Privacy Policy

Effective Date: 8 April 2026

1. Introduction

This Privacy Policy applies to all games, websites, and related services (collectively, the "Services") published by Sterren IT on behalf of the game's developer ("Developer"). The game and its underlying content are owned and developed by the Developer. Sterren IT acts solely as the publisher and distributor of the Services. Your continued use of the Services after the effective date will be subject to this Privacy Policy.

We are committed to being transparent about how personal data is collected and used in connection with the Services. Please read the following to learn more about the applicable data practices.

2. Data Controller

For the purpose of the General Data Protection Regulation (EU) 2016/679 ("GDPR") and applicable Dutch data protection legislation, Sterren IT is the data controller responsible for your personal data collected through the Services.

Sterren IT acts solely as the publisher and distributor of the Services. The game and its underlying content are developed and maintained by a third-party developer ("Developer"). All data protection requests, complaints, and enquiries received by Sterren IT will be immediately forwarded to the Developer for handling. Sterren IT will ensure that the Developer responds to such requests within the timeframes required by applicable law.

If you have any questions or concerns about this Privacy Policy or the processing of your personal data, please contact us at the email address above. All requests will be immediately forwarded to the Developer and handled without undue delay.

3. What Personal Data Is Collected

The following categories of personal data may be collected and processed through the Services:

A. Data You Provide

• Contact information (such as name, nickname, or email address if you contact our support team)
• Messages and communications you send to us (such as support tickets, chat messages, or feedback)
• Any other information you choose to provide to us

B. Data We Collect Automatically

• A unique player identifier we create when you use our Services
• Device information (such as device model, operating system, browser type, and language settings)
• IP address and unique device identifiers (such as device ID, advertising ID)
• Location data (country or region level) to place you on the appropriate leaderboard
• Game progress, account data, and in-game events
• Usage data and analytics (collected via Firebase Analytics)
• Purchase history and transaction details (if applicable)
• Data to detect and prevent fraud

4. How Personal Data Is Used

Personal data collected through the Services is used for the following purposes:

Purpose	Lawful Basis
To provide our games and services to you	Contract performance
To manage your account and provide customer support	Contract performance / Legitimate interest
To place you on the correct regional leaderboard	Legitimate interest
To analyse usage patterns and improve our games	Legitimate interest
To ensure security and prevent fraud	Legitimate interest
To send you service-related communications	Contract performance
To send you marketing communications (where opted in)	Consent
To comply with legal obligations	Legal obligation

5. Who Data Is Shared With

Personal data may be shared with the following categories of recipients:

• The Developer: The Developer receives and processes personal data collected through the game on behalf of Sterren IT, as the party responsible for the game's development, maintenance, and operation.
• Service providers: Third parties that help operate the Services, including analytics providers (such as Google Firebase), cloud hosting providers, payment processors, and customer support platforms.
• Professional advisers: Lawyers, accountants, auditors, and insurers where necessary.
• Law enforcement and regulators: Where required by law or to protect our legal rights.
• Business transfers: In connection with any merger, acquisition, or sale of assets.

6. International Data Transfers

Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA). Where we transfer data outside the EEA, we ensure appropriate safeguards are in place, including standard contractual clauses approved by the European Commission and other lawful transfer mechanisms as required by the GDPR.

7. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including for as long as you use our Services, as required by law, or as necessary to resolve disputes and enforce our agreements.

8. Your Rights

Under applicable data protection law, you have the following rights:

• Right of access: Request a copy of the personal data we hold about you.
• Right to rectification: Ask us to correct inaccurate or incomplete data.
• Right to erasure: Ask us to delete your personal data in certain circumstances.
• Right to restriction: Ask us to limit how we use your data.
• Right to data portability: Request your data in a structured, machine-readable format.
• Right to object: Object to our processing of your data based on legitimate interests.
• Right to withdraw consent: Where we rely on consent, you can withdraw it at any time.

To exercise any of these rights, please contact us at support@pdevs.net. All requests will be immediately forwarded to the Developer for processing. We will respond to your request within one (1) month of receipt, as required by the GDPR. In exceptional cases, this period may be extended by two further months, in which case we will inform you.

You also have the right to lodge a complaint with a supervisory authority. As Sterren IT is established in the Netherlands, the relevant supervisory authority is the Autoriteit Persoonsgegevens (Dutch Data Protection Authority). You can contact them at www.autoriteitpersoonsgegevens.nl.

9. Children's Privacy

Our Services are designed to be family-friendly. We do not knowingly collect personal data from children under the age of 13 without parental consent. If you believe we have collected data from a child under 13 without appropriate consent, please contact us immediately.

10. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. No method of transmission over the internet is completely secure, and we cannot guarantee absolute security.

11. Third-Party Services

We use the following third-party services:

• Firebase Analytics (Google): For analytics and event tracking. See Firebase Privacy Policy.
• Google reCAPTCHA: To protect our forms against spam and abuse. reCAPTCHA collects hardware and software information (such as device and application data) and sends it to Google for analysis. See Google Privacy Policy.
• Brevo (formerly Sendinblue): To manage our mailing list and send newsletters. If you subscribe, your email address is processed by Brevo. See Brevo Privacy Policy.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Effective Date" at the top.

13. Publisher Disclaimer

Sterren IT acts solely as the publisher and distributor of the Services. The game and its underlying content are owned and developed by a third-party developer ("Developer"). By using the Services, you acknowledge and agree that:

• Sterren IT does not develop, maintain, or control the game or its content. All intellectual property rights in the game belong to the Developer.
• The Developer is responsible for the game's content, functionality, features, updates, bug fixes, and overall quality.
• All data protection requests, complaints, and enquiries received by Sterren IT are immediately forwarded to the Developer for handling. The Developer performs all actual data processing activities in connection with the game.
• Sterren IT's role is limited to publishing and distributing the Services, operating this website, and acting as the point of contact for users on behalf of the Developer.
• Sterren IT makes no warranties, express or implied, regarding the game itself and disclaims all liability arising from the game's content, functionality, or performance to the fullest extent permitted by applicable law.

14. Contact Us

If you have any questions or requests regarding this Privacy Policy, please contact us: