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Privacy Policy — Animal Sound Match

Version 1 — Effective November 3, 2026

This privacy policy is applicable to the Animal Sound Match app for iOS and Android, together with any related services operated by Passu Studios (collectively, the "Application"). Passu Studios is hereinafter referred to as the "Service Provider".

Data Controller Information

Passu Studios acts as the Data Controller responsible for the processing of your personal data.

  • Name: Passu Studios
  • Email: support@passustudios.com

For data protection inquiries and to exercise your GDPR rights, please contact the Data Controller using the contact information above.

What information does the Application obtain and how is it used?

The Application does not offer registration or accounts, and it does not ask you to supply any personal information such as a name or email address. The Service Provider does not send marketing communications.

Legal basis for processing your personal data

Where the GDPR applies, the Service Provider relies on one or more lawful bases to process your personal data, including:

  • Contract performance: processing necessary to provide the Application or fulfil a contract with you.
  • Legitimate interests: where processing is necessary for the Service Provider's specific legitimate interests, such as maintaining network and information security, preventing fraud and abuse, or funding the free Application through contextual advertising, provided those interests are not overridden by your data protection rights or fundamental freedoms.
  • Legal obligation: to comply with laws or government requests.

Cookies and similar technologies

The Application or its third-party SDKs may use SDKs, identifiers, and similar technologies to support functionality and service delivery. Where required by law, the Service Provider will obtain consent before using non-essential tracking technologies.

Automated decision-making and profiling

The Application does not use automated decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you.

What information does the Application collect automatically?

The Application may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device's unique device ID, the IP address of your mobile device, your mobile operating system, and information about the way you use the Application.

On iOS, the Application does not request Apple's App Tracking Transparency permission and therefore has no access to the advertising identifier (IDFA). Advertising partners may process the identifier for vendors (IDFV), which is limited to the Service Provider's apps and cannot be used to track you across apps from other companies. On Android, advertising partners may process the Google advertising identifier when serving ads; because the Application is child-directed, they must not use it to build advertising profiles.

Does the Application collect precise real time location information of the device?

This Application does not gather precise information about the location of your mobile device.

Does the Application use Artificial Intelligence (AI) technologies?

The Application does not use Artificial Intelligence (AI) technologies to process your data or provide features.

Do third parties see and/or have access to information obtained by the Application?

Only aggregated, anonymized data is periodically transmitted to external services to aid the Service Provider in improving the Application and their service. The Service Provider may share your information with third parties in the ways that are described in this privacy statement.

International Data Transfers

The Service Provider or its third-party service providers may transfer personal data outside the European Economic Area (EEA). Where such transfers occur, the Service Provider will use an appropriate transfer mechanism required by GDPR Chapter V:

  • Adequacy decisions by the European Commission
  • Standard Contractual Clauses (SCCs) approved by the European Commission
  • Other safeguards or derogations recognized under GDPR Chapter V, including consent where legally permitted

Countries outside the EEA may not provide the same level of data protection as the EEA. Where required by law, the Service Provider will apply appropriate safeguards and obtain any consent required for the transfer.

Third-party services

Please note that the Application utilizes third-party services that have their own Privacy Policy about handling data. Below are the links to the Privacy Policy of the third-party service providers used by the Application:

Because the Application is made for children, the Service Provider signals the child-directed (COPPA) setting to its advertising partners. Advertising in the Application is therefore always non-personalized (contextual), and the advertising partners must not build advertising profiles of users.

The Service Provider may disclose Automatically Collected Information:

  • as required by law, such as to comply with a subpoena, or similar legal process;
  • when they believe in good faith that disclosure is necessary to protect their rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
  • with their trusted services providers who work on their behalf, do not have an independent use of the information the Service Provider discloses to them, and have agreed to adhere to the rules set forth in this privacy statement.

Where the GDPR applies, the Service Provider enters into Data Processing Agreements (DPAs) with third-party service providers that process personal data on its behalf, as required by Article 28 of the GDPR. These DPAs impose the same data protection obligations on those service providers as described in this Privacy Policy.

What are my opt-out rights?

You can stop further collection of information from your mobile device by uninstalling the Application. Uninstalling will stop the Application from collecting data from your device, but it does not automatically delete information that has already been transmitted to the Service Provider or to third parties.

To request deletion of your personal data, withdraw consent, or exercise any of your rights, contact the Service Provider at support@passustudios.com.

What is the data retention policy and how can you manage your information?

The Service Provider does not store personal data on its own servers. The Service Provider retains personal data based on its necessity for the stated purposes:

  • Automatically Collected Data: Retained by the third-party services for up to 24 months from collection, or the shorter periods stated in their own policies, unless longer retention is required for legal compliance or security purposes
  • Aggregated and Anonymized Data: Retained indefinitely as it no longer identifies you
  • Data required for legal compliance: Retained as long as required by applicable law

Game progress and settings are stored only on your device and are deleted when you delete the Application.

Data Deletion

You can request deletion of your personal data by contacting the Service Provider at support@passustudios.com. The Service Provider will process your request within the timeframes required by applicable law.

Because the Application has no accounts, the Service Provider usually cannot identify which data belongs to you or your child. In that case the Service Provider will tell you and help you direct the request to the third-party service provider (Unity), who can act on device-level identifiers.

How does the Application address children's privacy?

The Application is designed for children and treats all users as children:

  • Advertising is always non-personalized. The Service Provider signals the child-directed (COPPA) setting to its advertising partners, which prohibits them from building advertising profiles.
  • The Application offers no accounts, no chat, no social features, and no free-text input.
  • External links and purchase information are placed behind a parent gate intended for adults.

The Service Provider does not knowingly collect personal information from children beyond the automatically collected technical data described above. If you are a parent or guardian and believe the Application has collected personal information from your child, or you would like it reviewed or deleted, please contact the Service Provider at support@passustudios.com so that they will be able to take the necessary actions.

How is your information kept secure?

The Service Provider is committed to safeguarding the confidentiality of your information. The Service Provider implements physical, electronic, and procedural safeguards to protect information it processes and maintains. Access is limited to authorized persons who need to know that information to operate, develop, or improve the Application. However, no security system can prevent all potential security breaches.

Data Breach Notification

In the event of a personal data breach that poses a risk to your rights and freedoms, the Service Provider will notify the relevant supervisory authority within 72 hours of becoming aware of the breach, as required by applicable law. Where the breach is likely to result in a high risk to your rights and freedoms, the Service Provider will also notify you without undue delay, providing information about the nature of the breach, the categories of data affected, and the measures taken or proposed to address the breach.

How will you be informed of changes to this Privacy Policy?

The Service Provider may update this Privacy Policy from time to time. The Service Provider will notify you of material changes by posting the updated Privacy Policy at this address with a new version number and effective date. Where required by law, the Service Provider will seek your consent to material changes before they take effect.

Previous versions of this Privacy Policy will be maintained and made available upon request by contacting the Service Provider at support@passustudios.com.

This privacy policy is effective as of November 3, 2026.

What are your GDPR data protection rights?

Under the GDPR, you have the following rights:

  • Right of Access: You can request access to your personal data.
  • Right to Rectification: You can request correction of inaccurate data.
  • Right to Erasure: You can request deletion of your personal data (the "right to be forgotten").
  • Right to Restrict Processing: You can request that the Data Controller limits how they use your data.
  • Right to Data Portability: You can request a copy of your data in a structured, commonly used, machine-readable format.
  • Right to Object: You can object to processing based on legitimate interests. You have an absolute right to object to processing for direct marketing purposes at any time.
  • Right to Withdraw Consent: Where processing is based on your consent, you can withdraw it at any time.

If you believe your data protection rights have been violated, you have the right to lodge a complaint with your local Data Protection Authority. Contact details for each country's Data Protection Authority can be found at: https://edpb.ec.europa.eu/about-edpb/members_en

If you are located in the United Kingdom, you may contact the Information Commissioner's Office at https://ico.org.uk

What are your California privacy rights (CCPA/CPRA)?

If you are a resident of California, the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) provide you with additional rights regarding your personal information:

  • Right to Know: You can request disclosure of the categories and specific pieces of personal information the Service Provider has collected about you.
  • Right to Delete: You can request deletion of personal information the Service Provider has collected from you, subject to certain exceptions.
  • Right to Correct: You can request correction of inaccurate personal information.
  • Right to Opt-Out: You can opt out of the sale or sharing of your personal information for cross-context behavioral advertising. The Service Provider does not sell personal information and does not share it for cross-context behavioral advertising.
  • Right to Non-Discrimination: The Service Provider will not discriminate against you for exercising any of your CCPA/CPRA rights.

To exercise any of these rights, please contact the Service Provider at support@passustudios.com. The Service Provider will verify your request using the information you provide and respond within the timeframes required by law. You may designate an authorized agent to make a request on your behalf.

How do you give your consent?

Where processing is based on consent, you provide that consent by affirmatively opting in to the relevant feature or action. You may withdraw consent at any time without affecting processing carried out before withdrawal. Processing based on other lawful bases, including contract performance, legitimate interests, or legal obligations, is carried out as described above.

How can you contact the Data Controller?

If you have any questions regarding privacy while using the Application, or have questions about the practices, please contact the Service Provider via email at support@passustudios.com.

To request deletion of your personal data or to exercise any of your rights, contact the Service Provider using the details provided above. The Service Provider will respond within one month of receiving your request, extendable by up to two months where necessary due to the complexity or volume of requests, as permitted by applicable law.

This document is based on the template from the open-source App Privacy Policy Generator, adapted for a child-directed application.