Privacy Policy for Aeternum Games


Effective Date: May 24, 2025

1. Introduction

Welcome to Aeternum Games ("we," "us," or "our"). We are a solo game development studio based in Germany, and we are committed to protecting your privacy in compliance with the General Data Protection Regulation (GDPR) (EU) 2016/679 and national data protection laws, including the German Federal Data Protection Act (BDSG).

This Privacy Policy explains what limited information we handle when you use our games, why we handle it, and your rights concerning your data.

2. Data Controller

The data controller responsible for the processing of your personal data under this Privacy Policy is:

Aeternum Games
Yoel Kumbolu
Schönlanker Str. 14
25813 Husum
Germany
Email: contact@aeternumgames.com

3. Principles of Data Processing

We adhere to the following principles under GDPR:
Lawfulness, fairness, and transparency: We process data fairly, lawfully, and in a transparent manner.
Purpose limitation: We collect data only for specified, explicit, and legitimate purposes and do not further process it in a manner that is incompatible with those purposes.
Data minimisation: We collect only data that is adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed.
Accuracy: We keep data accurate and, where necessary, up to date.
Storage limitation: We keep data in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
Integrity and confidentiality: We process data in a manner that ensures appropriate security of the personal data.

4. What Information Do We Process (and Why)?

Generally, we strive to collect as little personal data as possible. We only process information that is strictly necessary for our games to function properly and to provide you with the intended game experience.

Game Functionality Data (Local Device Storage): Our games may store data locally on your device (e.g., save files, high scores, game progress, settings, unlockables). This data is essential for the game to work correctly, to remember your achievements and preferences, and to ensure continuity of your gameplay experience. This information is stored solely on your device and is not transmitted to, collected by, or accessible to us.
Legal Basis for Processing: Legitimate interest (Art.6(1)(f)GDPR) in providing a functional and enjoyable game experience. This data is essential for the "contract" of playing the game, even if not a formal contract.
Minimal, Anonymous Analytics (if applicable): If our games integrate very basic, default, and anonymous analytics provided by the game engine (e.g., Unity Analytics basic crash reporting, Unreal Engine's anonymous telemetry) or a platform (e.g., Steam's anonymous usage data), this data is typically aggregated and anonymized. This type of data does not identify you personally. It primarily helps us understand general game performance (e.g., crash rates, general stability) to identify and fix bugs and improve the overall stability and user experience.
Crucial Note for You: If you use an engine with analytics, you MUST ensure they are truly anonymous and cannot be linked back to an individual. Many engines offer options to disable or anonymize these features. If they collect anything that could be considered personal data (like IP addresses, unique device IDs, or detailed usage patterns), even if pseudonymised, you would need a clearer legal basis and more explicit information for users. For true GDPR compliance, aim for zero identifiable analytics or use a strictly opt-in system if you need more.
Legal Basis for Processing (if truly anonymous): Legitimate interest (Art.6(1)(f)GDPR) in improving and maintaining the functionality and security of our games. Since this data is anonymized and cannot identify you, it falls outside the scope of personal data for the most part.
No Personal Identifiable Information Collected Directly: We do not directly collect your name, email address, IP address (unless an essential, temporary part of a truly necessary connection, which we then immediately discard), device ID, or any other information that could directly identify you. We do not track your location or your online activities outside of our games.

5. How We Use Your Information

Any limited data we might encounter (primarily local game data) is used solely for the purpose of:
Enabling the core functionality of the game.
Allowing you to save your progress and settings.
Improving the stability and performance of our games (through truly anonymous crash reports, if applicable).

We DO NOT:
Sell your personal data to anyone.
Share your personal data with third parties for marketing, advertising, or profiling purposes.
Engage in targeted advertising.

6. Data Retention

Since we primarily do not collect or store personal data on our servers, data retention primarily applies to data on your own device (e.g., save files) which you control.
For any minimal, anonymized analytics data that might be processed (as described in section 4), this data is typically aggregated and used for statistical purposes, not retained in a way that allows for individual identification.

7. Data Security

Given our minimal data collection practices, the risk of data breaches involving your personal information handled by us is significantly reduced. Any local game data stored on your device is subject to the security measures of your own device. We implement appropriate technical and organizational measures to protect any minimal data we might process (e.g., related to our internal development tools or communication) against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.

8. Your Data Protection Rights under GDPR

Under the GDPR, you have the following rights regarding your personal data. Please note that these rights primarily apply to personal data we process. Since we aim to collect as little personal data as possible, the practical application of some of these rights might be limited regarding our direct processing.

Right of Access (Art.15GDPR): You have the right to request access to any personal data we hold about you.
Right to Rectification (Art.16GDPR): You have the right to request that we correct any inaccurate or incomplete personal data we hold about you.
Right to Erasure ('Right to be Forgotten') (Art.17GDPR): You have the right to request the deletion of your personal data under certain conditions.
Right to Restriction of Processing (Art.18GDPR): You have the right to request that we restrict the processing of your personal data under certain conditions.
Right to Data Portability (Art.20GDPR): You have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format, and to transmit those data to another controller, where technically feasible.
Right to Object (Art.21GDPR): You have the right to object to the processing of your personal data under certain conditions.
Right to Lodge a Complaint (Art.77GDPR): You have the right to lodge a complaint with a supervisory authority, particularly in the Member State of your habitual residence, place of work, or place of the alleged infringement if you believe that the processing of your personal data infringes the GDPR. The supervisory authority for Germany is the Federal Commissioner for Data Protection and Freedom of Information (BfDI).
To exercise any of these rights, please contact us using the details provided in the "Contact Us" section below. We will respond to your request in accordance with GDPR requirements.

9. Children's Privacy

Our games are not specifically directed at children under the age of 16. We do not knowingly collect any personal information from children under 16. If you are a parent or guardian and believe that your child has provided us with personal information without your consent, please contact us immediately so we can address it.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. We will notify you of any significant changes by posting the new Privacy Policy on this page and updating the "Effective Date" at the top. We encourage you to review this Privacy Policy periodically for any changes.

11. Contact Us

If you have any questions or concerns about this Privacy Policy, your data, or wish to exercise your data protection rights, please contact us at:

Aeternum Games
Email: contact@aeternumgames.com