08
Legal
Privacy Policy
What Leron Company games and this website collect, why, who else sees it, how long it is kept, and how to make it stop.
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.
| Game | Account | In-app purchases | Third-party ads | Analytics |
|---|---|---|---|---|
| Ashfall Drift | Yes | Yes | No | Yes |
| Tidecaller | Yes | Yes | No | Yes |
| Null Harbor | Yes | Yes | No | Yes |
| Paper Lantern | No | No | No | No |
| Ferrograde | Yes | No | No | Yes |
| Bramble & Bone | No | No | No | Yes |
This table must match the Data safety declaration in Play Console and the App Privacy answers in App Store Connect for every title, at all times.
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.
| Category | Specific data | Source | Required or optional |
|---|---|---|---|
| Identifiers | Player ID, account ID, device identifier [SPECIFY WHICH] | Generated on first launch | [REQUIRED / OPTIONAL] |
| Contact info | E-mail address, where you create an account | Provided by you | Optional — only if you sign in |
| Purchases | Purchase history, entitlements, store transaction ID | Apple / Google receipt | Required for purchases |
| App activity | Progress, level completion, run records, in-game settings | Generated by play | [REQUIRED / OPTIONAL] |
| Diagnostics | Crash logs, performance traces, device model and OS version | Generated by the app | [REQUIRED / OPTIONAL] |
| Usage data | Product interaction events [SPECIFY EVENT LIST] | Generated by the app | [REQUIRED / OPTIONAL] |
| Approximate location | [COLLECTED? — STATE "NOT COLLECTED" IF SO] | [SOURCE] | [REQUIRED / OPTIONAL] |
| User content | Support messages and any attachments you send us | Provided by you | Optional |
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
| Purpose | Data used | Legal basis |
|---|---|---|
| Running the game (app functionality) | Identifiers, app activity, diagnostics | [CONTRACT / LEGITIMATE INTEREST] |
| Saving and restoring progress across devices | Account ID, e-mail, app activity | [CONTRACT] |
| Delivering purchases and honouring entitlements | Purchases, identifiers | [CONTRACT] |
| Fixing crashes and performance problems | Diagnostics, device information | [LEGITIMATE INTEREST] |
| Aggregate analytics to decide what to build next | Usage data, app activity | [CONSENT / LEGITIMATE INTEREST — SEE §7] |
| Answering support and data requests | Contact info, identifiers, user content | [CONTRACT / LEGAL OBLIGATION] |
| Fraud prevention and security | Identifiers, diagnostics | [LEGITIMATE INTEREST / LEGAL OBLIGATION] |
| Meeting tax, accounting and regulatory duties | Purchases | [LEGAL OBLIGATION] |
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.
| Provider | Purpose | Data received | Games / site | Policy |
|---|---|---|---|---|
| [THIRD-PARTY SDK LIST — PROVIDER 1] | [PURPOSE] | [DATA CATEGORIES] | [TITLES] | [POLICY URL] |
| [THIRD-PARTY SDK LIST — PROVIDER 2] | [PURPOSE] | [DATA CATEGORIES] | [TITLES] | [POLICY URL] |
| [THIRD-PARTY SDK LIST — PROVIDER 3] | [PURPOSE] | [DATA CATEGORIES] | [TITLES] | [POLICY URL] |
| Apple (App Store, StoreKit) | Distribution, purchases, receipts | Purchase and account data, in Apple’s own right | All iOS titles | [APPLE POLICY URL] |
| Google (Play, Play Billing) | Distribution, purchases, receipts | Purchase and account data, in Google’s own right | All Android titles | [GOOGLE POLICY URL] |
This table is the single source of truth for the Data safety form and the App Privacy answers. Update it in the same change as any SDK addition.
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
| Data | Retention | Then what |
|---|---|---|
| Account and progress | [DATA RETENTION PERIOD] | Deleted on request, or after [INACTIVITY PERIOD] of inactivity |
| Purchase and transaction records | [DATA RETENTION PERIOD — TAX / ACCOUNTING] | Retained as a legal obligation, then deleted |
| Crash and diagnostic logs | [DATA RETENTION PERIOD] | Deleted automatically |
| Analytics events | [DATA RETENTION PERIOD] | Aggregated, then deleted |
| Support correspondence | [DATA RETENTION PERIOD] | Deleted |
| Record of a deletion request | [DATA RETENTION PERIOD] | Minimal record kept to prove we acted on 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
| Retained | Reason | Period |
|---|---|---|
| Transaction records | Tax and accounting obligations | [DATA RETENTION PERIOD — TAX / ACCOUNTING] |
| Fraud and abuse records | Fraud prevention and platform security | [DATA RETENTION PERIOD — FRAUD] |
| Minimal record of the deletion request | Proof that we acted on your request | [DATA RETENTION PERIOD — REQUEST LOG] |
| Aggregated, non-identifying statistics | No longer personal data; cannot be linked back to you | Indefinite |
| [ANY OTHER LEGAL HOLD] | [REASON] | [PERIOD] |
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.
| Store | Declaration | Must match |
|---|---|---|
| Apple App Store | App Privacy data types and purposes, per app | §3 and §4 |
| Apple App Store | Privacy Policy URL | This page |
| Apple App Store | Privacy Choices URL (optional field) | The Privacy Choices page |
| Apple App Store | Tracking declaration | §4 — we declare no tracking |
| Google Play | Data safety: collection and sharing | §3, §4 and §5 |
| Google Play | Data safety: security practices | §12 |
| Google Play | Data safety: data deletion questions | §15 |
| Google Play | Account deletion URL | The Account & Data Deletion page |
| Google Play | Privacy policy URL (store listing and in-app) | This page |
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
- info@leroncompany.com — privacy requests, player support and security reports
- Postal address
- [COMPANY ADDRESS]
- Data protection officer
- [DPO NAME AND CONTACT, IF APPOINTED]
19
Per work
Positions by title
Each work has its own anchor so a store listing can link directly to the paragraph that describes it. These values must stay identical to the Data safety form in Play Console and the App Privacy answers in App Store Connect.
Ashfall Drift
| Account created | Yes — deletion available in-game and at /data-deletion |
|---|---|
| In-app purchases | Yes — processed by Apple or Google; we never see card details |
| Third-party advertising | None |
| Analytics | Yes — [ANALYTICS PROVIDER], event list in §7 |
| Families / kids programme | Not enrolled |
| Support URL | /support?game=ashfall-drift |
Tidecaller
| Account created | Yes — deletion available in-game and at /data-deletion |
|---|---|
| In-app purchases | Yes — processed by Apple or Google; we never see card details |
| Third-party advertising | None |
| Analytics | Yes — [ANALYTICS PROVIDER], event list in §7 |
| Families / kids programme | Under review for [PROGRAMME NAME] — see §13 |
| Support URL | /support?game=tidecaller |
Null Harbor
| Account created | Yes — deletion available in-game and at /data-deletion |
|---|---|
| In-app purchases | Yes — processed by Apple or Google; we never see card details |
| Third-party advertising | None |
| Analytics | Yes — [ANALYTICS PROVIDER], event list in §7 |
| Families / kids programme | Not enrolled |
| Support URL | /support?game=null-harbor |
Paper Lantern
| Account created | No account is created and nothing is sent off your device |
|---|---|
| In-app purchases | None |
| Third-party advertising | None |
| Analytics | None. The work makes no network call at all. |
| Families / kids programme | Not enrolled |
| Support URL | /support?game=paper-lantern |
Ferrograde
| Account created | Yes — deletion available in-game and at /data-deletion |
|---|---|
| In-app purchases | None |
| Third-party advertising | None |
| Analytics | Yes — [ANALYTICS PROVIDER], event list in §7 |
| Families / kids programme | Not enrolled |
| Support URL | /support?game=ferrograde |
Bramble & Bone
| Account created | No account is created and nothing is sent off your device |
|---|---|
| In-app purchases | None |
| Third-party advertising | None |
| Analytics | Yes — [ANALYTICS PROVIDER], event list in §7 |
| Families / kids programme | Not enrolled |
| Support URL | /support?game=bramble-and-bone |
