Legal

Privacy governance

Version française

Effective 30 October 2026

This summary describes how we protect personal information, including for people in Quebec. TurnLoop Games, Inc. is established in the United States. Our internal governance policy is approved by the person in charge.

Responsibility and roles

Person in charge of the protection of personal information: Chief Executive Officer, TurnLoop Games, Inc., privacy@turnloop.games. The CEO approves practices, oversees requests and complaints, and leads incident response. Development implements access controls, consent choices and deletion. Support uses proportionate identity checks and passes requests to the person in charge. Only team members and providers who need information for their tasks have access, under written agreements appropriate to their role.

Retention and destruction

We keep information only as long as needed, then delete or irreversibly anonymise it. Ceilings are 13 months for raw analytics events and device-level attribution, 90 days for crash data, and 35 days for backup expiry after deletion. Purchase records remain for the period tax law requires, without a player link after account deletion. See the Privacy Policy and Account Deletion Notice for criteria and exceptions.

Requests and complaints

Write to privacy@turnloop.games or the address below to request access, correction or a copy in a structured, commonly used technological format such as JSON, or to complain. The person in charge reviews the issue, records the decision and tells you the outcome and action taken. We respond to Quebec access and correction requests and complaints within 30 days. New Zealand access and correction requests have a 20-working-day response period. If you are not satisfied, you may contact the Commission d’accès à l’information du Québec. We answer French requests in French.

Privacy impact assessments

Before launching or substantially changing a system that handles personal information, we assess privacy risks with the person in charge. Before communicating information outside Quebec or Canada, we assess every recipient, including independent ad partners, the sensitivity of the information, the purposes, contractual protections and the foreign legal framework. We document safeguards and written agreements before the transfer.

Privacy incidents

We keep one register for all markets and record every incident: information involved, circumstances, incident and discovery dates, number of people affected, harm assessment, notices and corrective measures. Each entry is retained for 5 years. We take steps to limit harm and prevent recurrence. For incidents posing a risk of serious injury in Quebec, we promptly notify the Commission and affected people. We also apply the notification duties of other markets.