Privacy Policy for 《象棋：戰鬥三國》 (Xiangqi: Battle of the Three Kingdoms)

Effective Date: October 26, 2026 (Online multiplayer, automated cleanup, and advertising features marked as "Planned" will take effect upon actual implementation and release)
Last Updated: October 26, 2026
Language Switch: This is the English version. For Traditional Chinese, please visit 繁體中文版隱私權政策.

Welcome to 《象棋：戰鬥三國》 (Tentative English Title: Xiangqi: Battle of the Three Kingdoms), developed by Midnight Violet Labs (hereinafter referred to as "the Game," "Midnight Violet Labs," "we," "us," or "our"). We value your privacy and data security. This Privacy Policy explains how we collect, use, store, share, and protect information relating to you when you download, install, and play the Game on iOS or Android devices, as well as the privacy rights available to you under applicable laws.

This Privacy Policy is prepared with reference to Taiwan's Personal Data Protection Act (PDPA), Apple App Store and Google Play Store privacy requirements, and applicable international privacy principles (such as the EU/UK General Data Protection Regulation (GDPR) and applicable U.S. state privacy laws).

1. Data Controller and Contact Information

The Game is developed and published under the independent game and application development brand Midnight Violet Labs, with personal data processing responsibilities managed by the individual operator listed below (Midnight Violet Labs is an unregistered independent creative brand/studio name, not an incorporated company or separate legal entity):

• Brand: Midnight Violet Labs (Independent Game & App Developer)
• Operator: CHEN KUANG YUAN (Independent Developer)
• Location: Taiwan
• Contact: midnightvioletlabs@gmail.com
• Target Initial Support Response Time: We aim to provide an initial response within 5 business days of receiving your inquiry (subject to complexity or public holidays).
• Official Studio Website: https://midnightvioletlabs.pages.dev/
• Game-Specific Privacy & Support Subdirectory: https://midnightvioletlabs.pages.dev/xiangqi-battle-of-the-three-kingdoms/

If you have any questions about this Privacy Policy, our data practices, or wish to exercise your personal data rights (including inquiring, reviewing, supplementing, correcting, restricting processing, or deleting your data), please contact us via the email address above.

2. Types of Data We Collect and Purposes of Processing

We adhere to the principle of data minimization and process data only to the extent necessary to operate core gameplay, provide online matchmaking (Planned), maintain service security, and deliver advertising services (Planned).

2.1 Data Stored Locally on Your Device Only (Not Transmitted to Our Cloud Servers)

The following game data is stored exclusively in your mobile device's local storage and is not uploaded to or stored in our cloud databases:

• Single-Player Progress: Single-player AI match records, and stage progress in the Romance of the Three Kingdoms Story Mode and Challenge Mode.
• Personal Gameplay Statistics: Your lifetime total match count, win/loss records, and win rates across game modes (Traditional Chinese Chess / Xiangqi, Small Dark Chess, and Full-Board Dark Chess).
• Local Visual, Audio, and Preference Settings: Character appearance selections, board and piece animations, background music (BGM) and sound effect (SFX) volume settings, and UI language preferences.

Note: If your mobile operating system has system-level cloud backup enabled (such as iOS iCloud Backup or Android Google Backup), whether local save files are included in system backups depends on your device settings and the app build configuration.

2.2 Online Multiplayer and Backend Service Data (Planned via Supabase)

• Anonymous User ID: When you use online features, the system automatically generates a random UUID (auth.users.id) via anonymous sign-in. While this identifier does not contain your real name or contact details, within the Game's ecosystem it serves as a pseudonymous persistent identifier linked to your in-game identity/session, used to recognize your connection state, room permissions, and match participation.
• Authentication Session Data (Auth Session): Encrypted session tokens (Access Token / Refresh Token), login timestamps, and basic client headers (User-Agent), used to maintain connection authorization and support reconnection.
• IP Address and Server Security Logs: When your device communicates with our cloud backend, the underlying infrastructure automatically receives your network IP address and request metadata for network routing, DDoS protection, anti-abuse enforcement, and server security.
• Room and Matchmaking Data: Friend room invite codes, matchmaking queue status, selected game mode (Traditional Xiangqi / Small Dark Chess / Full-Board Dark Chess), and the Anonymous User IDs of matched players.
• Match State and Move History: Only essential board data required to synchronize active gameplay—including board state, shuffled and flipped piece states in Dark Chess modes, move coordinates, turn thinking timers, and match outcomes—used for dual-client synchronization, move legality validation, and short-term debugging.

2.3 Advertising and Diagnostic Data (Planned via Google AdMob SDK)

• Device and Advertising Identifiers: Such as the Android Advertising ID (AAID), App Set ID, iOS Identifier for Advertisers (IDFA—accessed only if you explicitly grant permission via Apple's App Tracking Transparency prompt), IDFV, as well as device information such as device model, manufacturer, OS version, screen dimensions, and system language settings.
• Coarse Location Information: The third-party advertising SDK and servers may infer approximate country- or city-level location from your network IP address (the Game application itself does not request or access your device's precise GPS location permission).
• Product and Ad Interaction Data: App launches, screen views, ad impressions, ad clicks, and rewarded video completion events (used to grant in-game rewards, manage frequency capping, measure ad performance, and prevent invalid traffic/ad fraud).
• Performance and Diagnostic Data: SDK-related crash logs, app launch times, screen hang rates, and energy usage metrics used for stability and diagnostics.

Note on Third-Party SDKs: The exact technical parameters collected by third-party SDKs may vary depending on the SDK version or your device environment. Please refer to Google's official privacy and data disclosure documentation listed in Section 4 for details.

2.4 Customer Support Communications (Provided Only When You Voluntarily Contact Us Externally)

The Game does not require real-name account registration in-app. However, when you proactively send an email to midnightvioletlabs@gmail.com or contact us through our support channels, we will receive and process your email address, sender display name, message content, standard email header metadata, and any additional information you voluntarily provide to assist with troubleshooting or ownership verification (such as your Anonymous User ID, device model, or screenshots). This information is used solely to verify ownership, reply to your inquiry, and process your support or privacy rights requests.

2.5 Data Categories Not Actively Solicited by the Game App

Except as described above (such as your email address when you voluntarily email customer support, or device identifiers and coarse location processed by third-party SDKs), the Game application itself does not ask you to input, nor does it actively extract, your real name, government ID number, phone number, address book contacts, photo library, camera feed, microphone audio, precise GPS coordinates, credit card/bank account details, or health/biometric data.

3. Anonymous Sign-In Mechanism and Data Linkage (Planned)

The Game's planned online features use Supabase Anonymous Sign-Ins:

1. No Traditional Registration: You do not need to set a username/password or bind an email address, phone number, or social media account to access Friend Room Battles or Automated Matchmaking (Planned).
2. Nature of Pseudonymous Identifiers: When you first connect online, the system generates a random Anonymous User ID (UUID) stored on your device. Please note that although we cannot determine your real-world name solely from this UUID, within our cloud backend your online session and short-term match records remain linked to this UUID. Therefore, under Apple App Store and Google Play privacy standards, such data is treated as data linked to a specific in-app user/account rather than fully de-identified aggregate data.
3. Local Progress Cannot Be Recovered by Support: Because your lifetime win rates and story progress are saved only on your local device and anonymous accounts are not bound to personal contact information, if you clear the app's data, reset/delete your anonymous identity, or uninstall the Game, your local statistics and previous anonymous ID cannot be recovered by customer support.

4. Third-Party Service Providers and Data Sharing

To provide online multiplayer and advertising services (both Planned), the Game plans to integrate the following third-party service providers. When these modules are active, relevant data will be transmitted to these providers and processed under their respective privacy policies:

1. Supabase, Inc. (Cloud Database, Anonymous Authentication & Realtime Service — Planned)
   Purpose: Provides anonymous authentication (Supabase Auth), friend room and matchmaking synchronization (Supabase Realtime / Database), and server security logs.
   Privacy Policy: https://supabase.com/privacy
2. Google LLC / Google AdMob (Mobile Advertising & Consent Management Services — Planned)
   Purpose: Delivers App Open, Banner, Interstitial, and Rewarded advertisements, measures ad performance, prevents ad fraud, and manages user privacy consent (Google UMP SDK). Depending on your consent status and device settings, Google and its advertising partners may process advertising identifiers, coarse location, and interaction data.
   Google Privacy Policy: https://policies.google.com/privacy
   How Google uses information from sites or apps that use our services: https://policies.google.com/technologies/partner-sites

If additional third-party security verification or diagnostic tools are integrated in future updates to enhance anti-abuse protection or stability, we will update this Privacy Policy accordingly prior to activation. Except as required for the operation of the third-party services described above, with your consent, or where required by applicable law or valid legal process from judicial/regulatory authorities, we do not sell your data to unrelated third parties.

5. Advertising Choices and Consent Management (Distinguishing UMP Consent from Apple ATT — Planned)

Once the advertising module is integrated, we will respect your privacy and advertising choices through two distinct mechanisms. Please note that "Google UMP Consent Management" and "Apple ATT Tracking Authorization" are separate legal and system-level controls:

5.1 Regional Privacy and Personalized Ad Consent Management (Google UMP SDK — Planned)

• Scope and Function: If you access the Game from the European Economic Area (EEA), the United Kingdom (UK), Switzerland, or other jurisdictions with specific data protection requirements, the system is planned to present a consent form via the Google User Messaging Platform (UMP) to obtain your consent preferences for data processing and for serving "Personalized Ads" versus "Non-personalized / Limited Ads."
• How to Modify: We plan to provide a "Privacy & Ad Settings" option inside the Game's Settings menu (Planned; exact menu label subject to the final release UI) to reopen the consent form and modify or withdraw your consent preferences.

5.2 iOS App Tracking Transparency Authorization (Apple ATT — Planned)

• Scope and Function: On iOS / iPadOS devices, Apple's ATT framework specifically governs whether an app may access your Identifier for Advertisers (IDFA) and combine your app activity with third-party data for cross-app and cross-website tracking.
• Actual Effect of Declining ATT (Important Notice):
  • If you select "Ask App Not to Track" on the iOS ATT prompt, the Game and the Google AdMob SDK will not be able to access your IDFA (which will return all zeros) and will not use your IDFA for cross-app tracking.
  • However, please note that declining Apple ATT does not remove advertisements, nor does it guarantee that ads shown to you will under all circumstances be completely devoid of any first-party contextual or regional characteristics. Without accessing the IDFA or engaging in cross-app tracking, the ad system may still deliver ads, enforce frequency capping, and perform fraud prevention based on current app context, coarse location (such as country/language), basic device specifications, or non-cross-site data permitted under other applicable consent settings (such as UMP).
• How to Modify: You can grant or revoke ATT permission at any time in your iOS device's Settings > Privacy & Security > Tracking.

5.3 Android System Advertising ID Controls

• On Android devices, you can go to Settings > Google > All services > Ads (or Settings > Privacy > Ads) at any time to Reset advertising ID or Delete advertising ID to limit personalized ad tracking.

6. Data Retention and Deletion (Including Security Verification Principles — Planned)

6.1 Data Retention Periods and Automated Cleanup (Planned)

• Local Save Data: Stored on your mobile device until you manually clear the app's storage or uninstall the Game.
• Cloud Match and Room Temporary Records (Planned Retention: 7 Days): Online room states and match move records (for Friend Rooms and Automated Matchmaking) are retained only for real-time synchronization and short-term debugging, and are planned to be retained for 7 days after a match concludes, after which they are automatically deleted or unlinked from your anonymous account (excluding matches that are still actively in progress).
• Inactive Anonymous User Accounts and Auth Sessions (Planned Cleanup After 180 Days of Inactivity): If your cloud Anonymous User ID (UUID) remains inactive for 180 days from your last activity, our system is planned to periodically clean up and permanently delete the inactive anonymous account and session records; however, this automated cleanup will exclude special circumstances such as active/ongoing matches, unsettled rooms, or accounts under security/dispute holds to avoid disrupting active gameplay.
• Infrastructure Security Logs: Underlying cloud infrastructure security audit logs are retained for a short period in accordance with our cloud provider's (Supabase) standard security log retention cycle before being automatically rotated and overwritten.
• Customer Support & Privacy Request Emails: When you proactively email customer support (target initial response within 5 business days) or submit a deletion request, the correspondence is generally retained for 1 year after resolution (or for the period required by applicable laws) for dispute verification and legal compliance, and is periodically purged thereafter.
• Advertising SDK Data: Retained and managed by Google in accordance with Google's data retention policies (https://policies.google.com/technologies/retention).

6.2 How to Delete Your Account and Data (Planned)

• Deleting Local Device Data (Currently Supported): Uninstall 《象棋：戰鬥三國》 from your mobile device or clear the app's storage in your system settings to immediately delete all locally saved win rates, match counts, and single-player progress.
• Deleting Cloud Anonymous Account & Associated Match Records (Planned):
  1. Method 1: Direct In-App Self-Service Deletion (Primary Recommended Method — Planned)
     While the Game is installed on your device, we plan to provide an option in the Game's Settings menu under Account & Privacy to Delete Cloud Anonymous Account & Data (Planned; exact menu label subject to the final release UI). The system will verify that you are the genuine account holder using your device's active, cryptographically signed Supabase Auth Session Token and immediately and permanently delete your cloud auth.users account and associated match records.
  2. Method 2: External Web / Email Deletion Request (When Uninstalled — Planned)
     If you have already uninstalled the Game and cannot use the in-app button, you may visit our Data Deletion Instructions page and send a request to midnightvioletlabs@gmail.com. External data deletion requests are planned to be processed within a target of 30 days after receiving complete verification details, subject to any shorter or specific timeframes required by applicable laws in your jurisdiction.
  3. Why We Cannot Delete Data Based Solely on a Public "Anonymous User ID (UUID)" (Anti-Spoofing Security Principle — Pending Security Evaluation)
     During online matches (Friend Rooms or Automated Matchmaking), matched clients may exchange or read the opponent's public User ID (UUID) to synchronize room state. If an account could be deleted externally merely by submitting a raw public UUID, malicious actors could easily capture an opponent's UUID and submit unauthorized deletion requests for other players' accounts.
     Therefore, for external email deletion requests, we must enforce anti-spoofing ownership verification principles (the exact technical mechanism is currently retained as a Candidate Solution Pending Security Evaluation—such as evaluating a one-time in-app deletion request token, a private deletion verification code, or cross-checking non-public session/account attributes—and is not mandated as a fixed immediate implementation until finalized prior to launch).
     • Automated Expiration Cleanup Protection: If you uninstalled the Game without retaining information required to verify account ownership, to prevent unauthorized deletion of another player's data, we cannot forcefully delete a specific UUID whose ownership cannot be verified. However, our planned automated cleanup schedule (Planned) will still automatically remove completed match records after 7 days and permanently purge the inactive anonymous account after 180 days of inactivity (excluding active matches or special holds).

7. International Data Transfers and Security Safeguards

The Game primarily serves players in Taiwan while also being available to players in other countries and regions:

• When online multiplayer or advertising modules (Planned) operate, relevant data may be transferred to and processed on cloud servers located outside your country or region of residence, including cloud data centers used by Supabase (planned to be hosted in Asia-Pacific or U.S. cloud regions, subject to final production configuration) and Google AdMob's global server network.
• Data protection laws in those jurisdictions may differ from those in your jurisdiction. We implement reasonable technical and organizational security measures (including requiring HTTPS / WSS TLS encryption in transit and selecting established cloud and advertising providers that publicly maintain industry-standard security certifications and legal transfer mechanisms) to mitigate risks; however, no internet transmission or cloud storage system can be guaranteed to be 100% secure under all circumstances, and we continuously work to uphold security best practices.

8. Your User Rights

Under Article 3 of Taiwan's Personal Data Protection Act (PDPA) and applicable privacy laws in your jurisdiction (such as the GDPR or CCPA), you have the right to:

1. Inquire, review, or request a copy of the personal data we hold about you.
2. Request supplementation or correction of your data.
3. Request cessation of collection, processing, or use (including adjusting or withdrawing personalized advertising and tracking settings).
4. Request deletion of your data.

Identity Verification and Processing Timeframes: Because the Game does not collect your real name or registration email, if you submit an external request to access, copy, or delete your cloud anonymous account data, we must verify your ownership of the anonymous account under the security principles described in Section 6 to ensure we do not disclose your data to others or allow unauthorized deletion. We aim to provide an initial support response within 5 business days, and our planning target for completing verified external deletion or rights requests is within 30 days (or within the timeframe mandated by applicable laws).

9. Children's and Youth Privacy

1. The Game is a traditional board strategy game and is not directed to children under the age of 13 (or the applicable age of digital consent in your jurisdiction, such as 13–16 in certain European countries).
2. We do not knowingly collect personal contact information from children below the applicable legal age.
3. If a parent or legal guardian discovers that a child under their guardianship has provided personal information to us without consent (for example, by sending a support email), please contact us at midnightvioletlabs@gmail.com, and we will take reasonable steps to delete such information upon verification.

10. Changes to This Privacy Policy

We may revise this Privacy Policy as game features officially launch, third-party SDKs are updated, or applicable laws change. Updated versions will be posted on our public website (https://midnightvioletlabs.pages.dev/xiangqi-battle-of-the-three-kingdoms/privacy/en.html) with a revised "Last Updated" date at the top of the page. For material changes, we will provide notice within the Game or on our website. We encourage you to review this Privacy Policy periodically.