Privacy Policy

01 Scope

This Privacy Policy applies to all applications, online services, and cloud-based services published by Anchors Tech (HK) Limited ("we", "us", "our", or "Anchors Tech"), a company incorporated in Hong Kong (CR No. 79761079). This includes, but is not limited to, the game Edge Conflict — The Intro and any associated online features.

This policy is drafted in compliance with:

• The Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong
• The General Data Protection Regulation (EU 2016/679) for users in the European Economic Area
• The California Consumer Privacy Act / California Privacy Rights Act (CCPA/CPRA) for California residents
• The requirements of major digital distribution platforms through which our applications are made available

02 Data We Collect

We may collect the following categories of information when you use our applications and services:

• Device and technical identifiers — Such as device ID, operating system version, and hardware model
• Account information — Such as email address, display name, or credentials from third-party authentication providers, if you choose to create an account or use cloud-enabled features
• Application data — Such as game progress, preferences, and settings, which may be stored locally on your device and/or synchronized to our cloud servers
• Transaction records — Purchase and subscription records as provided by digital distribution platforms (e.g., Steam, Apple App Store, Google Play)
• Usage and interaction data — Such as session duration, feature usage patterns, and in-application events, used to improve service quality
• Diagnostic data — Such as crash reports, performance logs, and error data, collected through integrated analytics services

03 Data We Do Not Collect

We make the following explicit commitments:

• We do not collect advertising identifiers (IDFA/GAID) or use any cross-app tracking or targeted advertising mechanisms
• We do not collect precise geolocation data (GPS coordinates)
• We do not collect biometric data, including fingerprints, facial geometry, or voiceprints
• We do not access or collect your photos, camera, microphone input, contacts, call logs, or SMS messages
• We do not collect health, fitness, or financial data
• We do not sell, rent, or share personal data for third-party advertising or cross-contextual behavioral tracking
• We do not knowingly collect personal information from children under 13 (or the applicable minimum age in your jurisdiction)
• We do not use personal data for automated decision-making or profiling that produces legal effects

04 Purpose, Legal Basis, and Use of Data

Collected information is used solely for the following purposes:

Purpose	Description	Legal Basis (GDPR)
Service delivery	Operate, maintain, and provide core features	Art. 6(1)(b)
Cross-device sync	Synchronize data across devices via cloud services	Art. 6(1)(b)
Service improvement	Analyze aggregate patterns and diagnose issues	Art. 6(1)(f)
Transaction processing	Facilitate in-app purchases via platform payment	Art. 6(1)(b)
Communication	Send service-related notices and alerts	Art. 6(1)(f)
Legal compliance	Comply with applicable laws and regulations	Art. 6(1)(c)

05 Third-Party Services

Our applications may integrate third-party services in the following categories:

• Digital distribution platforms — For distribution, purchase processing, DRM, and platform-level authentication (e.g., Steam, Apple App Store, Google Play)
• Cloud infrastructure providers — For secure data storage, processing, and content delivery (e.g., AWS, Google Cloud Platform)
• Analytics and diagnostics — For crash reporting, performance monitoring, and aggregate usage analysis (e.g., Unity Analytics, Sentry)
• Authentication services — For account creation and identity verification through federated login providers

Privacy policies of key third-party service providers:

• Steam Privacy Policy
• Unity Privacy Policy
• Sentry Privacy Policy
• AWS Privacy Notice
• Google Cloud Privacy Notice

06 Storage, Security, Retention, and Deletion

Application data may be stored locally on your device and/or on secure servers operated by third-party cloud infrastructure providers.

We implement industry-standard security measures, including encryption of data in transit (TLS) and at rest, access controls, and regular security assessments.

Data Category	Retention Period
Account information	Active account + 30 days post-deletion
Transaction records	Per tax/accounting law (up to 7 years)
Diagnostic data	Up to 90 days
Usage / session data	Raw: up to 12 months; then aggregated
Inactive accounts	Notified at 12 months; removed at 13 months

You may request deletion of your personal data through any of the following methods:

• In-app — Initiate account deletion through the account settings menu
• Web portal — Request deletion at supergraph.net/delete-account
• Email — Contact [email protected]

Upon a verified request, cloud-stored data will be permanently deleted within 30 days. Locally stored data can be removed by uninstalling the application.

07 Your Rights

Under the Personal Data (Privacy) Ordinance of Hong Kong and other applicable laws:

• Access — Request a copy of the personal data we hold about you
• Correction — Request correction of inaccurate or incomplete data
• Deletion — Request deletion, subject to legal retention requirements
• Withdrawal of consent — Withdraw consent at any time where processing is consent-based
• Complaint — Lodge a complaint with the Office of the Privacy Commissioner for Personal Data, Hong Kong

Contact [email protected]. We will respond within 30 days.

08 Supplemental Terms for EU/EEA Users

If you are located in the European Economic Area, the following additional terms apply:

Legal basis. The legal basis for each processing activity is specified in Section 04. Where we rely on legitimate interest, we have conducted balancing tests to ensure our interests do not override your fundamental rights.

Additional rights:

• Data portability — Receive your data in a structured, machine-readable format
• Restriction — Request restriction of processing in certain circumstances
• Objection — Object to processing based on legitimate interest

Supervisory authority. You have the right to lodge a complaint with your local data protection supervisory authority.

Data protection contact. For GDPR-specific inquiries, email [email protected] with the subject line "GDPR Request."

09 Supplemental Terms for California Residents

If you are a California resident, the following terms apply under CCPA/CPRA:

• Do Not Sell or Share — We do not sell or share your personal information for cross-context behavioral advertising
• Right to Know — Request disclosure of the categories and specific pieces of personal information collected
• Right to Delete — Request deletion, subject to legal exceptions
• Right to Correct — Request correction of inaccurate information
• Right to Opt-Out — Opt out of sale or sharing (we do not engage in such practices)
• Non-discrimination — We will not discriminate for exercising your rights

Contact [email protected]. We will respond within 45 days as required by law.

10 International Data Transfers

Your data may be transferred to and processed in jurisdictions outside your country of residence, including Hong Kong and cloud infrastructure regions.

We ensure appropriate safeguards including Standard Contractual Clauses (SCCs) approved by the European Commission, or equivalent contractual commitments with service providers.

11 Data Security Incidents

In the event of a security incident that may affect your personal data, we will:

• Notify affected individuals and relevant regulatory authorities as required by applicable law
• Provide details regarding the nature of the incident, categories of data affected, and measures taken
• Take immediate steps to contain the incident and prevent further unauthorized access

12 Children

Our applications are not directed at children under 13 (or the applicable minimum age in your jurisdiction). We do not knowingly collect personal information from children. If we become aware of such collection without appropriate parental consent, we will delete it promptly.

If you believe a child has provided personal information to us, contact [email protected].

13 Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices, technology, or legal requirements. When we make material changes, we will:

• Post the updated policy with a revised effective date
• Provide notice through our applications where practicable

Continued use after changes take effect constitutes acceptance of the updated policy.

14 Contact