Privacy Policy
Developer: Kene Cheng · Contact: support@wilddivegame.com · [POSTAL ADDRESS]
Data protection representative / DPO (if needed): [DPO/REPRESENTATIVE if needed]
Effective date: [EFFECTIVE DATE] · Applies to: the WildDive app for Android (v1)
1. The short version
- You can play WildDive without an account. Guest progress stays on your device.
- If you choose to sign in with Google Play Games, we receive a Google-issued player ID so your saves can follow you to another phone (stored in your own Google Drive app folder, which only WildDive can read).
- Purchases are handled by Google Play. We never see your card or bank details. Our server checks each purchase with Google so it can't be faked and so refunds are handled correctly.
- We ask for year of birth once and keep only an age group (under 13 or 13+). The year itself never leaves your device.
- No ads, no ad tracking, no analytics or crash-reporting tools in v1. We don't sell personal information.
- Players under 13 need a grown-up (parent gate) to turn on cloud save, sign in, or buy anything.
- Selfie Studio uses the camera on your device only; the face picture is never uploaded by us.
- You (or a parent) can ask us to see or delete data at any time: [CONTACT EMAIL].
In-app purchases, sign-in and cloud save (summary)
DRAFT for lawyer review. Prices are the US list price; Google Play shows the local price.
- Lucky Draw tickets (`wilddive_tickets_200`): 200 tickets for $0.99, sold only on the Lucky Draw page. Consumable. Odds for every prize tier are shown before purchase. You must be signed in with Google Play Games to buy tickets, so they can be restored to your account. Not offered in Belgium (store country from Google Play).
- Supporter card (`wilddive_supporter`): one-time $0.99 unlock that supports development and includes lifetime free expansions. Offered in Settings at any time and once as a pop-up after beating Stage 5. It is a paid unlock with stated benefits, not a donation.
- How payment works: all payments go through Google Play Billing. We never receive card or bank details. Our server (Google Firebase) checks every purchase with Google before granting it, and listens for refunds so they are handled correctly. We keep the purchase token, product ID, order ID, purchase state and Google's country code (see §2).
- Under 13: a parent gate must be passed before buying tickets or the Supporter card, and before signing in or turning on cloud save. Google Family Link purchase approval also applies.
- Sign-in: optional Google Play Games sign-in (automatic for 13+, parent-gated for under-13s). We receive only a Google player ID. Guests can still play offline.
- Cloud save: one cloud copy per save slot, stored in your own Google Drive app folder (Saved Games). If two copies conflict, you choose which to keep, and tickets bought on the other copy are restored once.
2. What we collect
| Data | Source | Purpose | Legal basis (GDPR/UK GDPR) |
|---|---|---|---|
| **Age band** (`u13` / `13plus`) derived from year of birth | You, on the first-launch age screen | Apply child protections (no auto sign-in, parent gate on purchases and cloud save) | Legal obligation (child protection, Art. 6(1)(c)); legitimate interests (Art. 6(1)(f)) |
| **Google Play Games player ID** (stable, per-game) | Google Play Games Services, only if you sign in | Identify your account for cloud save; link verified purchases to you | Contract (Art. 6(1)(b)); for under-13s, parental consent (Art. 6(1)(a) + Art. 8) |
| **Game progress** (save slots: Day, coins, tickets, prizes, BudDex, settings, age band for 13+) | The game | Run the game; cloud save across devices | Contract |
| **Purchase records**: purchase token, product ID (`wilddive_supporter`, `wilddive_tickets_200`), order ID, purchase state, refund/void status, country code from Google | Google Play Billing and the Play Developer API, via our Firebase server | Verify and deliver purchases, prevent fraud/duplicate grants, handle refunds, hide paid tickets where required (Belgium) | Contract; legal obligation (tax/consumer law); legitimate interests (fraud prevention) |
| **Ticket purchase ledger** (`granted_tokens`: token → product/amount) | The game, inside your save | Make sure each purchase is granted once, restore tickets after reinstall or a save conflict | Contract |
| **Technical request data** (e.g. IP address, timestamps) in server logs **[VERIFY]** | Automatically, when the game calls our Firebase function | Security and running the service | Legitimate interests |
3. What we don't collect
- No name, email, phone number, postal address or contact list from players. (Google may hold these for your Google account; we do not receive them. [VERIFY] the PGS plugin does not request email/profile scopes.)
- No card, bank or payment details: Google Play handles payment.
- No precise or approximate location from GPS/network. (Google gives us a store country code for purchases only.)
- No advertising ID, ad SDKs, analytics SDKs or crash-reporting SDKs in v1.
- No chat, friends lists or user-to-user messaging.
- No selfie/face photos: Selfie Studio processes the camera image and saves the face texture on your device only (`user://` app storage). It is not part of the cloud save and not sent to us. [VERIFY] it stays excluded from the cloud snapshot and from Android auto-backup.
- No exact birth date or birth year stored: only the age band.
4. How we use information
- To run the game and keep your progress (local and, if you opt in, cloud).
- To sign you in with Google Play Games and restore your saves and purchases on a new phone.
- To check that purchases are real, deliver what you bought exactly once, and take items back if a purchase is refunded or cancelled.
- To apply age protections and regional rules (e.g. paid Lucky Draw tickets are not offered in Belgium).
- To answer your support or privacy requests.
We do not use data for advertising, profiling, or selling, and we do not make automated decisions with legal or similarly significant effects.
5. Sharing
We do not sell or rent personal information and we do not share it for advertising (there are no ads in v1). We use these providers, who process data under their own terms:
- Google Play / Google Play Billing: app distribution and payments. https://policies.google.com/privacy · https://payments.google.com/payments/apis-secure/u/0/get_legal_document?ldo=0&ldt=privacynotice
- Google Play Games Services (sign-in, player ID): https://policies.google.com/privacy · https://developers.google.com/games/services/terms
- Google Drive app data folder (Saved Games): your cloud save sits in your Google account, in a hidden folder only WildDive can access. https://support.google.com/drive/answer/2375057
- Google Firebase / Google Cloud (Cloud Functions, Firestore, Pub/Sub; purchase checks and refund notices), acting as our processor: https://firebase.google.com/support/privacy · https://cloud.google.com/terms/data-processing-addendum
- Legal reasons: if required by law, to protect users, or in a business transfer (with notice).
6. Children
WildDive is made for a mixed audience that includes children under 13 and is enrolled in Google Play's Families programme [VERIFY target-audience setting].
- Neutral age screen: at first launch we ask for year of birth with no pre-selected answer, then keep only an age band.
- Under-13 default = guest mode: no automatic Play Games sign-in, no cloud save, no data leaves the device except what Google Play itself handles.
- Parent gate: a grown-up task must be completed before an under-13 player can (a) sign in / turn on cloud save, (b) buy Lucky Draw tickets, or (c) buy the Supporter Pack. Google Family Link purchase approval also applies on top.
- COPPA (US): the Play Games player ID is a persistent identifier and is "personal information" under COPPA unless used only to support internal operations. Our approach: use it only for internal operations (saving progress, delivering purchases, security), and collect it from under-13s only after the parent-gated opt-in. [VERIFY with counsel] whether a parent gate is sufficient or a recognised verifiable parental consent method (e.g. via Google Family Link supervision, card check, or a consent provider) is required for the cloud-save opt-in.
- GDPR-K (Art. 8): where a child is under the digital-consent age of their country (13–16), cloud save/sign-in relies on consent from the holder of parental responsibility, and we make reasonable efforts to verify it. [VERIFY] the age band may need country-specific thresholds (e.g. 16 in some EU states) rather than a single 13 line.
- UK Age Appropriate Design Code: high-privacy defaults, data minimisation, no profiling, no nudge techniques, no geolocation; we follow these.
- No behavioural or targeted ads, no profiling of children, no public profiles or chat.
- If we learn we collected a child's data without required consent, we will delete it.
6a. For kids (plain language)
Hi diver! 🐠 Here's how WildDive treats your info:
- You can play without logging in. Your game is saved on your phone.
- We asked what year you were born only to know if you're under 13. We don't keep the year.
- Want your game saved online, or want to buy something? Ask a grown-up. They'll need to help.
- Your selfie stays on your phone. We never see it.
- No ads. We don't sell anything about you.
- Questions? Ask your parent to email us at [CONTACT EMAIL].
6b. For parents and guardians
- What your child's play involves: guest mode by default; only an age band is stored on the device. If you pass the parent gate and sign in with Play Games, we receive the player ID and a cloud copy of game progress is stored in that Google account's Drive app folder; purchase records are kept on our Firebase server.
- Purchases: made through Google Play; we never see payment details. Use Google Family Link to require approval for purchases. Lucky Draw tickets give randomized rewards; the odds for every tier are shown before any purchase. Paid tickets are not offered in Belgium.
- Your rights: you can review your child's data, ask us to delete it, and refuse/withdraw consent to further collection (the child can keep playing in guest mode). Email [CONTACT EMAIL]; we may ask you to confirm you control the child's Google account.
- Do it yourself: see §8 (delete cloud save, unlink Play Games, clear app data).
7. Retention
- On-device data (local saves, age band, selfie texture): until you delete it in-game, clear app data or uninstall.
- Cloud save (Drive app folder): until you delete it or remove WildDive's access to your Google account (§8).
- Player ID on our server: kept with purchase records; deleted when no longer needed for those records.
- Purchase records (token, product, order ID, status): as long as needed for refunds, fraud prevention and legal/tax duties, then deleted: [RETENTION PERIOD, e.g. X years]. [VERIFY with counsel]
- Server logs: [LOG RETENTION, e.g. 30 days]. [VERIFY Firebase/Cloud Logging default]
- Support emails: as long as needed to resolve the request, then [PERIOD].
8. Access, correction and deletion
Ask us: email support@wilddivegame.com (subject "Privacy request") or write to [POSTAL ADDRESS]. Include your Play Games player name, or describe the device/purchase so we can find the records. We respond within 30 days (and within the shorter/longer periods the local law allows: e.g. 40 days under the HK PDPO, one month under GDPR, extendable). We may verify your identity first.
Do it yourself:
- Delete cloud saves / app data: in-game Settings → Cloud save → Delete cloud data [VERIFY: feature not yet in spec]; or in Google Drive on the web → Settings → Manage apps → WildDive → *Delete hidden app data*, then *Disconnect from Drive*.
- Unlink Play Games / remove the profile: Google Play Games app → Settings → *Delete Play Games account & data* (or remove WildDive's data there); or Google Account → Security → Third-party connections.
- Local data: Android Settings → Apps → WildDive → Storage → Clear data, or uninstall.
- Purchases: Google Play holds the payment record; refunds via Google Play. We may keep a minimal purchase record for the period in §7.
9. International transfers
We are based in [COUNTRY, presumably Hong Kong]. Google/Firebase may process data in the US and other countries. Where required, transfers rely on Google's standard contractual clauses / data processing terms. Firebase region: [FIREBASE REGION] [VERIFY].
10. Security
Data sent between the app, Google and our server is encrypted in transit (HTTPS/TLS). Payment data stays with Google. The server key is kept in Google Secret Manager / the default service identity and never in the app. Access to the Firebase project is limited to Kene Cheng. No system is perfectly secure; we will notify you and regulators of breaches as the law requires.
11. Hong Kong (Personal Data (Privacy) Ordinance, Cap. 486)
Kene Cheng is the data user. We collect only data that is necessary and adequate (DPP1), keep it accurate and no longer than needed (DPP2), use it only for the purposes above or directly related ones unless you consent (DPP3), protect it (DPP4), are open about our practices (DPP5), and you may request access to and correction of your personal data (DPP6). Send data access/correction requests to our data protection contact: [NAME/TITLE], support@wilddivegame.com, [POSTAL ADDRESS]. We will respond within 40 days; a fee may be charged for a data access request only as permitted by the Ordinance. We do not use personal data for direct marketing.
12. EEA / UK rights
You may request access, rectification, erasure, restriction, portability and object to processing based on legitimate interests; withdraw consent at any time; and complain to your local supervisory authority (UK: ICO). EU/UK representative: [DPO/REPRESENTATIVE if needed] [VERIFY Art. 27 need].
13. US state privacy rights (brief)
Residents of California and other states with privacy laws may have rights to know, access, delete and correct personal information and to opt out of "sale" or "sharing" for targeted ads. We do not sell or share personal information and do not use it for targeted ads. Use §8 to make a request; we won't discriminate against you for using your rights. [VERIFY] thresholds may mean these laws don't apply to Kene Cheng yet.
14. Belgium
Paid Lucky Draw tickets are not offered to players whose Google Play country is Belgium. We use the store country code supplied by Google Play (on the device and again on our server) only for this check. Free tickets and draws still work.
14a. WildDive website: Wish List and Forum
DRAFT for lawyer review. Backend: Supabase (database, sign-in) [REGION — VERIFY]; bot check: Cloudflare Turnstile.
Wish List (all ages). You can vote on ideas and send us a suggestion without an account. We do not ask for your name, email, or age. We store the suggestion text, its category and the time it was sent, and a random ID saved in your browser so you can only vote once per idea. We do not store your IP address. We filter out emails, phone numbers, links and addresses, and ask you not to write personal details. Suggestions are private: only our team reads them, and we write any public idea in our own words. Suggestions are deleted 30 days after we handle them. To remove your votes, clear your browser's site data.
Forum (13+ and parents only). Before entering, you give your year of birth; if you are under 13 we do not let you in and do not keep what you entered. To post, you sign in with your email address (a one-time link). We store your email, the display name you choose, your posts, reports you make, and moderation records. Your email is never shown. Posts are checked by a filter and moderated; your first posts are reviewed before they appear. We do not use forum data for ads, and we do not sell it. You can delete your account in your profile settings; your posts will then show as "deleted user" within 30 days. If we learn that a forum user is under 13, we delete the account.
Cloudflare Turnstile checks that a real person is submitting on both pages: https://www.cloudflare.com/turnstile-privacy-policy/ . Cloudflare acts as our host and database processor: https://www.cloudflare.com/privacypolicy/
15. Changes
We'll post any update here with a new effective date. For material changes we'll show a notice in the game before they take effect and, where the law requires (e.g. new collection from children), ask for consent again.
16. Contact
Kene Cheng · [POSTAL ADDRESS] · support@wilddivegame.com · [DPO/REPRESENTATIVE if needed]
Drafting sources (delete before publishing)
Reference game policies: https://www.pokemon.com/us/legal/privacy-notice · https://parents.pokemon.com/en-us/ · https://www.tocaboca.com/docs/en/privacy-policy · https://www.tocaboca.com/kids/docs/en/privacy-policy · https://supercell.com/en/privacy-policy/ · https://supercell.com/en/parents/ · https://www.nintendo.com/us/privacy-policy/ · https://play.nintendo.com/parents/tools-for-parents/nintendo-accounts-kids/ · https://www.lego.com/en-us/legal/notices-and-policies/privacy-policy · https://kids.lego.com/en-us/legal/privacy-policy · https://en.help.roblox.com/hc/en-us/articles/115004630823-Roblox-Privacy-and-Cookie-Policy
Laws & regulators: https://www.ftc.gov/legal-library/browse/rules/childrens-online-privacy-protection-rule-coppa · https://www.ftc.gov/business-guidance/resources/complying-coppas-frequently-asked-questions · https://gdpr-info.eu/art-8-gdpr/ · https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/childrens-information/childrens-code-guidance-and-resources/ · https://www.pcpd.org.hk/english/data_privacy_law/ordinance_at_a_Glance/ordinance.html · https://www.gamingcommission.be/sites/default/files/2021-08/onderzoeksrapport-loot-boxen-Engels-publicatie.pdf
Google: https://support.google.com/googleplay/android-developer/answer/9893335 (Families) · https://support.google.com/googleplay/android-developer/answer/10787469 (Data safety) · https://support.google.com/googleplay/android-developer/answer/9858738 (loot-box odds) · https://support.google.com/families/answer/7106960 · https://developers.google.com/games/services/terms · https://policies.google.com/privacy · https://firebase.google.com/support/privacy · https://support.google.com/drive/answer/2375057