Privacy Policy - Kortiva, LLC

Effective Date: January 1, 2026 Last Updated: May 9, 2026

Kortiva, LLC (“Kortiva,” “we,” “us,” or “our”) respects your privacy and is committed to protecting it through this Privacy Policy.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile applications, websites, and related services (collectively, the “Services”), including but not limited to applications such as Domino-Slam and Sitcom Showdown.

By accessing or using the Services, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access or use the Services.

1. Definitions

• Personal Information: Any information that identifies, relates to, or could reasonably be linked with a particular individual or household.
• Services: Our mobile applications (including but not limited to Domino-Slam and Sitcom Showdown), websites, and related services.
• Usage Data: Information that is collected automatically when you use the Services, such as device information, IP address, and crash reports.

2. Information We Collect

We collect only the information reasonably necessary to operate, improve, and secure our Services.

2.1 Information You Provide to Us

• Account Information: When you create an account, we may collect your email address, username, and account credentials (such as a password or third-party sign-in tokens from services like Apple or Google). We use this to create and secure your account.
• Communications: When you contact us for support or provide feedback, we collect the content of your communications to respond to your inquiries and improve our Services.

2.2 Information We Collect Automatically (Usage Data)

When you use the Services, our servers or third-party analytics tools may automatically collect:

• Device Information: Device type, operating system and version, and unique device identifiers.
• Application Information: The version of the application you are using.
• Performance Data: Crash reports and other data related to the performance of our Services.
• IP Address: We collect your IP address for security purposes (e.g., to prevent fraud or abuse) and for aggregated, non-personal analytics.

This data is typically collected through industry-standard services such as Firebase Analytics.

2.2.1 Advertising Data

We use Google AdMob to serve third-party advertisements in certain apps (such as Sitcom Showdown and Domino-Slam). AdMob may collect:

• Device advertising identifiers (IDFA on iOS, GAID on Android)
• Ad interaction data (impressions, clicks)
• Device information to serve personalized ads and measure ad performance

This data collection constitutes “tracking” as defined by Apple’s App Tracking Transparency framework. You can control ad tracking through your device settings (see Section 7).

2.2.2 Game Services Data

Our apps may integrate with Apple Game Center and/or Google Play Games Services to provide leaderboards and achievements. These platforms collect and process data according to their own privacy policies. We receive only your public display name and achievement/score data necessary for the game features.

2.2.3 Performance and Diagnostics

We use Firebase Crashlytics to collect crash logs (including stack traces, device state, and device identifiers such as IDFV) and Firebase Performance Monitoring to collect app performance metrics (launch time, screen rendering, network latency). This data is associated with your device but is not linked to your name or account. It is used solely for diagnosing and fixing issues.

2.2.4 Over-the-Air Updates

Our mobile apps may check for and download updates through Expo’s update service (EAS Update). This involves your device communicating with update servers to check for new app versions. Only standard network request data (IP address, device type, app version) is transmitted during this process.

2.3 Special Use-Case Information

• Camera Usage: Certain features (e.g., “aura-reader”) may require access to your device’s camera. Camera access is used only in real-time to provide the feature. Images and video are processed on your device and are not stored or transmitted by Kortiva for this feature. You can disable camera access at any time in your device settings.

2.4 Information from Third-Party Services

• Authentication: If you sign in using Apple Sign-In or Google Sign-In, we receive an authentication token to verify your identity. We do not receive your password for these third-party accounts.
• Payments: Payments for in-app purchases or subscriptions are processed exclusively by the Apple App Store or Google Play Store. Kortiva does not collect or store your payment card information.

2.5 Cookies and Website Tracking

Our websites may use cookies and similar technologies (such as localStorage and web beacons) to improve your browsing experience and analyze website traffic. We may use third-party analytics services on our websites. You can control cookies through your browser settings.

2.6 Business Platform Services

Kortiva operates a website and marketing platform (Kortiva Site Engine) on behalf of business clients. When we process data on behalf of our business clients (such as their customers’ contact information for SMS marketing), we act as a data processor. Our business clients are the data controllers responsible for their own privacy policies. Our processing of such data is governed by our data processing agreements with those clients, not this Privacy Policy.

3. How We Use Your Information

We use the information we collect for the following purposes:

• To Provide and Maintain the Services: Including creating and managing user accounts, authenticating users, and providing customer support.
• To Improve and Personalize the Services: To understand how users interact with our Services, to fix bugs, and to develop new features.
• For Security and Fraud Prevention: To monitor for and prevent malicious activity, and to protect the integrity of our Services.
• To Comply with Legal Obligations: To comply with applicable laws, regulations, court orders, or other legal processes.

We do not sell your Personal Information in the traditional sense. However, under the California Consumer Privacy Act (CCPA/CPRA), sharing device identifiers with advertising partners for targeted advertising may constitute a “sale” or “sharing” of personal information (see Section 7.2).

3.1 Legal Bases for Processing (EEA Users)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, we process your personal data under the following legal bases:

• Contractual Necessity (Art. 6(1)(b)): To provide and maintain our Services, including account creation, authentication, and customer support.
• Legitimate Interests (Art. 6(1)(f)): To improve and secure our Services, including analytics, crash reporting, and fraud prevention. Our legitimate interests do not override your fundamental rights and freedoms.
• Consent (Art. 6(1)(a)): For personalized advertising and ad tracking. You may withdraw consent at any time through your device settings (see Section 7.1).
• Legal Obligation (Art. 6(1)(c)): To comply with applicable laws and regulations.

4. How We Share Your Information

We do not share your Personal Information except in the circumstances described below:

• Service Providers: We may share information with trusted third-party vendors who perform services on our behalf (e.g., hosting, analytics). These providers are contractually obligated to safeguard your data and are prohibited from using it for any other purpose.
• Advertising Partners: We share device identifiers and usage data with advertising partners (Google AdMob) for the purpose of serving targeted advertisements and measuring ad effectiveness. Users may opt out of personalized advertising through their device settings (see Section 7).
• Legal Requirements: We may disclose your information if required by law or in the good faith belief that such action is necessary to comply with a legal obligation, protect our rights or property, or prevent illegal activity.
• Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your Personal Information.

4.1 Third-Party Services and SDKs

Our mobile apps integrate the following third-party services, each of which has its own privacy policy:

5. Data Security and Retention

5.1 Security: We use reasonable administrative, technical, and organizational measures to protect your Personal Information. All data transmitted between our apps and our servers is encrypted in transit using TLS (Transport Layer Security). However, no electronic transmission or storage is 100% secure, and we cannot guarantee its absolute security.

5.2 Retention: We retain your Personal Information only for as long as is necessary to provide the Services, fulfill the purposes outlined in this policy, comply with our legal obligations, resolve disputes, and enforce our agreements. When no longer needed, your data will be deleted or anonymized. Firebase Analytics data is retained for 14 months. Firebase Crashlytics data is retained for 90 days. Advertising data collected by AdMob is retained according to Google’s advertising data retention policies.

6. International Data Transfers

Our Services are hosted and operated in the United States. If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, your personal data will be transferred to the United States for processing.

We rely on the following safeguards for these transfers:

• Standard Contractual Clauses (SCCs): We use European Commission-approved Standard Contractual Clauses with our service providers to ensure adequate protection for your data.
• Data Processing Agreements: Our third-party service providers (including Google/Firebase) maintain their own data transfer mechanisms compliant with GDPR.

By using our Services, you acknowledge that your data will be processed in the United States. You may contact us for a copy of the safeguards we use for international transfers.

7. Your Privacy Rights and Choices

Depending on your jurisdiction (e.g., the European Economic Area, California), you may have certain rights regarding your Personal Information. These rights may include:

• Right to Access: The right to request access to the Personal Information we hold about you.
• Right to Rectification: The right to request that we correct any inaccurate Personal Information.
• Right to Erasure (Deletion): The right to request the deletion of your Personal Information.
• Right to Restrict Processing: The right to request that we restrict the processing of your Personal Information.
• Right to Data Portability: The right to receive your Personal Information in a structured, machine-readable format.
• Right to Object: The right to object to the processing of your Personal Information where we rely on legitimate interests as our legal basis.
• Right to Lodge a Complaint: If you are in the EEA, you have the right to lodge a complaint with your local data protection supervisory authority.

To exercise these rights, including requesting deletion of your data, please contact us at support@kortiva.com. You may also delete your account and associated data directly within the app by navigating to Settings > Account > Delete Account. We will respond to verified requests within 30 days.

7.1 Ad Tracking Opt-Out

• iOS: You can control ad tracking through Settings > Privacy & Security > Tracking. You can also reset your advertising identifier or limit ad tracking through Settings > Privacy & Security > Apple Advertising.
• Android: You can opt out of personalized ads through Settings > Google > Ads > Opt out of Ads Personalization.

Our apps respect these device-level preferences. When you opt out, ads will still be shown but they will not be personalized based on your activity. Withdrawing consent (opting out of ad tracking) does not affect the lawfulness of processing that occurred before the withdrawal.

7.2 California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have the following additional rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act:

Categories of Personal Information Collected:

• Identifiers (device advertising identifiers, IP address, username, email address)
• Internet or electronic network activity (app usage data, ad interaction data, crash logs)
• Inferences drawn from the above (ad personalization profiles created by our advertising partners)

Categories of Personal Information Sold or Shared:

• Identifiers (device advertising identifiers) — shared with Google AdMob for targeted advertising
• Internet or electronic network activity (ad interaction data) — shared with Google AdMob

Your California Rights:

• Right to Know: You may request the categories and specific pieces of personal information we have collected about you.
• Right to Delete: You may request deletion of your personal information.
• Right to Opt-Out of Sale/Sharing: You may opt out of the sale or sharing of your personal information for targeted advertising by adjusting your device’s ad tracking settings (see Section 7.1) or by contacting us at support@kortiva.com.
• Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.

To exercise your rights, contact us at support@kortiva.com. We will verify your identity before processing your request and respond within 45 days.

8. Children’s Privacy

Our Services are not directed to children under the age of 13. We do not knowingly collect Personal Information from children under 13. If we learn that we have collected Personal Information from a child under 13, we will take steps to delete it as soon as possible.

9. Third-Party Links

The Services may contain links to third-party websites or services that are not owned or controlled by Kortiva. We are not responsible for the privacy practices of these third parties.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new policy and updating the “Last Updated” date at the top of this document. Your continued use of the Services after any changes constitutes your acceptance of the new policy.

11. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:

Kortiva, LLC
9101 138th Place
Jamaica, NY 11435
Email: support@kortiva.com

For users in the European Economic Area: You may direct any data protection inquiries to support@kortiva.com.