Grow A Fish

This privacy policy is applicable to the Grow A Fish app for mobile devices, together with any related services operated by Elomar Studio (collectively, the "Application"). Elomar Studio is hereinafter referred to as the "Service Provider".

Data Controller Information

Elomar Studio acts as the Data Controller responsible for the processing of your personal data.

• Name: Elomar Studio

• Address: Bogøgade 6, 1.th, 9000 Aalborg

• Email: elomarstudio@gmail.com

For data protection inquiries and to exercise your GDPR rights, please contact the Data Controller using the contact information above.

 What information does the Application obtain and how is it used?

  The Application acquires the information you supply when you download and register for the service.

• User Provided Information: Through our authentication provider (Supabase), we collect your email address and the username you choose. We also store your game progress, including fish data (species, growth, names), tank configurations, currency (coins/pearls), and unlocked inventory (avatars/frames).

• Social & Communication: If you use the chat feature, we process your messages. Crucially, our chat uses End-to-End Encryption (E2EE) using X25519 and AES-GCM-256. The Service Provider stores the encrypted blobs to facilitate delivery, but we do not possess the keys to decrypt or read your private messages.

Legal basis for processing your personal data

Where the GDPR applies, the Service Provider relies on one or more lawful bases to process your personal data, including:

• Contract performance: processing necessary to provide the Application or fulfil a contract with you.

• Consent: where you have given explicit consent to processing, including for marketing, analytics, or optional features. You may withdraw consent at any time without affecting processing that occurred before withdrawal.

• Legitimate interests: where processing is necessary for the Service Provider's specific legitimate interests, such as maintaining network and information security, preventing fraud and abuse, or improving the Application's core functionality through analytics, provided those interests are not overridden by your data protection rights or fundamental freedoms.

• Legal obligation: to comply with laws or government requests.

Cookies and similar technologies

The Application uses local storage (Shared Preferences/Hive) and its third-party SDKs may use cookies, SDKs, pixels, and similar technologies to support functionality, analytics, and service delivery. Where required by law, the Service Provider will obtain your consent before using non-essential tracking technologies. 

Automated decision-making and profiling

If the Application uses automated decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you, you have the right to request human review, express your point of view, and contest the decision. Information about the logic involved and the likely consequences of that processing will be provided where required by law.

What information does the Application collect automatically?

In addition, the Application may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device's unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, and information about the way you use the Application.

Does the Application collect precise real time location information of the device?

This Application does not gather precise information about the location of your mobile device.

Does the Application use Artificial Intelligence (AI) technologies?

The Application does not use Artificial Intelligence (AI) technologies to process your data or provide features.

Do third parties see and/or have access to information obtained by the Application?

Only aggregated, anonymized data is periodically transmitted to external services to aid the Service Provider in improving the Application and their service. The Service Provider may share your information with third parties in the ways that are described in this privacy statement.

International Data Transfers

The Service Provider or its third-party service providers may transfer personal data outside the European Economic Area (EEA). Where such transfers occur, the Service Provider will use an appropriate transfer mechanism required by GDPR Chapter V.

• Adequacy decisions by the European Commission

• Standard Contractual Clauses (SCCs) approved by the European Commission

• Other safeguards or derogations recognized under GDPR Chapter V, including consent where legally permitted

Countries outside the EEA may not provide the same level of data protection as the EEA. Where required by law, the Service Provider will apply appropriate safeguards and obtain any consent required for the transfer.

Please note that the Application utilizes third-party services that have their own Privacy Policy about handling data. Below are the links to the Privacy Policy of the third-party service providers used by the Application:

• Supabase

• Google Play Services

• Google Analytics for Firebase

• Firebase Crashlytics

The Service Provider may disclose User Provided and Automatically Collected Information:

• as required by law, such as to comply with a subpoena, or similar legal process;

• when they believe in good faith that disclosure is necessary to protect their rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;

• with their trusted services providers who work on their behalf, do not have an independent use of the information the Service Provider discloses to them, and have agreed to adhere to the rules set forth in this privacy statement.

Where the GDPR applies, the Service Provider enters into Data Processing Agreements (DPAs) with third-party service providers that process personal data on its behalf, as required by Article 28 of the GDPR. These DPAs impose the same data protection obligations on those service providers as described in this Privacy Policy.

What are my opt-out rights?

You can stop further collection of information from your mobile device by uninstalling the Application. Uninstalling will stop the Application from collecting data from your device, but it does not automatically delete information that has already been transmitted to the Service Provider or to third parties.

To request deletion of your personal data you can go to your "profile page" --> "settings" --> "delete account" or contact the Service Provider at elomarstudio@gmail.com.

What is the data retention policy and how can you manage your information?

The Service Provider retains personal data based on its necessity for the stated purposes:

• User Provided Data: Retained for the duration of your use of the Application plus 12 months thereafter, unless longer retention is required by law

• Automatically Collected Data: Retained for up to 24 months from collection, unless longer retention is required for legal compliance or security purposes

• Aggregated and Anonymized Data: Retained indefinitely as it no longer identifies you

• Data required for legal compliance: Retained as long as required by applicable law

You have the right to request deletion of your personal data at any time, except where retention is required by law. If you'd like the Service Provider to delete User Provided Data that you have provided via the Application, please contact them at elomarstudio@gmail.com and they will respond within the time required by applicable law. Please note that some User Provided Data may be required in order for the Application to function properly.

How does the Application address children's privacy?

The Application is not intended for children under 16 years of age, or where a higher age of digital consent is established under applicable law. The Service Provider does not knowingly solicit data from children or market the Application to them.

Where parental or guardian consent is required under applicable law, the Application is not intended for use without that consent. The Service Provider does not knowingly collect personally identifiable information from children under 16 years of age, or where a higher age of digital consent is established by applicable law, in violation of applicable law. In the event the Service Provider discovers that a child has provided personal information, the Service Provider will immediately delete this from their servers. If you are a parent or guardian and you are aware that your child has provided the Service Provider with personal information, please contact the Service Provider (elomarstudio@gmail.com) so that they will be able to take the necessary actions.

How is your information kept secure?

The Service Provider is committed to safeguarding the confidentiality of your information. The Service Provider implements physical, electronic, and procedural safeguards to protect information it processes and maintains. For example, access is limited to authorized employees and contractors who need to know that information to operate, develop, or improve the Application. However, no security system can prevent all potential security breaches. Notably, our E2EE Chat architecture ensures that even in the event of a server-side breach, your private communications remain unreadable to unauthorized parties.

Data Breach Notification

In the event of a personal data breach that poses a risk to your rights and freedoms, the Service Provider will notify the relevant supervisory authority within 72 hours of becoming aware of the breach, as required by applicable law. Where the breach is likely to result in a high risk to your rights and freedoms, the Service Provider will also notify you without undue delay, providing information about the nature of the breach, the categories of data affected, and the measures taken or proposed to address the breach.

How will you be informed of changes to this Privacy Policy?

The Service Provider may update this Privacy Policy from time to time. The Service Provider will notify you of material changes by posting the updated Privacy Policy with an effective date. Where required by law, the Service Provider will seek your consent to material changes before they take effect.

Previous versions of this Privacy Policy will be maintained and made available upon request by contacting the Service Provider at elomarstudio@gmail.com.

This privacy policy is effective as of 2026-05-27

What are your GDPR data protection rights?

Under the GDPR, you have the following rights:

• Right of Access: You can request access to your personal data.

• Right to Rectification: You can request correction of inaccurate data.

• Right to Erasure: You can request deletion of your personal data (the "right to be forgotten").

• Right to Restrict Processing: You can request that the Data Controller limits how they use your data.

• Right to Data Portability: You can request a copy of your data in a structured, commonly used, machine-readable format.

• Right to Object: You can object to processing based on legitimate interests. You have an absolute right to object to processing for direct marketing purposes at any time.

• Right to Withdraw Consent: Where processing is based on your consent, you can withdraw it at any time. Withdrawal is as simple as toggling preferences in the Application's settings or contacting the Data Controller.

• Rights Regarding Automated Decision-Making: You have rights related to automated decisions that affect you.

If you believe your data protection rights have been violated, you have the right to lodge a complaint with your local Data Protection Authority. Contact details for each country's Data Protection Authority can be found at: https://edpb.ec.europa.eu/about-edpb/members_en

If you are located in the United Kingdom, you may contact the Information Commissioner's Office at https://ico.org.uk

What are your California privacy rights (CCPA/CPRA)?

If you are a resident of California, the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) provide you with additional rights regarding your personal information:

• Right to Know: You can request disclosure of the categories and specific pieces of personal information the Service Provider has collected about you.

• Right to Delete: You can request deletion of personal information the Service Provider has collected from you, subject to certain exceptions.

• Right to Correct: You can request correction of inaccurate personal information.

• Right to Opt-Out: You can opt out of the sale or sharing of your personal information for cross-context behavioral advertising.

• Right to Limit Use of Sensitive Personal Information: You can limit the use of your sensitive personal information to essential purposes.

• Right to Non-Discrimination: The Service Provider will not discriminate against you for exercising any of your CCPA/CPRA rights.

To exercise any of these rights, please contact the Service Provider at elomarstudio@gmail.com. The Service Provider will verify your request using the information you provide and respond within the timeframes required by law. You may designate an authorized agent to make a request on your behalf.

How do you give your consent?

Where processing is based on consent, you provide that consent by affirmatively opting in to the relevant feature or action. You may withdraw consent at any time without affecting processing carried out before withdrawal. Processing based on other lawful bases, including contract performance, legitimate interests, or legal obligations, is carried out as described above.

How can you contact the Data Controller?

If you have any questions regarding privacy while using the Application, or have questions about the practices, please contact the Service Provider via email at elomarstudio@gmail.com.

To request deletion of your personal data or to exercise any of your rights, contact the Service Provider using the details provided above. The Service Provider will respond within one month of receiving your request, extendable by up to two months where necessary due to the complexity or volume of requests, as permitted by applicable law.

This privacy policy page was generated by App Privacy Policy Generator

These terms and conditions apply to the Grow A Fish app for mobile devices, together with any related services operated by Elomar Studio (collectively, the "Application"). Elomar Studio is hereby referred to as the "Service Provider".

By downloading or using the Application, you agree to these Terms and Conditions. You should read them carefully before using the Application.

License to use the Application

Subject to your compliance with these Terms, the Service Provider grants you a limited, non-exclusive, non-transferable, revocable license to install and use the Application on a mobile device for personal or internal business purposes. You may not reproduce, distribute, modify, create derivative works from, reverse engineer, decompile, or disassemble the Application, except as and only to the extent that such activity is expressly permitted by applicable law.

Intellectual Property

The Service Provider retains all intellectual property rights in the Application, including its code, design, trademarks, service marks, trade names, logos, and branding (the "IP"). Nothing in these Terms grants you any license or right to use the Service Provider's trademarks, logos, or branding for any purpose. You agree not to remove, alter, or obscure any copyright, trademark, or other proprietary notices displayed in or on the Application.

Termination

The Service Provider may suspend your access to the Application or services if you materially breach these Terms. The Service Provider will provide you with written notice of the breach and, where the breach is capable of cure, you will have 14 days from receipt of notice to remedy the breach. If you fail to cure the breach within that period, the Service Provider may terminate your access.

The Service Provider may suspend or terminate your access immediately without notice if you violate applicable law, infringe intellectual property rights, or engage in activity that could cause harm to other users or the Service Provider.

Upon termination, your right to use the Application will end and you must delete all copies from your devices.

By accessing and using this Application, you represent that you are legally permitted to use it in your jurisdiction. You must be at least 16 years of age (the age of digital consent in your jurisdiction) to use the Application. If you are below 16, a parent or legal guardian must review and accept these Terms on your behalf.

Unauthorized copying, modification of the Application, any part of the Application, or the Service Provider's trademarks is strictly prohibited. Any attempts to extract the source code of the Application, translate the Application into other languages, or create derivative versions are not permitted. All trademarks, copyrights, database rights, and other intellectual property rights related to the Application remain the property of the Service Provider.

User-Generated Content and Acceptable Use

If this Application allows users to post, share, or upload content, you agree not to post content that:

• Is illegal or violates third-party intellectual property rights (copyright, trademark, patents)

• Is abusive, threatening, harassing, defamatory, or hate speech

• Contains discrimination or incitement to violence or illegal activity

• Is spam, phishing, or contains malware

• Violates the privacy or personal data rights of others

• Is misleading, false, or deceptive

• Contains explicit violence or sexual content (unless age-gated appropriately)

The Service Provider reserves the right to:

• Remove or disable access to content that violates these guidelines

• Suspend or terminate accounts of users who repeatedly violate these guidelines

• Cooperate with law enforcement if illegal content is reported

• Moderate, filter, or hide content that violates these Terms, applicable law, or the guidelines set out above

Content submitted through the Application may be visible to other users or to the public, depending on how the Application functions.

If you believe content violates these Terms, infringes your rights, or is unlawful, you may report it to the Service Provider at elomarstudio@gmail.com. The report should include enough information for the Service Provider to identify the content, evaluate the complaint, and contact you if follow-up is required.

Where the Application provides such features, you may also report content, block other users, or mute notifications directly through the Application's interface. The Service Provider will review in-app reports with the same standards described in these Terms.

The Service Provider may review reported content, request additional information where necessary, remove or restrict access to content, and take action against the responsible account where appropriate. Users affected by moderation decisions may contact the Service Provider at elomarstudio@gmail.com to request further review. The Service Provider will respond to appeals within a reasonable period and provide the reasons for any upheld moderation decision, subject to applicable law.

By submitting User-Generated Content you grant the Service Provider a non-exclusive, worldwide, royalty-free license to use, reproduce, distribute, prepare derivative works of, display and perform the content in connection with the Application and the Service Provider's business. This license does not grant the Service Provider the right to sell or sublicense your content to third parties independently of the Application. You represent and warrant that you own or control all rights in the content you post and that use of the content does not violate these Terms or applicable law.

Your content may include personal data. Processing of personal data related to User-Generated Content is governed by the Privacy Policy. Do not post personal data of others without their consent.

The Service Provider is dedicated to ensuring that the Application is as beneficial and efficient as possible. As such, they reserve the right to modify the Application or charge for their services at any time and for any reason. The Service Provider assures you that any charges for the Application or its services will be clearly communicated to you.

The Application stores and processes personal data that you have provided to the Service Provider in order to provide the Service. It is your responsibility to maintain the security of your phone and access to the Application. The Service Provider strongly advises against jailbreaking or rooting your phone, which involves removing software restrictions and limitations imposed by the official operating system of your device. Such actions could expose your phone to malware, viruses, malicious programs, compromise your phone's security features, and may result in the Application not functioning correctly or at all.

Please note that the Application utilizes third-party services that have their own Terms and Conditions. Below are the links to the Terms and Conditions of the third-party service providers used by the Application:

• Supabase

• Google Play Services

• Google Analytics for Firebase

• Firebase Crashlytics

Please be aware that the Service Provider does not assume responsibility for certain aspects. Some functions of the Application require an active internet connection, which can be Wi-Fi or provided by your mobile network provider. The Service Provider cannot be held responsible if the Application does not function at full capacity due to lack of access to Wi-Fi or if you have exhausted your data allowance.

If you are using the application outside of a Wi-Fi area, please be aware that your mobile network provider's agreement terms still apply. Consequently, you may incur charges from your mobile provider for data usage during the connection to the application, or other third-party charges. By using the application, you accept responsibility for any such charges, including roaming data charges if you use the application outside of your home territory (i.e., region or country) without disabling data roaming. If you are not the bill payer for the device on which you are using the application, they assume that you have obtained permission from the bill payer.

Similarly, the Service Provider cannot always assume responsibility for your usage of the application. For instance, it is your responsibility to ensure that your device remains charged. If your device runs out of battery and you are unable to access the Service, the Service Provider cannot be held responsible.

Nothing in these Terms shall limit any rights you have under applicable consumer protection laws that cannot be lawfully excluded.

Limitation of Liability

To the fullest extent permitted by law, the Service Provider shall not be liable for any indirect, incidental, special, consequential, or punitive damages, including but not limited to lost profits, data loss, or business interruption, even if advised of the possibility of such damages.

However, the Service Provider retains full liability for:

• Death or personal injury caused by negligence

• Fraud or fraudulent misrepresentation

• Any other liability that cannot be excluded or limited under applicable law

To the fullest extent permitted by law, the total liability of the Service Provider for any claim shall not exceed the amount paid by you to the Service Provider for the Application in the 12 months preceding the claim, or the minimum amount that must be paid under applicable law, whichever is greater. If the Application is provided free of charge, this means the Service Provider's liability is limited to the minimum amount permitted by applicable law.

The Service Provider accepts no liability for any loss, direct or indirect, that you experience as a result of relying entirely on third-party information provided through this Application, or for inaccuracies in content provided by third parties.

Indemnification

To the fullest extent permitted by law, you agree to indemnify and hold harmless the Service Provider, its affiliates, officers, directors, employees and agents from and against any claims, liabilities, damages, losses and expenses, including reasonable legal fees, arising out of or directly related to your breach of these Terms or your intentional misuse of the Application, including User-Generated Content you submit in violation of these Terms.

This indemnification does not apply to claims arising from the Service Provider's own negligence, breach of these Terms, or violation of applicable law. In jurisdictions where consumer indemnification is restricted by law, this clause shall be limited to the maximum extent permitted.

The Service Provider may wish to update the application at some point. The application is currently available as per the requirements for the operating system (and for any additional systems they decide to extend the availability of the application to) may change, and you will need to download the updates if you want to continue using the application. The Service Provider does not guarantee that it will always update the application so that it is relevant to you and/or compatible with the particular operating system version installed on your device. You should accept updates when offered; if you choose not to, the Service Provider may cease to support earlier versions and the Application may not function properly. The Service Provider may also wish to cease providing the application and may terminate its use at any time without providing termination notice to you. Unless they inform you otherwise, upon any termination, (a) the rights and licenses granted to you in these terms will end; (b) you must cease using the application, and (if necessary) delete it from your device.

Governing Law and Jurisdiction

These Terms and Conditions are governed by the laws of the jurisdiction in which the Service Provider is established, excluding conflict of law rules, except to the extent mandatory consumer protection laws provide otherwise.

Any dispute arising out of or relating to these Terms will be brought before the courts that have jurisdiction under applicable law. Nothing in this clause limits any rights you may have to bring a claim in a court that is competent under mandatory law.

DSA Compliance (Digital Services Act)

If the Application is an intermediary service as defined under the Digital Services Act (Regulation (EU) 2022/2065, "DSA"), the following provisions apply in addition to the terms above.

Point of Contact: The Service Provider maintains a single point of contact for direct communication with EU authorities and recipients of the service, reachable at elomarstudio@gmail.com. Where the Service Provider is established outside the European Union, a legal representative in the EU has been designated in accordance with Article 13 of the DSA.

Content Moderation and Statement of Reasons: When the Service Provider restricts access to content, suspends or terminates an account, or otherwise limits the availability of the Application's features, a clear and specific statement of reasons will be provided to the affected user. The statement will include the nature of the restriction, the legal or contractual basis for the decision, and information on available redress mechanisms, in accordance with Article 17 of the DSA.

Notice and Action: Users and third parties may submit notices of allegedly illegal content through the contact details provided in these Terms. The Service Provider will process notices promptly, diligently, and without automated decision-making where the circumstances require human review. Notices will be acknowledged electronically and a decision communicated without undue delay, in accordance with Article 16 of the DSA.

Out-of-Court Dispute Settlement: Disputes regarding content moderation decisions, including decisions to restrict content or suspend accounts, may be submitted to an out-of-court dispute settlement body certified in accordance with Article 21 of the DSA. The Service Provider will engage with such bodies in good faith. Use of out-of-court dispute settlement does not affect your right to seek judicial remedy under applicable law.

Transparency Reporting: The Service Provider publishes periodic transparency reports covering content moderation activities, including the volume of notices received, actions taken, and automated means used, in accordance with Article 24 of the DSA. Reports are made available upon request at elomarstudio@gmail.com.

These DSA provisions apply to the extent that the Application qualifies as an intermediary service under the DSA and does not replace or limit any rights or obligations under applicable consumer protection or data protection law.

Severability

If any provision of these Terms and Conditions is held to be invalid, illegal, or unenforceable by a court of competent jurisdiction, such provision shall be modified to the minimum extent necessary to make it valid and enforceable, and the remaining provisions of these Terms shall remain in full force and effect.

Entire Agreement

These Terms and Conditions, together with the Privacy Policy, constitute the entire agreement between you and the Service Provider concerning your use of the Application, superseding any prior agreements or understandings.

Changes to These Terms and Conditions

The Service Provider may periodically update their Terms and Conditions. Therefore, you are advised to review this page regularly for any changes. The Service Provider will notify you of any changes by posting the new Terms and Conditions on this page.

Previous versions of these Terms and Conditions will be maintained and made available upon request by contacting the Service Provider at elomarstudio@gmail.com.

These terms and conditions are effective as of 2026-05-27

Contact Us

If you have any questions or suggestions about the Terms and Conditions, please do not hesitate to contact the Service Provider at elomarstudio@gmail.com.

This Terms & Conditions page was generated by App Privacy Policy Generator