Privacy Policy

1. Who is responsible for your data

This policy is issued by LERON COMPANY, trading as Leron Company, registered at [COMPANY ADDRESS], company number 5 - 1286992 / 002. For the purposes of applicable data protection law, LERON COMPANY is the controller of the personal data described here.

Data controller

[DATA CONTROLLER INFORMATION — legal entity, address, registration]

Privacy contact

info@leroncompany.com

Data protection officer

[DPO NAME AND CONTACT, OR "NOT APPOINTED — NOT REQUIRED BECAUSE …"]

EU / UK representative

[ARTICLE 27 REPRESENTATIVE, IF APPLICABLE]

Supervisory authority

[LEAD SUPERVISORY AUTHORITY AND COMPLAINT ROUTE]

2. What this policy covers

This policy covers the Leron Company website and the Leron Company games listed below. Each game differs in what it collects, so the per-game sections state the actual position for that title. Where a game collects nothing, that is stated plainly rather than omitted.

3. What we collect

The categories below follow the same vocabulary as the Apple App Privacy data types and the Google Play Data safety data categories, so that this policy, the store declarations and the in-app disclosure all say the same thing.

What we do not collect

• Payment card numbers. Purchases are processed entirely by Apple or Google.
• Precise location.
• Contacts, calendar, photos, microphone or camera data.
• Health, biometric or other special-category data.
• [CONFIRM EACH LINE AGAINST THE ACTUAL SDK INVENTORY BEFORE PUBLISHING]

4. Why we process it

5. Who else sees it

We share personal data only with the processors listed in §6, and only for the purposes in §4. We do not sell personal data, and we do not share it with data brokers.

• Service providers acting on our instructions under a written data processing agreement.
• Apple and Google, in their own right, for store, purchase and delivery functions.
• Professional advisers, where necessary and under confidentiality.
• Authorities, where we are legally required to disclose. [DISCLOSURE POLICY / TRANSPARENCY REPORTING — TO BE CONFIRMED]
• A successor entity, in the event of a merger or acquisition. [TO BE CONFIRMED]

6. Third-party services and SDKs

Every SDK embedded in a Leron Company game or on this website must appear in the table below with its purpose, the data it receives and a link to its own policy. An SDK that is not in this table must not ship.

7. Analytics

We use aggregate analytics to see which parts of a game people reach and where they stop. [ANALYTICS PROVIDER] processes this on our behalf under [PROCESSING AGREEMENT REFERENCE].

• Event list: [SPECIFY THE FULL EVENT LIST — no "and similar"]
• Retention in the analytics system: [DATA RETENTION PERIOD]
• Identifier used: [PSEUDONYMOUS ID / DEVICE ID — SPECIFY]
• How to opt out in-game: [IN-GAME ANALYTICS OPT-OUT LOCATION]
• How to opt out on this website: the Privacy Choices page.

8. Advertising

None of the current Leron Company titles serve third-party advertising, and none share data with advertising networks or data brokers.

If a future title includes advertising, this section will state the networks, the data they receive, the consent mechanism and the opt-out route before that title is released, and the corresponding store declarations will be updated in the same release. [ADVERTISING POSITION PER TITLE — CONFIRM AT EACH SUBMISSION]

9. Purchases

In-app purchases are processed by Apple or Google. We receive a receipt and a transaction identifier so that we can grant what you bought and honour it on your other devices. We never receive your card number, billing address or bank details.

• Refunds are handled by the store you purchased from, not by us.
• Transaction records are retained for [DATA RETENTION PERIOD — TAX / ACCOUNTING] to meet tax and accounting obligations, and survive account deletion for that reason.
• Entitlement records are deleted with the account, subject to the line above.

10. International transfers

Personal data is stored in [HOSTING REGION(S)] and processed by providers located in [PROCESSOR REGIONS]. Where data leaves [PRIMARY JURISDICTION], the transfer relies on [TRANSFER MECHANISM — e.g. STANDARD CONTRACTUAL CLAUSES / ADEQUACY DECISION], and a copy of the safeguards can be requested from info@leroncompany.com.

11. How long we keep it

12. Security

• Data in transit is encrypted with TLS. [CONFIRM COVERAGE — this is also a Data safety question]
• Data at rest: [ENCRYPTION AT REST POSITION]
• Access control: [ACCESS CONTROL AND LEAST-PRIVILEGE POLICY]
• Retention and deletion automation: [DELETION PIPELINE DESCRIPTION]
• Incident response and breach notification: [INCIDENT RESPONSE PROCESS AND NOTIFICATION TIMELINE]
• Security reporting: report a vulnerability privately to info@leroncompany.com. [VULNERABILITY DISCLOSURE POLICY URL]

13. Children

Our age ratings are set per title and shown on each game page and store listing. [STATE THE MINIMUM AGE FOR ACCOUNT CREATION PER JURISDICTION].

• Titles in a families programme: [LIST — currently Tidecaller is flagged for review]
• Verifiable parental consent mechanism, where required: [MECHANISM]
• Behavioural advertising to children: not used, in any title.
• How a parent or guardian can request access or deletion on a child’s behalf: [PARENT / GUARDIAN REQUEST PROCESS], or use the Account & Data Deletion page and say so in the request.
• Applicable regimes to confirm: [COPPA / GDPR ART. 8 / OTHER — CONFIRM PER TERRITORY]

14. Your rights

Depending on where you live, you may have some or all of the following rights. We do not charge for exercising them and we do not degrade your experience for doing so.

• Access — a copy of the personal data we hold about you.
• Rectification — correction of data that is wrong.
• Erasure — deletion of your account and associated data, subject to §15.
• Restriction — pausing our processing while a dispute is resolved.
• Portability — your data in a machine-readable format.
• Objection — to processing based on legitimate interests.
• Withdrawal of consent — at any time, where processing relies on consent.
• Opt out of sale or sharing — we do not sell or share personal data, so there is nothing to opt out of; the route exists anyway.
• Complaint — to [LEAD SUPERVISORY AUTHORITY] or your local authority.

Submit any of these from the Privacy Choices page, or by e-mail to info@leroncompany.com. We respond within [STATUTORY RESPONSE PERIOD] and will tell you if we need to extend that, and why.

15. Deleting your account and data

Every Leron Company title that lets you create an account also lets you delete it, both inside the game and from this website. The in-game route is Settings → Account → Delete account. The web route is the Account & Data Deletion page, which is the URL we supply to Google Play for the account-deletion field.

What deletion means

• The account itself is removed, not deactivated, disabled or frozen.
• Progress, entitlements, leaderboard entries and stored settings tied to the account are deleted.
• Support correspondence linked to the account is deleted, subject to the exceptions below.
• Deletion is irreversible. We cannot restore a deleted account, including its purchases.

What survives deletion, and why

16. Store disclosures

The declarations we make to the two stores must always match this policy. This section records where each one lives so a discrepancy is findable.

17. Changes to this policy

We will post any change here with a new "last updated" date. Where a change materially affects how we use data you have already given us, we will tell you in-game before it takes effect and, where the law requires it, ask for consent again rather than assume it.

Previous versions are archived at [POLICY ARCHIVE URL].

18. Contact

E-mail

info@leroncompany.com — privacy requests, player support and security reports

Postal address

[COMPANY ADDRESS]

Data protection officer

[DPO NAME AND CONTACT, IF APPOINTED]