Privacy Policy

Effective Date: November 1, 2025

Last Penny Game Studio LLC (hereinafter referred to as "we", "Last Penny" or "the Company"), as a creative enterprise specializing in independent game development and publishing, deeply understands that every player's trust stems from the respect and protection of personal privacy. In an increasingly complex digital entertainment ecosystem, players' personal information is not only the foundation for service provision but also a valuable digital asset. This Privacy Policy aims to clearly and transparently explain how we collect, use, store, share, and protect your personal information generated when you experience our game products, visit our official website, and use related services (collectively referred to as "Services" hereinafter).

We strictly comply with the framework of U.S. federal and state privacy laws, including the California Consumer Privacy Act (CCPA), the Children's Online Privacy Protection Act (COPPA), the Federal Trade Commission Act (FTC Act), etc., to ensure that all data processing activities are legal and compliant. Before registering an account, logging into the game, using the Services, or participating in related activities, please carefully read and fully understand all terms of this Policy. If you have any questions, needs, or suggestions regarding this Policy, please contact us through the methods specified at the end of this document. By clicking "Agree", completing the registration, or actually using our Services, you indicate that you have fully understood and accepted all the provisions of this Policy.

I. Core Privacy Principles

We adhere to the four core principles of "Player-Centric, Minimal Necessity, Transparency and Controllability, and Security First", integrating privacy protection deeply into the entire process of game development and service provision:

- Player-Centric: Endow you with full control over your personal information, allowing you to independently choose the scope of information collection, usage methods, and sharing permissions.

- Minimal Necessity: Only collect information necessary for realizing core game functions and optimizing user experience, without collecting additional irrelevant data.

- Transparency and Controllability: Disclose the entire process of information processing in easy-to-understand language, avoiding obscure terminology to ensure your right to know.

- Security First: Adopt industry-leading technical and management measures to build a comprehensive data security protection system and safeguard your information security.

II. Scope and Methods of Information Collection

(I) Information You Voluntarily Provide

1. Account Registration and Login: When registering a game account, you need to provide an email address and password, and may optionally provide a nickname, avatar, and other information; if you log in through a third-party platform (such as Google, Facebook, Apple ID), we will obtain basic information such as your nickname and avatar authorized for sharing. Such information is used to create an exclusive account, verify identity, ensure account security, and provide personalized services.

2. Service and Transaction-Related Information: When you submit a technical support request, you may need to provide a problem description, game screenshots, device model, and other information to enable us to quickly respond and resolve the issue; if you purchase in-game paid content or peripheral products, you need to provide payment information (such as credit card number, payment account), shipping address, contact information, etc., for completing the transaction, logistics and distribution, and after-sales support (payment information is directly processed by third-party payment service providers, and we do not store complete payment card information).

3. Interaction and Feedback: When you participate in in-game community discussions, submit product reviews, participate in questionnaires, or feedback activities, you may share opinions, game experiences, suggestions, and other information. Such information is used to promote player community communication, optimize game products, and improve service quality.

(II) Automatically Collected Information

1. Device and Network Information: When you visit the official website or run the game, our servers will automatically record device information (such as device model, operating system version, browser type, unique device identifier), network information (such as IP address, network service provider, network type), which is used to adapt to the game operating environment, ensure service stability, and prevent security risks.

2. Game Usage Behavior Information: Automatically collect your game login time, online duration, game progress, level completion status, function usage frequency, item acquisition and usage records, and other data, which is used to optimize game balance, fix bugs, and enhance gameplay experience.

3. Location Information: Only with your explicit authorization may we infer approximate geographic location through IP address or obtain device GPS positioning information to provide localized services (such as region-specific events, language adaptation). You can disable location authorization in the game settings at any time.

4. Cookies and Similar Technologies: We use Cookies, Web Beacons, and other technologies to remember your login status, preference settings (such as sound effects, image quality selection), and count game visits and user interaction data. You can disable non-essential Cookies through browser or device settings, but this may cause functions such as automatic login and personalized settings to not work properly.

(III) Information from Third-Party Sources

1. Shared by Partners: With your authorization, we obtain information authorized for sharing from third-party cooperation platforms (such as game distribution platforms, social media, payment service providers) (such as account association information, transaction records, logistics information), which is only used for account association, service docking, and ensuring transaction security, and must comply with the privacy rules of the third-party platforms.

2. Publicly Available Information: Within the scope permitted by law, we may collect your publicly available information (such as nickname, public reviews) from public channels (such as public game industry reports, publicly shared content on player communities) for market analysis and game optimization, and such information is not associated with your personal identity information.

III. Purposes of Information Use

We only use your personal information within the scope permitted by law and agreed in this Policy, for the following specific purposes:

1. Provision and Maintenance of Core Services: Used for opening accounts, ensuring the normal operation of the game, processing transaction orders, delivering goods, responding to technical support requests, fixing system failures, etc., to ensure that you can smoothly experience the game and related Services.

2. Game and Experience Optimization: By analyzing your game behavior data and device information, optimize game performance (such as adapting to more devices, improving operational smoothness), adjust gameplay balance, and push personalized game content (such as level recommendations adapted to your game style) to enhance your game experience.

3. Security Assurance and Risk Prevention: Use device information, IP address, login records, and other data to identify abnormal access behaviors (such as login from an unusual location, multiple incorrect password attempts), prevent risks such as account theft and fraud, detect and block malicious attacks (such as DDoS attacks, cheating with plug-ins), and protect your account security and the fairness of the game ecosystem.

4. Communication and Marketing: With your consent, send you marketing content such as game update notifications, event reminders, new product releases, and preferential benefits through email, in-game pop-ups, text messages, etc.; you can unsubscribe at any time through account settings or unsubscribe links.

5. Compliance and Legal Matters: To comply with U.S. federal and state laws and regulations (such as data retention period requirements), respond to legal procedures (such as court subpoenas, regulatory investigations), and protect the legitimate rights and interests of us and third parties (such as addressing intellectual property infringement, resolving service disputes), legally use or disclose your personal information.

6. Business Analysis and Improvement: After anonymizing and de-identifying personal information, use it for internal business analysis (such as statistics on player behavior trends, service satisfaction surveys), game development (such as optimizing gameplay functions based on player feedback), and market research. The processed data cannot be associated with specific individuals.

IV. Information Sharing and Disclosure

We strictly control the scope of personal information sharing and only share or disclose your personal information with third parties in the following circumstances, ensuring that third parties comply with the same data protection standards:

1. Third-Party Service Providers: To achieve service purposes, we may share necessary information with third parties that provide support services for us, including:

- Cloud service providers (such as Amazon Web Services): Share device information, game usage records, etc., for server hosting, data storage, and backup;

- Payment service providers (such as PayPal, Stripe): Share transaction-related information (such as order amount, shipping address) for processing payments and refunds;

- Customer support tool providers: Share your service request content and contact information to assist in handling technical support tickets;

- Marketing tool providers: With your consent, share your email address for sending marketing information.We will sign data processing agreements with the above third parties, clarify their data protection obligations, require them to use information only within the authorized scope, and take security measures to protect the information.

2. Affiliated Companies: If you use the services of our affiliated companies (referring to enterprises that directly or indirectly control us, are controlled by us, or are under common control with us), or if we provide services in collaboration with affiliated companies, we may share your necessary personal information within the group to achieve cross-platform service docking (such as account interoperability, game data synchronization). Affiliated companies will comply with this Policy or an equally strict privacy policy.

3. Business Transfer: In the event of major business changes such as company merger, acquisition, asset sale, restructuring, or bankruptcy liquidation, your personal information may be transferred to a third party as part of the business assets. We will notify you through official website announcements, in-game notifications, or emails before the transfer, and require the transferee to continue to comply with the privacy protection terms of this Policy.

4. Legal Requirements and Protection of Rights and Interests: We may disclose your personal information in accordance with the law without your prior consent in the following circumstances:

- Respond to court subpoenas, arbitration awards, legitimate requests from government regulatory authorities, or legal procedures;

- To protect the personal safety, property safety, or legitimate rights and interests of us, you, or third parties (such as preventing fraudulent acts, responding to emergencies);

- Comply with applicable laws and regulations, industry standards, or perform legal duties.

5. Other Circumstances with Your Consent: With your explicit consent, we will share personal information with designated third parties in accordance with your instructions (such as authorizing us to synchronize game achievements to social media).

V. Information Storage and Security

(I) Storage Location and Period

1. Storage Location: Your personal information is mainly stored on compliant servers within the United States (including self-operated servers and computer rooms of third-party cloud service providers located in the United States) to ensure that data processing complies with relevant U.S. laws and regulations. If cross-border data transmission is involved, we will adopt compliant safeguard measures such as signing standard contractual clauses to ensure the security of data transmission.

2. Storage Period: We only retain your personal information for the shortest period necessary to achieve the purposes of use agreed in this Policy, and not exceeding the maximum retention period stipulated by law:

- Account information: Retained for 1 year after you cancel your account (to address potential disputes);

- Transaction records: Retained for at least 7 years in accordance with the requirements of the U.S. Internal Revenue Code;

- Game usage records, interaction information, etc.: Retained for 2 years after you stop using the Services (for system audits and product optimization).After the expiration of the retention period, we will process your personal information in a secure manner such as encrypted deletion or anonymization. Anonymized data can be used for business analysis and no longer associated with specific individuals.

(II) Security Protection Measures

We adopt physical, technical, and management measures that meet industry standards for games to fully protect your personal information:

1. Technical Security: Adopt SSL/TLS transmission encryption and AES-256 storage encryption technologies for sensitive information (such as account passwords, payment-related information); implement access control mechanisms to allow only authorized personnel to access personal information with different permissions based on job responsibilities; conduct regular security vulnerability scans and penetration tests to promptly fix security risks; deploy firewalls and intrusion detection systems to prevent malicious attacks and cheating with plug-ins.

2. Physical Security: Implement 24/7 monitoring, access control, data backup, and other measures for server computer rooms storing personal information; third-party data centers must comply with SOC 2 certification standards.

3. Management Security: Formulate data security management systems, employee confidentiality agreements, and standardized data processing procedures; provide privacy protection and data security training to employees, who can only participate in data processing after passing the assessment; establish a data breach emergency response plan. In the event of a security incident, we will promptly notify affected users and regulatory authorities and take remedial measures.

Please note that no information transmitted over the Internet or stored electronically can be guaranteed to be 100% secure. We will make every effort to protect your personal information but shall not be liable for information security risks caused by force majeure (such as natural disasters, hacker attacks) or your own reasons (such as password leakage, device theft).

VI. Your Rights Regarding Personal Information

In accordance with relevant U.S. laws, you have the following rights regarding your personal information, and we will provide you with free channels to exercise these rights:

1. Right of Access: You have the right to request us to confirm whether we store your personal information and obtain a copy of your personal information (such as account registration information, transaction records, game usage records). You can submit a written request through account settings or the contact information at the end of this document, and we will respond within 15 working days (complex cases may be extended to 30 working days, and we will notify you in advance).

2. Right of Correction: If you find that the personal information we store is inaccurate (such as incorrect nickname, changed contact information), you have the right to request correction. You can modify some information independently through the "Personal Center" of your account or submit a correction request. We will complete the correction within 5 working days after verification and notify you of the result.

3. Right to Erasure: You have the right to request us to delete your personal information in the following circumstances:

- The personal information is no longer necessary for the purpose for which it was collected;

- You withdraw your prior consent and there is no other legal basis for processing;

- Our processing activities violate laws and regulations or the agreement of this Policy;

- You no longer use our Services and have no outstanding transactions or disputes.You can submit a deletion request. We will delete the information within 10 working days after verification (except for information that must be retained in accordance with laws and regulations) and notify you of the result.

4. Right to Withdraw Consent: You can withdraw your prior consent to the processing of personal information (such as consent to receive marketing information, location authorization, use of Cookies) at any time. After withdrawing consent, we will stop the relevant processing activities, but this will not affect the legality of processing based on consent before withdrawal; if withdrawing consent results in the inability to use some service functions, we will notify you in advance.

5. Right to Data Portability: You can request to obtain your personal information in a structured, commonly used, and machine-readable format and transfer it to other service providers (subject to technical feasibility and without prejudice to the rights of others).

6. Exclusive Rights for California Residents (Pursuant to CCPA):

- Right to Opt-Out of Sale: We will not sell your personal information; if future business model changes involve the sale of information, we will notify you in advance through official website announcements and provide a free and convenient "opt-out" mechanism.

- Right to Request Disclosure: You have the right to request us to disclose, within the past 12 months:

- The categories, sources, and purposes of personal information collected;

- The categories and purposes of personal information shared with third parties;

- If information is sold, disclose the categories of personal information sold and the information of recipients.You can submit such requests free of charge twice every 12 months, and we will respond within 45 working days (complex cases may be extended to 90 working days).

- Right to Non-Discrimination: You will not be discriminated against (such as increasing service prices, reducing service quality, or refusing to provide services) for exercising the rights granted by the CCPA.

VII. Protection of Minors' Privacy

Our Services are mainly oriented to adult players. We strictly comply with the Children's Online Privacy Protection Act (COPPA) and will not intentionally collect personal information of minors under the age of 13. If we discover that personal information of a minor has been collected without the consent of their parents/guardians, we will immediately delete the relevant data and terminate the service. If you are a parent or guardian and find that your child has used our Services and submitted personal information without your consent, please contact us through the contact information at the end of this document, and we will assist you in handling the matter.

VIII. Third-Party Links and Services

Our games or official website may contain third-party links (such as social media sharing links, partner promotion links) or integrate third-party services (such as payment tools, statistical analysis tools). Such third parties may independently collect, use, or disclose your information, and their privacy policies are independent of this Policy. We recommend that you read and understand the privacy policies of third parties and carefully authorize information sharing. We are not responsible for the privacy practices of third parties.

IX. Updates and Notifications of the Policy

We may revise this Policy in accordance with changes in laws and regulations, adjustments to business models, and optimization of game functions. In the event of major changes (such as substantive adjustments to the purposes of information collection, scope of sharing, or methods of exercising user rights), we will notify you at least 30 days in advance through the following methods:

- Publish a change announcement in a prominent position on the homepage of the official website;

- Send a change notification to the email address you provided during registration;

- Pop up a change prompt when you log in to your account next time, requiring you to confirm reading the new Policy.

The revised Policy will take effect on the effective date specified in the notification. Your continued use of our Services indicates that you accept the revised Policy; if you do not agree to the changes, you should immediately stop using the Services and cancel your account.

X. Dispute Resolution and Governing Law

This Policy shall be construed, enforced, and resolved in accordance with the laws of the State of Idaho, United States. In the event of a dispute, both parties shall first attempt to resolve it through friendly negotiation; if negotiation fails, the dispute may be submitted to the competent court located in the Company's place of business for litigation.

XI. Contact Information

If you have any questions, comments, or suggestions regarding this Privacy Policy, or need to exercise your rights regarding personal information or complain about data processing-related issues, please contact us through the following methods:

- Dedicated Email for Privacy Matters: [email protected] (usually replies within 5 working days);

- Mailing Address: Last Penny Game Studio LLC, 201 E A St, Kendrick, ID 83537 US;

- If you are a California resident and have questions about exercising your rights, you can additionally contact our California Privacy Officer ( [email protected]); if you believe our privacy practices violate the CCPA, you can file a complaint with the California Attorney General's Office.