EmberFrost
Privacy Policy
Effective date · 6 October 2026
Developer and data controller: Burak Tunç, trading as Fios Apps, Türkiye ("we", "us")
Contact: contact@fiosapps.com
This policy explains what information the mobile game EmberFrost Survival (the "Game") handles, why, and what choices you have. It is written to meet the EU/EEA General Data Protection Regulation (GDPR), the UK GDPR and the Turkish Personal Data Protection Law No. 6698 (KVKK).
1. The short version
- You do not need an account to play.
- The Game shows no ads and contains no analytics, tracking or advertising SDKs. We do not track you across other companies' apps or websites, and we do not sell or share your personal data for advertising.
- Your progress is saved only on your device.
- If you buy something, the payment is handled by Apple (App Store) or Google (Google Play). We never see your card details.
- Some features described in sections 4 and 5 (purchase validation through RevenueCat, Apple Game Center, Google Play Games) only process data when they are present in the version you use and when you use them.
2. Information stored on your device
The Game saves your progress (save slots, village state, play time, settings such as language, sound and difficulty) in local files on your device. We do not receive these files. They may be included in your device's own backups (for example iCloud or Google backups) according to your device settings; those backups are run by Apple or Google under their privacy policies.
3. Purchases through the App Store and Google Play
The Game is free to start. A one-time "Full Story" purchase unlocks the rest of the story, and optional coin packs are offered later in the Game. Purchases are processed by Apple or Google under their terms and privacy policies. They tell the Game whether a purchase succeeded; they do not give us your name, e-mail address or payment details.
4. Purchase validation (RevenueCat)
To validate purchases, unlock what you bought on your devices and let you restore purchases, the Game uses RevenueCat, Inc. (USA) as our service provider (processor). When you open the store screen, buy or restore, RevenueCat processes:
- a random, anonymous app user ID created by the Game (not linked to your name or e-mail);
- the store receipt or transaction data: product, price, currency, purchase date, store country, transaction IDs;
- technical data needed to deliver the service: device type, operating system and app version, and your IP address (used for security and approximate country, not stored by us).
We use this only to provide and secure your purchases, to prevent fraud and to keep the accounting records the law requires. RevenueCat's privacy policy: https://www.revenuecat.com/privacy
5. Apple Game Center and Google Play Games
If the version you use offers achievements and leaderboards and you are signed in to Apple Game Center (iOS) or Google Play Games (Android), the platform shares with the Game your player ID and the display name or alias you chose, and the Game sends your achievements and scores (for example your fastest finish time) to the platform. These services are run by Apple and Google under their own privacy policies; your name and score may be visible to other players according to your platform settings. You can sign out or change visibility in your device's settings.
6. Purposes and legal bases
| Purpose | Data | GDPR basis | KVKK basis (Art. 5(2)) |
|---|---|---|---|
| Deliver and restore purchases | Section 4 data | Contract, Art. 6(1)(b) | (c) performance of a contract |
| Fraud prevention, security | Section 4 technical data | Legitimate interests, Art. 6(1)(f) | (f) legitimate interest |
| Tax and accounting records | Transaction data | Legal obligation, Art. 6(1)(c) | (ç) legal obligation |
| Achievements and leaderboards | Section 5 data | Contract, Art. 6(1)(b) | (c) performance of a contract |
| Answering your messages | Your e-mail and message | Legitimate interests, Art. 6(1)(f) | (f) legitimate interest |
7. Sharing and international transfers
We share personal data only with the service providers named above (RevenueCat; Apple and Google as platform operators) and with authorities when the law requires it. RevenueCat stores data in the United States. Transfers from the EEA/UK rely on the European Commission's Standard Contractual Clauses (and the UK addendum) or the EU-U.S. Data Privacy Framework where the recipient is certified; transfers from Türkiye are made under Article 9 of the KVKK, using the standard contracts announced by the Personal Data Protection Authority, which are notified to the Authority as required.
8. Retention
- Save data stays on your device until you delete it or delete the Game.
- Purchase records at RevenueCat are kept while the Game offers purchases and as long as needed to restore them, and transaction data as long as tax and commercial law requires (in Türkiye generally up to 10 years).
- Support e-mails are deleted within 2 years after the matter is closed.
9. Children
EmberFrost Survival is suitable for all ages but is not directed at children under 13 (or the minimum age of digital consent in your country). We do not knowingly collect personal data from children; the Game itself collects no personal data from any player, and purchases go through the platform's family controls (such as Apple's "Ask to Buy" and Google Play parental controls). If you believe a child has sent us personal data, contact us and we will delete it.
10. Your rights
Depending on where you live, you can ask us to access, correct or delete your personal data, to restrict or object to its processing, and to receive it in a portable format (GDPR Arts. 15–22). Under KVKK Article 11 you can ask whether your data is processed, request information about it, learn its purpose and recipients, request correction or deletion, and object to results that are against you and request compensation for unlawful processing. Write to contact@fiosapps.com; we answer within 30 days. Because the Game does not ask who you are, please include the anonymous app user ID or the store order number so we can find your purchase records.
You can complain to your local data protection authority; in Türkiye this is the Personal Data Protection Board (Kişisel Verileri Koruma Kurulu, www.kvkk.gov.tr).
11. Deleting your data
- Game progress: delete the save slot in the Game, or delete the Game from your device.
- Purchase records: your purchase history with Apple or Google is managed in your Apple or Google account. To delete the records held for us by RevenueCat, e-mail us; note that a deleted record may prevent purchases from being restored until the store receipt is checked again.
- Game Center / Play Games: manage or delete your data in your Apple or Google account settings.
12. Security
The Game makes no network connections except the ones listed in sections 4 and 5, which use encrypted connections (HTTPS). Our service providers protect data with industry-standard safeguards.
13. Changes
If we change this policy, for example when a new feature processes data, we will update the effective date above and, for significant changes, tell you in the Game or on the store page before the change applies.
14. Contact
Fios Apps (Burak Tunç), Türkiye · contact@fiosapps.com · https://fiosapps.com