Privacy Policy

Effective Date: August 4, 2025 | Last Updated: August 4, 2025

1. Introduction

SEABIRD Games ("we," "our," or "us") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile games and visit our website.

This policy complies with:

  • General Data Protection Regulation (GDPR) - European Union
  • California Consumer Privacy Act (CCPA) - United States
  • Personal Information Protection Law (PIPL) - China
  • Lei Geral de Proteção de Dados (LGPD) - Brazil
  • Other applicable privacy laws worldwide

2. Information We Collect

2.1 Information You Provide Directly

  • Contact Information: Email address, name when you contact us
  • Communication Data: Messages, feedback, and support requests
  • Account Information: Game progress, preferences, and settings

2.2 Information Collected Automatically

Data Type Purpose Legal Basis (GDPR) Retention Period
Device Information Game optimization, compatibility Legitimate Interest 2 years
Usage Analytics Improve gameplay experience Legitimate Interest 13 months
Crash Reports Bug fixing, stability Legitimate Interest 6 months
IP Address Security, fraud prevention Legitimate Interest 12 months

2.3 Third-Party Information

  • Google Play Games Services: Achievements, leaderboards
  • Apple App Store & Game Center: Purchases, achievements, multiplayer data
  • Advertising Partners: Ad performance metrics (anonymized)
  • Analytics Providers: Usage patterns and trends
  • Payment Processors: Transaction data (Apple, Google)

2.4 Apple Subscription Data

When you subscribe to premium features through the Apple App Store, we collect:

Data Type Source Purpose Retention Period
Subscription Status Apple App Store Verify premium access, prevent fraud Active subscription + 1 year
Transaction ID Apple App Store Transaction verification, support 7 years (tax compliance)
Purchase Timestamp Apple App Store Access management, analytics Active subscription + 2 years
Product Identifier Apple App Store Feature activation, billing support Active subscription + 1 year
App Store Country Apple App Store Regional compliance, tax calculation 7 years (tax compliance)

Note: We do not collect or store your Apple ID, payment methods, or billing address. This information is managed exclusively by Apple.

3. How We Use Your Information

We use your information for the following purposes:

  • Game Operation: Provide game services, save progress, enable features
  • Customer Support: Respond to inquiries and provide assistance
  • Analytics & Improvement: Understand user behavior to enhance games
  • Security: Detect fraud, abuse, and ensure platform security
  • Legal Compliance: Meet legal and regulatory requirements
  • Marketing: Send updates about new games (with consent)
  • Subscription Management: Process Apple/Google subscriptions and in-app purchases

3A. Data Compliance Framework

3A.1 Legal Basis for Data Processing

Processing Activity Legal Basis (GDPR) CCPA Category PIPL Legal Basis Consent Required
Game Service Provision Contract Performance (Art. 6(1)(b)) Service/Performance Contract Performance No
Apple Subscription Processing Contract Performance (Art. 6(1)(b)) Commercial Information Contract Performance No
Customer Support Legitimate Interest (Art. 6(1)(f)) Service/Performance Legitimate Interest No
Game Analytics Legitimate Interest (Art. 6(1)(f)) Usage Data Legitimate Interest Soft Consent
Marketing Communications Consent (Art. 6(1)(a)) Marketing Information Explicit Consent Yes
Security & Fraud Prevention Legitimate Interest (Art. 6(1)(f)) Security Data Legitimate Interest No
Legal Compliance Legal Obligation (Art. 6(1)(c)) Legal Compliance Legal Obligation No

3A.2 Data Minimization Principles

  • Collection Limitation: We only collect data necessary for specified purposes
  • Purpose Limitation: Data is used only for the purposes it was collected
  • Storage Limitation: Data is kept only as long as necessary
  • Quality Assurance: We ensure data accuracy and completeness
  • Proportionality: Processing is proportionate to the intended purpose

3A.3 Consent Management

  • Granular Consent: Separate consent for different processing purposes
  • Explicit Consent: Clear affirmative action required
  • Informed Consent: Plain language explanations provided
  • Withdrawable Consent: Easy withdrawal mechanism available
  • Documented Consent: Consent records maintained
  • Age-Appropriate Consent: Special provisions for minors

3A.4 Regional Compliance Specifics

🇪🇺 GDPR Compliance

  • Data Protection Officer appointed
  • Privacy by Design implementation
  • Data Protection Impact Assessments
  • 72-hour breach notification
  • Right to be forgotten enforcement

🇺🇸 CCPA Compliance

  • Do Not Sell opt-out available
  • Consumer rights request portal
  • Third-party disclosure tracking
  • Non-discrimination policy
  • California resident verification

🇨🇳 PIPL Compliance

  • Explicit consent for cross-border transfers
  • Local data representative
  • Personal data impact assessments
  • CAC reporting compliance
  • Data localization requirements

🇧🇷 LGPD Compliance

  • Data Protection Officer (DPO)
  • ANPD authority notifications
  • Sensitive data special handling
  • Data impact assessment reports
  • Cross-border transfer safeguards

3A.5 Data Retention Schedule

Data Category Retention Period Deletion Trigger Legal Requirement
Game Progress Data Account active + 2 years Account deletion request User consent withdrawal
Apple Subscription Data 7 years from last transaction Tax compliance period end Financial record keeping laws
Support Communications 3 years from resolution Legal limitation period Customer service quality
Analytics Data (Anonymized) 26 months maximum Statistical analysis complete GDPR Article 89
Security Logs 12 months Security threat analysis Incident investigation needs
Marketing Consent Until withdrawal User opt-out action Consent management requirement

4. Information Sharing and Disclosure

We do not sell your personal information. We may share information in these circumstances:

4.1 Service Providers

  • Google Play Services: Game features and analytics
  • Cloud Storage Providers: Data backup and synchronization
  • Analytics Services: Firebase Analytics, Google Analytics
  • Customer Support Tools: Help desk and ticketing systems

4.2 Legal Requirements

We may disclose information if required by law, legal process, or to:

  • Comply with legal obligations
  • Protect our rights and property
  • Ensure user safety and security
  • Investigate potential violations

4.3 Apple App Store Integration

When using Apple services, certain data is shared with Apple under their Privacy Policy:

  • Purchase Verification: Transaction receipts shared for subscription validation
  • App Store Analytics: Aggregate usage data (anonymized)
  • Crash Reports: Technical data for app stability improvement
  • Game Center Data: Achievements and leaderboard information (if enabled)

4A. Apple Subscriptions & In-App Purchases

4A.1 Subscription Processing

Our premium features are available through Apple App Store subscriptions. Here's how we handle your subscription data:

What We Collect:

  • Subscription Status: Active, expired, cancelled, or pending renewal
  • Product Identifier: Which premium features you've purchased
  • Transaction Information: Purchase date, expiration date, renewal status
  • Receipt Data: Apple-provided verification data (encrypted)
  • Regional Information: App Store country/region for tax compliance

What We DON'T Collect:

  • ❌ Your Apple ID or personal Apple account information
  • ❌ Payment methods (credit cards, PayPal, etc.)
  • ❌ Billing addresses or contact information
  • ❌ Purchase history from other apps
  • ❌ Financial information or payment credentials

4A.2 Apple Privacy Labels Compliance

Our app's Apple Privacy Label accurately reflects our data collection practices:

Data Category Collected Linked to You Used for Tracking Purpose
Purchase History ✅ Yes ✅ Yes ❌ No App Functionality
Game Progress ✅ Yes ✅ Yes ❌ No App Functionality
Usage Data ✅ Yes ❌ No ❌ No Analytics
Crash Data ✅ Yes ❌ No ❌ No App Functionality
Device Information ✅ Yes ❌ No ❌ No App Functionality

4A.3 Subscription Management

Auto-Renewal

  • Subscriptions automatically renew through Apple unless cancelled
  • You can manage subscriptions in iOS Settings > Apple ID > Subscriptions
  • Cancellation takes effect at the end of the current billing period
  • We do not control Apple's billing process or payment methods

Family Sharing

  • Premium features may be shared with family members if enabled
  • Family sharing is managed entirely by Apple
  • We verify subscription status but don't access family member data
  • Each family member's game progress remains separate

Subscription Verification

  • We verify subscriptions with Apple's servers in real-time
  • Verification data is cached temporarily for offline play
  • Receipt validation protects against subscription fraud
  • No subscription data is shared with third parties

4A.4 Refunds and Customer Support

Apple Refund Policy

  • All subscription refunds are handled by Apple
  • Contact Apple Support for billing issues or refund requests
  • We cannot process refunds directly
  • Refund eligibility determined by Apple's policies

Our Support for Subscription Issues

  • Help with subscription feature access problems
  • Guidance on managing subscriptions in iOS Settings
  • Troubleshooting premium feature activation
  • Assistance with restoring purchases on new devices

4A.5 Data Retention for Subscriptions

Data Type Retention Period Reason Deletion Process
Active Subscription Data Duration of subscription Service provision Automatic upon cancellation
Transaction Records 7 years from purchase Tax and legal compliance Automatic after retention period
Premium Feature Usage Subscription + 1 year Customer support Manual upon request or automatic
Receipt Validation Cache 30 days maximum Offline functionality Automatic cache expiration

4A.6 Your Subscription Rights

🔐 Privacy Rights Specific to Subscriptions:

  • Access: Request details about your subscription data we hold
  • Correction: Update subscription-related account information
  • Deletion: Request deletion of subscription history (subject to legal requirements)
  • Portability: Export your premium content and game progress
  • Restriction: Limit processing of subscription data for specific purposes

📱 Apple-Specific Rights:

  • Subscription Control: Manage all subscriptions through iOS Settings
  • Receipt Access: View purchase history in App Store
  • Family Sharing Control: Enable/disable sharing of subscriptions
  • Notification Preferences: Control subscription renewal notifications

Important: While we handle the technical aspects of subscription verification and premium feature access, Apple maintains full control over the billing relationship, payment processing, and subscription management interface.

5. Your Rights Under GDPR and Other Laws

If you are in the EU, EEA, UK, or other applicable regions, you have the following rights:

5.1 Data Subject Rights

  • Right of Access: Request copies of your personal data
  • Right to Rectification: Correct inaccurate or incomplete data
  • Right to Erasure: Request deletion of your data ("right to be forgotten")
  • Right to Restrict Processing: Limit how we use your data
  • Right to Data Portability: Receive your data in a portable format
  • Right to Object: Object to processing based on legitimate interests
  • Right to Withdraw Consent: Withdraw consent at any time

5.2 California Residents (CCPA)

  • Right to know what personal information is collected
  • Right to delete personal information
  • Right to opt-out of the sale of personal information
  • Right to non-discrimination for exercising privacy rights

5.3 How to Exercise Your Rights

To exercise any of these rights, contact us at: seabird1533@gmail.com

We will respond to your request within 30 days (GDPR) or 45 days (CCPA).

6. Cookies and Tracking Technologies

We use cookies and similar technologies to:

  • Essential Cookies: Enable basic website functionality
  • Analytics Cookies: Understand how you use our website
  • Preference Cookies: Remember your settings and preferences

You can control cookies through your browser settings. Note that disabling cookies may affect website functionality.

7. Children's Privacy

Our games are designed for general audiences. We do not knowingly collect personal information from children under 13 (or applicable age in your jurisdiction). If we discover we have collected information from a child, we will delete it promptly.

Parents and guardians: If you believe your child has provided us with personal information, please contact us immediately.

8. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place:

  • EU-US Data Privacy Framework (for US transfers)
  • Standard Contractual Clauses (SCCs)
  • Adequacy Decisions by the European Commission
  • Other appropriate safeguards as required by law

9. Data Security

We implement appropriate technical and organizational measures to protect your data:

  • Encryption: Data encrypted in transit and at rest
  • Access Controls: Limited access on a need-to-know basis
  • Regular Audits: Security assessments and vulnerability testing
  • Secure Infrastructure: Industry-standard security practices
  • Incident Response: Procedures for security breach notifications

10. Data Retention

We retain your information only as long as necessary for:

  • Providing our services
  • Complying with legal obligations
  • Resolving disputes
  • Enforcing our agreements

General retention periods:

  • Account data: Until account deletion + 30 days
  • Support communications: 3 years
  • Analytics data: 13-26 months
  • Legal compliance data: As required by law

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will:

  • Post the updated policy on our website
  • Update the "Last Updated" date
  • Notify you of material changes via email or in-game notification
  • Provide additional notice as required by applicable law

Your continued use of our services after changes constitutes acceptance of the updated policy.

12. Contact Information

Data Controller: SEABIRD Games

Privacy Contact: seabird1533@gmail.com

General Contact: seabird1533@gmail.com

Data Protection Officer (DPO)

For GDPR-related inquiries, contact our DPO:

Email: seabird1533@gmail.com

Supervisory Authority

EU residents have the right to lodge a complaint with their local data protection authority. You can find your local authority at: https://edpb.europa.eu/about-edpb/board/members_en

Response Time

We will respond to privacy-related inquiries within:

  • GDPR requests: 30 days (may be extended by 60 days for complex requests)
  • CCPA requests: 45 days (may be extended by 45 days)
  • General inquiries: 7 business days

This Privacy Policy is available in multiple languages and formats upon request.

Thank you for trusting SEABIRD Games with your information. We are committed to protecting your privacy and providing transparent, compliant data practices.

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