CCPA / CPRA Notice

Do Not Sell or Share My Personal Information

Last updated: 2026-07-27 (v1.0 launch)

Operator: Moru合同会社 (Moru LLC) — Representative: PARK DONGMIN (代表社員)

Summary: Sumdle does NOT sell personal information, and Sumdle does NOT share personal information for cross-context behavioral advertising as defined under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA). This page exists so California consumers have a clearly labeled "Do Not Sell or Share My Personal Information" disclosure as required by CPRA §§1798.135 and 1798.140(ad).

1. What "Sell" and "Share" Mean Here

Under the CCPA/CPRA:

"Sell" means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic means a consumer's personal information to a third party for monetary or other valuable consideration.
"Share" means disclosing personal information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.

2. Our Practices in v1.0

Sumdle v1.0 (released 2026-07-27) is free and ad-supported. Its data processing is limited to the categories listed in the Privacy Policy §2. With respect to "Sell" and "Share":

We do not sell personal information for monetary or other valuable consideration to any party.
We do not share personal information for cross-context behavioral advertising. Advertising via Google AdMob in Sumdle is performed using AdMob's service-provider configuration: AdMob is contractually restricted to use the data we pass it (after Apple App Tracking Transparency consent or the equivalent Android consent) solely to serve and measure ads inside Sumdle. When the user has not granted ATT consent, AdMob serves non-personalized ads, and no identifier suitable for cross-context behavioral advertising leaves the device.
If our practices ever change — for example, if a future release introduces an ad partner that requires "share for cross-context behavioral advertising" status — we will update this page before activating that flow and will provide an in-app and on-site opt-out control here.

3. How to Exercise Your Right

Because Sumdle does not sell or share personal information today, you do not need to submit an opt-out to stop a sale or share that is not happening. Nevertheless, California consumers may at any time:

Confirm our current Sell / Share status by emailing info@moru.tech with the subject line "CCPA Do Not Sell or Share — Confirmation Request".
Withdraw ad personalization consent at any time via your device privacy settings (iOS: Settings → Privacy & Security → Tracking → Sumdle → off; Android: Settings → Google → Ads → Opt out of Ads Personalization).
Submit a verifiable consumer request to access, delete, or correct your personal information by emailing info@moru.tech. Because Sumdle has no account login, we may ask for the PostHog anonymous ID shown inside the App (Settings → About → Diagnostic IDs) to locate your records.

We will respond within 45 days of receipt as required by the CCPA/CPRA, with one possible 45-day extension if reasonably necessary; we will explain the reason for any extension.

4. Authorized Agents

You may use an authorized agent to submit a request on your behalf. The agent must provide signed written permission from you. We may require you to verify your identity directly with us in addition.

5. Non-Discrimination

We will not deny you our services, charge you a different price, or provide a different level of quality because you exercised your CCPA/CPRA rights.

6. Categories Collected, Sources, Purposes, and Disclosures

See the Privacy Policy §2 (Information We Collect) and §4 (Third-Party Processors) for the full breakdown. Summary for California consumers:

Categories collected: Identifiers (pseudonymous IDs, IDFA/AAID after consent), Internet or other electronic network activity information (gameplay events, crash diagnostics), Commercial information (purchase records — v1.1+ only).
Sources: Directly from your interaction with the App.
Business or commercial purposes: Provide the App, debugging and quality improvements, advertising (service-provider basis), and legal compliance.
Categories disclosed for a business purpose: All of the above, to the sub-processors listed in the Privacy Policy §4, under service-provider contracts.
Categories sold or shared (cross-context behavioral advertising): None.
Categories of sensitive personal information collected: None within the meaning of CPRA §1798.140(ae).
Retention: See Privacy Policy §5.

7. Global Privacy Control (GPC)

Sumdle is a mobile application and does not browse the web on your behalf, so a browser-issued GPC signal is not directly observable inside the App. If you reach this page from a browser that transmits a GPC signal, Moru treats it as a confirmation that you do not want personal information sold or shared — which already matches the default behavior described above.

8. Contact

For questions about this notice or to submit a CCPA/CPRA request:

Email: info@moru.tech
Postal: Moru合同会社, 〒150-0043 東京都渋谷区道玄坂1丁目10番8号渋谷道玄坂東急ビル 2F-C, Japan.

Related disclosures: Privacy Policy · Terms of Use · 特定商取引法に基づく表記