Privacy Policy
Last updated: [EFFECTIVE_DATE]
This Privacy Policy explains how [LEGAL_ENTITY_NAME] ("Zorzen Studios", "we", "us") handles information in connection with the mobile game Splish (the "App") and the website at getsplish.app (the "Site"). It should be read together with our Terms of Use.
1. Who we are
The data controller is [LEGAL_ENTITY_NAME], [REGISTERED_ADDRESS]. For any privacy question or to exercise your rights, contact privacy@getsplish.app.
2. Our approach
Splish is designed to be local-first. We do not operate accounts, logins, or a backend server that stores your personal data. Your level progress, settings, and purchase status are stored on your device and, if you enable it, in your platform's own cloud backup (Apple iCloud or Google backup), which is governed by Apple's or Google's privacy terms, not ours.
3. Information processed, and why
3.1 Game and device data for advertising
The free version of the App shows ads served by Google AdMob. To do so, Google may process a mobile advertising identifier, coarse device and app information, and ad-interaction data. Where required (for example in the European Economic Area, the United Kingdom, and Switzerland), a Google User Messaging Platform (UMP) consent prompt is shown before any personalised-ads processing. On iOS, the App also presents Apple's App Tracking Transparency (ATT) prompt; if you decline, ads are non-personalised. See Google's policies at policies.google.com.
3.2 Analytics
We use Google Analytics for Firebase (GA4) to understand, in aggregate, how the App is used (for example which levels are completed) so we can improve difficulty and fix problems. This data is pseudonymous and is not used to identify you.
3.3 Purchases
The optional one-time "Splish Forever" purchase (price localized to your region) is processed by the Apple App Store or Google Play, and entitlement is managed through RevenueCat. We receive confirmation that a purchase or restore occurred; we do not receive or store your payment card details.
3.4 Support
If you email support, we process the message and your email address solely to respond.
4. Legal bases (EEA/UK GDPR)
- Consent — personalised advertising and any tracking that requires it.
- Legitimate interests — non-personalised advertising, aggregate analytics, and keeping the App secure and functional, balanced against your rights.
- Contract — processing a purchase or restoring it.
You may withdraw advertising consent at any time in the App's settings or your device settings.
5. Children
Splish is rated for everyone (4+) and applies family-safe ad content filters. It is not directed at children under [CHILD_AGE_THRESHOLD], and we do not knowingly collect personal information from children in a manner that would require verifiable parental consent under the Children's Online Privacy Protection Act (COPPA) or comparable laws. Where a mixed or child audience applies, ads are configured as non-personalised and tagged accordingly. If you believe a child has provided personal information, contact us and we will address it.
6. Sharing
We share data only with the service providers named above (Google, Apple, RevenueCat) acting as processors or independent controllers for their stated purposes, and where required by law. We do not sell your personal information, and we do not "share" it for cross-context behavioural advertising as those terms are defined under the California Consumer Privacy Act (CCPA/CPRA).
7. Your rights
Depending on where you live, you may have rights to access, correct, delete, or port your personal information, to object to or restrict certain processing, and to withdraw consent. California residents may exercise the rights described under the CCPA/CPRA, including the right to opt out of sale or sharing (which we do not do). To make a request, contact privacy@getsplish.app. You may also lodge a complaint with your local data protection authority.
8. Retention and transfers
We keep support correspondence only as long as needed to handle your request. Data processed by Google and Apple is retained under their own policies. Where data is transferred outside your region, our providers rely on mechanisms such as Standard Contractual Clauses.
9. Changes
We may update this Policy; material changes will be reflected by the "Last updated" date above and, where appropriate, noted in the App.
This document is a draft template and not legal advice. It contains placeholders in square brackets that must be completed, and should be reviewed by qualified legal counsel before publication.