Dragon Odyssey - Flight Action

1.Who we are and how to reach us

Privacy requests are answered within 15 days of receipt.

2.Data we collect

The Game does not display ads and has no chat or communication between players. The information below matches what we declare in the Data safety section on Google Play and in App Privacy on the App Store.

2.1 Global leaderboards and achievements

The Game offers global leaderboards and achievements through Google Play Games Services (Android) and Apple Game Center (iOS). This feature is optional: it only works if you choose to sign in with your Google or Apple account.

If you use the feature, the following is processed:

Please note: when you submit a score, your display name and your score become publicly visible to other players on the leaderboard. You control that name in your Google Play Games or Game Center account settings.

If you do not sign in with the platform account, the Game works normally in offline mode and none of the data in this section is collected.

2.2 Data you provide to us directly

None of this is requested inside the Game, nor is any of it necessary in order to play.

2.3 Data collected automatically

Outside the leaderboard feature, this data is processed in pseudonymous or aggregated form and is not used by us to identify you individually.

2.4 Data we do not collect

The Game and the Site do not access or collect: GPS location, contacts or phone book, SMS or call logs, microphone, camera, photos, videos or files on the device, health or fitness data, biometric data, inventory of installed apps, financial data or payment credentials.

The Game does not display ads and does not use the Android Advertising ID (AAID) or the IDFA for advertising, ad personalization or advertising measurement.

2.5 In-app purchases

Purchases, where available, are processed entirely by Google Play Billing (Android) or the Apple App Store (iOS). We receive only the purchase confirmation, in order to unlock the content. We do not receive, store or have access to card numbers, banking details or any payment credentials.

3.What we use the data for

• Running the Game and saving your progress
• Operating global leaderboards and achievements, when you choose to use them
• Unlocking and restoring purchased content
• Providing support and answering requests
• Diagnosing crashes and improving stability and performance
• Analyzing aggregate usage metrics in order to balance and evolve the Game
• Preventing fraud, leaderboard tampering and abusive use
• Sending development updates, if you have subscribed
• Complying with legal obligations and orders from competent authorities

Legal bases (LGPD, art. 7): performance of a contract (operation of the Game, leaderboards, delivery of purchases, support); legitimate interest (fixing faults, security, leaderboard integrity, aggregate metrics); consent (updates by e-mail); compliance with a legal obligation (tax records).

We do not carry out automated decision-making that produces significant legal effects on you. We do not build advertising profiles.

4.Who we share data with

We do not sell users' personal or sensitive data and we do not transfer it to third parties in exchange for monetary consideration.

Each of these third parties processes the data as a processor, under our instructions or under the terms of their own policies and, as far as we have verified, does not sell personal data obtained through the Game. The privacy policies of Google, Apple and Unity are available on their respective websites.

We also share data with public authorities, upon a valid request or court order, and with successors, in the event of a merger, acquisition or corporate reorganization, with adequate prior notice and with the same protection obligations maintained.

5.Cookies and Site logs

The Site uses only the cookies necessary for it to work, including the server session cookie. Our hosting provider records IP address, date, time and pages accessed, for operation and security purposes. We do not use advertising or cross-site tracking cookies. You can block or delete cookies in your browser settings without impairing your browsing.

6.Security

• Encrypted transmission: all communication between the Game, the Site and the services in section 4 uses HTTPS / TLS 1.2 or higher
• Storage: your progress is saved on your device. We do not run our own servers with player databases; leaderboards and achievements are held in Google's and Apple's infrastructure
• Access control: access to the dashboards is restricted to authorized members of HARPIA GAMES LTDA, with individual authentication and two-step verification
• Permissions: the Game requests only strictly necessary permissions, at runtime
• Review: we periodically assess our processes and the integrated SDKs

In the event of a security incident with significant risk to your rights, we will notify you and the ANPD under art. 48 of the LGPD.

7.Retention and deletion

Once those periods end, the data is permanently deleted or irreversibly anonymized.

8.Deleting your data

The Game does not create an account of its own — access to the leaderboards uses your existing Google or Apple account. You can:

• Erase local progress: uninstall the Game, or use Settings → Apps → Dragon Odyssey → Storage → Clear data (Android) / remove the app (iOS)
• Remove your score from the leaderboards: write to darkfantasyisland@harpiagames.com telling us the display name used on the leaderboard, and we will remove your entries
• Unlink the platform account: in your Google Play Games or Game Center settings you can disconnect the Game and delete the game data associated with it
• Unsubscribe from the updates: through the unsubscribe link in any message
• Delete support messages and diagnostic data: request it through the privacy e-mail address

We fulfil requests within 30 days. Because the analytics data is pseudonymous, we may be unable to locate it without additional information from you — in that case we will explain the limitation, in line with art. 11 of the GDPR. Only tax records of purchases are retained, as a legal obligation, and are kept segregated.

9.Your rights

Under art. 18 of the LGPD, you may request: confirmation that processing takes place; access to the data; correction of incomplete or outdated data; anonymization, blocking or deletion of unnecessary data or data processed in breach of the law; portability; information about who we share your data with; and withdrawal of consent.

Write to darkfantasyisland@harpiagames.com. We may ask for additional information in order to locate the records or confirm your identity.

Users in the EEA, the United Kingdom and Switzerland: you also have the rights set out in arts. 15 to 22 of the GDPR, including lodging a complaint with the data protection authority of your country.

Users in California: we do not sell or share personal data for cross-context behavioral advertising.

10.International transfers

The services in section 4 are operated by companies based outside Brazil, including in the United States. We adopt the safeguards of art. 33 of the LGPD, including standard contractual clauses entered into with those processors and verification of the level of protection in the destination country.

11.Children and teenagers

The Game is rated USK: approved for all ages and can be played by children.

We do not display ads, there is no chat or communication between players, and we do not ask for a name, e-mail address or any contact detail in order to play. The integrated SDKs are configured not to carry out ad personalization or targeted advertising.

The leaderboard feature is optional and depends on a Google or Apple account, whose use by minors is controlled by parents or guardians through those platforms' family supervision tools. We recommend that guardians review the display name in use, since it is publicly visible on the leaderboard.

Parents or guardians may request the deletion of data associated with a child's use at darkfantasyisland@harpiagames.com, and we will comply as set out in section 8.

12.Social media and community

We maintain profiles on third-party platforms, including Discord, Instagram, TikTok, X, YouTube, LinkedIn and Medium. Interactions on those channels are also governed by the privacy policies of the respective platforms, over which we have no control. From those platforms we receive only aggregate audience metrics and the public content you send us.

13.Changes

We may update this Policy. In the event of a material change, we will give notice in the Game or on the Site before it takes effect and will update the date at the top. Changes that expand the collection of personal data will be preceded by a prominent notice and, where required, by fresh consent.

14.Governing law

This Policy is governed by the laws of the Federative Republic of Brazil, in particular Law No. 13,709/2018 (LGPD), with the courts of the district of HARPIA GAMES LTDA's registered office elected to settle disputes, without prejudice to the rights afforded to you by the law of your country of residence.

15.Complaints

Besides contacting us at darkfantasyisland@harpiagames.com, you may lodge a complaint with the Brazilian National Data Protection Authority (ANPD) through its website gov.br/anpd.