Zen Color - Color By Number

"If you access the Services through a mobile device (e.g. a smart phone or tablet), we may be able to identify your devices' operating system, generic physical location and geographic regions of your device from your Wi-Fi, Bluetooth and other device settings, your mobile network information (e.g. eUICC ID, IMSI), and your mobile device's advertising ID, etc."

Collecting eUICC ID, IMSI (SIM card identifiers), Bluetooth settings, and advertising IDs goes well beyond what a puzzle/match game needs to function, enabling deep device fingerprinting.

"When you use our Services, we may infer the generic physical location and geographic regions of your device from your Wi-Fi, Bluetooth and other device settings. For example, your IP address may indicate your general geographic region. You may choose not to share your location details with us by adjusting your mobile or desktop device's location services settings."

The app passively infers location from Wi-Fi, Bluetooth, and other device settings — not just IP-based geolocation — which enables more precise location tracking than a casual game requires.

"Such information may include your Internet Protocol ("IP") address, device identifier, advertising identifier, MAC address, operating system, browser type, language preferences, referring and exiting pages, crash data, location data, purchasing activity, and other data regarding your activities on the Services."

Collecting advertising identifiers, MAC addresses, and device identifiers enables cross-service and cross-device tracking, and this data is shared with analytics and advertising partners for lookalike audiences and custom audience matching.

"We may disclose your personal information to business partners, co-sponsors of Promotions, and other third parties in order to provide you with Services that may interest you. We may share your personal information with marketing and advertising partners for targeted advertising purposes, such as matching custom audience or creating lookalike audience on social media or other marketing platforms."

Personal data is shared with a wide range of third parties including business partners, sponsors, analytics providers, and advertising partners for marketing, audience matching, and lookalike audience creation.

"We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. If you wish to cancel your account or request that we no longer use your information to provide you services, we may still retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements."

No specific retention timeline is provided, and data may be kept indefinitely after account cancellation under broad justifications like resolving disputes and enforcing agreements.

"We may make changes to this Privacy Policy from time to time and will post the date it was last updated at the top of this Privacy Policy. Any changes to this Privacy Policy will become effective on the "Last Updated" date indicated above. We will provide additional notice to you if we make changes to this Privacy Policy that materially affect your privacy rights."

Changes take effect immediately when posted, with additional notice only promised for 'material' changes — giving Oakever broad discretion to modify non-material terms without meaningful user consent.

"If you are not able to do so or if you wish to terminate and delete your account, you may contact us at privacy@oakevergames.com. Following receipt of a request from you, we will take reasonable steps to make changes or delete your information as required under the applicable law."

There is no in-app self-service account deletion option; users must email privacy@oakevergames.com and go through an identity verification process, creating friction around exercising deletion rights.