Privacy Policy

1. Who is responsible for your data

[Crown Games B.V., your registered legal name] ("Crown Games", "we", "us") is the data controller for the personal data described in this policy. We make Apple Watch and iPhone games and related subscriptions.

• Registered office: [Registered address, the Netherlands]
• Chamber of Commerce (KvK): [KvK number]
• VAT (BTW): [BTW-nummer / VAT ID]
• Privacy contact: hello@playcrowngames.com

2. What data we collect

We aim to collect the minimum needed to run the Apps. Depending on how you use them, this may include:

• Subscription and purchase data: which subscription you bought (Royal Pass Weekly or Yearly), its status, and renewal or cancellation events. Apple handles the actual payment; we receive transaction and entitlement information, not your card details.
• Device and technical data: device model, operating-system version, app version, language, and similar diagnostics used to make the games work and to fix bugs.
• Gameplay data: progress, scores, settings, and in-app activity needed to save your game and improve it.
• Support communications: if you email us, the contents of your message and your contact details.
• Analytics and crash data: aggregated or pseudonymised usage and stability data, where you have not opted out. We do not use this to identify you personally.

We do not knowingly collect special categories of data, and we do not build advertising profiles about you.

3. Apple's role in payments

All subscriptions are sold and processed by Apple through the App Store. Apple acts as the merchant of record and is an independent controller of the payment data it collects. We never receive or store your payment-card number. Apple's handling of your data is governed by Apple's Privacy Policy.

4. Why we use your data and our legal basis

Under the GDPR, we rely on the following legal bases:

• Performance of a contract (Art. 6(1)(b)): to provide the Apps, deliver subscription content, and manage renewals and cancellations.
• Legitimate interests (Art. 6(1)(f)): to keep the Apps secure, prevent fraud and abuse, fix bugs, and improve our games, balanced against your rights.
• Consent (Art. 6(1)(a)): for optional analytics or communications, where required. You can withdraw consent at any time.
• Legal obligation (Art. 6(1)(c)): to meet tax, accounting, and consumer-law duties.

5. Who we share data with

We do not sell your personal data. We share it only with service providers ("processors") who help us run the Apps, under contracts that require them to protect it. These currently include:

• Apple (App Store, in-app purchases, App Analytics)
• [Hosting / website provider, e.g. Vercel]
• [Analytics, e.g. Plausible / Google Analytics, or "none"]
• [Crash reporting, e.g. Apple / Sentry, or "none"]

We may also disclose data where required by law or to protect our legal rights.

6. International transfers

Some processors (including Apple) may process data outside the European Economic Area. Where they do, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses or an adequacy decision, so your data keeps an equivalent level of protection.

7. How long we keep data

We keep personal data only as long as needed for the purposes above: for the life of your subscription and account, plus any period required to meet legal obligations (for example, tax records are typically kept for seven years under Dutch law). We then delete or anonymise it.

8. Your rights

As a person in the EU, you have the right to:

• access the personal data we hold about you;
• have inaccurate data corrected;
• have your data erased ("right to be forgotten");
• restrict or object to certain processing;
• receive your data in a portable format;
• withdraw consent at any time, without affecting prior processing.

To exercise any of these, email hello@playcrowngames.com. You also have the right to lodge a complaint with the Dutch Data Protection Authority, the Autoriteit Persoonsgegevens, or your local supervisory authority.

9. Children

Our Apps are not directed at children under 16. We do not knowingly collect personal data from children under the age of digital consent without parental consent. If you believe a child has provided us data, contact us and we will delete it.

10. Security

We use appropriate technical and organisational measures to protect your data against loss, misuse, and unauthorised access. No method of transmission or storage is completely secure, but we work to keep your data safe and to notify you and the authorities of any breach where the law requires.

11. Changes to this policy

We may update this policy from time to time. We will revise the "Last updated" date above and, for material changes, give reasonable notice in the App or by email where appropriate.

12. Contact

Questions about your privacy? Email hello@playcrowngames.com or write to [Crown Games B.V., your registered legal name], [Registered address, the Netherlands].