Privacy Policy

SHADOW GAMES SOFTWARE

PRIVACY POLICY

Effective Date: March 21, 2026     Last Updated: March 23, 2026     Version: 1.0

1. INTRODUCTION

Shadow Games Software ("we", "us", or "our"), operated by CoWirshing, is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile applications, games, and related services (collectively, the "Services").

This policy applies to all current and future applications and games published by Shadow Games Software. By downloading, installing, or using any of our Services, you agree to the terms of this Privacy Policy. If you do not agree, please do not use our Services.

2. WHO WE ARE

Shadow Games Software is an independent game and application developer based in the United States. For the purposes of applicable data protection laws, Shadow Games Software is the data controller responsible for your personal information.

Contact Information

• Developer:  Shadow Games Software / CoWirshing

• Email:  CoWirshing@gmail.com

• Google Play:  Available through our app listing on Google Play Store

• Privacy enquiries:  CoWirshing@gmail.com

We aim to respond to all privacy-related enquiries within 30 days.

3. INFORMATION WE COLLECT

3.1 Information You Provide Directly

Most of our applications are designed to function without requiring you to provide any personal information. Where our apps do not collect user-provided data, this section does not apply. Future applications may collect information you voluntarily provide, such as:

• Account registration details (username, email address)

• Feedback, support requests, or correspondence submitted to us

3.2 Information Collected Automatically

We currently do not collect any personal data automatically. Future applications may collect limited technical data automatically, which may include:

• Device type and operating system version

• App version and crash/error reports

• Anonymous gameplay statistics (e.g., session length, feature usage) — not linked to your identity

Any automatically collected data will be described specifically in the relevant application’s supplementary notice where applicable. We will update this policy before deploying any new data collection tools or SDKs.

3.3 Information Stored Locally on Your Device

Some of our applications store data locally on your device only. This data never leaves your device and is not transmitted to us or any third party, and includes items such as game progress and high scores.

Local data can be cleared at any time by uninstalling the application or clearing the app’s data through your device settings.

3.4 Information We Do Not Collect

Unless explicitly stated in a specific application’s supplementary notice, Shadow Games Software does not collect:

• Your name, address, or contact details

• Location data (precise or approximate)

• Financial or payment information

• Microphone, camera, or media access data

• Contact lists or phonebook data

• Advertising identifiers or device fingerprints

• Biometric data

4. HOW WE USE YOUR INFORMATION

We use any information collected solely for the following purposes:

• To provide, operate, and maintain our Services

• To improve the performance, features, and user experience of our applications

• To respond to your support requests or enquiries

• To diagnose technical issues and prevent crashes

• To comply with applicable legal obligations

We will never sell, rent, or lease your personal information to third parties.

5. PURCHASES AND PAYMENTS

Some of our applications are available as paid downloads through the Google Play Store. All payment transactions are processed entirely by Google Play and are subject to Google’s own Privacy Policy (https://policies.google.com/privacy). Shadow Games Software does not receive, process, or store your payment card details or financial information of any kind.

6. ADVERTISING

Shadow Games Software does not currently serve advertisements in any of its applications.

Future Notice

We may introduce advertising into select applications in the future. If and when we do, we will:

• Update this Privacy Policy before activating any advertising SDK

• Clearly identify any advertising networks used (such as Google AdMob) and link to their respective privacy policies

• Disclose any advertising identifiers (such as Google Advertising ID) that may be collected

• Provide opt-out mechanisms where required by applicable law

We will not enable advertising in any application without first updating this policy and, where required, seeking your consent.

7. LEGAL BASIS FOR PROCESSING (GDPR / UK GDPR)

Where the General Data Protection Regulation (GDPR) or UK GDPR applies, we process personal information on the following legal bases:

• Legitimate Interests: To operate and improve our Services in ways that do not override your privacy rights

• Legal Obligation: To comply with applicable laws and regulations

• Consent: Where we explicitly request your consent for a specific processing activity — you may withdraw consent at any time without affecting prior processing

For applications that do not collect personal data, no legal basis for processing is required.

8. SHARING OF YOUR INFORMATION

Shadow Games Software does not sell, trade, or otherwise transfer your personal information to third parties, except in the following limited circumstances:

• Service Providers: Trusted third-party vendors who assist in operating our Services (e.g., crash reporting or analytics tools) — only under strict confidentiality agreements and solely for the purposes outlined in this policy.

• Legal Requirements: If required to do so by law, court order, or governmental authority

• Business Transfer: In the event of a merger, acquisition, or sale of assets, your information may be transferred — we will notify you before your data is transferred and becomes subject to a different privacy policy

• Platform Providers: Google Play may collect certain information in connection with the distribution and purchase of our applications, subject to Google’s own privacy policy

Any third-party service providers we engage are contractually obligated to protect your information and may not use it for their own purposes.

9. DATA RETENTION

We retain personal information only for as long as necessary to fulfil the purposes described in this policy, or as required by law.

• Locally stored data (e.g., game progress, high scores): Retained on your device until you uninstall the app or clear app data

• Support correspondence: Retained for up to 24 months from the date of resolution

• Crash/diagnostic data (where applicable): Retained for up to 12 months

When personal data is no longer required, we securely delete or anonymize it.

10. DATA SECURITY

We take the security of your information seriously and implement appropriate technical and organizational measures to protect it against unauthorized access, alteration, disclosure, or destruction.

Where data is stored locally on your device, the security of that data is also dependent on your device’s own security measures, including screen lock and operating system protections. We recommend keeping your device’s software up to date.

No method of electronic storage is completely secure. While we strive to use commercially reasonable means to protect your information, we cannot guarantee absolute security.

10.1 Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will:

• Notify relevant supervisory authorities within 72 hours of becoming aware of the breach, where required under applicable law (including GDPR Article 33)

• Notify affected individuals without undue delay where the breach is likely to result in a high risk to their rights and freedoms

• Take prompt steps to contain and remediate the breach

You may contact us at CoWirshing@gmail.com if you believe your data has been affected by a security incident.

11. CHILDREN’S PRIVACY

Our Services are designed for a general audience and are not directed specifically to children. We do not knowingly collect personal information from children under the age of 13 (the threshold under the Children’s Online Privacy Protection Act, “COPPA”) or under the age of 16 where required by applicable law, including under the GDPR and UK GDPR.

Because our apps are available to a general audience and may be used by younger players, we are committed to the following:

• We do not knowingly collect personal information from children

• We do not serve behavioral advertising or build user profiles

• Locally stored data does not leave the device

If you are a parent or guardian and believe your child has submitted personal information to us, please contact us at CoWirshing@gmail.com. We will take prompt steps to delete any such information from our records.

If we introduce any application specifically directed at children in the future, we will comply with COPPA, the UK Age Appropriate Design Code, and all applicable international children’s privacy laws, and will update this policy accordingly.

12. APP PERMISSIONS

Our applications request only the permissions necessary to deliver their core functionality.

Where future applications request device permissions (such as camera, microphone, location, or storage), the purpose of each permission will be clearly disclosed within the application before the permission is requested. You may deny or revoke permissions at any time through your device settings; however, this may affect certain functionality.

13. YOUR PRIVACY RIGHTS

13.1 Rights Under GDPR / UK GDPR (EU and UK Residents)

If you are located in the European Union or United Kingdom, you have the following rights regarding your personal data:

• Right of Access: To request a copy of the personal data we hold about you

• Right to Rectification: To request correction of inaccurate or incomplete data

• Right to Erasure (“Right to be Forgotten”): To request deletion of your personal data

• Right to Restriction of Processing: To request that we limit how we use your data

• Right to Data Portability: To receive your data in a structured, machine-readable format

• Right to Object: To object to processing based on legitimate interests

• Right to Withdraw Consent: Where processing is based on consent, to withdraw it at any time

If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority.

13.2 Rights Under CCPA / CPRA (California Residents)

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

• Right to Know: To know what personal information we collect, use, disclose, or sell

• Right to Delete: To request deletion of your personal information

• Right to Correct: To request correction of inaccurate personal information

• Right to Opt-Out of Sale/Sharing: We do not sell or share your personal information

• Right to Non-Discrimination: You will not be discriminated against for exercising your privacy rights

13.3 Exercising Your Rights

To exercise any of the above rights, please contact us using one of the following methods:

• Email:  CoWirshing@gmail.com

• Google Play: Through our developer page on the Google Play Store

We will respond to verified requests within the timeframes required by applicable law (generally 30 days under GDPR; 45 days under CCPA). We may need to verify your identity before processing certain requests.

14. ACCOUNT DELETION

Our current applications do not require account creation. No user accounts are created, stored, or managed by Shadow Games Software at this time. Accordingly, no account deletion mechanism is required for existing applications.

If a future application introduces account functionality, we will provide users with the ability to request full deletion of their account and all associated personal data. In compliance with Google Play’s Account Deletion Policy, such applications will include:

• An in-app mechanism to request account and data deletion

• Deletion of all personal data associated with the account upon request, unless retention is required by law or for legitimate security and fraud prevention purposes

• Clear disclosure of any data retained after deletion and the reasons for retention

To request deletion of any data we currently hold about you, please contact us at CoWirshing@gmail.com. We will process all verified deletion requests promptly and in accordance with applicable law.

15. THIRD-PARTY LINKS AND SERVICES

Our applications may contain links to third-party websites, services, or resources. This Privacy Policy applies only to our Services. We are not responsible for the privacy practices of third parties. We encourage you to review the privacy policies of any third-party services you access.

16. GOOGLE PLAY AND PLATFORM SERVICES

Our applications are currently distributed through the Google Play Store. Google may independently collect information about your device and your use of the Play Store platform in accordance with Google’s Privacy Policy (https://policies.google.com/privacy).

Shadow Games Software does not control Google’s data collection practices and is not responsible for them.

17. INTERNATIONAL DATA TRANSFERS

Shadow Games Software is based in the United States. If you are located outside the United States, please be aware that any information you provide may be transferred to and processed in the United States, where data protection laws may differ from those in your country.

Where we transfer personal data from the European Economic Area (EEA) or United Kingdom to the United States or other countries not deemed adequate by the European Commission, we will ensure such transfers are made in accordance with applicable data protection laws, including through the use of appropriate safeguards such as Standard Contractual Clauses (SCCs) where required under GDPR.

18. CHANGES TO THIS PRIVACY POLICY

We reserve the right to update this Privacy Policy at any time to reflect changes in our practices, legal requirements, or for other operational reasons.

When we make material changes, we will:

• Update the “Last Updated” date at the top of this policy

• Notify users through an in-app notification or prominent notice

• For significant changes that affect how we use personal data — including the introduction of advertising SDKs or new data collection — we will seek your consent where required by law before the changes take effect

We recommend reviewing this policy periodically. The current version will always be accessible through our Google Play Store listing.

19. CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Shadow Games Software / CoWirshing

• Email:  CoWirshing@gmail.com

• Google Play:  Available through our developer page on the Google Play Store

We take all privacy enquiries seriously and aim to respond within 30 days.

© 2026 Shadow Games Software / CoWirshing. All rights reserved.

DISCLAIMER: This Privacy Policy was prepared for Shadow Games Software. This document does not constitute legal advice.