Introduction
Snowy Ghost LLC ("we," "our," or "us") operates the Glitch mobile application (the "Service"). This Privacy Policy informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service. By using our Service, you agree to the collection and use of information in accordance with this Privacy Policy.
Information We Collect
We collect the following categories of information:
- Account Information: Username and display name you create within the app.
- Game Data: Game progress, statistics (wins, losses, games played), and gameplay preferences such as deck style.
- Device Information: IP address, device type, operating system version, and unique device identifiers.
- Subscription Data: Subscription status and purchase history, processed through RevenueCat, Apple App Store, and Google Play Store. We do not directly collect or store your payment card information.
- Usage Data: App interaction data collected for analytics and service improvement purposes.
Legal Basis for Processing (GDPR)
If you are located in the European Economic Area (EEA), our legal basis for collecting and using your personal data depends on the data concerned and the context in which we collect it:
- Contract Performance: Processing necessary to provide the Service (account data, game data).
- Legitimate Interests: Analytics, fraud prevention, and service improvement, where these interests are not overridden by your data protection rights.
- Legal Obligation: Where we are required to process data to comply with applicable laws.
- Consent: Where you have given specific consent, such as for marketing communications. You may withdraw consent at any time.
How We Use Your Information
We use your data to:
- Provide, operate, and maintain the game service
- Process subscription payments and manage your account
- Send important updates, security alerts, and support communications
- Improve the game experience, fix bugs, and develop new features
- Detect, prevent, and address fraud, abuse, and technical issues
- Comply with legal obligations
Third-Party Service Providers
We share data with the following categories of third-party service providers, solely for the purposes described in this policy:
- RevenueCat, Inc. — Subscription management and payment processing. RevenueCat Privacy Policy
- Apple Inc. — App distribution, in-app purchases, and payment processing via the App Store. Apple Privacy Policy
- Google LLC — App distribution and payment processing via Google Play Store. Google Privacy Policy
- Amazon Web Services (AWS) — Cloud hosting, data storage, and server infrastructure.
We do not sell, rent, or trade your personal information to third parties for marketing purposes.
Data Retention
We retain your personal information only as long as necessary to provide our Service and fulfill the purposes outlined in this Privacy Policy. Specifically:
- Account and game data are retained while your account is active.
- After account deletion or inactivity, data may be retained for up to 2 years for legal compliance, dispute resolution, and fraud prevention purposes.
- Anonymized or aggregated data may be retained indefinitely for analytics.
Your Rights
Depending on your jurisdiction, you may have the following rights regarding your personal data:
- Access: Request a copy of the personal data we hold about you.
- Correction: Request correction of inaccurate or incomplete data.
- Deletion: Request deletion of your personal data, subject to legal retention requirements.
- Data Portability: Request a machine-readable copy of your data (where applicable under GDPR).
- Objection: Object to processing based on legitimate interests (where applicable under GDPR).
- Restriction: Request restriction of processing in certain circumstances.
To exercise any of these rights, contact us at team@snowyghost.com. We will respond within 30 days (or the timeframe required by applicable law).
California Residents (CCPA/CPRA)
If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):
- Right to Know: You may request disclosure of the categories and specific pieces of personal information we have collected about you.
- Right to Delete: You may request deletion of your personal information, subject to certain exceptions.
- Right to Opt-Out of Sale: We do not sell your personal information. If this changes, we will provide a "Do Not Sell My Personal Information" link.
- Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA/CPRA rights.
To make a request, email team@snowyghost.com. We may need to verify your identity before processing your request.
Do Not Track
Our Service does not respond to Do Not Track (DNT) browser signals. We do not track users across third-party websites. However, some third-party service providers may track your activity as described in their respective privacy policies.
Data Security
We implement commercially reasonable technical and organizational security measures to protect your personal data, including encryption in transit (TLS/SSL) and secure cloud infrastructure. However, no method of transmission over the Internet or method of electronic storage is 100% secure, and we cannot guarantee absolute security.
International Data Transfers
Your information may be transferred to and processed in countries other than your country of residence, including the United States. These countries may have different data protection laws. Where required by applicable law (such as GDPR), we ensure appropriate safeguards are in place for such transfers, including Standard Contractual Clauses approved by the European Commission. By using our Service, you acknowledge these transfers.
Data Breach Notification
In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify affected users and relevant supervisory authorities within the timeframes required by applicable law (72 hours under GDPR where feasible, or as otherwise required).
Children's Privacy
Our Service is not directed at children under the age of 13. We do not knowingly collect personal information from children under 13 in compliance with the Children's Online Privacy Protection Act (COPPA). If we become aware that we have collected personal data from a child under 13 without parental consent, we will take steps to delete that information promptly. If you believe your child has provided us with personal data, please contact us immediately at team@snowyghost.com.
Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on this page and updating the "Last updated" date. For significant changes, we may also notify you through the app or by email. Your continued use of the Service after changes become effective constitutes acceptance of the revised Privacy Policy. We encourage you to review this policy periodically.
Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, contact us at:
Snowy Ghost LLC
Email: team@snowyghost.com