Privacy Policy

1. Data controller

The data controller is Anathema Studio, Via A. De Gasperi 43, 07041 Alghero (SS), Italy, phone +39 340 807 0536, e-mail info@anathema-studio.com, website https://anathema-studio.com. We have not appointed a data protection officer (it is not required for our activity): for any question, write to the e-mail address above.

This policy applies to the Arcane Tempest app downloaded from Google Play. It explains which data is processed, by whom, why, and what your rights are under Regulation (EU) 2016/679 ("GDPR"), the Italian Privacy Code (Legislative Decree 196/2003) and the equivalent laws of the countries where the game is available.

2. What data is processed and why

2.1 Data stored on your phone

The game stores in the app's storage on your device your progress (heroes, familiars, relics, levels, stars, in-game currencies and materials), your settings (sound, language, sensitivity, reminders), gameplay statistics, the state of your purchases (for example which bundles you have already bought, the days left on the Moon Blessing and the codes of purchases already delivered, so that the same purchase is never delivered twice) and, for the online features, the random installation identifier, the access token, the server player ID and public name (section 2.2), plus any event results waiting to be sent (for at most 2 hours).

Keeping the identifier and token on your phone is strictly necessary to provide the online features you use (Art. 122(1) of the Italian Privacy Code), so we do not ask for separate consent. If you have enabled device backup in Android settings, Android may include this data in the backup of your Google account, according to Google's settings and policies: restoring the backup on a new phone also restores your online account.

2.2 Game server: world events, leaderboard and mail

World events (the world boss whose hit points are shared by all players, every day at fixed times), their leaderboard and the mail with rewards run on our own server. The first time you open the game with an internet connection, the game automatically creates a pseudonymous guest account, identified by random codes: we do not ask for your real name, e-mail, password, date of birth or phone number. "Pseudonymous" means that the account does not contain your name but remains linked to your phone (and, if you link it, to your Play Games profile): this is why we treat it as personal data.

Which data.

• Identifiers: a random identifier generated by the game for your installation and an access token (on the server we keep them only as a SHA-256 cryptographic fingerprint computed with a secret key, never in clear); the player ID assigned by the server.
• Online profile: your public name (at first "Evocatore" followed by four digits; you can change it from the world event screen), any title you have earned and chosen to show, the creation date and the date of your last access.
• Event participation: for each attempt the damage dealt, the damage actually counted, the duration, the team power, the heroes used (up to 9) and the lead hero, plus any flags raised by our automatic anti-cheat checks; for each event your final rank and grade.
• Mail: the messages and rewards we send you (for example end-of-event rewards) and whether you claimed them.
• Technical data: your IP address, used to limit the number of requests and protect the service from abuse. It stays in the server's memory while the instance that handled the request is running (usually a few hours); for account creation it is also in the database, until about 3 hours after the last account creation from that address, so it may also appear in database backups (section 4). The service's technical logs may contain IP address, date and time, requested address, device model, Android and WebView version (User-Agent) and the approximate location (country, region or city) that Cloudflare derives from the IP address. We use the logs only for security and to fix errors: we do not use the location for game features, advertising or profiling.
• Link with Google Play Games (when the feature is active and you are signed in to Play Games): the game asks Google for a one-time code and sends it to the server, which exchanges it with Google to learn your Play Games player ID. We keep only a cryptographic fingerprint of that ID, to find your online account (name, titles, leaderboard) on another phone. In the same reply Google also sends the server your Play Games player name and profile picture: the server uses only the ID and stores nothing else. We do not receive your e-mail, real name or any other data from your Google account. If the link finds an online account you already had, the guest account used until then on this phone is merged into it or deleted, so no account is left that you can no longer reach.

Why. To run events, the leaderboard, mail and rewards; to find your online account again; to calculate ranks and rewards; to prevent cheating, multiple accounts used to multiply rewards and other abuse; to protect the security of the service; to fix technical errors.

Legal bases. Performance of the contract, i.e. providing the game's online features described in the Terms of Service (Art. 6(1)(b) GDPR); legitimate interest in the security of the service, fraud prevention and a fair leaderboard (Art. 6(1)(f)) for IP addresses, technical logs, anti-cheat checks and backups. You can object to processing based on legitimate interest (section 5).

What other players see. On each event's leaderboard (the top 100 and your own rank) other players see your public name, title, damage, lead hero and rank, plus the number of participants. Do not use your real name or other personal data as your public name. We may change names that are offensive or impersonate others (see the Terms).

Who runs the server. The server runs on Cloudflare Workers with a Cloudflare D1 database, services of Cloudflare, Inc., which acts as our processor (Art. 28 GDPR) under its Data Processing Addendum. The database is created in Cloudflare's EU jurisdiction, so the stored data stays in the European Union; requests may be processed in the Cloudflare data centre closest to you, including outside the EU (see section 3).

If you play without a connection, none of this data is sent: events can only be played in training mode and stay off the leaderboard. The same applies while our server is not in service: in that case the game creates no online account and sends none of this data.

2.3 Remote configuration and news

At start-up the game downloads a signed configuration file (event times, news, offers, maintenance, minimum version) from our server and from our website anathema-studio.com. The request contains no player data, but like any internet request it tells the server your IP address and device type (User-Agent), which may appear in the technical logs of Cloudflare and of the provider hosting the website. News images are hosted on our own domains; news links open in your browser only if you tap them.

2.4 Google Play Games Services (optional)

If you have a Google Play Games profile, the game signs you in automatically (you can also play without it). In that case Google processes:

• your player ID, gamer name and avatar from your Play Games profile, which the game shows on the Account screen;
• the achievements you unlock and the scores submitted to Play Games leaderboards (visible to other players according to your Play Games profile visibility settings);
• the cloud save (Saved Games): a copy of the progress described in 2.1, including the state of your purchases and your world event data (medals, titles), so you can restore it on another phone.

This data is stored by Google in your Play Games profile / Google account; we have no separate access to it: the game only reads and writes it from your device while you are signed in. The only Play Games data that reaches our server is the link described in 2.2. Legal basis: performance of the contract, to provide the features you choose to use (Art. 6(1)(b) GDPR). Retention: until you delete the save or the game's data from your Play Games profile (section 7). Google also processes diagnostic and statistical data to operate and improve its services, as an independent controller: see data collected by Play Games Services and the Google Privacy Policy.

2.5 In-app purchases (Google Play Billing)

Purchases are made through Google Play's billing system. Payment data (card, account, billing address) is processed by Google and we never receive it. The game receives from Google Play the product ID, order number, purchase token and purchase state, and uses them on your phone to deliver what you bought and to prevent duplicate deliveries; this data is not sent to our server. In Play Console, Google gives us order data (order number, date, product, price, country or region), which we use for customer support, refunds and accounting.

Legal bases: performance of the contract (Art. 6(1)(b)), tax and accounting obligations (Art. 6(1)(c)), legitimate interest in preventing fraud and abuse (Art. 6(1)(f)). Order data is retained for as long as tax and accounting rules require (in Italy up to 10 years, Art. 2220 of the Italian Civil Code). The Google Play Terms of Service and the Google Privacy Policy also apply.

2.6 Rewarded video ads (Google AdMob)

You can choose to watch a video ad in exchange for an in-game reward (gems, a free summon, a second chance, double rewards, gold). The videos are provided by Google AdMob. To show and measure them, the Google Mobile Ads SDK included in the app, active from start-up, collects and sends to Google:

• your IP address, which may be used to estimate your approximate location (city or area);
• the Android advertising ID and the App Set ID;
• device information (model, Android version, language) and interactions with ads (app launches, taps, video views);
• diagnostic data about how the SDK performs (for example loading times).

Purposes: showing ads, capping their frequency, measuring them, preventing fraud and, only if you consent, showing you personalised ads. For this processing Google acts as an independent controller (Google Ireland Limited for people in the European Economic Area or Switzerland, Google LLC elsewhere).

Consent. In the European Economic Area, the United Kingdom and Switzerland, on first launch the game shows the consent form of Google's User Messaging Platform (a certified consent management platform compliant with the IAB Transparency & Consent Framework). You can accept, refuse or choose individual purposes, and change your mind at any time under Settings → Ad privacy in the game. If you refuse, Google may show non-personalised or "limited" ads, or no ads at all: the game stays fully playable. Legal bases: consent (Art. 6(1)(a) GDPR and Art. 122 of the Italian Privacy Code for accessing information on your device); legitimate interest for security and fraud prevention, where the consent framework allows it. In US states with specific privacy laws you can opt out of the "sale" or "sharing" of data for targeted advertising from the same Ad privacy button, when it is shown.

You can also reset or delete your advertising ID in Android settings (Settings → Google → Ads, or Privacy → Ads) and manage personalisation in My Ad Center. More information: how Google uses information from apps that use its services, Google advertising, how Google retains data.

2.7 Event reminders (notifications)

If you turn on Settings → Event reminders (off by default), the game schedules on your phone a notification a few minutes before each world event and only then asks for permission to send notifications. The notifications are local: they are scheduled and shown by your phone, without sending any data to us or to anyone else. The game schedules them again after the phone restarts. You can turn them off from the same setting or from Android settings.

2.8 Google Play statistics, reviews and updates

In Play Console, Google Play gives us aggregated statistics about installs, crashes and freezes (Android vitals), with technical information such as device model and Android version that does not allow us to identify you. We use them to fix bugs and improve the game (legitimate interest, Art. 6(1)(f)). If you leave a review from inside the game, the review window belongs to Google Play and the review is public according to Google Play's rules. To offer you updates inside the game, Google Play receives from your phone information such as the app and device version, under its own policies.

2.9 If you write to us

If you contact us by e-mail we process your address and the content of your message (and any order number, player ID or public name you give us) to answer and help you. Legal basis: performance of the contract or pre-contractual steps (Art. 6(1)(b)) and legitimate interest in handling requests (Art. 6(1)(f)). We keep the correspondence for up to 24 months after the request is closed, unless the law requires otherwise.

2.10 What we do not do

• We do not create accounts with a real name, e-mail or password, and we do not ask for your name, e-mail, date of birth or phone number inside the game.
• We do not use our own analytics or advertising tools, we do not sell data, we do not use it for advertising and we do not profile you.
• We do not access your precise location, contacts, photos, camera or microphone.
• The game has no chat and no messages between players: the only data other players see is the leaderboard data (section 2.2).

3. Recipients and transfers outside the EU

The data described above is processed:

• by Google for the services listed (Google Play, Play Games Services, AdMob), partly as an independent controller;
• by Cloudflare, Inc., as our processor, for the game server, the database and the remote configuration;
• by the provider hosting the website anathema-studio.com, as our processor, for the website pages and the configuration file;
• by other players, who see public name, title, damage, lead hero and rank on the leaderboard;
• for order data only, by the professionals who help us with accounting, who are bound by confidentiality.

We may disclose data to authorities when the law requires it. Google and Cloudflare may also process data in the United States and other countries: Google LLC and Cloudflare, Inc. participate in the EU-U.S. Data Privacy Framework (European Commission adequacy decision of 10 July 2023, see dataprivacyframework.gov) and use the standard contractual clauses approved by the Commission (see Google Business Data Responsibility and the Cloudflare Data Processing Addendum).

4. How long

5. Your rights

You have the right to request access to your data, rectification, erasure, restriction of processing and portability, and to object to processing based on legitimate interest (Arts. 15–21 GDPR). You can withdraw your consent to ads at any time under Settings → Ad privacy, without affecting processing already carried out. We do not take decisions based solely on automated processing that produce legal effects on you: our automatic anti-cheat checks may exclude a score from the leaderboard, and if you think this is a mistake you can write to us for a review by a person.

To exercise your rights, write to info@anathema-studio.com: we answer within one month. For server data we first need to be sure that the account is yours, because it is not linked to a name or e-mail: follow the identification instructions in section 7. For data held by Google (cloud save, advertising data) the request is made with the Google tools listed in section 7; we will gladly help you. You also have the right to lodge a complaint with the Italian Data Protection Authority (garanteprivacy.it) or with the supervisory authority of the country where you live or work (for example the ICO in the UK or the FDPIC in Switzerland).

6. Children

Arcane Tempest is designed for an audience of at least 16 years of age (the expected PEGI rating in Europe is 16) and is not directed at children: we do not knowingly collect data from children under 13. If you are below the age at which you can consent to online services on your own in your country (14 in Italy; between 13 and 16 in other European countries), ask a parent or guardian before accepting personalised ads and before making purchases. Never use your real name as your public name. Parents can restrict downloads and purchases with Google Play parental controls and require authentication for every purchase. If you believe we have processed a child's data in breach of these rules, write to us and we will delete it.

7. How to delete your data

This section explains how to ask Anathema Studio to delete your online account and data for the game Arcane Tempest (Tempesta Arcana), without having to reinstall the game.

• Online account, by e-mail: write to info@anathema-studio.com with the subject "Arcane Tempest data deletion". To identify the account, give your player ID, which you find under Settings → Account. If you cannot find it, give your public name, the day and time of an event you took part in and the result the game showed you for that event (rank, grade and damage): if this is not enough to identify a single account with certainty we will ask you for more details, and without a certain identification we do not proceed, so that nobody else can delete or read your account. The same rules apply to requests for access to your data. Within 30 days we delete your online account, public name, title, scores, attempt details, mail and Play Games link, and confirm the deletion to you. Backups are overwritten within a further 30 days. Leaderboards and rewards of events that have already closed are not recalculated. If you later open the game again with a connection, a new guest account will be created.
• On your phone: in the game use Settings → Start over, or Android → Settings → Apps → Arcane Tempest → Storage → Clear data, or uninstall the game. Please note: these steps delete the data on your phone but not your online account on the server, which remains until you ask for its deletion or until 24 months without access.
• Play Games (cloud save, achievements, scores): from your Play Games profile (profile settings → delete the Play Games data of a single game, or the whole profile) or from your Google Account.
• Advertising: delete or reset your advertising ID in Android settings and withdraw consent under Settings → Ad privacy.
• Order data and e-mails: write to info@anathema-studio.com with your order number or the address you wrote from; within 30 days we delete everything we are not legally required to keep (order data is kept as long as tax rules require, section 4).

Please note: if you delete both the data on your phone and the cloud save, your progress and the purchased content already delivered cannot be recovered. Deleting your online account means losing your public name, titles and unclaimed mail rewards.

8. Security

Data travels between the app, our server and Google's services over encrypted connections (HTTPS/TLS). In the server's database, the installation identifier, the token and the Play Games ID are kept only as cryptographic fingerprints computed with a secret key; the database contains no real names, e-mail addresses or payment data. Administrative access to the server requires a secret key, and our Cloudflare, Google Play and AdMob accounts are protected with two-step verification. Data on your phone is protected by Android's app sandbox.

9. Changes

If we change this policy (for example because we add a service), we will publish the new version on this page with an updated date at the top and, for significant changes, let you know in the game.

10. Contact

Anathema Studio · info@anathema-studio.com · anathema-studio.com
Terms of Service: anathema-studio.com/tempesta-arcana/terms