HyperWhale Privacy Policy

The controller responsible for data processing in connection with the Game is:

Hyper Hollow Games
Germany
Email: info@hyperhollowgames.net
Website: www.hyperhollowgames.net

A data protection officer is not required as the company regularly employs fewer than 20 persons engaged in automated data processing.

HyperWhale does not directly collect personal information such as your name or email address. The Game:

• Does not require account creation or sign-up
• Does not ask for your name, email address, or other personal details
• Does not use third-party analytics or tracking SDKs and does not build behavioural profiles
• Does not contain third-party advertisements

The Game keeps no account, balance or inventory on our servers. It sends only limited diagnostic error reports and aggregated, non-identifying promotion interaction events to our own servers, as described in the sections below.

HyperWhale integrates with Google Play Games Services to provide leaderboard functionality. When you sign in to Google Play Games:

• Your Google Play Games profile name and avatar may be visible on leaderboards
• Your high scores are submitted to Google Play Games leaderboards
• Achievements you unlock are recorded in your Google Play Games profile
• This data is managed by Google according to their privacy policy

Sign-in is entirely optional and based on your voluntary consent. You can play the Game without signing in, but leaderboard features will be unavailable.

For information about Google Play Games' data practices, please review Google's Privacy Policy at https://policies.google.com/privacy

HyperWhale is free to play in part. One optional one-time purchase, "Unlock everything", opens seven more stocks, three more rival traders and the options market. It is sold through Google Play Billing and may also be included in a Google Play Pass subscription. The Game sells no virtual currency.

• We do not collect, store, or have access to your payment information
• All payment processing is handled by Google Play
• Your purchase is validated through Google Play Billing and restored by Google Play on a new device
• The Game stores on your device only whether the purchase is owned

Processing is necessary to fulfil the purchase you initiated. For information about Google Play's payment data practices, please review Google's Privacy Policy at https://policies.google.com/privacy

Versions of HyperWhale before 1.40 were an ocean runner that sold virtual gold through Google Play Billing and synchronised a pseudonymous player ID, the gold balance, lifetime gold counters, a gold transaction log and inventory with our backend, hosted by Hetzner Online GmbH in Germany. The current Game does none of this and sells nothing.

Data from those versions stays on our backend only to preserve what players bought and to meet legal retention duties. We never received payment information. You can ask us to delete it at any time using the deletion request above.

HyperWhale may fetch promotional content from our server, hosted by Hetzner Online GmbH in Germany, to show you other games by Hyper Hollow Games inside the Game. This content is:

• Randomised and not personalised
• Not selected based on your in-game behaviour, play history, profile, device identifiers, or any other user signal
• Limited to games published by Hyper Hollow Games; we do not integrate third-party advertising networks or SDKs, and the Game contains no third-party ads

When a promotion is displayed or tapped, the Game reports an interaction event to our self-hosted analytics service, also hosted by Hetzner Online GmbH in Germany. An event contains the event name ("shown" or "clicked"), the promotion's ID, and the game's ID. Our server additionally records your device's browser user agent string and, where provided by the network, a coarse country code. No player ID, device identifier, or advertising ID is attached to these events, we do not build user profiles from them; they are used only as aggregate statistics to measure whether promotions are useful.

The requests to our servers may expose your IP address to our hosting provider Hetzner; the IP address is not stored with the events. Based on our legitimate interest in informing users about our other products and measuring the effectiveness of these promotions.

If a technical error occurs, for example a failed Google Play Games sign-in or a failed purchase, HyperWhale sends a diagnostic report to our self-hosted logging service, hosted by Hetzner Online GmbH in Germany. A report contains:

• The game identifier and a severity level
• A short technical error message
• Technical context about the failure, without any player identifier

Reports never include your name, email address, advertising ID, or location, and we do not use them to track your behaviour or build profiles. The request may expose your IP address to our hosting provider Hetzner; the IP address is not stored with the report. Processing is based on our legitimate interest in detecting and fixing defects to provide a stable Game.

All your markets in progress, your best score, reputation, achievements, settings, and preferences are stored locally on your device using the Android SharedPreferences mechanism. This data never leaves your device and is not accessible to us.

Local storage is technically necessary for the Game to function and is therefore exempt from the consent requirement under the German Telecommunications Digital Services Data Protection Act.

The Game is distributed through the Google Play Store. Google may collect certain information as part of their platform services, including:

• Download statistics
• Crash reports (handled by Google Play Console)
• Device compatibility information

We may access aggregated, anonymized statistics provided by Google Play Console to understand game performance and stability, based on our legitimate interest in maintaining and improving the Game. This data is not stored separately by us.

The Game integrates with the following third-party services, which may process data as described above:

• Google Ireland Limited / Google LLC (Ireland/USA) — Google Play Games Services for leaderboards, Google Play Billing for gold pack purchases, Google Play Console for crash reports and statistics
• Hetzner Online GmbH (Germany) — hosting of our backend, including the database that stores gold balances, transaction logs, in-game inventory, cross-game promotional content, diagnostic error reports, and aggregated promotion interaction events

Data may be transferred to the United States. Where applicable, transfers are safeguarded by the EU-US Data Privacy Framework. Google LLC is DPF-certified. Hetzner Online GmbH processes data exclusively within the EU. No third-party analytics, advertising, or user tracking services are used.

Retention periods depend on the data category:

• Gold balance, aggregate counters, transaction log, and inventory (Hetzner) — retained for as long as the player ID remains active. Deleted on request to info@hyperhollowgames.net
• Google Play Games leaderboard data — retained by Google for as long as your Google account is active
• Diagnostic error reports (Hetzner) — kept only as long as needed to diagnose and fix the underlying issue, then deleted. Deleted earlier on request to info@hyperhollowgames.net
• Promotion interaction events (Hetzner) — stored without player or device identifiers and retained as aggregate statistics
• Google Play purchase records — retained by Google per their retention policy
• Google Play Console crash reports — retained by Google for up to 180 days
• Server logs from our backend (Hetzner) — retained per Hetzner's data processing practices, typically no more than 30 days
• Local device data — retained until you uninstall the Game or clear app data

We implement appropriate technical measures to protect data related to the Game. All network communication between the Game and third-party services uses SSL/TLS encryption (HTTPS). Local game data is stored within Android's application sandbox, which restricts access to other applications.

Under the GDPR, you have the following rights regarding your personal data:

• Access — obtain confirmation of whether your data is processed and receive a copy
• Rectification — correct inaccurate or incomplete data
• Erasure — request deletion of your data under the conditions specified by law
• Restriction — restrict the processing of your data in certain cases
• Data portability — receive your data in a structured, commonly used, machine-readable format
• Object — object to processing based on legitimate interests (see Section 14)
• Withdraw consent — withdraw any consent at any time without affecting the lawfulness of prior processing
• Automated decision-making — we do not use automated decision-making or profiling that produces legal effects

You can exercise rights over the gold balance, transaction log, and inventory we hold on our Hetzner-hosted backend by contacting info@hyperhollowgames.net. Rights relating to data held by third parties, such as your Google Play Games profile or Google Play purchase history, are exercised through the respective third-party services. We will respond within 30 days.

The Game is designed to be safe for all ages. We do not knowingly collect personal information from children under 16. The optional Google Play Games integration is governed by Google's age requirements and parental controls.

Where we process data on the basis of legitimate interests, you have the right to object at any time for reasons relating to your particular situation. This applies to cross-game promotion requests and interaction events (Section 5), diagnostic error reporting (Section 6) and Google Play Store analytics access (Section 8). If you object, we will no longer process your data for those purposes unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms. To object, email info@hyperhollowgames.net.

You have the right to lodge a complaint with a supervisory authority if you believe that the processing of your personal data violates the GDPR. You may contact any EU supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement. For Germany, a list of all data protection authorities is available at www.bfdi.bund.de. For the United Kingdom, you may contact the Information Commissioner's Office (ICO) at ico.org.uk.

We may update this Privacy Policy from time to time to reflect changes in our data processing activities or legal requirements. Any changes will be posted in the Game and on our website with an updated "Last updated" date. The current version is always available at www.hyperhollowgames.net/games/hyperwhale/privacy.

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

Hyper Hollow Games
Germany
Email: info@hyperhollowgames.net
Website: www.hyperhollowgames.net

We will respond within 30 days.