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

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.

2. What we collect

DataSourcePurposeLegal basis (GDPR/UK GDPR)
**Age band** (`u13` / `13plus`) derived from year of birthYou, on the first-launch age screenApply 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 inIdentify your account for cloud save; link verified purchases to youContract (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 gameRun the game; cloud save across devicesContract
**Purchase records**: purchase token, product ID (`wilddive_supporter`, `wilddive_tickets_200`), order ID, purchase state, refund/void status, country code from GoogleGoogle Play Billing and the Play Developer API, via our Firebase serverVerify 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 saveMake sure each purchase is granted once, restore tickets after reinstall or a save conflictContract
**Technical request data** (e.g. IP address, timestamps) in server logs **[VERIFY]**Automatically, when the game calls our Firebase functionSecurity and running the serviceLegitimate interests

3. What we don't collect

4. How we use information

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:

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].

6a. For kids (plain language)

Hi diver! 🐠 Here's how WildDive treats your info:

6b. For parents and guardians

7. Retention

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:

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

Questions about privacy? Contact us.