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Privacy Policy – Arcfall

Last updated: December 5, 2025

22nd Century Dev OU ("Company", "we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile game Arcfall and related services (collectively, the "Game").

By installing, accessing, or using the Game, you agree to this Privacy Policy. If you do not agree, please do not use the Game.

1. Information We Collect

1.1. We may collect personal information that you provide directly to us, for example when you create an account, make a purchase, or contact support, including:

Account information – username, email address, password (if you register directly with us);
Third-party login information – identifiers and tokens provided by Apple ("Sign in with Apple") or Google ("Sign in with Google") when you choose those login options;
Guest account identifier – if you play without registration, we may assign a device-based or random ID to your profile;
Profile information – avatar, display name, in-game preferences;
Payment-related information – details about your in-app purchases (e.g. purchased items, transaction ID, price and currency, time of purchase). Payment card details are processed by Apple or Google and are not stored by us;
Communications with us – support requests, feedback, bug reports, and any information you choose to include.

1.2. When you use the Game, we automatically collect certain technical and usage information, such as:

Device information – device type and model, operating system and version, language and region, device identifiers where allowed by the platform;
Game usage data – gameplay statistics, progress, achievements, in-game purchases, in-game currency, session duration, frequency of play;
Log data – IP address, access times, in-game events, error messages;
Analytics and crash data – performance metrics, crash reports, diagnostic data from analytics/crash reporting tools integrated in the Game.

1.3. The Game and any in-game web views may use cookies, mobile identifiers, and similar tracking technologies (such as SDKs) to:

remember your settings and preferences;
measure usage and performance;
diagnose and fix technical issues.

1.4. You can usually control tracking at the device or operating system level (for example, by resetting advertising identifiers or limiting ad tracking where applicable). If you block or limit certain technologies, some features of the Game may not function properly.

2. How We Use Your Information

2.1. We use the information we collect for the following purposes:

To provide and operate the Game – to create and manage your account, save and synchronise your game progress, enable gameplay features, and process in-app purchases;
To maintain and improve the Game – to monitor performance, fix bugs and crashes, balance gameplay, and develop new features;
To communicate with you – to send technical notices, updates, security alerts, and respond to your comments, questions, and support requests;
To process transactions – to verify and record in-app purchases and deliver the purchased content;
To monitor and analyse usage – to understand usage patterns and trends and improve user experience;
To prevent abuse – to detect, prevent, and address technical issues, cheating, and fraudulent or abusive activity;
To personalise your experience – to remember your settings and present content in line with your preferences;
To send promotional communications – only where permitted by law and, where required, with your consent (you can opt out at any time).

2.2. Where required by applicable law (for example, in the EU/EEA or UK), we rely on legal bases such as:

performance of a contract (providing the Game and in-app purchases);
our legitimate interests (security, improvement, analytics, preventing abuse);
compliance with legal obligations;
your consent (for certain communications or optional tracking where needed).

3. Information Sharing and Disclosure

3.1. We may share your information in the following circumstances:

Service providers: with third-party service providers that perform services on our behalf, such as hosting, analytics, crash reporting, and customer support. These providers are authorised to use your information only as necessary to perform services for us.
Platform providers: with Apple and Google as independent controllers when you download the Game, sign in with Apple/Google, or make in-app purchases through their stores.
Legal requirements: if we are required to do so by law or in response to valid legal requests (such as a court order or request from authorities).
Business transfers: in connection with a merger, acquisition, reorganisation, or sale of all or part of our assets, your information may be transferred as part of that transaction.
With your consent: with third parties when you have given your consent or when you direct us to do so.

3.2. We do not sell your personal information to third parties.

4. Data Security

4.1. We implement appropriate technical and organisational measures to protect your information from unauthorised access, loss, misuse, or alteration. However, no method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.

5. Data Retention

5.1. We retain your information for as long as necessary to:

provide and operate the Game and related services;
comply with legal, accounting, or reporting obligations;
resolve disputes and enforce our agreements.

5.2. When information is no longer needed, we will delete it or anonymise it in a secure manner.

6. Your Rights and Choices

6.1. Depending on your location and subject to applicable law (in particular, the EU/EEA and UK data protection laws such as the GDPR), you may have some or all of the following rights in relation to your personal data:

Right of access – to obtain confirmation as to whether or not we process personal data concerning you and, if so, to receive a copy of such data and certain related information.
Right to rectification – to obtain without undue delay the correction of inaccurate personal data concerning you and to have incomplete personal data completed.
Right to erasure ("right to be forgotten") – to request the deletion of your personal data in certain circumstances (for example, when the data are no longer necessary for the purposes for which they were collected, or you withdraw consent and there is no other legal ground for processing).
Right to restriction of processing – to request that we restrict the processing of your personal data in certain cases (for example, while we are verifying the accuracy of the data or our legitimate interests).
Right to data portability – to receive the personal data concerning you which you have provided to us in a structured, commonly used and machine-readable format, and to transmit those data to another controller, where technically feasible.
Right to object – to object at any time, on grounds relating to your particular situation, to the processing of your personal data which is based on our legitimate interests, including profiling. We will no longer process your data unless we demonstrate compelling legitimate grounds which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims. You also have the right to object at any time if your personal data are processed for direct marketing purposes.
Right not to be subject to a decision based solely on automated processing, including profiling – to request that you are not subject to a decision based solely on automated processing which produces legal effects concerning you or similarly significantly affects you, unless certain conditions are met.
Right to withdraw consent – where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

6.2. To exercise any of these rights, please contact us using the details set out in Section 11. We may need to verify your identity before responding to your request.

6.3. If you are in the EU/EEA or UK, you also have the right to lodge a complaint with your local data protection authority if you believe that our processing of your personal data infringes applicable data protection law.

7. Children's Privacy

7.1. The Game is not intended for children under 13 years of age, or under the age of digital consent in your jurisdiction if higher. We do not knowingly collect personal information from children under that age.

7.2. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us and we will take appropriate steps to delete the information and, if necessary, close the account.

8. International Data Transfers

8.1. Your information may be transferred to and processed in countries other than your country of residence. These countries may have data protection laws that are different from those of your country.

8.2. Where we transfer personal data from the EU/EEA or UK to countries that do not provide an adequate level of protection, we will use appropriate safeguards (such as standard contractual clauses) or other mechanisms permitted by law.

9. Third-Party Services

9.1. The Game may contain links to third-party websites or services, or integrate third-party SDKs and tools. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party services you use.

10. Changes to This Privacy Policy

10.1. We may update this Privacy Policy from time to time. If we make material changes, we will notify you by updating the "Last updated" date at the top of this page and, where appropriate, by providing additional notice in the Game or by other means.

10.2. Your continued use of the Game after the effective date of the updated Privacy Policy constitutes your acceptance of the changes.

11. Contact Us

11.1. If you have any questions about this Privacy Policy or our privacy practices, or if you wish to exercise your rights, please contact us:

22nd Century Dev OU
Email: publisher@whitegames.io
Address: Vesivarava tn 50-201, Tallinn 10152, Estonia (EE)