Privacy Policy

1. Who We Are

This Privacy Policy explains how Amphoteric LTD ("we", "us", "our") processes personal data when you use the mobile game Crom's Escape (the "Game").

Amphoteric LTD is the data controller for the purposes described in this Policy.

Contact:
Amphoteric LTD
Email: info@amphotericstudio.com

2. What Data We Process

We only process personal data that is necessary to operate and improve the Game.

2.1 Automatically Collected Data

When you use the Game, the following technical data may be processed:

Device information (device model, operating system version)
IP address (used for security and regional compliance purposes)
Android Advertising ID (only with consent, where applicable)
Gameplay data (level progress, in-game events, session duration)
Crash logs and diagnostic data (via Firebase Crashlytics)

2.2 Google Play Games (Optional Login)

If you choose to sign in with Google Play Games Services:

Display name
Player ID
Avatar URL

Your email address and account credentials are managed by Google and are not stored on our own servers.

2.3 Cloud Save and Leaderboards

If you use Google Play cloud save or leaderboards:

Game progress data
High scores

These are linked to your Google Play account and stored on Google's infrastructure.

2.4 In-App Purchases

All payments are processed by Google Play Billing.
We do not receive or store payment card details.

We may receive confirmation of successful transactions and purchased items.

3. Legal Basis for Processing (UK GDPR)

We rely on the following legal bases:

Purpose	Legal Basis
Providing gameplay features (including cloud save, leaderboards)	Article 6(1)(b) — Performance of a contract
Personalised advertising (if enabled)	Article 6(1)(a) — Consent
Analytics (if enabled)	Article 6(1)(a) — Consent
Security, fraud prevention, crash reporting	Article 6(1)(f) — Legitimate interests

Where consent is required, you may withdraw it at any time in the Game's privacy settings.

4. Children's Privacy

The Game is rated PEGI 3 and may be accessible to children.

We apply the principles of the UK Age Appropriate Design Code:

No direct collection of children's contact details
No location tracking
No behavioural profiling of children
For users identified as under 13, advertising is configured as non-personalised (using Google's TFCD/TFUA settings)

Analytics and personalised advertising are only activated where valid consent has been obtained in accordance with applicable law.

We do not knowingly collect personal data directly from children beyond what is necessary to provide the Game.

5. Third-Party Services and Data Recipients

The Game integrates services provided by Google and Unity.

Depending on the specific service used, these providers may act either:

As an independent data controller, or
As a processor acting on our behalf.

Integrated services include:

Google Play Games Services
Google Play Billing
Unity Ads (Unity Technologies)
Firebase Analytics
Firebase Crashlytics

Further details are available in the respective privacy documentation of Google and Unity.

We do not sell personal data.

6. International Data Transfers

Some data may be processed outside the United Kingdom, including in the United States.

Where personal data is transferred internationally, appropriate safeguards are used, such as:

The UK International Data Transfer Addendum to the EU Standard Contractual Clauses, and/or
Adequacy decisions recognised under UK law (where applicable).

These mechanisms ensure an appropriate level of data protection.

7. Data Retention

We retain personal data only as long as necessary:

Cloud save data: Until you delete it or your Google Play account remains active
Analytics data: Up to 14 months (Google default retention)
Crash logs: Approximately 90 days
Advertising-related data: Managed by Google in accordance with its own retention policies

Local data stored on your device remains until you uninstall the Game or clear app data.

8. Your Rights (UK GDPR)

You have the right to:

Access your personal data (Art. 15)
Rectify inaccurate data (Art. 16)
Request erasure (Art. 17)
Restrict processing (Art. 18)
Data portability (Art. 20)
Object to processing (Art. 21)
Withdraw consent at any time

Self-Service Deletion

Within the Game under:
Settings → Delete Data

This removes:

Local game progress
Cloud save data (via Google Play integration)
Leaderboard entries

For other requests, contact:
info@amphotericstudio.com

We respond within 30 days.

You also have the right to lodge a complaint with the UK Information Commissioner's Office (ICO):
https://ico.org.uk

9. Security Measures

We implement appropriate technical and organisational measures to protect personal data, including:

Encrypted data transmission (HTTPS)
Access controls and multi-factor authentication for administrative accounts
Restricted access to developer consoles

No system can guarantee absolute security, but we take reasonable steps to protect your information.

10. Data Breach Procedures

In the event of a personal data breach:

We assess the risk to users
We notify the ICO within 72 hours where required
We inform affected users where legally necessary

11. Automated Decision-Making

We do not carry out automated decision-making that produces legal or similarly significant effects on users under Article 22 UK GDPR.

12. California Privacy (CCPA/CPRA)

For users in California:

We do not sell personal information
Advertising identifiers may be shared with advertising partners in accordance with Google's Restricted Data Processing settings
You may exercise applicable rights by contacting us

13. Changes to This Policy

We may update this Privacy Policy from time to time.

Material changes will be communicated via an in-app notice.

The current version is always available in the Game settings and on our website.

14. Contact

Amphoteric LTD
Email: info@amphotericstudio.com

We respond to privacy inquiries within 30 days.