Tycoon Games Privacy Policy

Your privacy is important to us. Learn how we collect, use, and protect your information in our mobile tycoon simulation games.

Last updated: November 24, 2025

TYCOON GAMES PRIVACY POLICY Effective Date: November 24, 2025 Last Updated: November 24, 2025 Company: Further Theory, LLC ("we," "us," "our," "Company") Address: 6 Liberty Square #2327 Boston, MA 02109 United States Contact: support@plotwings.com Website: plotwings.com This Privacy Policy describes how Further Theory, LLC collects, uses, shares, and protects personal information when you use our mobile tycoon simulation games (including but not limited to any business simulation, resource management, or strategy games we develop and publish) accessed through the Apple App Store (collectively, the "Games," "App," "Service," or "Platform"). ═══════════════════════════════════════════════════════════ IMPORTANT NOTICES ═══════════════════════════════════════════════════════════ • WE DO NOT SELL YOUR PERSONAL INFORMATION to third parties for their own purposes. • SUBSCRIPTION SERVICES: Our Games offer auto-renewable subscriptions through the Apple App Store. Subscription data is processed by Apple pursuant to Apple's privacy policies. • CHILDREN'S PRIVACY: Our Games are not intended for children under 13 years of age. See Section 10. • YOUR RIGHTS: You have rights to access, correct, delete, and control your data under applicable privacy laws. See Section 8. • THIRD-PARTY SERVICES: We use third-party service providers for cloud hosting, analytics, subscription management, advertising, and other services. See Section 6. • APPLE APP STORE: Apple independently collects and processes data through Sign in with Apple, In-App Purchase, Apple Game Center, and iOS system services. We do not control Apple's data practices. See Sections 2 and 11. • GAME DATA AND ANALYTICS: We collect gameplay data, progression statistics, in-game actions, and device information to improve game experience, balance gameplay, and provide customer support. • CALIFORNIA RESIDENTS: See Section 9 for your specific privacy rights under the California Consumer Privacy Act (CCPA). • EUROPEAN RESIDENTS: See Section 9 for your specific privacy rights under the General Data Protection Regulation (GDPR). By using the Games, you acknowledge that you have read and understood this Privacy Policy and consent to our collection, use, and disclosure of your information as described herein. If you do not agree with any part of this Privacy Policy, you must not use our Games. Read our Terms of Service at plotwings.com/tycoon-terms-of-service for additional information about your rights and obligations. ═══════════════════════════════════════════════════════════ TABLE OF CONTENTS ═══════════════════════════════════════════════════════════ 1. Information We Collect 1.1 Account and Profile Information 1.2 Gameplay and Usage Data 1.3 Subscription and Transaction Data 1.4 Device and Technical Information 1.5 Communication Data 1.6 Social and Multiplayer Features 1.7 Advertising and Marketing Data 2. How We Collect Information 2.1 Information You Provide Directly 2.2 Automatic Collection Through Technology 2.3 Apple App Store and Apple Services 2.4 Third-Party Sources 3. How We Use Your Information 3.1 Game Operation and Service Delivery 3.2 Subscription Management 3.3 Customer Support 3.4 Analytics and Game Improvement 3.5 Personalization and Content Delivery 3.6 Advertising and Marketing 3.7 Legal Compliance and Safety 4. Legal Basis for Processing (For European Users) 5. How We Share Your Information 5.1 Service Providers and Business Partners 5.2 Apple and App Store Services 5.3 Advertising Partners 5.4 Legal Requirements and Protection 5.5 Business Transfers 6. Third-Party Services and Data Processors 7. Data Retention 8. Your Privacy Rights and Choices 8.1 Access and Correction 8.2 Deletion and Erasure 8.3 Opt-Out and Marketing Preferences 8.4 Account Deactivation 8.5 Do Not Track Signals 9. Privacy Rights for Specific Jurisdictions 9.1 California Residents (CCPA/CPRA Rights) 9.2 European Economic Area, UK, and Switzerland (GDPR Rights) 9.3 Other Jurisdictions 10. Children's Privacy 11. Apple App Store and iOS Specific Provisions 11.1 In-App Purchases and Subscriptions 11.2 Sign in with Apple 11.3 Apple Game Center 11.4 Apple Privacy Controls 12. Data Security 13. International Data Transfers 14. Changes to This Privacy Policy 15. Contact Information and Data Protection Officer 16. Dispute Resolution and Arbitration ═══════════════════════════════════════════════════════════ 1. INFORMATION WE COLLECT ═══════════════════════════════════════════════════════════ 1.1 ACCOUNT AND PROFILE INFORMATION When you create an account or profile in our Games, we may collect: • User identifier (username, display name, player ID) • Email address (if you choose to provide it or sign in with Apple using your email) • Authentication credentials and tokens • Profile picture or avatar selections • Game preferences and settings • Account creation date and last login date • Sign in with Apple identifier (anonymized email relay or shared email, if you use Apple authentication) 1.2 GAMEPLAY AND USAGE DATA To provide game services and enhance your experience, we collect detailed gameplay information: • Game progress, levels completed, and achievements unlocked • In-game resources, currency balances (both virtual and premium currencies), and inventory • Buildings, assets, and businesses constructed or acquired in the simulation • Strategic decisions, actions taken, and gameplay patterns • Time spent playing, session duration, and frequency of play • Tutorial completion status and feature usage • Leaderboard rankings and competitive performance • Game economy interactions (purchases, sales, trades within the game) • Challenges completed and rewards claimed • Multiplayer interactions and social features usage • In-game events participation • Feature adoption rates and engagement metrics • Error logs, crash reports, and performance data • Customer support interactions related to gameplay 1.3 SUBSCRIPTION AND TRANSACTION DATA When you purchase subscriptions or in-app content through the Apple App Store: • Subscription type, tier, and plan selected • Subscription start date, renewal dates, and status (active, expired, cancelled) • Transaction date and time • Order identification numbers • Purchase history and transaction records • Payment method type (processed and stored by Apple, not by us) • Refund and cancellation requests • Promotional offer usage and redemption • Free trial usage and conversion data IMPORTANT: We do NOT collect or store your credit card numbers, banking information, or other direct payment credentials. All payment processing is handled exclusively by Apple through the App Store. We receive only transaction confirmation data and subscription status information from Apple. 1.4 DEVICE AND TECHNICAL INFORMATION We automatically collect technical information about your device and how you access our Games: • Device type, model, and manufacturer (e.g., iPhone 15 Pro) • Operating system version (e.g., iOS 17.1) • Unique device identifiers (IDFA - Identifier for Advertisers, IDFV - Identifier for Vendors, or alternative identifiers) • IP address and general geographic location (country, region, city-level) • Language and locale settings • Time zone • Mobile carrier and network information • Screen resolution and device orientation • Battery level and charging status • Available storage space • App version and build number • Internet connection type (WiFi, cellular data) • Performance metrics (frame rate, load times, memory usage) • Crash logs and debugging information • Device settings relevant to game performance 1.5 COMMUNICATION DATA When you contact us for support or communicate with us: • Support request content and correspondence • Email messages sent to or from us • Chat or messaging history with customer support • Feedback, reviews, and survey responses • User-generated content submitted through the Games • Bug reports and feature requests 1.6 SOCIAL AND MULTIPLAYER FEATURES If you use social or multiplayer features: • Friends list and social connections within the Games • Messages, chat logs, and communications with other players • Guild, clan, or team membership and activity • Cooperative or competitive gameplay data • User-generated content shared with other players • Reputation scores and player ratings • Social media account information (if you choose to connect accounts) 1.7 ADVERTISING AND MARKETING DATA For advertising and marketing purposes: • Ad interaction data (views, clicks, conversions) • Marketing campaign engagement and response rates • Advertising identifiers (IDFA, if you have not opted out) • Attribution data (how you discovered our Games) • A/B test group assignments and experiment data • Push notification preferences and engagement • Email marketing preferences and engagement metrics ═══════════════════════════════════════════════════════════ 2. HOW WE COLLECT INFORMATION ═══════════════════════════════════════════════════════════ 2.1 INFORMATION YOU PROVIDE DIRECTLY You provide information directly when you: • Create an account or player profile • Make in-app purchases or subscribe to premium features • Customize your game settings and preferences • Contact customer support • Participate in surveys, contests, or promotional events • Communicate with other players through in-game features • Submit feedback or reviews • Opt in to marketing communications 2.2 AUTOMATIC COLLECTION THROUGH TECHNOLOGY We automatically collect information using various technologies: • Software Development Kits (SDKs) integrated into the Games • Cookies and similar tracking technologies • Analytics tools and services • Log files and server logs • Device APIs and system interfaces provided by iOS • Crash reporting and error tracking systems • Performance monitoring tools 2.3 APPLE APP STORE AND APPLE SERVICES We receive information from Apple when you: • Download or install our Games from the App Store • Make in-app purchases or subscribe through Apple • Use Sign in with Apple for authentication • Connect to Apple Game Center • Grant permissions through iOS privacy controls • Interact with App Store listings, ratings, and reviews Apple's collection and use of your data is governed by Apple's Privacy Policy, available at apple.com/legal/privacy. We have no control over Apple's data practices. 2.4 THIRD-PARTY SOURCES We may receive information from third-party sources including: • Analytics service providers • Advertising networks and attribution partners • Marketing partners and campaign platforms • Cloud service providers • Security and fraud prevention services • Social media platforms (if you connect accounts) • Public databases and data enrichment services ═══════════════════════════════════════════════════════════ 3. HOW WE USE YOUR INFORMATION ═══════════════════════════════════════════════════════════ 3.1 GAME OPERATION AND SERVICE DELIVERY We use your information to operate and deliver our Games: • Authenticate your identity and maintain your account • Provide access to game content, features, and functionality • Save and sync your game progress across devices • Enable multiplayer and social features • Deliver in-game content, rewards, and virtual items • Maintain leaderboards and competitive features • Process and fulfill in-game transactions • Enforce game rules and terms of service • Prevent cheating, fraud, and abuse • Ensure fair play and game integrity 3.2 SUBSCRIPTION MANAGEMENT We use subscription data to: • Activate and maintain your subscription benefits • Process subscription renewals through Apple • Grant access to premium features and content • Track subscription status and entitlements • Handle subscription cancellations and refunds • Offer upgrade and promotional opportunities • Communicate subscription-related information • Comply with consumer protection laws and regulations 3.3 CUSTOMER SUPPORT We use your information to provide customer support: • Respond to your inquiries and support requests • Troubleshoot technical issues and bugs • Investigate account problems and disputes • Restore lost progress or purchased content • Provide game guidance and assistance • Handle refund requests and billing issues • Communicate service updates and maintenance 3.4 ANALYTICS AND GAME IMPROVEMENT We analyze data to improve our Games: • Understand how players interact with game features • Identify popular content and gameplay patterns • Optimize game difficulty, balance, and progression • Improve user interface and user experience design • Fix bugs and technical issues • Enhance game performance and stability • Measure feature adoption and engagement • Conduct A/B testing and experiments • Inform game design and development decisions • Plan future content and updates 3.5 PERSONALIZATION AND CONTENT DELIVERY We use your information to personalize your experience: • Recommend in-game content, items, and features • Customize gameplay difficulty and challenges • Deliver relevant in-game events and promotions • Tailor notifications and communications • Show personalized offers and deals • Create customized player experiences • Adjust game content based on preferences and behavior 3.6 ADVERTISING AND MARKETING We use your information for advertising and marketing: • Deliver targeted advertisements within the Games (if applicable) • Measure advertising effectiveness and attribution • Send promotional communications and offers (with consent) • Market new games, features, and content • Conduct marketing campaigns and promotions • Analyze marketing performance and ROI • Remarket to previous players and subscribers • Cross-promote our other games and services You can opt out of personalized advertising through iOS privacy settings (see Section 11.4). 3.7 LEGAL COMPLIANCE AND SAFETY We use your information to: • Comply with legal obligations and regulatory requirements • Respond to legal processes, court orders, and government requests • Enforce our Terms of Service and other agreements • Protect our rights, property, and intellectual property • Detect, prevent, and address fraud, security breaches, and technical issues • Ensure player safety and prevent harmful conduct • Investigate violations of our policies • Defend against legal claims and disputes ═══════════════════════════════════════════════════════════ 4. LEGAL BASIS FOR PROCESSING (FOR EUROPEAN USERS) ═══════════════════════════════════════════════════════════ If you are located in the European Economic Area, United Kingdom, or Switzerland, we process your personal data based on the following legal grounds under GDPR: CONTRACTUAL NECESSITY: Processing is necessary to perform our contract with you (Terms of Service), including: • Providing game services and features • Managing your account and subscriptions • Delivering purchased content • Providing customer support LEGITIMATE INTERESTS: Processing is necessary for our legitimate business interests, including: • Improving and developing our Games • Analytics and game optimization • Marketing our Games and services • Preventing fraud and ensuring security • Defending legal claims CONSENT: Where you have provided explicit consent for: • Marketing communications • Personalized advertising • Optional data collection • Sharing data with third parties for specific purposes You may withdraw consent at any time through game settings or by contacting us. LEGAL OBLIGATIONS: Processing is necessary to comply with legal requirements, including: • Tax and financial reporting • Responding to legal processes • Consumer protection laws • Data protection regulations ═══════════════════════════════════════════════════════════ 5. HOW WE SHARE YOUR INFORMATION ═══════════════════════════════════════════════════════════ We do NOT sell your personal information to third parties for their own purposes. We share your information only in the limited circumstances described below: 5.1 SERVICE PROVIDERS AND BUSINESS PARTNERS We share information with trusted third-party service providers who perform services on our behalf: • Cloud hosting and storage providers (e.g., AWS, Google Cloud) • Analytics and data analysis services • Customer support platforms and ticketing systems • Email and communication service providers • Payment processors (coordinating with Apple for subscription validation) • Push notification services • Content delivery networks (CDNs) • Security and fraud prevention services • Marketing and advertising platforms • Performance monitoring and crash reporting services These service providers are contractually obligated to use your information only to provide services to us and must protect your information consistent with this Privacy Policy and applicable law. 5.2 APPLE AND APP STORE SERVICES We share information with Apple in connection with: • App Store distribution and downloads • In-app purchase and subscription processing • Sign in with Apple authentication • Apple Game Center integration • App Store Connect analytics and reporting • Apple Developer Program compliance Apple's use of your information is governed by Apple's Privacy Policy. 5.3 ADVERTISING PARTNERS With your consent or where permitted by law, we share information with advertising partners: • Advertising networks and exchanges • Attribution and measurement providers • Marketing platforms and campaign managers • Ad fraud prevention services You can control personalized advertising through iOS settings (see Section 11.4). 5.4 LEGAL REQUIREMENTS AND PROTECTION We may disclose your information when we believe in good faith that disclosure is necessary to: • Comply with legal obligations, laws, regulations, or legal processes • Respond to lawful requests from courts, law enforcement, or government authorities • Enforce our Terms of Service and other agreements • Protect our rights, property, safety, or interests • Protect the rights, property, safety, or interests of our users or the public • Detect, prevent, or address fraud, security, or technical issues • Investigate potential violations of our policies 5.5 BUSINESS TRANSFERS If we are involved in a merger, acquisition, bankruptcy, reorganization, dissolution, or sale of all or part of our assets, your information may be transferred as part of that transaction. We will notify you of any such change and any choices you may have regarding your information. 5.6 AGGREGATED AND DE-IDENTIFIED DATA We may share aggregated, anonymized, or de-identified data that cannot reasonably be used to identify you with third parties for research, marketing, analytics, or other purposes. 5.7 WITH YOUR CONSENT We may share your information with third parties when you explicitly consent or direct us to do so. ═══════════════════════════════════════════════════════════ 6. THIRD-PARTY SERVICES AND DATA PROCESSORS ═══════════════════════════════════════════════════════════ Our Games integrate with the following categories of third-party services: CLOUD INFRASTRUCTURE: Amazon Web Services (AWS), Google Cloud Platform Purpose: Data storage, server hosting, database management ANALYTICS: Firebase Analytics, Google Analytics, Amplitude, Mixpanel Purpose: Game analytics, user behavior analysis, performance tracking CRASH REPORTING: Crashlytics, Sentry Purpose: Error tracking, crash analysis, debugging CUSTOMER SUPPORT: Zendesk, Intercom Purpose: Support ticket management, player communications MARKETING: Mailchimp, SendGrid, Braze Purpose: Email marketing, push notifications, campaign management ADVERTISING: Google AdMob, Unity Ads, AppLovin (if applicable) Purpose: Ad serving, measurement, attribution ATTRIBUTION: AppsFlyer, Adjust, Branch Purpose: Marketing attribution, campaign tracking PAYMENT COORDINATION: RevenueCat, Apple App Store Server APIs Purpose: Subscription validation, receipt verification Each third-party service operates under its own privacy policy and data practices. We encourage you to review their privacy policies: • Apple Privacy Policy: apple.com/legal/privacy • Google Privacy Policy: policies.google.com/privacy • Firebase Privacy Information: firebase.google.com/support/privacy • AWS Privacy Notice: aws.amazon.com/privacy We require our service providers to handle your data securely and in compliance with applicable privacy laws. ═══════════════════════════════════════════════════════════ 7. DATA RETENTION ═══════════════════════════════════════════════════════════ We retain your personal information for as long as necessary to provide our Games and fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. ACCOUNT DATA: Retained while your account is active and for up to 90 days after account deletion or inactivity, unless you request earlier deletion. GAMEPLAY DATA: Retained while your account is active to maintain game progress and for up to 30 days after account deletion. SUBSCRIPTION DATA: Retained for the duration of your subscription and for up to 7 years thereafter to comply with financial, tax, and legal obligations. TRANSACTION RECORDS: Retained for up to 7 years to comply with financial record-keeping requirements and to handle disputes, refunds, and chargebacks. CUSTOMER SUPPORT DATA: Retained for up to 3 years after the last interaction to provide ongoing support and resolve disputes. MARKETING DATA: Retained until you opt out of marketing communications or for up to 2 years of inactivity. ANALYTICS DATA: Aggregated and anonymized analytics data may be retained indefinitely for statistical and business intelligence purposes. LEGAL DATA: Information required for legal compliance, dispute resolution, or enforcement of our Terms may be retained for up to 10 years or as required by applicable law. After the applicable retention period, we will delete or anonymize your personal information in accordance with applicable law and our data retention policies. You may request deletion of your data at any time by contacting us (see Section 15). ═══════════════════════════════════════════════════════════ 8. YOUR PRIVACY RIGHTS AND CHOICES ═══════════════════════════════════════════════════════════ 8.1 ACCESS AND CORRECTION You have the right to: • Access the personal information we hold about you • Request a copy of your data in a portable format • Correct inaccurate or incomplete information • Update your account information and preferences To exercise these rights, contact us at support@plotwings.com or through in-game settings. 8.2 DELETION AND ERASURE You have the right to request deletion of your personal information, subject to certain exceptions for legal compliance, fraud prevention, and legitimate business purposes. To request deletion: • Contact us at support@plotwings.com • Use the account deletion feature in game settings (if available) Upon deletion, your game progress and purchased content will be permanently lost and cannot be recovered. 8.3 OPT-OUT AND MARKETING PREFERENCES You can opt out of marketing communications by: • Clicking "unsubscribe" in promotional emails • Adjusting notification preferences in game settings • Contacting us at support@plotwings.com You can control personalized advertising through: • iOS Settings → Privacy → Tracking (Limit Ad Tracking) • iOS Settings → Privacy → Apple Advertising (Personalized Ads) 8.4 ACCOUNT DEACTIVATION You may deactivate your account at any time through game settings or by contacting us. Account deactivation will: • Suspend access to game features and content • Remove your profile from public view • Stop marketing communications • Preserve your data for potential reactivation (up to 90 days) 8.5 DO NOT TRACK SIGNALS Our Games do not currently respond to "Do Not Track" browser signals. You can control tracking through iOS privacy settings (see Section 11.4). ═══════════════════════════════════════════════════════════ 9. PRIVACY RIGHTS FOR SPECIFIC JURISDICTIONS ═══════════════════════════════════════════════════════════ 9.1 CALIFORNIA RESIDENTS (CCPA/CPRA RIGHTS) If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA): RIGHT TO KNOW: You have the right to request: • Categories of personal information we collect about you • Categories of sources from which we collect personal information • Business or commercial purposes for collecting or selling personal information • Categories of third parties with whom we share personal information • Specific pieces of personal information we have collected about you RIGHT TO DELETE: You have the right to request deletion of your personal information, subject to certain exceptions. RIGHT TO OPT-OUT OF SALE/SHARING: You have the right to opt out of the "sale" or "sharing" of your personal information. We do not sell personal information for monetary consideration. However, sharing data with advertising partners may constitute "sharing" under CCPA. To opt out: • Use iOS privacy settings: Settings → Privacy → Tracking • Contact us at support@plotwings.com with subject "CCPA Opt-Out" RIGHT TO NON-DISCRIMINATION: We will not discriminate against you for exercising your CCPA rights. RIGHT TO CORRECT: You have the right to request correction of inaccurate personal information. RIGHT TO LIMIT USE OF SENSITIVE PERSONAL INFORMATION: We do not use sensitive personal information for purposes other than permitted under CCPA. To exercise your California privacy rights, contact us at: Email: support@plotwings.com Subject: "California Privacy Rights Request" We will respond to verified requests within 45 days. CALIFORNIA "SHINE THE LIGHT" LAW: California residents may request information about disclosures of personal information to third parties for their direct marketing purposes. We do not share personal information with third parties for their own direct marketing purposes. CALIFORNIA MINORS: If you are a California resident under 18 and a registered user, you may request removal of content or information you posted publicly. Contact support@plotwings.com with subject "California Minor Privacy Request." 9.2 EUROPEAN ECONOMIC AREA, UK, AND SWITZERLAND (GDPR RIGHTS) If you are located in the EEA, UK, or Switzerland, you have rights under the General Data Protection Regulation (GDPR): RIGHT OF ACCESS: You have the right to access your personal data and receive information about how we process it. RIGHT TO RECTIFICATION: You have the right to correct inaccurate or incomplete personal data. RIGHT TO ERASURE ("Right to be Forgotten"): You have the right to request deletion of your personal data in certain circumstances. RIGHT TO RESTRICTION OF PROCESSING: You have the right to request that we restrict processing of your personal data in certain circumstances. RIGHT TO DATA PORTABILITY: You have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller. RIGHT TO OBJECT: You have the right to object to processing of your personal data based on legitimate interests or for direct marketing purposes. RIGHT TO WITHDRAW CONSENT: Where processing is based on consent, you have the right to withdraw consent at any time. RIGHT TO LODGE A COMPLAINT: You have the right to lodge a complaint with your local data protection authority (supervisory authority). To exercise your GDPR rights, contact us at: Email: support@plotwings.com Subject: "GDPR Rights Request" DATA PROTECTION OFFICER: You may contact our Data Protection Officer at dpo@plotwings.com EU REPRESENTATIVE: Further Theory, LLC, 6 Liberty Square #2327, Boston, MA 02109, United States LEGAL BASIS FOR PROCESSING: See Section 4 for details on our legal basis for processing your data. INTERNATIONAL DATA TRANSFERS: We transfer personal data from the EEA, UK, and Switzerland to the United States and other countries. We implement appropriate safeguards including Standard Contractual Clauses approved by the European Commission. 9.3 OTHER JURISDICTIONS If you are located in other jurisdictions with applicable privacy laws (including Australia, Canada, Brazil, Japan, South Korea, and others), you may have additional privacy rights under local law. Contact us at support@plotwings.com to exercise rights available to you. ═══════════════════════════════════════════════════════════ 10. CHILDREN'S PRIVACY ═══════════════════════════════════════════════════════════ Our Games are NOT intended for children under the age of 13 years (or the applicable age of digital consent in your jurisdiction). We do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13 without verifiable parental consent, we will take steps to delete that information as soon as possible. If you are a parent or guardian and believe that your child under 13 has provided personal information to us, please contact us immediately at support@plotwings.com with subject "Children's Privacy Concern" and we will take appropriate action. AGE VERIFICATION: We rely on Apple's age verification and parental control systems. Parents can use iOS Screen Time and Family Sharing features to restrict children's access to in-app purchases and content. COPPA COMPLIANCE: Our Games comply with the Children's Online Privacy Protection Act (COPPA) in the United States. GDPR AGE OF CONSENT: For users in the European Economic Area, the age of digital consent varies by country (typically 13-16 years). Our Games are not directed to users below the applicable age of consent. ═══════════════════════════════════════════════════════════ 11. APPLE APP STORE AND iOS SPECIFIC PROVISIONS ═══════════════════════════════════════════════════════════ 11.1 IN-APP PURCHASES AND SUBSCRIPTIONS All in-app purchases and subscriptions are processed by Apple through the App Store. Apple's policies govern: • Payment processing and transaction security • Subscription management and billing • Refunds and cancellations • Family Sharing of subscriptions • Purchase history and receipts We receive limited transaction data from Apple (order ID, product ID, transaction date, subscription status) but do NOT receive your payment method details or financial information. SUBSCRIPTION MANAGEMENT: To manage your subscriptions: 1. Open iOS Settings 2. Tap your Apple ID (top of screen) 3. Tap "Subscriptions" 4. Select the subscription to manage 5. Choose options to change, cancel, or configure CANCELLATION POLICY: You can cancel your subscription at any time through iOS Settings. Cancellation takes effect at the end of the current billing period. You will retain access to subscription features until the end of the paid period. REFUNDS: Refund requests must be submitted to Apple. We do not control Apple's refund decisions. To request a refund: • Visit reportaproblem.apple.com • Sign in with your Apple ID • Find the transaction and request a refund 11.2 SIGN IN WITH APPLE If you use Sign in with Apple: • Apple provides us with a unique user identifier • You can choose to share or hide your email address • If you hide your email, Apple provides a private relay email address • We cannot access your Apple ID password or other Apple account information • Apple's authentication is subject to Apple's Privacy Policy 11.3 APPLE GAME CENTER If you connect to Apple Game Center: • Your Game Center profile information may be visible to other players • We may access your Game Center ID, display name, and achievements • Leaderboard and multiplayer features use Game Center data • Game Center privacy is controlled by iOS Settings → Game Center 11.4 APPLE PRIVACY CONTROLS You can control privacy settings through iOS: LIMIT AD TRACKING: Settings → Privacy & Security → Tracking → Toggle off "Allow Apps to Request to Track" ADVERTISING PREFERENCES: Settings → Privacy & Security → Apple Advertising → Toggle off "Personalized Ads" APP PERMISSIONS: Settings → [App Name] → Review and adjust permissions for: • Notifications • Location (if requested) • Photos (if requested) • Other device features RESET ADVERTISING IDENTIFIER: Settings → Privacy & Security → Apple Advertising → Reset Advertising Identifier ═══════════════════════════════════════════════════════════ 12. DATA SECURITY ═══════════════════════════════════════════════════════════ We implement commercially reasonable technical, administrative, and physical security measures to protect your personal information against unauthorized access, disclosure, alteration, and destruction. SECURITY MEASURES INCLUDE: TECHNICAL SAFEGUARDS: • Encryption of data in transit using TLS/SSL protocols • Encryption of sensitive data at rest • Secure authentication and access controls • Regular security testing and vulnerability assessments • Intrusion detection and prevention systems • Secure software development practices • Regular security updates and patches ADMINISTRATIVE SAFEGUARDS: • Employee training on data security and privacy • Access controls limiting employee access to personal data • Background checks for employees with data access • Incident response and breach notification procedures • Data protection impact assessments • Third-party security audits and compliance reviews PHYSICAL SAFEGUARDS: • Secure data center facilities with restricted access • Environmental controls and redundancy systems • Secure disposal of physical media containing personal data ACCOUNT SECURITY: • Strong password requirements (if applicable) • Secure authentication through Apple Sign In • Account activity monitoring for suspicious behavior • Automatic logout after periods of inactivity However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security. You are responsible for maintaining the security of your device and Apple ID credentials. SECURITY INCIDENTS: In the event of a data breach that affects your personal information, we will notify you and applicable authorities as required by law, typically within 72 hours of becoming aware of the breach. REPORTING SECURITY VULNERABILITIES: If you discover a security vulnerability in our Games, please report it to security@plotwings.com. We appreciate responsible disclosure and will work with you to address the issue promptly. ═══════════════════════════════════════════════════════════ 13. INTERNATIONAL DATA TRANSFERS ═══════════════════════════════════════════════════════════ We are based in the United States, and your personal information may be transferred to, processed, and stored in the United States and other countries where our service providers operate. These countries may have data protection laws that differ from your jurisdiction. When we transfer personal data internationally, we implement appropriate safeguards to protect your information: TRANSFER MECHANISMS: • Standard Contractual Clauses (SCCs) approved by the European Commission • Data Processing Agreements with service providers • Adequacy decisions recognized by applicable data protection authorities • Other lawful transfer mechanisms under applicable law UNITED STATES TRANSFERS: If you are located outside the United States, please be aware that the United States may not provide the same level of data protection as your jurisdiction. By using our Games, you acknowledge and consent to the transfer of your information to the United States. EEA, UK, AND SWITZERLAND TRANSFERS: We comply with applicable legal requirements for transfers of personal data from the EEA, UK, and Switzerland to third countries, including the use of Standard Contractual Clauses and other approved transfer mechanisms. ═══════════════════════════════════════════════════════════ 14. CHANGES TO THIS PRIVACY POLICY ═══════════════════════════════════════════════════════════ We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, we will: • Update the "Last Updated" date at the top of this Privacy Policy • Notify you through the Games (in-game notification, alert, or message) • Send you an email notification (if you have provided an email address) • Post a notice on our website at plotwings.com MATERIAL CHANGES: If we make material changes that significantly affect your privacy rights or how we process your personal information, we will provide prominent notice and may require you to acknowledge the updated Privacy Policy before continuing to use the Games. CONTINUED USE: Your continued use of the Games after the effective date of the updated Privacy Policy constitutes your acceptance of the changes. If you do not agree with the updated Privacy Policy, you must stop using the Games and may request deletion of your account. REVIEW REGULARLY: We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. You can always access the current version of this Privacy Policy at plotwings.com/tycoon-privacy-policy or through the Games' settings menu. ═══════════════════════════════════════════════════════════ 15. CONTACT INFORMATION AND DATA PROTECTION OFFICER ═══════════════════════════════════════════════════════════ If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us: GENERAL INQUIRIES: Email: support@plotwings.com Subject: "Privacy Inquiry" PRIVACY RIGHTS REQUESTS: Email: privacy@plotwings.com Subject: Specify your jurisdiction and request type (e.g., "CCPA Delete Request" or "GDPR Access Request") DATA PROTECTION OFFICER: Email: dpo@plotwings.com Subject: "DPO Inquiry" MAILING ADDRESS: Further Theory, LLC Attn: Privacy Department 6 Liberty Square #2327 Boston, MA 02109 United States WEBSITE: plotwings.com/support We will respond to your inquiries within a reasonable timeframe, typically within 30 days for general inquiries and within the timeframes required by applicable law for privacy rights requests (45 days for CCPA requests, 30 days for GDPR requests). Please provide sufficient information to verify your identity when making privacy rights requests. We may request additional information to confirm your identity before processing your request. ═══════════════════════════════════════════════════════════ 16. DISPUTE RESOLUTION AND ARBITRATION ═══════════════════════════════════════════════════════════ INFORMAL RESOLUTION: Before initiating formal dispute resolution, please contact us at support@plotwings.com to attempt to resolve any privacy-related disputes informally. ARBITRATION: Any disputes arising from this Privacy Policy or our data practices shall be resolved through binding arbitration in accordance with the arbitration provisions in our Terms of Service, except where prohibited by law or where you have statutory rights to bring claims in other forums (such as rights under GDPR or CCPA). GOVERNING LAW: This Privacy Policy is governed by the laws of the Commonwealth of Massachusetts and the United States, without regard to conflict of law principles. EXCEPTION FOR EUROPEAN USERS: If you are located in the European Economic Area, United Kingdom, or Switzerland, you retain the right to bring disputes before your local data protection authority or courts, and the mandatory consumer protection laws of your jurisdiction apply. EXCEPTION FOR CALIFORNIA USERS: California residents retain all rights under CCPA/CPRA, which cannot be waived through arbitration agreements. ═══════════════════════════════════════════════════════════ ACKNOWLEDGMENT ═══════════════════════════════════════════════════════════ BY USING OUR TYCOON GAMES, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THIS PRIVACY POLICY. If you do not agree with this Privacy Policy, you must not use our Games. Thank you for trusting us with your personal information. We are committed to protecting your privacy and providing you with an exceptional gaming experience. ═══════════════════════════════════════════════════════════ Further Theory, LLC Last Updated: November 24, 2025