve personalized or non-personalized ads. On first run (and on iOS, via App Tracking Transparency) you choose your consent; non-consented users receive non-personalized ads.

e) Product analytics (only if you turn it on).
Lucky Cat HSK includes an optional, off-by-default setting — Settings → "Share anonymous usage data." If, and only if, you switch it on, the app sends a small set of anonymous, aggregate usage events so we can see how the game is used and improve it:

You can turn this off again at any time in Settings; turning it off stops all event collection immediately. This setting is independent of ads (§2d) and is off unless you choose it. Basic crash/technical diagnostics provided by the app stores or operating system may still apply under their own policies.

We do not collect contacts, precise location, photos, microphone, or health data.

3. Why we use it and the legal basis (GDPR)

PurposeDataLegal basis
Run the game / save progress locally§2aContract / necessary to provide the service
Optional cloud save & cross-device sync§2bContract (you chose to sign in)
Process purchases & restore entitlements§2cContract
Show ads to support the free app§2dConsent (personalized) / legitimate interest (non-personalized), per your choice
Optional product analytics to improve the game§2eConsent (opt-in, off by default; withdraw any time in Settings)
Keep the app stable and secure (store/OS crash diagnostics)§2eLegitimate interest

Under PDPA the equivalent bases (consent, contractual necessity, legitimate interest) apply.

4. Who we share it with (processors)

We use these service providers, who process data on our behalf. Each also handles data under its own privacy policy:

We use no third-party analytics or advertising SDK for the optional analytics in §2e — those events go only to our own Supabase. We do not sell personal data or share it for cross-context behavioral advertising beyond the ad-serving described above.

5. Children

Lucky Cat HSK is directed to a general audience aged 13 and older (HSK is a formal proficiency exam taken by teens and adults). It is not directed to children under 13, and we do not knowingly collect personal data from children under 13. If you believe a child has provided personal data, contact us and we will delete it.

6. Your rights

Subject to PDPA/GDPR, you may access, correct, delete, or export your personal data, object to or restrict processing, and withdraw consent (including ad-personalization consent) at any time.

Withdrawing consent or deleting your account does not affect the lawfulness of processing already carried out, and you may continue to play as an offline guest.

7. Retention

Cloud data is kept while your account is active and deleted within 30 days after you request account deletion or after 24 months of inactivity. Local device data persists until you clear it or uninstall. Purchase records are retained as required for tax/audit purposes.

8. International transfers

Your data may be processed outside your country. Our cloud/analytics data is hosted with Supabase in Singapore (ap-southeast-1); RevenueCat and Google AdMob (only if you buy something or ads are shown) process data on US-based infrastructure. Where a transfer requires it (e.g., from the EU/UK), we and our providers rely on appropriate safeguards such as the Standard Contractual Clauses. Each provider's own policy (§4) describes its transfer mechanisms.

9. Security

We use industry-standard measures (encrypted transport, Supabase Row-Level Security so users can access only their own data, server-side validation of purchases). No system is perfectly secure, but purchased entitlements and coins are server-authoritative to limit abuse.

10. Changes

We will update this policy as the app evolves and post the new effective date here; material changes will be surfaced in-app.

11. Contact

Questions or requests: sarach.northbear@gmail.com — Sarach Sriklab, Bangkok 10400, Thailand. Thailand users may also lodge a complaint with the PDPC; EU/UK users with their local supervisory authority.


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