Privacy Policy

Last Revised: November 21, 2025

Part 1: What This Policy Covers

PolarTidal Tech Inc. ("we," "us," or "our") explains in this Privacy Policy how we collect, use, disclose, and protect personal data when you access our platform, use games offered through the platform (including developer-hosted games), and use social or community features (collectively, the "Services").

By using the Services, you acknowledge the practices described here. If you continue to use the Services after updates, that continued use indicates acceptance of the updated Policy.

Part 2: The Information We Collect

Information you provide: This can include your name and contact details, account credentials, demographic details (such as date of birth), billing details and transaction records, identity documents when required for age verification or regulatory compliance, and messages or content you choose to submit through the Services.

Information collected automatically: When you use the Services, we may collect device identifiers and device characteristics, operating system information, usage and engagement metrics, session timing information, diagnostics and crash reports, and network information. We may also collect location information, including GPS data when enabled and approximate location based on IP address.

Information from third parties: If you connect a third-party account (such as Apple, Google, or other social platforms), we may receive limited profile information from those platforms. We may also receive risk or fraud signals, marketing insights, and verification information from service providers.

Sensitive information: We collect biometric authentication data and government-issued identification numbers only when needed for enhanced security verification or to satisfy regulatory requirements.

Part 3: How We Use Personal Data

We use personal data to provide the Services, including account creation and authentication, customer support, and secure payment processing.

We use personal data to operate and improve the Services, including analyzing gameplay patterns, monitoring performance, and developing features.

We use personal data for safety, security, and compliance, including fraud prevention, enforcement of anti-cheating controls, and compliance with legal obligations.

We use personal data to communicate with users. Essential operational notices may be sent even if you opt out of certain promotional communications.

Part 4: When We Share Personal Data

Service providers: We share information with vendors who help us host the Services, process payments, provide analytics, deliver customer support tooling, and operate security and compliance programs.

Legal and regulatory: We may disclose information in response to court orders, subpoenas, lawful government requests, tax reporting obligations, and law-enforcement requests as permitted by law.

Business transactions: We may share information as part of a merger, acquisition, reorganization, or other transaction involving a transfer of assets, subject to appropriate safeguards.

International transfers: Where we transfer personal data internationally, we use safeguards such as EU Standard Contractual Clauses and reliance on adequacy decisions where applicable.

Third-party integrations: If you use third-party integrations, those third parties may process information under their own policies. This Policy does not control third-party privacy practices.

Part 5: Security

We use layered controls designed to protect information. Controls may include encryption in transit (TLS 1.3) and at rest (AES-256), multi-factor authentication, role-based access controls, vulnerability assessments, SOC 2 aligned infrastructure practices, and continuous monitoring. No security measure is perfect, and users should also protect their own accounts.

Part 6: Retention and Disposal

We keep personal data for as long as needed to operate the Services and meet legal obligations. Typical retention periods can include: active account data retained for 36 months after the last user activity, financial records retained for 84 months for tax compliance, and support communications retained for 24 months after resolution. Marketing preferences are retained until you change or revoke them.

When information is no longer needed, we use secure deletion methods. Physical media used for archival records may be destroyed.

Part 7: Your Rights and Choices

Depending on where you live, you may have the right to access and portability, correction, deletion, restriction of processing, and the right to object to certain uses.

Region-specific rights may apply, including California CCPA/CPRA rights, European GDPR rights, and Canadian PIPEDA-related rights.

Requests: You can submit requests through the designated privacy portal. We may require identity verification to protect users. Standard requests are generally processed within 45 days and typically at no charge.

Part 8: Age Restrictions

Our Services are intended only for verified users who are 18 years of age or older.

If we discover data that appears to relate to minors, we will take steps to delete it promptly without prior notification.

Part 9: Changes to This Policy

We may update this Policy. If changes are material, we aim to provide notice through multiple channels at least 30 days before implementation.

Part 10: Contact

For privacy-related inquiries, contact:

Email: [email protected]

Response Standard: We typically acknowledge requests within 2–3 business days

Verification: We may request identity confirmation for requests involving sensitive security information

Appendix A: Privacy FAQ (Non-binding)

Q: Do you sell personal data?

A: This Policy describes sharing with service providers and limited legal or transactional disclosures. It does not describe selling personal data for money.

Q: Why do you collect location information?

A: Location signals are used to support eligibility checks, enforce geographic restrictions, and strengthen security controls.

Q: What happens if I request deletion?

A: We process deletion requests according to applicable law. Some information may be retained for legal compliance, fraud prevention, or recordkeeping obligations.

Q: How do you protect payment information?

A: Payment processing typically involves specialized payment providers. We also apply encryption and access controls to reduce risk.

Appendix B: Practical Examples (Non-binding)

Example 1: Crash diagnostics may be used to troubleshoot stability problems and improve performance.

Example 2: Unusual login patterns may be used for fraud detection and to protect accounts from unauthorized access.

Example 3: Support tickets may be retained so we can resolve issues and prevent repeated problems.

Appendix C: Glossary Notes (Non-binding)

Personal data: Information that identifies, relates to, describes, or could reasonably be linked to an individual.

Service provider: A vendor that processes information on our behalf to support hosting, payments, analytics, support tooling, or security programs.

Processing: Any operation performed on data, such as collection, storage, use, disclosure, deletion, or analysis.

Appendix D: Extended Guidance (Non-binding)

Cookies and similar technologies: We may use cookies or similar identifiers to keep sessions working, remember preferences, measure performance, and reduce fraud. Some identifiers are essential for functionality, while others support analytics and marketing measurement.

Opt-out concepts: Opting out typically means you can stop receiving certain promotional communications. It does not necessarily stop processing required for account security, legal compliance, or core service delivery.

Appendix E: Making a Rights Request (Non-binding)

If you submit a privacy request, include the account email associated with your profile and describe the request type (access, correction, deletion, or objection). If your request relates to marketing communications, describe what you received and when.

Verification is used to protect users. When we request verification, we generally ask for the minimum information needed to confirm identity. Without verification, we may be unable to complete certain requests because doing so could expose personal data to unauthorized parties.

Appendix F: Account and Device Privacy Tips (Non-binding)

Protect your account: Use a strong, unique password, keep devices updated, and avoid sharing credentials.

Review device permissions: Location services, notifications, and advertising identifiers can affect what information is available to the Services.

Appendix G: Marketing and Preferences (Non-binding)

You may be able to opt out of certain promotional communications. Essential operational messages may still be sent, such as security alerts, service changes, and account notices.

If you use multiple devices, your preferences may need to be updated on more than one device, depending on how you access the Services.