Privacy Policy
Privacy Policy
Effective Date: 27 September 2026
Element Empire Privacy Policy
Effective Date: 27 September 2026
Welcome to Element Empire ("we," "us," or "our"), developed and published by Shy Guy Lab ApS. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application (the "App") available on Android and iOS. By using the App, you agree to the collection and use of information in accordance with this policy.
Shy Guy Lab ApS is the data controller responsible for your personal data.
Shy Guy Lab ApS
CVR: 46484053
C/O LegalDesk.dk ApS Njalsgade 21F, 2, 2300 , København S, Denmark
Email: support@shyguylab.com
Website: shyguylab.com
Account & Profile Information
When you create an account or sign in, we collect:
Display name and custom display name
Email address
Phone number (stored in E.164 international format and national digit format for contact matching)
Profile photo URL or selected preset avatar
User ID (a unique identifier assigned to your account)
Authentication Data
We support Google Sign-In and Sign in with Apple. Authentication is handled through Google Firebase Authentication, which may collect and process authentication tokens and related credentials on our behalf.
Device Contacts
If you choose to use the contact matching feature and grant permission, the App reads names and phone numbers from your device's address book to identify which of your contacts already play Element Empire. Contact data is sent to our servers only to perform this matching and is not stored permanently. We never contact your contacts, and their data is not used for advertising. You can decline this permission, and the rest of the App will continue to work.
Content You Create
In-match chat messages. Messages you send during a match are stored so they can be delivered to the other players in that match.
Blocked players. If you block another player, we store that player's identifier, name and avatar so we can keep them out of your games.
Reports. If you report another player, we store your report so we can review it. This includes the reason you select, any message you write, the identity of the player you reported, and the context of the report, such as the match it relates to.
Game Data
We collect gameplay-related data to provide the core experience, including:
The moves you make and the state of the matches you play
Games played, won, lost, abandoned and completed
Net worth achieved, including your highest and average results
Account creation and "last seen" timestamps
Support Requests
If you contact us, we keep your message and email address so we can respond.
Notifications
We store a Firebase Cloud Messaging token for your device so we can send game-related notifications, such as when it is your turn or when someone invites you to a match. You can turn notifications off in your device settings at any time.
In-App Purchases
We offer in-app purchases, such as the Ad-Free Pass and cosmetic backdrops. We use RevenueCat to manage and validate these purchases. We do not process or store your payment information (such as credit card numbers). All payments are handled by Google Play or the Apple App Store. We only store purchase history, entitlement status, which items you own, and transaction IDs so we can unlock your purchased features.
Automatically Collected Information
The App automatically collects certain information to improve performance and serve advertisements:
Device information: device type and operating system version.
App interaction data: for example screen views and session length, collected through Firebase Analytics and AdMob.
Analytics: Firebase Analytics is only fully enabled with your consent. If you decline, the App still sends limited usage signals without an analytics identifier (such as device type, language and which screens are opened), which Google uses to estimate overall usage. Firebase Analytics is never used for advertising and does not collect your advertising identifier.
Device identifiers: the Identifier for Vendor (IDFV) on iOS, used to manage app performance.
Advertising identifiers: Google AdMob collects your device's advertising identifier (AAID on Android, IDFA on iOS) to serve ads.
IP address and approximate location: AdMob collects your IP address, which may be used to estimate your general location. We do not collect precise location.
Diagnostic data: crash logs and performance information, collected by AdMob and Firebase.
Your Choices About Advertising
Before any ads are shown, we ask for your consent using Google's consent management platform. The same choice decides whether Firebase Analytics is fully enabled. If you do not consent, you will still see ads, but they will be non-personalised. On iOS, we also ask for permission to track through Apple's App Tracking Transparency prompt. If you decline, your advertising identifier is not used.
You can change your choices at any time through the Privacy Settings option in the App and through your device's privacy settings. If you purchase the Ad-Free Pass, no ads are shown while it is active.
How We Use Your Information and Our Legal Basis
Analytics and bug fixing: We analyse usage and crashes to improve the App. Legal basis: consent for analytics; legitimate interest for limited usage signals without an analytics identifier and for crash diagnostics.
Multiplayer features: We match you with other players and show your name and avatar in lobbies and matches. Legal basis: performance of contract.
Gameplay and statistics: We run your matches and track your results. Legal basis: performance of contract.
Communication between players: We deliver chat messages and honour your blocking choices. Legal basis: performance of contract.
Contact matching: We use your phone number and, with your permission, your contacts to find friends who play. Legal basis: consent, which you can withdraw at any time in your device settings.
Notifications: We send turn reminders and invitations. Legal basis: performance of contract.
Purchases: We process and restore your in-app purchases. Legal basis: performance of contract.
Safety and moderation: We review reports and act on inappropriate behaviour. Legal basis: legitimate interest in keeping the App safe for all players.
Analytics and bug fixing: We analyse usage and crashes to improve the App. Legal basis: legitimate interest in a stable, working App.
Personalised advertising: We show ads based on your advertising identifier. Legal basis: consent.
Non-personalised advertising and fraud prevention: We show ads and prevent ad fraud. Legal basis: legitimate interest in funding the App.
Legal requirements: We comply with the law and valid requests from authorities. Legal basis: legal obligation.
We do not sell your personal information. We share data only in these cases:
With other players: your display name, avatar and statistics are visible to other players in multiplayer, and your chat messages are visible to the other players in that match.
Service providers: Google Firebase and RevenueCat process data on our behalf, under our instructions.
Advertising partner: Google AdMob receives your advertising identifier, IP address, app interaction data and diagnostic data. Google may use this data for its own purposes, including ad personalisation (only with your consent), ad measurement and fraud prevention.
Legal requirements: where required by law or by valid legal requests from public authorities.
Firebase, AdMob and RevenueCat may process data outside the European Economic Area, including in the United States. Where this happens, the transfer is protected by the EU-U.S. Data Privacy Framework or by the European Commission's Standard Contractual Clauses.
Your data is stored on Firebase cloud infrastructure and is encrypted in transit. We implement reasonable measures to protect your data, but no method of electronic storage is 100% secure.
Account and profile data: kept for as long as your account is active.
Matches: after a period of time, its chat messages, moves and detailed game data are deleted. A short summary (players, names, avatars, final results and winner) is kept so your statistics and head-to-head records stay accurate.
Contacts: used only for matching and not stored permanently.
Reports: kept for as long as needed to review the report and handle any repeated behaviour.
Support requests: kept for as long as needed to resolve your request.
You can delete your account and all associated personal data at any time by:
Using the "Delete Account" option in the App's settings menu
Using our account deletion page: https://sites.google.com/view/elementempire/delete-account
Emailing us at support@shyguylab.com
When your account is deleted, your personal data is permanently removed from our active databases. Your active matches end as if you had left them. So that other players' results are not affected, matches you played remain in their history, where you appear as "Deleted player."
Element Empire is not intended for children under 13, and we do not knowingly collect personal data from children under 13. In some countries the minimum age for consenting to data processing is higher. Where that applies, the App is not intended for users below that age. If we discover that such data has been collected, we will delete it promptly.
Under the EU General Data Protection Regulation (GDPR) and similar laws, you have the right to:
Access your personal data and receive a copy of it
Correct inaccurate data
Delete your data
Restrict or object to our processing, including processing based on legitimate interest
Receive your data in a portable format
Withdraw consent at any time, without affecting processing that took place before
To exercise these rights, contact us at support@shyguylab.com.
You also have the right to lodge a complaint with a data protection authority. In Denmark, this is Datatilsynet (datatilsynet.dk).
The App uses the following services. Please review their privacy policies:
Google Firebase (Authentication, Firestore, Storage, Cloud Messaging, Analytics): policies.google.com/privacy
Google AdMob: policies.google.com/privacy
Sign in with Apple: apple.com/legal/privacy
RevenueCat: revenuecat.com/privacy
We may update this Privacy Policy from time to time. We will change the Effective Date above and, for significant changes, notify you in the App.
If you have questions about this Privacy Policy, contact us at support@shyguylab.com.