Privacy Policy

1. Overview and Scope

This Privacy Policy applies to all mobile games, applications, and digital products (collectively, "Games" or "Apps") developed and published by Elite Hexagone LLC ("we," "us," or "our"), as well as our website at elitehexagone.com.

This policy is designed to comply with the following laws and platform requirements:

• Google Play Store Developer Program Policies
• Apple App Store Review Guidelines (Section 5 — Privacy)
• General Data Protection Regulation (GDPR) — European Union / European Economic Area
• California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA)
• Children's Online Privacy Protection Act (COPPA) — United States
• Brazil's Lei Geral de Proteção de Dados (LGPD)
• UK Data Protection Act 2018 (UK GDPR)

By downloading, installing, or using any of our Games or Apps, you confirm that you have read and agree to this Privacy Policy. If you do not agree, please uninstall the Game or App and do not use our services.

2. Data Controller

Elite Hexagone LLC is the data controller responsible for the personal information collected through our Games and Apps.

• Legal Name: Elite Hexagone LLC
• Registration: Wyoming Secretary of State, USA
• Contact Email: privacy@elitehexag.one
• Address: 30 N Gould St Ste R, Sheridan, WY 82801, USA

3. Information We Collect

We collect the minimum data necessary to operate our Games and Apps. Here is a precise breakdown:

3.1 Information Collected Automatically

• Device Identifiers: Advertising ID (Google AAID / Apple IDFA or IDFV), device model, operating system version, and device type. These are used for analytics and advertising purposes only.
• Gameplay Data: Level progression, scores, achievements, in-game actions, session duration, and frequency of play. This data is used to improve game design and player experience.
• Technical Data: App version, crash logs, performance data (frame rate, load times), and error reports. Used exclusively for debugging and quality assurance.
• Network Data: IP address (for geolocation approximation at country/region level), network type (WiFi/cellular). We do not store full IP addresses.
• Advertising Data: Ad impressions, ad clicks, rewarded ad completions, and ad network interactions. This data is processed by our third-party ad network partners (see Section 6).

3.2 Information You Provide Voluntarily

• Player Name / Username: If our Games include user-created usernames or display names, this information is stored to personalize your experience.
• Email Address: Only if you voluntarily contact us for support, subscribe to our newsletter on our website, or create an account. We do not require email registration to play our games.
• Support Communications: If you contact us via email or our website contact form, we retain those communications to respond to your inquiry.

3.3 Information We Do NOT Collect

• Payment card numbers or banking information (all purchases are processed by Google Play Billing or Apple StoreKit)
• Social Security numbers or government-issued ID numbers
• Precise real-time location (GPS coordinates)
• Contacts, photos, camera, or microphone data (unless explicitly disclosed in a specific app)
• Biometric data of any kind

4. How We Use Your Information

We use collected data for the following purposes:

• Game Operation: To save your progress, synchronize data across sessions, and provide a functioning game experience.
• Analytics and Improvement: To understand how players interact with our games, identify bugs, measure feature engagement, and make data-driven improvements to game design.
• Advertising: To display relevant advertisements through our ad network partners. This includes frequency capping, fraud prevention, and measuring ad performance. You may opt out of personalized advertising at any time (see Section 11).
• Technical Support: To respond to support requests, investigate bugs, and resolve technical issues you report.
• Legal Compliance: To comply with applicable laws, regulations, and platform policies, and to respond to valid legal requests.
• Safety and Security: To detect and prevent cheating, fraud, and abuse within our games and services.

5. Legal Basis for Processing (GDPR)

For users in the European Economic Area (EEA) and the United Kingdom, we process your personal data under the following legal bases:

• Consent (Art. 6(1)(a) GDPR): Personalized advertising and analytics cookies. You may withdraw consent at any time through in-app privacy settings.
• Legitimate Interests (Art. 6(1)(f) GDPR): Fraud prevention, crash reporting, game security, and non-personalized analytics. We balance these interests against your rights.
• Legal Obligation (Art. 6(1)(c) GDPR): Where processing is required to comply with applicable law.
• Performance of a Contract (Art. 6(1)(b) GDPR): Processing necessary to fulfill in-app purchases and provide the services you have requested.

For players under 16 in EEA jurisdictions, we obtain verifiable parental consent before any data processing beyond strictly necessary operation, in compliance with Article 8 GDPR.

6. Third-Party Services and SDKs

Our games integrate the following third-party services. Each has its own privacy policy governing data it collects:

6.1 Advertising

• Google AdMob: We use AdMob to display ads in our free-to-play games. AdMob may collect the Android Advertising ID (AAID) or Apple's IDFA to serve personalized or non-personalized ads. Privacy policy: policies.google.com/privacy. You can opt out of personalized ads via your device's advertising settings.
• Google Ad Manager: Used for ad mediation and campaign management. Data processed in accordance with Google's data processing terms.

6.2 Analytics

• Google Firebase Analytics: Provides event-based analytics on player behavior, session data, and app performance. Data is aggregated and anonymized. Firebase Privacy: firebase.google.com/support/privacy
• Unity Analytics (where applicable): Collects gameplay metrics for games built with Unity engine. Unity Privacy Policy: unity.com/legal/privacy-policy

6.3 Crash Reporting

• Firebase Crashlytics: Automatically collects crash logs including device state at the time of crash. No personally identifiable information is intentionally included in crash reports.

6.4 In-App Purchases

• Google Play Billing (Android): All payment processing on Android is handled exclusively by Google. We receive transaction confirmations but never receive, process, or store payment card details. Google's privacy policy applies to all payment data.
• Apple StoreKit (iOS): All payment processing on iOS is handled exclusively by Apple. We receive purchase receipts for validation but never receive, process, or store payment card details. Apple's privacy policy applies to all payment data.

6.5 Cloud Services

• Google Firebase / Firestore: Used for cloud save functionality, leaderboards, and real-time features where applicable. Data is stored on Google-operated servers with encryption at rest and in transit.

7. Children's Privacy (COPPA Compliance)

The protection of children's privacy is extremely important to us. We comply with the Children's Online Privacy Protection Act (COPPA), and applicable international laws including GDPR-K (EEA) and the UK Age Appropriate Design Code.

7.1 Age Classification of Our Games

Each of our games carries a content rating assigned by Google Play and Apple App Store (e.g., "Everyone," "Everyone 10+," "Teen," "Mature 17+"). The applicable age rating is disclosed on each game's store page. For games rated "Everyone" that may attract users under 13:

• We do not knowingly collect personal information from children under 13 (or under 16 in the EEA).
• We configure Google AdMob to serve only non-personalized, COPPA-compliant, child-directed ads in applicable games.
• We disable behavioral advertising and interest-based advertising for child-directed app configurations.
• We do not use any persistent cross-app identifiers in child-directed content.
• We do not enable social features (chat, user profiles, friend lists) in child-directed games.

7.2 Parental Rights (COPPA)

If you believe your child under 13 has provided us with personal information without your consent, please contact us immediately at privacy@elitehexag.one. We will promptly delete such information upon verified request. Parents and guardians may also:

• Review personal information we have collected about their child
• Request deletion of their child's personal information
• Refuse to permit further collection of their child's information

8. Data Sharing and Disclosure

We do not sell, rent, or trade your personal information. We may share data in the following limited circumstances:

• Third-Party Service Providers: As described in Section 6, we share data with analytics, advertising, and infrastructure providers strictly for the purposes described in this policy, under data processing agreements that require them to protect your data.
• Legal Requirements: We may disclose information if required by law, regulation, subpoena, court order, or valid governmental request.
• Protection of Rights: To protect the rights, property, or safety of Elite Hexagone LLC, our players, or others. This includes exchanging information with other organizations for fraud protection and cheat detection.
• Business Transfers: In the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred to a successor entity, subject to the same privacy protections.
• Aggregate / Anonymized Data: We may share aggregated, anonymized statistical data (e.g., "our games have X million sessions per month") that cannot identify you personally.

9. In-App Purchases — Data Practices

Our games offer optional in-app purchases. Regarding purchases:

• All payment transactions are processed exclusively by Google Play (Android) or Apple StoreKit (iOS). Elite Hexagone LLC never receives, processes, or stores full payment card numbers or financial account information.
• We receive a transaction receipt and purchase token to verify and fulfill the purchase within the game.
• Purchase history (item purchased, date, amount) may be retained to provide purchase restoration and for tax/legal compliance purposes.
• Refund requests must be submitted directly to Google Play or Apple (via their respective support channels), as payment processors control refund eligibility.
• Virtual items (in-game currency, cosmetics, power-ups) have no real-world monetary value and cannot be exchanged for cash.

10. Data Retention

We retain personal data only as long as necessary for the purposes described in this policy:

• Game Progress Data: Retained while you actively use the game. Deleted or anonymized after 24 months of account inactivity.
• Analytics Data: Aggregated analytics are retained for up to 24 months. Raw event data is typically retained for 60 days before aggregation.
• Crash Reports: Retained for up to 90 days.
• Support Communications: Retained for up to 3 years for quality assurance and legal compliance.
• Purchase Records: Retained for 7 years for tax and legal compliance purposes.
• Advertising Data: Governed by the retention policies of our ad network partners (see Section 6).

11. Your Privacy Rights

11.1 All Users — General Rights

• Opt Out of Personalized Ads (Android): Go to Settings > Google > Ads > Opt out of Ads Personalization, or reset your Advertising ID.
• Opt Out of Personalized Ads (iOS): Go to Settings > Privacy & Security > Tracking, and disable "Allow Apps to Request to Track." Additionally, go to Settings > Privacy & Security > Apple Advertising and disable "Personalized Ads."
• Limit Ad Tracking: Your device's advertising settings allow you to limit tracking without disabling ads entirely.

11.2 EEA, UK, and Switzerland — GDPR Rights

If you are located in the EEA, UK, or Switzerland, you have the following rights under the GDPR:

• Right of Access (Art. 15): Request a copy of the personal data we hold about you.
• Right to Rectification (Art. 16): Request correction of inaccurate personal data.
• Right to Erasure / "Right to be Forgotten" (Art. 17): Request deletion of your personal data, subject to legal retention obligations.
• Right to Restriction of Processing (Art. 18): Request that we limit processing of your data in certain circumstances.
• Right to Data Portability (Art. 20): Receive your data in a structured, machine-readable format.
• Right to Object (Art. 21): Object to processing of your data for direct marketing or where we rely on legitimate interests.
• Right to Withdraw Consent: Withdraw consent for personalized advertising at any time without affecting prior processing.
• Right to Lodge a Complaint: You have the right to lodge a complaint with your local supervisory authority (e.g., ICO in the UK, CNIL in France, BfDI in Germany).

11.3 California Residents — CCPA/CPRA Rights

Under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), California residents have the following rights:

• Right to Know: Request disclosure of the categories and specific pieces of personal information collected about you in the past 12 months.
• Right to Delete: Request deletion of personal information we have collected, subject to certain exceptions.
• Right to Correct: Request correction of inaccurate personal information.
• Right to Opt-Out of Sale/Sharing: We do not sell personal information. We do share certain identifiers (Advertising ID) with ad network partners for advertising purposes. You may opt out via your device settings (see Section 11.1) or by contacting us at privacy@elitehexag.one.
• Right to Limit Use of Sensitive Personal Information: We do not collect sensitive personal information as defined under CPRA.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights.

Designated Methods for Submitting CCPA Requests: Email privacy@elitehexag.one or use our contact form at elitehexag.one/contact.html. We will respond within 45 days.

12. Data Security

We implement industry-standard technical and organizational security measures to protect your information:

• Encryption of data in transit using TLS 1.2 or higher
• Encryption of sensitive data at rest
• Access controls limiting data access to authorized personnel only
• Regular security reviews and vulnerability assessments
• Use of Google Cloud / Firebase infrastructure, which maintains ISO 27001, SOC 2, and other security certifications

Despite these measures, no system is 100% secure. In the event of a data breach that affects your rights or freedoms, we will notify affected users and relevant supervisory authorities as required by applicable law (within 72 hours under GDPR where applicable).

13. International Data Transfers

Elite Hexagone LLC is based in the United States. If you are located outside the US, your information may be transferred to, processed in, and stored in the United States and other countries where our service providers operate. For transfers from the EEA/UK to the US, we rely on:

• Standard Contractual Clauses (SCCs) approved by the European Commission, incorporated into our agreements with processors
• Adequacy decisions where applicable
• Google and Firebase's compliance with applicable cross-border transfer mechanisms

14. Platform-Specific Disclosures

14.1 Google Play — Data Safety Section

In compliance with Google Play's Data Safety requirements, our store listings disclose:

• Data types collected: Device or other IDs, App activity, App info and performance
• Data sharing: Shared with third parties (ad networks, analytics) for advertising and analytics purposes
• Security practices: Data encrypted in transit; data deletion available upon request
• Whether data collection is required: Analytics and crash reporting are required for app operation; personalized advertising is optional and can be opted out

14.2 Apple App Store — Privacy Nutrition Label

In compliance with Apple App Store privacy label requirements, we disclose the following data practices in our App Store listings. Precise disclosures vary by app and are listed on each individual App Store product page under the "App Privacy" section.

• Data Used to Track You: Advertising ID (if user consents via ATT prompt on iOS 14.5+)
• Data Linked to You: Purchases, game activity, crash data
• Data Not Linked to You: Device identifiers for non-personalized advertising

App Tracking Transparency (ATT): On iOS 14.5 and above, we display Apple's mandatory ATT prompt before accessing your IDFA for advertising purposes. You may deny tracking, in which case only non-personalized ads will be shown.

15. Cookies and Similar Technologies (Website)

Our website elitehexag.one may use cookies and similar technologies. Types used:

• Strictly Necessary Cookies: Required for basic website functionality. Cannot be disabled.
• Analytics Cookies: Used to understand how visitors interact with our site (Google Analytics). May be disabled by browser settings or cookie consent tools.
• Preference Cookies: Remember your settings. Can be managed through browser settings.

Our Games (mobile applications) do not use traditional browser cookies. Mobile equivalents (local storage, device identifiers) are disclosed in Section 3.

16. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technologies, legal requirements, or platform policies. When we make material changes, we will:

• Update the "Last Updated" date at the top of this policy
• Display an in-app notification or update notice for significant changes
• Where required by law, obtain fresh consent from affected users

We encourage you to review this policy periodically. Your continued use of our Games or Apps after any changes constitutes your acceptance of the updated policy.

17. Contact Us — Privacy Requests

For any privacy-related requests, questions, or concerns — including data access, deletion, correction, or opt-out requests — please contact our privacy team:

• Email (Privacy): privacy@elitehexag.one
• General Contact: contact@elitehexag.one
• Postal Address: Elite Hexagone LLC, 30 N Gould St Ste R, Sheridan, WY 82801, USA
• Contact Form: elitehexag.one/contact.html

We will respond to verifiable privacy requests within 30 days (or within the timeframe required by applicable law, e.g., 45 days under CCPA, 30 days under GDPR).